The European Commission’s F-Gas regulations were changed. The original legislation was published in 2006 as EC 842/2006 and put in place controls on Fluorinated Green House gases (F-Gases) as part of the EU’s commitment to the United Nations Framework Convention on Climate Change, Kyoto protocol. The new regulations were published in the summer of 2014 and came into force January 2015.
The original regulation, EC 842/2006, was an overarching document with supporting acts and put into place the regime Europe has been working to in refrigeration and fire for the last ten years.
If for some reason this regulation has slipped past you here’s a brief reminder of what it is and was supposed to do.
What are F-Gases ?
These are a range of gases, all of which contain fluorine e.g. Hydroflurocarbons (HFC), perfluorocarbons (PFC) and sulphur hexafluoride (SF6). All have a global warming potential (GWP) greater than 1 (1 being equivalent to the warming potential of 1 kg of CO2 over 100 years which was chosen as the base level).
Global warming is of course a bad thing and the legislation is aimed at containing, preventing and thereby reducing emissions of fluorinated greenhouse gases covered by the Kyoto Protocol.
These gases are used in a number of areas including car air conditioning, Air conditioning, Refrigeration, Building foam blowing – foam sealants, Novelty aerosols, Fire protection. The refrigeration/air conditioning market is the biggest user by far. Fire protection is a smaller but very important use of these gases and in reality is also non emissive.
The regulation puts requirements on the operators (owners) of systems and equipment containing F-Gases to ensure that they do everything possible to reduce leaks and so must only use appropriately registered companies using trained and certificated personnel to undertake the installation and carry out the leak checking and maintenance of those systems and equipment.
For fire protection we are talking about systems containing HFC 227ea (FM200), HFC 236fa (FE-36) HFC-23 (FE-13) and HFC 125(FE -25/NAF125) which cover most installed equipment.
You are reading this and thinking yes we know that gaseous extinguishing systems are covered so what’s new, ‘portables are not covered’ – think again.
You may have missed the term “equipment” the European Legislation uses the term “fire protection equipment” and defines it as:
(33) ‘fire protection equipment’ means the equipment and systems utilised in fire prevention or suppression applications and includes fire extinguishers;
If you read the legislation it does then refer to “Stationery fire protection equipment” so again you may think ‘portables’ are not in. However, the FIA have questioned this and the European Commission have confirmed that they include portable fire extinguishers in the term Stationery fire protection equipment.
Again you may say well the requirements only apply if the equipment is of a certain size. The revised legislation makes it clear that if fire protection equipment contains any of the above agents then the installation, service and maintenance, of that equipment has to be carried out by trained and certificated personnel employed by a certificated company.
In very simple terms it is illegal to install or service a portable fire extinguisher that contain an F-Gas if you don’t have the personal certification and company certification
The leak checking (called containment in the regulation) is related to the size of the equipment in the original F-Gas regulation if the equipment contained more than 3Kg of an F-Gas then leak checking had to be done at set intervals.
The revised the regulations were published in 2014 as 517/2014 and it came into force on 1 January 2015.
So what’s changed, well firstly and most importantly there is now a requirement to decrease the amount of F-Gases in the European market by up to two thirds of the 2010 emissions by 2030. This will be achieved by a gradual phase down on the use of F-Gases. The new regulation allocates quotas to individual producers and importers for the placing of F-Gases on the market. The quota system includes the amount of F-Gases in equipment. The quotas will be based on the quantities of F-Gases that reported as having been placed on the marked during a reference period from 2009 to 2012.
The proposed reduction each year up to 2030 will be a percentage of average annual total quantity of F-Gases placed on the market during reference period. What this means is in 2016 -17 the quota is 91% of the 2015 amount and steps down as per the table.
In addition to this phase down certain F-Gases will be prohibited – i.e. banned – for fire protection there is only one that will be banned for new systems from January 2016 and that’s HFC 23 (FE-13) on a positive note there are very few if any systems or equipment containing FE-13 in the UK.
Training and certification that has not really changed. All companies involved in handling F-Gases (installation and/or maintenance) need to be registered and the relevant personnel be trained and certificated.
As mentioned earlier, the regulations had a limit on the size of system that was covered by the leak checking requirements of the regulation and in 842/2006 it was based on the weight of the system as shown below.
3kgs up to 30kgs – every 12 months
30kgs up to 300kgs – every 6 months*
300kgs and above – every 3 months or 6 months if leak detection fitted
In the new regulation this has changed. The requirements for leak checking are now determined by CO2 equivalent and start to apply if the system contains more than 5 tonnes so the criteria now becomes
5 to 50 tonnes of CO2 equivalent – every 12 months or 24 months if leak detection fitted
50 to 500 tonnes of CO2 equivalent – every 6 months or 12 months if leak detection fitted
Above 500 tonnes of CO2 equivalent – every 3 months or 6 months if leak detection fitted
Again if the fire protection system is inspected in accordance with the standards, ISO 14520 or EN 15004 then the requirements are deemed to be met.
With regards to portables in the UK if they are serviced in accordance with recommendations of BS 5306-3 then the requirements will be met.
The CO2 equivalent is calculated from the GWP of the gas times the mass of the system/extinguisher which can be related to the size of the extinguisher. Under the previous regime the smallest system/Extinguisher covered was 3kg, now if you look at the two most common agents FM 200 (GWP 3220) and FE-36 (GWP 9810) it’s immediately obvious this is no longer the case. For FE -36 even a 1kg extinguisher is now covered by the requirements and for FM200 a 1.6kg extinguisher is included.
There is a ‘phase in’ on the requirement for systems less than 3kg so that the requirements are delayed until December 2016.
This change means that equipment previously seen as outside the scope of the regulation with regard to the leak checking is now in. For example small systems used on boats and other craft are generally based on 2kg FE-36 extinguishers, or police forces who moved from Halon to FE-36 for their personal protection are now covered as they used extinguishers around 1-2kg in size.
The good news is that in the UK there are not that many F-Gas extinguishers out there, the best estimate that the FIA have is around 10,000 units, 8,000 of which are in use by UK Police.
So there is no requirement for every portables service technicians to rush out and get the qualification only those who have sites where there are F-Gas extinguishers and then only those technicians who are responsible for that site.
As the UK training and certification body FIA has agreed with DEFRA the route to training and certification for the UK portables industry.
It is very simple the legislation requires theory elements and practical elements,
The theory side is the FIA F-Gas training course;
The practical is covered by the BAFE exam.
Just to re-iterate not everyone needs the certification but if you do come across one of these extinguishers you cannot legally touch it without it. However, it is easy to get.