R22 AND HCFC PHASE-OUT

OZONE DEPLETING SUBSTANCES (ODS) REGULATION

WARNING

This European Regulation has been in force for some time but has tended to become forgotten as the industry has focused on the new F-Gas regulations.

There is some critical timing associated with the ODS regulation and it is important that all those involved with the distribution and use of HCFCs including R-22 are fully aware of the issues and take action now.

BACKGROUND

Regulation (EC) No 2037/2000 on (ODS) Ozone Depleting Substances came into force on 1st October 2000.
This regulation has a number of impacts on the RAC industry:
HCFCs have been banned in most new equipment since 1st January 2001 and all new equipment since 1st January 2004.
Strengthened requirements were introduced around handling and prevention of leakage of HCFCs similar to those in the new F-Gas regulations that cover HFCs

SCOPE

The remaining parts of the regulation deal with the banning of use of HCFCs in the EU.

The key points are:

• It will be illegal to use virgin HCFCs after 31st December 2009 for the maintenance and servicing of refrigeration and air conditioning equipment.
• As the regulation deals with a ban on use of virgin HCFCs there will be no possibility to stockpile these products.
• A complete ban on use of all HCFCs including reclaimed/recycled product will be in place by 1st January 2015.
• Some of the HCFCs and blends covered by this legislation in addition to R22 are R123, R124, R141b, R142b, R401A/B/C, R402A/B, R403A/B, R406A, R408A, R409A/B, R411B. In some cases these may also be known by the manufacturer’s trade name.

INDUSTRY ACTION

Ensure that all those handling and using HCFCs are aware of the Ozone Depleting Substance regulations, that they are still relevant and what impact they will have as the ban on HCFCs approaches.

Ensure that all those handling and using HCFCs have plans in place and are taking action to be compliant with the regulations as the date of the HCFC ban gets ever closer.

GUIDANCE & UPDATED ADVICE

A guidance document was published at: www.dti.gov.uk/files/file29101.pdf

This document provides a wide range of information on the regulation and what steps should be taken by all users of HCFCs. There is specific guidance on the steps to be taken by equipment owners around the ban on ODS. Unfortunately it has not been updated since it’s publication in 2000 and is somewhat out of date.

Given below is an updated summary of the key steps that users in conjunction with their contractors should follow:

• Establish which HCFC refrigerants are being used and in what equipment
• Make plans as to the impact of the phase out of ODS on this equipment
• Take actions from the options below.
• Replace existing equipment with a new system.
• Keep existing equipment operational with an alternative non ozone depleting refrigerant
• There are a range of readily available retrofit refrigerants for direct replacement. Please consult your suppliers.
• HFC Retrofit options e.g. R134a, R404A, R407C, R507 but will require change to synthetic oil.
• Other refrigerants with component changes (note: it is not possible to retrofit existing systems with CO2, Ammonia, Hydrocarbons and 410A)
• In conjunction with 1) and 2) above, recover R-22 for recycling to use in remaining systems.
• A planned mix of all the above options.
• Do nothing. This is a very risky option. Remember – it is illegal to stockpile virgin HCFCs for use after 1st Jan 2010. Those doing nothing will be dependant on obtaining supplies of reclaimed/recycled R-22. It is recommended that consultation be made with suppliers of reclaimed/recycled R-22 to ascertain that the required quantity and quality of material will be available.

ACT NOW AS TIME IS RUNNING OUT

Wholesalers and distributors will begin running down stocks of R-22 and particularly HCFC blends during 2009.