Health & Safety Matters: Waste regs must be workable

Over-enthusiastic bureaucrats must not be allowed to undermine the good intentions of safety regulations, says Bob Towse, head of Technical and Safety at the HVCA
SAFETY regulations are normally created for a very good reason but there is always the danger that complicated bureaucracy will undermine all those good intentions and make the regulations unworkable.

A case in point is how the UK Hazardous Waste Regulations (2005) for England and Wales have been applied to the air conditioning and refrigeration sector since they came into force last July.

Contractors are having real nightmares with these because of the particular issues surrounding recovering, recycling and/or destroying of waste refrigerant.

Trade bodies and individual companies have issued strong protests to the Environment Agency (EA) and DEFRA because the industry was not consulted before the new rules were imposed on CFC, HCFC and HFC refrigerants.

What everyone is trying to achieve, including the regulators, is more waste refrigerant recovered to minimise environmental harm, but the vagaries of this particular regulation could well end up having the opposite effect.

The system is so complex and costly; that many people believe it is more likely to increase the numbers of firms failing to comply – some because they will deliberately avoid it and others because it is so complicated they just can’t.

Contractors are now required to notify the Environment Agency (EA) that they are offering a mobile refrigerant recovery service. Premises producing less than 200kg of “hazardous waste” a year are exempt but most refrigerant handling businesses are well above that limit and will need a “premises code” from the EA.

Moving any recovered refrigerant then needs a consignment note and contractors must report all of their consignments in a quarterly return to the EA.

This means producing a note and paying a fee every time a consignment is moved from one place to another which is highly impractical for refrigerant cylinders.

In extreme cases, one cylinder could be used to recover 10 1kg charges from 10 separate systems. This would require the contractor to raise 10 separate notes for that single cylinder. Bonkers.

There are plenty of people seeking a solution to this and so, hopefully, commonsense will prevail in the end. After all, it is in everyone’s interest that we recover more refrigerant and reduce impact on climate change.

For more information contact Bob Towse on 020 7313 4928 (
1 December 2006


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