FAQs

These questions and answers are from a growing compilation based on the most commonly asked questions to BOC and HRP direct and through 'Ask Barry'. Others have been reproduced with the consent of industry 'legal eagle' Steve Gill, and Ireland's Environmental Protection Agency.

Irish customers should check the EPA site for updates at www.epa.ie/downloads/

Reclaimed and Recycled R22

Where can I buy reclaimed R22?

Only a limited quantity of reclaimed R22 is available and BOC's direct supply has already been allocated to its contracted customers. However, HRP do have supplies available for general sale, so please speak to your nearest HRP Service Centre to check availability. The best option is to move away from R22 to a non HCFC alternative as soon as is practically possible.

Where can I buy reclaimed R22?

According to the British Refrigeration Association (BRA), the total amount of R22 reclaimed in 2007 was 205 tonnes and 210 tonnes in 2008 (2009 data not yet published). This was only between 10-12% of the demand for virgin R22 in those years and if demand continues at these levels supplies will soon be exhausted.

What's the difference between reclaim and recycled?

Recycled HCFCs are recovered HCFC that has been subject only to a basic cleaning process (this might include mechanical filtering and moisture removal).

Recycled HCFCs may only be used by either the undertaking which carried out the recovery (in most cases the refrigeration contractor) or the undertaking for which the recovery was carried out (the owner). Recycled HCFCs may not be placed on the market - "placing on the market" means the supplying or making available to third persons within the Community for payment or free of charge. For example, the owner could use the recycled. HCFC in RAC equipment at other sites they operate from but they cannot sell recycled HCFC to a third party.

Reclaimed HCFCs are recovered HCFC gas that has been chemically reprocessed to a specified standard.

Reclaimed HCFCs may be placed on the wider market and used by undertakings other than the original contractor and owner. Reclaimed HCFCs must be held in containers labelled as such, with information on the batch number and name and address of the reclamation facility. Reclaimed material has been reprocessed to a specified quality that is suitable for use in a refrigeration system whereas recycled material is of an unknown quality - it might contain contaminants that could impair the performance of a refrigeration plant.

Reclaim Grade Product. This is any recovered refrigerant which is not to be returned to the originating system (or recycled to another system on that site) but which needs to be recovered and returned to a refrigerant waste handling company. There, it can be analysed to assess its quality and then either reclaimed to bring it up to new material standard (ARI 700) using specialist equipment, or disposed of through incineration by an approved waste disposal company. It can then be placed on the market for resale.

What purity are BOC / HRPs' reclaimed R22?

BOC produces its reclaimed R22 to virgin / ARI 700 specification which have a purity of 99.5%. Use of reclaimed R22 of lower specification, or recycled R22 which has not been subjected to the full reclaim process might contain contaminants that could impair the performance and may well damage the refrigeration system.

What do I do with the R22 / other HCFCs I have?

When safely removed from the system, they need to be returned to BOC or HRP to be either reclaimed or safely disposed of. Credits are available for recovered R22 above specific volumes that is reclaimable. If you have a significant quantity of product available, BOC has specialist technology available that can help you in recovering that product quickly with minimal disruption to plant operations.

Will BOC / HRP buy my recovered R22?

Yes - providing it is not contaminated with other refrigerants, customers returning over 40kg of reclaimable R22 in a single cylinder will be paid a credit of at least £2.00 per kg after the refrigerant has been processed. Higher credit rates may be available for quantities over 1 tonne returned in a single transaction. Credits are also available for reclaimable R134a.

Can we stockpile recovered/reclaimed/recycled R22 for use up until 2015?

This is a complicated area and we recommend you contact us for full advice. Essentially yes, subject to the normal restrictions for the storage of refrigerants, but bear in mind that refrigerant that is recovered from a system is considered as waste. It is legal to hold hazardous waste on the site on which it was produced. The waste regulations mainly take effect when it is decided to move it from the site, when you will require a premises code (assuming the site is not exempt) . It is only permissible to hold the waste for a period less than 12 months. When the storage period hits 12 months the site effectively becomes a 'landfill site' and must meet the planning permissions and licensing requirements to operate a land fill site.

Can we recover the R22 from one system and charge it into another system after 1st January 2010?

Recovered R22 is a waste product and as such there are certain restrictions on the transportation and handling of the substance. However, assuming that the two systems are on the same site, and the refrigerant doesn't require transporting it would be legal to charge from one system to another. There may be other non-legal reasons such as unknown levels of contamination, why it may not be desirable to take R22 straight from one system to another without it being sent back to the supplier for cleaning.

