R22 Phase Out
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The EC Ozone Regulation has been recast and the new Regulation (EC/1005/2009) provides the legislative framework for EU Member States to meet their obligations under the Montreal Protocol, the international agreement drawn up to halt damage to the ozone layer.
The most harmful ozone-depleting substances (e.g. CFCs like R12) were banned in the 1990s. New equipment using less harmful “transitional” HCFC refrigerants like R22 were banned in 2001 (or 2004 for small air-conditioning systems). From the end of 2009 the use of virgin HCFCs to service and maintain existing refrigeration and air-conditioning (RAC) equipment was banned in all EC Member States.
The two key phaseout dates are:
The ban on the use of virgin HCFC gases represents a very real business threat to any company which uses refrigerants like R22 or R408A in their processes or air conditioning systems. R22 remains one of the most commonly used refrigerants in the UK so many organisations are going to be affected by the ban. Sectors at greatest risk include the food and drink industry, petro-chemicals, pharmaceuticals, health, retail, hospitality, finance and data-processing. Typical applications can vary widely, but examples include refrigeration systems in supermarkets, blast chillers, cold stores and process coolers and many types of building air-conditioning as well as in transport refrigeration. Many of these applications are absolutely critical to the continued operation of their owner’s business.
It should be noted that the bans described above refer to the “use” of HCFCs. In terms of considering what action needs to be taken it should be noted that ‘use’ in relation to equipment containing HCFCs means –
“the utilisation of controlled substances in the production or maintenance, in particular refilling, of products or equipment’’
This means that it is permissible to carry on using equipment that contains HCFCs beyond the phaseout dates, but there must be no maintenance or servicing undertaken on the equipment that involves breaking into the refrigerant circuits.
Given that most RAC systems leak to a certain degree, in practical terms this implies that any equipment that is of strategic importance to a business should not be using HCFCs by 2015 so all current users of HCFC systems must develop a plan to manage their operations without HCFCs. To do nothing is not a sustainable option given the serious implications and potential costs, businesses should follow a strategic approach.