EU F-Gas regulations – Fire Protection System Contractors

Fire Protection System Contractors

This guidance is for organisations affected by the 2014 EU F-Gas Regulation (517/2014). The F-Gas
Regulation creates controls on the use and emissions of fluorinated greenhouse gases (F-Gases)
including HFCs, PFCs and SF6.

Fire protection system (FPS) contractors play a major role supporting operators of FPS equipment.
They have to comply with a number of requirements under the F-Gas Regulation. The 2014 EU F-Gas
Regulation replaces the 2006 Regulation, strengthening all of the 2006 requirements and introducing
a number of important new measures.

The F-Gas Regulation is an important piece of legislation that will result in significant reductions in the
emissions of F-Gases. These are very powerful greenhouse gases, with global warming impacts that
are several thousand times higher than CO2 (per kg of gas emitted). All EU Member States agree that
it is important to reduce emissions of these gases.

This Information Sheet describes the requirements that apply to FPS contractors.

Sector description

EU F-Gas Regulations – Fire Protection System Contractors 


The fire protection industry make use of HFC fire extinguishing products in certain specialised building
applications, where building contents have a high value and other fire protection systems (e.g. water
based) could cause too much damage. In the UK most systems of this type use HFC 227ea (also
referred to by trade names such as FM 200).

Most operators of FPS make use of specialist contractors for installation and maintenance work. The
skill and expertise of the FPS contracting industry is crucial, providing operators with various services
through the life cycle of FPS equipment. The F-Gas Regulation places legally binding obligations on
contractors to ensure that they help end users minimise the use and emissions of high GWP HFCs.

It is important that contractors comply with the Regulations that apply to them and also that they are
aware of other relevant parts of the F-Gas Regulation so that they can provide their clients with
appropriate advice.

Advice regarding purchase of new equipment

EU F-Gas Regulations – Fire Protection System Contractors 


 

Contractors often provide important advice to their clients about purchase of new equipment. In the
2014 F-Gas Regulation there are 2 important new requirements that will change the advice that
contractors give to their clients.

These are:

a) Various specific bans, that will require lower GWP fire extinguishing fluids to be used
b) The impact of the HFC phase down, that will encourage low GWP fluids in all applications

NEW: HFC Bans

EU F-Gas Regulations – Fire Protection System Contractors 


 

The 2014 Regulation adds a ban on HFC 23 from 1st January 2016 to an exisiting ban on PFCs. Bans affecting FPS Equipment Ban description Start date from 1st January:
1 Fire protection systems containing PFCs 2007
2 NEW: Fire protection systems containing HFC 23 2016

NEW: Impact of the HFC Phase Down on the purchase of new equipment

When purchasing new FPS equipment your clients should also consider the HFC phase down

This will reduce the quantity of HFCs that can be sold in the EU – by 2030 there will be an 80% cut in virgin HFC supply. Equipment bought now may still be use when these cuts in virgin supply take effect.

Irrespective of the bans described above, it makes sense to always purchase equipment using fluids
with the lowest practical GWP to minimise the future impact of the phase down.
The fire protection industry is committed to the responsible use of HFCs in fire protection and always
recommends minimising the impact on the environment by recycling material at end-of-life. There is a significant bank of HFCs in installed systems. As these systems reach the end of their natural life the fire extinguishant may be available for recycling.

Contractor training and certification requirements

EU F-Gas Regulations – Fire Protection System Contractors 


 

All HFC handling operations on FPS equipment containing HFCs must be carried out by suitably trained technicians holding an F-Gas ‘Competency’ certificate and working for an F-Gas Certificated company.
This includes system installation, leak testing, HFC recovery, maintenance and end-of-life
decommissioning. The training and certification requirements are based on those already specified
in the 2006 F-Gas Regulation.

Existing individual F-Gas qualification certificates remain valid in accordance with the conditions under
which they were originally issued.

