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Ian asked me to post this…
F Gas Wallies wrote:F-Gas Support – Promoting Compliance with F-Gas and Ozone Regulations
This message and any attachments have been prepared by F-Gas Support; the information provided is intended as guidance and must not be taken as formal legal advice nor as a definitive statement of the law. Ultimately only the courts can decide on legal questions and matters of legal interpretation. If you have continuing concerns you should seek legal advice from your own lawyers.F-Gas Support is a Government funded team set up to help organisations understand their obligations under the EU Fluorinated Greenhouse Gases and Ozone Regulations. F-Gas Support is also working with Regulators to promote compliance. It is being run on behalf of Defra and the devolved administrations by the Local Authorities Coordinators of Regulatory Services (LACORS) and Enviros.
Err, what? 😕
K.
Re: Refrigeration Legislation
And after I got with the program and spotted the attachment…
Does your RAC business need a Company Certificate?
By 4th July 2009 all businesses (including sole traders) that install, maintain or service refrigeration, air-conditioning or heat-pump equipment that contains “F gases” will need a company certificate. Common F gases are HFC refrigerants such as R134a, R404A, R407A, R410A. There is a full list of F gases in Information Sheet GEN 2 which can be found at http://www.defra.gov.uk/fgas.
A company certificate is required under EC F gas Regulation 842/2006, Commission Regulation 303/2008 and the 2009 GB F gas Regulations SI no. 261.
Your business has until 4th July 2009 to apply for a company certificate from REFCOM.
You can apply to REFCOM for an interim company certificate if your engineers hold the following qualifications:
City & Guilds 2078 or CITB J01.
Alternatively, if your engineers only work on equipment containing less than 3 kg of F gas then they can use an in-house qualification or an “interim personnel certificate” issued by DASA based on their pre-4th July 2008 experience.
All those applying for an interim company certificate will need a full certificate by July 2011.
You can apply to REFCOM for a full company certificate if your engineers hold the following qualifications:
City & Guilds 2079 or CITB J11 – J14 or have a European qualification recognised under EC F gas Regulation 842/2006.
When a business applies for a full company certificate it needs proof that it employs a sufficient number of engineers to do the work and that the necessary tools and procedures are available to the engineers doing this work.
Does your business manufacture equipment containing F gas? You do not need a company certificate unless you carry out repair work and this is undertaken away from your manufacturing site.
When don’t you need a company certificate? You do not need a company certificate if your business sells on F gas or does not handle F gases for installation, maintenance or servicing activities.
Contacts and Further Information
REFCOM can be contacted to apply for a company certificate.
Website: http://www.refcom.org.uk, telephone: 01768 860409 or email: refcom@welplan.co.ukDASA can be contacted to apply for an interim personnel certificate, if you are relying on pre-4 July 2008 experience for working on systems containing less than 3 kg of F gas.
Website: http://www.dasa.org.uk, telephone: 0870 224 0343 or email: office@dasa.org.ukF-Gas Support can be contacted for general queries.
Website: http://www.defra.gov.uk/fgas, helpline: 0161 874 3663 or email: fgas-support@enviros.comRe: Refrigeration Legislation
Ta Ken – The gist of it is that if you work on appliances that have less than 3 Kg of F gas ie CFC/HCFC R12/R134a etc you have got to have an ‘in house certificate from DASA’ or a qualification such as C&G 2078 etc. (Legislation came on line today by the way.)
Those of you at the last meeting will remember that I was bashing away at the F Gas rep saying ‘no way not going to happen’ , ‘do you really think that the WTA/UKW lot are having DASA doing the paperwork – not a chance’ or ‘you think that they represent the industry – tosh’ His response was that it ‘was too late we have missed the boat should have signed up in 2001’ My answer was OK if thats how you want to go i guess no-one will bother This went on after the meeting and up until friday when I thought bugger it, I’ve had enough. Or as Ken is want to tell me most days ‘welcome to my word’
Imagine my surprise to receive a call from Defra today wanting to talk about what we were trying to do. I explained that as the youngest but largest TA I felt we should have an input even as a latecomer. We would like to do our own ‘in house certification’ and that I expected that if we couldn’t work something out we just wouldn’t bother. I further explained that if anything, engineers would just refuse to work on F Gas products and likely increase the WEEE pile. Surprisingly, he agreed and suggested that he would look into us doing our own register as long as we were prepared to sign up to the same terms as DASA. These will be forthcoming in the next few days and I’ll keep you posted.
Whichever, hopefully we will once again have the tiller. 🙂
Now you may ask why I’m bothering with something that is on its way out but reading between the lines sometime in the future the hydro carbons are sure to enter the debate. Better to be in now than trying later. 8)
Re: Refrigeration Legislation
Quite what the grounds would be to include hydrocarbons is beyond me, they are naturally occurring and released gases to atmosphere so that one’s a bit odd. But point taken in any event and, let’s face it, government is generally to be regarded as “stupid” only influenced by lobbyists in some ways.
So I suppose becoming a lobby might not be so bad. It’d be a whole lot better if the idiots listened to common sense but I guess we can’t have everything. 😉
I’ll have think about this over the next few days although I have already in some measure and I’m still struggling to get my head round why or how it relates to domestic units.
One question, is R600a used in any commercial refrigeration system?
If not you can bet your ass that ACRIB won’t be even remotely interested. 😉
K.
Re: Refrigeration Legislation
R600a – Yes it is used in commercial refrigeration, and just to add the sauce the Care range of refrigerants (another HC) is used in industrial too! Not a time to be taking our eye off the ball.
