ACR Journal

October 2022 | November 2022 Every time I am asked to write an update such as this, I seem to be talking about seismic shifts or game-changers for our sector. This year is no di erent, although we are in a bit of limbo with regard implementation dates for the changes currently, and for the first time we are looking at divergence between UK and EU regulations. In-scope refrigerants In last year’s update I brought up the concept of bringing non-HFCs into the scope of the regulations going forward. The reasoning was two-fold: REFRIGERANT UPDATE 16 By Graeme Fox, head of technical at REFCOM and the BESA Group F-Gas Regulations Review As we transition increasingly away from high or even medium GWP fluorinated greenhouse gases towards so-called “naturals” it is easy to forget those alternative gases are also greenhouse gases which are not good for the environment. Even Propane (R290) has four times the potency of carbon dioxide as a greenhouse gas. The term “natural” is used to create an aura of environmental friendliness, but the reality is less environmentally friendly in terms of direct emissions when released into the atmosphere than some HFOs, which are ritually slammed by environmental lobbyists. So the first aspect of the reasoning was to ensure we do not eradicate direct emissions of one refrigerant with another which also has environmental consequences. The second aspect comes from the sales of systems using non-HFCs and being marketed as “not needing to be installed by a qualified person”. When we are talking about highly flammable substances that is simply reckless and not something any responsible industry should be encouraging. I will come onto engineers’ competency requirements and evidencing under the Building Safety Act later, but simple good practice would demand a basic level of competency is required before anybody is let loose on a system which by design works at relatively high pressures and temperatures. So the changing of what is “in-scope” of the regulations to include all greenhouse gases is necessary for the better enforcement of regulations and is very much on the table right now in discussions with DEFRA about the future UK/GB regulations. The European Commission lawyers are not seriously considering a similar approach simply because the black and white legal text is currently for “fluorinated greenhouse gases” and apparently the removal of the word “fluorinated” is such a fundamental change to the current regulation that it would demand a complete re-write rather than apply common sense and simply amend some text throughout. It is still up for debate of course, and the European contractors’ association AREA are very much still pressing for this common sense approach to prevail, but it is heartening to see DEFRA take a far more pragmatic approach here in the UK. Volume 8 No.6 Graeme Fox