NEW: Qualified technicians must also be given “information on relevant technologies to replace or to
reduce the use of fluorinated greenhouse gases and their safe handling”. No further assessments are
required, but all technicians should be aware of relevant information about the use of alternatives. It
is expected that standard information will be prepared and then circulated via Certification Bodies.

Company Certification is required by all contractors carrying out installation and maintenance work.
This applies to sole traders as well as limited companies. The process is unchanged from the 2006
Regulation.

Contractor responsibilities to minimise HFC emissions

EU F-Gas Regulations – Fire Protection System Contractors 


 

Under the 2006 F-Gas Regulation the legal responsibilities related to F-Gas emissions from FPS
equipment were held only by the system operator.

NEW: In the 2014 Regulation there is an explicit legal requirement for contractors to share this
responsibility. Article 3 of the Regulation states that “The intentional release of F-Gases into the
atmosphere shall be prohibited where the release is not technically necessary for the intended use.”

The Regulation then states that contractors “carrying out the installation, servicing, maintenance,
repair or decommissioning of FPS equipment shall be certified and shall take precautionary measures
to prevent leakage of F-Gases”.
This is an important new requirement about which contractors may need to inform a client, if they are
being asked to do something that does not comply with the Regulation.

Contractor responsibilities during system installation

EU F-Gas Regulations – Fire Protection System Contractors 


 

All contractor staff carrying out installation work related to HFC handling must hold the appropriate
F-Gas competence certificate and must take precautionary measures to prevent leakage. Technicians
carrying out unrelated installation activities, e.g. electrical work, do not need a competence
qualification. However, anyone doing work that could affect the activation of the FPS and give rise to
possible leakage must be qualified.

Product Labeling

EU F-Gas Regulations – Fire Protection System Contractors 


 

All FPS products that contain F-Gases (including HFCs) shall not be placed on the market unless the FGases are identified with a label.

The label shall indicate the following information:

1) A reference that the FPS system contains F-Gases
2) The accepted industry designation for the F-Gas concerned or, if no such designation is
available, the chemical name
3) NEW: From 1 January 2017, the quantity expressed in weight and in CO2 equivalent of F-Gas
contained in the equipment, or the quantity in weight and the global warming potential of the
gas

For most FPS equipment the label will be provided by the equipment manufacturer that fills the
cylinders of fire extinguishing fluid – however, the contractor should always check that the system is
properly labelled.

Contractor responsibilities during maintenance activities

EU F-Gas Regulations – Fire Protection System Contractors 

 

The 2014 F-Gas Regulation includes a number of requirements that affect the use and maintenance
of existing FPS containing HFCs. The rules depend on the size of FPS being used. The regulations
affecting existing equipment relate to

(a) leak prevention and

(b) record keeping.

These requirements are described below.

Mandatory leak checks

EU F-Gas Regulations – Fire Protection System Contractors 


 

Mandatory leak checks are required on all FPS equipment above certain size thresholds.
Under the 2006 F-Gas Regulation, the thresholds were set in terms of the physical quantity of
refrigerant in the system – those containing more than 3 kg required a regular leak check.
NEW: Under the 2014 Regulation the requirements are similar, but the size thresholds are defined
in terms of tonnes CO2 equivalent under both Regulations. Example thresholds are given for HFC 23 and HFC 227ea. All stationary fire protection systems using HFCs contain considerably more than the lower threshold shown in Table 2, so they will all require a mandatory leak test regime.

This is unlikely to impact the fire protection industry as there is already a strict 6 monthly maintenance regime for most systems.

The Regulation recognises that most fire protection systems have regular maintenance and leak
checks.

The leak checking obligations shall be considered to be fulfilled provided the following two
conditions are met:

• the existing inspection regime meets ISO 14520 or EN 15004 standards; and
• the fire protection equipment is inspected

If a leak is found during a mandatory leak check it must be repaired without undue delay and the leak
test repeated within one month to ensure the repair was effective.