Re: Refrigeration Legislation
My point was, which I just made in the Dispatches thread…
Rather than joining in and being all cosy, cosy we should explain to them why it is not required, what will happen if it is enforced and what the troops will do which is, effectively, to tell them to go forth and multiply although in a far shorter phrase.
Thing is, how are they going to enforce it?
Most of the suppliers buy the gas from foreign shores and it’s unregulated. And, even if it were, how are they going to find out who’s bringing it in and who’s selling it.
Then if it does lead to a load of people simply saying, stuff that for a caper, and dropping the refrigeration servicing then how are domestic units going to get repaired? Or, do we just scrap them all?
In short, this will go exactly the way that gas did when CORGI came in to regulate it, we end up with no bugger wanting to do it bar a select few. It then forces prices up, removes competition from the marketplace and makes a bigger pile of scrap.
There’s few enough people that do refrigeration as it is, I have to ask is there any point in putting more hurdles in the way of those that can or want to do it than there already are?
K.
Re: Refrigeration Legislation
Through my youth work side of things I have seen so much wasted money on stupid projects when there could have been funding to make a diffrence on the ground its criminal ,but from a WTA perspective , are we not better on the inside p~#~ing out ,not on the outside Pi@/#ng in whilst being accused of not bothering to take notice of something that is going to affect our trade one way or another ,just because we are “cosy,cosy” doesn’t mean that we can’t make some very salient points ,and we all know Ian can be salient 😉 .
Re: Refrigeration Legislation
Yes, but you’re into that shady old area known as politics.
You are dealing with civil servants who, in some measure, carry out the instruction/s of politicians. Civil servants are isolated from reality and voters, they get paid and have a job irrespective of what happens. They do however have to justify their existence to their masters and be seen to getting results.
Now, here’s where it all goes rather pear shaped…
What’s a result?
Is a result instigating legislation or systems that are effectively a dead duck as it can’t be enforced?
Or, is it saving the taxpayer and industry the hassle of trying to implement something that is almost bound to prove fruitless and a waste of time and money in the long run?
I need to explain something here, I don’t gamble very often on very much. I do take calculated risks though, that I will hold my hands up to. But those risks are very carefully calculated, the various scenarios played out and then it all weighed up to give a likely result based on as much information as is possible to get.
On this I’d be tempted to play it to DEFRA that it won’t work as it is unworkable in the real world. There’s a plethora of reasons that you can give them for that and, if required, any defence of it they throw up can be torn to shreds easily. Do it in a nice way though, you can’t be too blunt and if you want help just ask.
On the other hand, we play ball and say: “sure, we’ll do our best and work with DASA to bring this to fruition”, but with the caveats that we stress.
That way if it’s a success you take the glory.
If it fails you can point and say, “told you so”.
Either way, the WTA wins.
But you simply MUST consider the angles and play to them when you get into this stuff.
Don’t bet, be right. And if you can’t be sure of being right, cover the bases. Make sure you do as much as you can by email or in writing so you can cover those bases. 😉
K.
Re: Refrigeration Legislation
Agreement Document from DEFRA that Ian asked me to post for you to have a read of.
🙂
K.
Re: Refrigeration Legislation
If you have time read the above but the gist of it is that subject to signing and having a government minister authorising it we can run our own ‘in house certification scheme’ for f-gas engineers. The only requirement is that we keep records (an excel file) together with evidence of experience should the government bods want to have a look. I have also offered to certify ‘non WTA members’ for a small fee (which might be waivered if they join WTA). If you are all happy with this I would like to go forward as we only have until 4th July to have it signed off and the engineers registered. Doesn’t leave much time to get all the engineers on board and supporting evidence in and paperwork up to DEFRA..
Re: Refrigeration Legislation
The emails have been flying between Defra and me and I now have most of the bits in place. However, today I was bowled a googly and need a concensus. The offer made by the WTA was that we would certificate our own people free of charge but would charge £25 to register a non WTA person. HM Treasury have indicated that this would not be acceptable as those non members of WTA would be subsidising the WTA. I disagreed turning it around saying that the WTA should not cough up funds for non members. This was also rejected. Having moved the goal posts they now have indicated that for the WTA to be allowed to issue certificates we have to issue to anyone who presents their evidence. Normally, I would just tell them to stick it but I feel we should stay with this as it gives an input when 2011 get here and they come up with something else. With this in mind could I suggest that we offer to charge everyone £25 which will generate some funds and those that sign up and are WTA members get a discount on their next years subs. This will keep HMT off our backs as we are seen to be charging the same rate to everyone. I am sure we could bias things to dissuade those that we dont want to register. Let me know which way you want to go :rolls:
Like you, I’d have that reaction at first as well and add that it’s not that valuable to be worth the effort.
But then, it’s not my call.
I also cannot see why the TA can’t discount it’s own services to its own members, that seems a bit odd.
K.
Re: Refrigeration Legislation
There would have to be a charge levied to cover the admin. If anything, as in the perennial “call out charge” arguement, the charge adds value to what is being offered. None of the recipients of the certificates will work for nowt, so the WTA cannot be expected to either. Are DEFRA offering to cover our costs if the WTA get the nod?
Just a question – does the WTA have training facilities in place for applicants to upgrade if required? I don’t do refrigeration normally, but I took the C&G refrigerant handling certificate back along to be covered just in case I needed it in the future. Do we have a list of centres?Steve.
Re: Refrigeration Legislation
Steve – At this time this certificate only applies to work on R134a appliances and is designed to cover us until they disappear and we have only R600a to play with. Regarding a course for Hydro-Carbon refrigerants (R600a), Grimsby College, Graham Dixon and me had a meeting on Tuesday and are in the midst of getting a training course approved by C&G
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