Refrigerant Fluid Regulation – The Essentials
The process cooling industry is governed by an important regulatory context which frequently evolves. This situation imposes a specific expertise and a precise knowledge of the regulatory and sustainable development issues on the process cooling industry “operators”, in order to satisfy customers’ legitimate expectations in terms of advice.
For the customer, the “holder” of any HFC-based process cooling plant (see below), the obligations relate to containment inspections of circuits containing greenhouse gases, the frequency of these inspections and the keeping of registers documenting the maintenance operations.
Recently, the legal framework has been accompanied by a repressive arsenal, with the Ministry of Environment’s announcement of a large-scale review of the operator certification system, and penalties for non-compliance with certain obligations.
The texts governing the regulation of refrigeration equipment and refrigerant fluids are as follows:
- The decree of 25/07/2016 amending the decree of 20/12/2007, relating to the accreditation of organisations.
- Commission Implementing Regulation (EU) 2016/879 of 2/06/2016.
- The decree of 29/02/2016 concerning certain refrigerant fluids and fluorinated greenhouse gases.
- Decree 2015-1790 of 28/12/2015 concerning certain refrigerant fluids and fluorinated greenhouse gases.
- EU Regulation 517/2014 of 16/04/2014 (F-GAS) relating to fluorinated greenhouse gases and repealing EC Regulation 842/2006.
- EC Regulation 1005/2009 of 16/09/2009 relating to depleting substances.
- Environmental Code, 18/5/2008 – Section 6: Refrigerant fluids used in refrigeration and air conditioning equipment. Articles R543-75 to R543-123.
For all documentation and measures specifically concerning Pressure Equipment Devices (PED), we refer to the document “PED Regulation – The Essentials”.
CERTIFICATE OF PROFESSIONAL COMPETENCE
Any operator carrying out operations involving the handling of refrigerant fluids must hold a Certificate of Professional Competence. The operator shall request a Certificate of Professional Competence from one of the eight accredited certification bodies if it can be justified that:
- Its agents are competent in process cooling,
- Its tooling is adequate and in perfectly maintained condition,
- It has established a traceability procedure allowing annual statements of the movements of the company’s refrigerant fluids.
No operator can buy refrigerant fluids in the EU without Certificate of Professional Competence justification.
CERTIFICATE OF APTITUDE
Every operator satisfies the conditions for professional competence when refrigeration agents operating under its responsibility hold a Certificate of Aptitude, authorising actions with refrigerant fluids.
No agent other than those holding a Certificate of Aptitude on the list declared to the organisation approved by the operator, holder of the Certificate of Professional Competence, is entitled to perform any handling of refrigerant fluids whatsoever, under penalty of criminal sanctions.
Handling refrigerant fluids means:
- Implementing refrigeration equipment,
- Maintenance and repair of refrigeration equipment,
- Inspections for leakages,
- Dismantling of plants,
- Recovering and loading of refrigerant fluids,
- Any other operation carried out on refrigerating and climate control equipment.
Any fluid handling must be recorded in a CERFA 15497 file (one per refrigerant circuit), signed by the customer (the holder or owner) and the operator.
INITIAL OPERATION AND MAINTENACE
Any cooling plant containing more than 2kg of HFC refrigerant fluid must be commissioned and maintained by a certified refrigeration technician, holder of a Certificate of Aptitude, who reports to an operator holding the adapted Certificate of Professional Competence.
A special sticker stating the equipment designation, the type of fluid per circuit, its GWP, its initial and additional load (in kg), its total load (in kg and T CO₂ eq) must be affixed to any chiller when it is commissioned.
PERIODIC INSPECTIONS FOR LEAKAGE
For greenhouse gases (HFC fluids according to the F-gas regulation), in the absence of an on-board leak detection device, leakage inspection operations and their frequency depending on the quantity of refrigerant fluid contained per circuit (not per chiller) means:
Equipment capacity (per circuit) Inspection frequency
- 5 t CO₂ eq < load < 50 t CO₂ eq >12 months
- 50 t CO₂ eq < load < 500 t CO₂ eq >6 months
- 500 t CO₂ eq < load >3 months
This periodic inspection must be carried out by a certified refrigeration technician, holder of a Certificate of Aptitude, who reports to an operator holding a Certificate of Professional Competence. The conditions of the inspection, in particular the detector used and the date of its last calibration (sensitivity according to EN 14624) are specified on the CERFA 15497 form.
The certified refrigeration technician will affix a special self-adhesive sticker per verified circuit. Any leak is subject to a precise treatment directing the holder to urgent corrective action.
The owner/ holder is responsible for the recovery of HFC fluids by certified personnel. The operator is responsible for recovering the fluids and ensuring their recycling, regeneration or destruction. A CERFA 15497 form (one per circuit) and one of its annexes will be completed by the refrigeration technician authorised for the follow-up treatment of the recovered/ reprocessed fluid.
When renewing the plants, the owner, accompanied by the operator, should prioritise the use of fluids with a low GWP or alternatives to HFC fluids.
Holders of equipment subject to leak testing shall establish and maintain records for all parts of the equipment concerned. These records should be kept for at least 5 years and include:
- The quantity and type of fluorinated GES installed or added to the plant, during maintenance or repair, or in the event of a leak.
- The quantity of fluorinated GES recovered.
- The dates and results of the inspections carried out.