Mandatory automatic leak detection

EU F-Gas Regulations – Fire Protection System Contractors 


NEW: For all fire protection systems containing 500 tonnes CO2e or more there is a mandatory
requirement for an automatic leak detection system to be fitted. This is a continuation of a similar
requirement in the 2006 Regulation, although the size threshold is changed from 300 kg to 500 tonnes
CO2e. This will have an impact on systems using high GWP fire extinguishing fluids. For HFC 227ea systems the new threshold for automatic leak detection systems is reduced from 300 kg to 155 kg. For HFC 23 systems the threshold for automatic leak detection is even lower at just 34 kg. This rule applies from 1st January 2015.

Most systems are provided with an automatic leak detection facility as standard.

An automatic leak detection system is defined as a “calibrated mechanical, electrical or electronic
device for detecting leakage of F-Gases which, on detection, alerts the operator or a service company
of any leakage”.

Automatic leak detection systems must be tested at least once every 12 months to ensure their proper
functioning.

Record keeping

EU F-Gas Regulations – Fire Protection System Contractors 


Operators of fire protection systems must keep records for each piece of equipment that is subject to
a mandatory leak check (i.e. above the 5 tonnes CO2e threshold).

The records that must be kept are similar to those required under the 2006 Regulation:

a) quantity and type of F-Gas installed
b) quantities of F-Gas added during installation, maintenance or when repairing a leak
c) NEW: whether the F-Gases used have been recycled or reclaimed (including the name and
address of the recycling or reclamation facility and, where applicable, the certificate number).
d) quantity of any F-Gases recovered
e) the identity of the undertaking that installed, serviced or decommissioned the equipment,
including, where applicable, their certificate number
f) dates and results of all mandatory leak checks
g) NEW: if the equipment was decommissioned, the measures taken to recover and dispose of
the F-Gases.

NEW: Records must be kept by the “operator” for at least 5 years. Where a contractor prepares
records for the operator, the records should also be kept by the contractor for at least 5 years. The
records shall be made available on request to the UK Government’s competent authority (i.e. the
Environment Agency) or to the Commission.

Purchase of bulk HFCs

EU F-Gas Regulations – Fire Protection System Contractors 


HFCs shall only be sold to and purchased by certified undertakings. This means that HFC suppliers will require evidence that contractors are certified or qualified to make the purchase. You should contact your suppliers to confirm what new requirements they plan to introduce – it is likely to be evidence based on your Company F-Gas Certificate.

Contractor responsibilities for systems at end-of-life

EU F-Gas Regulations – Fire Protection System Contractors 


 

Any fire protection systems containing HFCs that is being disposed of at end-of-life must undergo an
HFC recovery process. Recovery must be carried out by a certificated technician.

All recovered F-Gases can either be:

a) given a basic cleaning process, to create “recycled HFC”.
b) sent to a specialist facility that can re-process the old HFC into a fluid with properties identical
to virgin HFC, to create “reclaimed HFC”
c) sent for destruction by incineration at a licenced waste facility
Given the HFC supply shortage that will be created by the phase down process, it is worth trying to
send the old HFC for reclamation as it may have a good residual value. If the old HFC is too
contaminated it cannot be reclaimed and must be sent for destruction. It is important not to mix
different gases in the same recovery cylinder – as this would render them unsuitable for reclamation.

The SRAC industry and the world as a whole, now understand that fluorinated gases have a potentially devastating global warming effect when released into the atmosphere.

F-Gas regulations have been implemented in order to contain, prevent and thereby reduce emissions of fluorinated greenhouse gases.

On 2nd April 2008, the Commission Regulation 303/2008 set out the requirements for a company certification scheme.

This scheme is specifically for businesses working with F-Gas refrigeration, air-conditioning and heat pump equipment containing or designed to contain fluorinated greenhouse gases.

These F-Gas Certification requirements are in accordance with Article 5.1 of EC Regulations 842/2006 on certain fluorinated greenhouse gases (the EC F-Gas Regulation).