Graeme Fox, managing director of Specialist Mechanical Services and a director of AREA, looks at the review of the F-gas regulation and calls on government to beef up the policing.
Even as we turned into the New Year, trade associations across Europe were starting to turn their attention towards the review of the F-gas regulation.

This is the opportunity for national governments to put right what went wrong during the implementation process, to extend the scope if and where necessary and generally to ensure any loopholes in some countries' implementation are closed off to allow full mutual recognition between countries.

So where, you may ask, can the UK improve its own scheme to implement the law better?

Formal recognition

The first, and probably most obvious, improvement would be for formal recognition of the ACRIB register for operatives. Trade associations across Europe placed a very high priority on mandatory operative registration during the consultation for the initial regulation but UK government decided - despite an overwhelming majority of support from respondents to the UK consultation - that it would not mandate this because it claims it is not specifically written into the EC842/2006 Regulation. This is, however, an absolute must if we are finally to police this regulation properly.

Secondly we need seriously to address the issue of leakages where they still occur. This problem is not nearly as bad in the air conditioning sector as certain environmentalists have claimed as it has reportedly been in large refrigeration but nevertheless it is the area where improvement is always possible. Better brazing techniques would undoubtedly improve containment but while flare nuts are still widely used there will continue to be some leakage from some systems. Pressure needs to be put on manufacturers to stop them supplying split systems with flare nuts. If brazing stubs were left on outdoor units rather than flares we would see an immediate improvement in leakage rates.

Certified

Thirdly, pressure could also be put on manufacturers to stop supplying equipment with a holding charge, or in some cases the entire charge, of refrigerant in the outdoor unit. As there are legal restrictions on buying HFC refrigerants unless you are competently qualified, buying a system with no holding charge would be pointless if you could not buy the refrigerant to put into it. Which is where the next desirable change comes in - that of ensuring the elimination of the cowboy element from our sector.

Preventative

The easiest way of cutting the cowboys out is to prevent non-qualified people from buying equipment. Lawyers claim this is a restriction of trade, but there doesn't appear to have been a similar outcry about preventing the purchase of refrigerants. So by supplying the equipment without the refrigerant in it we cut out the loophole in one swoop.

The biggest problem in the air conditioning sector though, where the cowboy element is strongest, is in the small mini-split market. High wall units bought over the internet and installed by non-qualified people with little or no training and supplied with the entire charge means that cowboys have no need to be in the supply chain for our sector and, therefore, slip through the net with REFCOM and the other certification bodies. Banning the sale of equipment with a holding charge would force the cowboys to get trained and registered if they want to keep trading.

Of course the most important aspect of any regulatory implementation is how effectively it is policed. Government will have to give our industry the support we need to implement the law properly with effective self-policing so that the F Gas Regulation can finally achieve the minimal emissions it was set up to achieve.