HCFC Alternatives

Has there ever been a ban on designing a new system that uses R403B as the refrigerant gas? If so what year did it come into effect?

Yes as R403B is an HCFC and contains 56% by wt of R22 it falls under the ODS (Ozone Depleting Substance) regulation EN 2037/2000 which banned the use of HCFC refrigerants in new equipment in 2000.

What's the replacement for R123?

Unfortunately there is no replacement for R123 - it means a new chiller, I am sorry to say.

Can I use one of the HFC retrofit gases to top up an existing R22 system?

No, this would create a cocktail of gases which would not follow the correct thermodynamic profile and fail to perform to the requirements of the end user. The whole charge will then need to be removed and incinerated

What alternatives are available?

Which alternative you should use would depend on the application, the system design and equipment used. See the product selector as a guide, or contact BOC or HRP for advice and support on identifying the most suitable alternative for your needs.

What system changes will I need to make?

Under normal circumstances, system changes are minimal; adjustment to expansion valves may be required. Some alternatives may also require a change from mineral to a POE oil. ISCEON MO79 (R422A) and RS52 (R428A) will require an expansion valve change to a R404A valve as these refrigerants are replacements for R502. For further advice, speak to BOC or HRP.

How much are the new alternatives?

Please contact BOC or HRP to discuss the alternatives and the latest prices available.

How long will these alternatives last?

With the exception of vehicle air-conditioning, there is no legislation currently in place to ban or restrict the supply or use of HFC refrigerants in stationary equipment.

Legal

Who do I need to call and talk to about a heating and air conditioning company releasing refrigeration in the atmosphere? In the UK contact:

F-Gas Support Help Desk
Tel: 0161 874 3663
Fax: 0161 848 0181
Email: fgas-support@enviros.com
Web: www.defra.gov.uk/fgas

Why have R22 and the other HCFCs subject to phase out?

Under the Montreal Protocol, it was agreed that ozone-depleting substances (ODS) including CFCs and HCFCs would be phased out globally. The EC regulation number 2037/2000 set a timetable to remove the most hazardous refrigerants, and new HCFCs cannot be used from 1 January 2010.

Do we need to remove all the R22 from the system now?

The Regulation bans the 'top-up' of the system with 'virgin' R22 after 1st January 2010. There is no legal requirement to remove the existing R22 from the system.

Do we need to remove all the R22 from the system before 1st January 2015?

No. The Regulation bans the 'topping-up' of the system with virgin HCFC refrigerant but reclaimed or recycled HCFC can be used up till 31st December 2014, but if the plant is still operating, there isn't a requirement to recover it by that date. Of course, servicing of the system will be difficult because no HCFC in any condition will be legally available after that date.

If we are caught using virgin R22 after 1st January 2010, what will happen?

It is difficult to speculate as to the possible consequences for the company responsible or the individual as the law has obviously not been tested yet, but it would be a criminal offence as opposed to civil offence, so any individual would be prosecuted as opposed to being sued, and as such could receive a criminal record with a fine. Local Magistrates Court can impose a maximum fine of £5,000.00 and if the case is moved to a Crown Court the fines are unlimited.

Can we stockpile unused R22 after 1st January 2010?

No virgin R22 can be used after 1st January 2010 and any that is unused at that time must be returned to the refrigerant supplier for destruction.

What is 'virgin' R22?

Interestingly, the Regulation itself does not give a definition of what 'virgin' means, however, it is likely that its common meaning will be used. Therefore, virgin R22 is unused R22 that has not been charged into a system. Even 'clean' R22 that has passed through a system (if there is such a thing) may no longer be considered as 'virgin' R22.

Questions from End Users

What qualifications should I look out for when selecting a contractor?

Your contractor should currently hold a City and Guilds Certificate 2078 in Refrigerant Handling or the Construction Industry Training Board (CITB) J01 equivalent.

In addition, your contractor should be making plans to become qualified to the City and Guilds 2079 Level 1 Award in F-gas Regulation or the CITB J11-J14 equivalent by July 2011.

Your contracting company should also hold a full or interim certificate from one of the organisations approved to register refrigerant handling companies (i.e. Refcom).

I have a system on my site containing R22, and there appears to be a leak. If my contractor recovers the gas from the system and repairs the leak, can he/she charge the recovered gas back into the same system?

