In reference to the article 'Time to face facts about the F-Gas Regulations' on page 34 of HVR, September: 31st December 2014 is the phase out date for Hydrochlorofluorocarbons (HCFC) gases which includes R22. This is part of the Ozone Depleting Substances Regulations, not the F-gas Regs.
The Department for Environment, Food and Rural Affairs have produced a guide called 'RAC8, Strategies for HCFC Phase-out'. A copy can be found on the following page:
https://www.gov.uk/managing-fluorinated-gases-and-ozone-depleting-substances
Within RAC8, summarised in the final 3 paragraphs on page 1, it states : '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 phase-out dates, but there must be no maintenance or servicing undertaken on the equipment that involves breaking into the refrigerant circuits.'
Therefore, from 1st January 2015, equipment containing HCFC could still be operated with the correct records and leak checks but it would be illegal to replenish any gas during maintenance, leak checking or repairs as HCFC gas (of any kind including stockpiled) would be banned from 31st December 2014.
Richard Troup,
Regulatory Officer 1,
Waste & Industry Regulatory Service (WIRS) - Chemical Compliance, F-Gas,
Part of National Trading & Regulatory Services,
Environment Agency