Yes, the recovered gas should be passed through a recovery unit to ensure it is recycled and then it can be charged back into the same system by your contractor.

I have a system on my site containing R22. If my contractor recovers the R22 and replaces it with another type of gas, can the R22 he/she has recovered be used to service and maintain another R22 system on my site?

Yes, the recovered R22 must be passed through a recovery unit to ensure it is recycled and then it can be charged into another system on your site.

My contractor has recovered R22 from systems on my site and I have no further need for it. What should I do with the gas?

The following options are available to you:

  • You can reuse the recovered gas on another site within your organisation, as Long as it has been recycled (i.e. subjected to a basic cleaning process);
  • . You can arrange to have the recovered gas collected and managed as a hazardous waste by engaging the services of a hazardous waste contractor. All such movement should be made in purpose built designated recovery cylinders. You should confirm with your contractor that the recovery cylinder is their Property and that they agree to allow the waste company to remove it from your site before shipment.
  • Where your contractor has the required paperwork from the Environment Agency you can allow them to move the R22 to an appropriately permitted waste facility.

How do I know if my contractor has used recycled or reclaimed HCFC in the maintenance or servicing of equipment on my site?

Any equipment that is maintained or serviced using recycled or reclaimed HCFCs must be labelled with an indication of the type of substance and its quantity contained in the equipment. Where your contractor is using recycled R22 you should ensure that they advise you in writing of the source of the R22 and you should maintain this information in the system log book as defined in the F-Gas regulations for future inspection by environment inspectors.

Am I required to keep any particular records of recycled or reclaimed HCFCs used during maintenance or servicing?

Yes, any undertaking (end-user or contractor) using recycled or reclaimed HCFCs during maintenance or servicing must keep a record of the supplier of reclaimed HCFCs and of the source of the recycled HCFCs. Such information should be placed in the system log book and be available for inspection.

Questions from Contractors

What qualifications should I have for handling refrigerants?

You should currently hold a City and Guilds Certificate 2078 in Refrigerant Handling or the Construction Industry Training Board (CITB) J01 equivalent.

In addition, you should be making plans to become qualified to the City and Guilds 2079 Level 2 Award in F-gas Regulation or the CITB J11-J14 equivalent by July 2011.

You should also hold a full or interim certificate from one of the organisations approved to register refrigerant handling companies (i.e. Refcom).

Can I recover refrigerant gas from a system on my client's site, service the system, and return the gas to the same system on that site?

Yes, the refrigerant gas is not being discarded and is therefore not a waste. If the gas has undergone a basic cleaning process, it is considered recycled.

I have recovered R22 from a system on my client's site. Can I use it for maintenance or servicing of other equipment on that same site?

Yes, the recovered R22 should be recycled on-site and can then, with the end-user's permission, be used for maintenance or servicing of other equipment on that site.

Can I recover refrigerant gas from a system on my client's site and charge the system with a different type of gas?

Yes, but what you do or the end-user does with the recovered gas must comply with the waste legislation and the requirements set out in the ODS Regulations.

I have recovered R22 from a system on my client's site and I have no further use for the gas. Can I give/sell the recovered gas to another contractor who I know needs it?

No, recycled HCFC can only be used by your client on that site or any other site within their organisation, or by you on that site or another site on which you are carrying out maintenance or servicing. This means that the recovered gas cannot be given/sold by you or your client to any other contractor for maintenance or servicing on an unrelated site.

If I use recycled or reclaimed HCFCs during maintenance or servicing, do I need to use any special labels?

Yes, any equipment that is maintained or serviced using recycled or reclaimed HCFCs must be labelled detailing the type of substance and its quantity contained in the equipment.

Am I required to keep any particular records of recycled or reclaimed HCFCs used during maintenance or servicing?

Yes, any undertaking (contractor or end-user) using recycled or reclaimed HCFCs during maintenance or servicing must keep a record of the supplier of reclaimed HCFCs and of the source of the recycled HCFCs. Such records should be available for inspection.

Disclaimer

The information on this website is furnished free of charge and is based on the technical data provided by BOC's suppliers which is believed to be reliable at the time it was provided. It is intended for use by persons having the appropriate technical skill, at their own discretion and risk. Because conditions of product use are outside our control, we make no warranties, expressed or implied, and assume no liability in connection with any use of this information. For technical support please refer to BOC or HRP prior to use.