A simplified Waste Tracking Slip for used refrigerant fluids

A new CERFA form (15497) merges the intervention sheet and BSD to simplify the management of used refrigerants, an obligation often overlooked but subject to penalties.

Marie Faucon
Consultante HSE
Publication : 
05.03.2016
Table of Contents
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Please note: This article concerns French legislation. The requirements described may not apply in other countries.

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Mandatory since 2011, the issuance of a waste tracking slip (BSD) when recovering used refrigerants for treatment, remains an unknown and often disregarded requirement. To reinforce and simplify this formality, a new CERFA form is now available to refrigeration service providers who drain refrigerants. This form serves as both an intervention sheet and a BSD.

The new Cerfa form, numbered 15497, is available on the website Service-public.fr . It is also available in software.

formulaire Cerfa 15497

Pursuant to an order dated February 29, 2016, this form must now be used by refrigeration technicians holding a certificate of capacity:

  1. As an Intervention Sheet, during leak checks and operations requiring the handling of refrigerants (with the exception of interventions on vehicle air conditioning systems)
  2. As a BSD, when recovering used refrigerants intended for treatment.

This avoids the need to fill out two documents (Intervention Sheet + BSD) that partially cover the same information (particularly the nature, quantity, and destination of the recovered fluid). Thus, this form simplifies administrative procedures. It addresses the difficulties raised by refrigeration professionals regarding the establishment and tracking of BSDs.

In practice, Cerfa form 15497 must be completed:

  • By the refrigeration technician, and not by the owner of the equipment containing the removed refrigerant

=> For any equipment where the HCFC charge (e.g., R22 fluid) exceeds 3 kg or where the HFC charge (e.g., R134a, R404a, R407c, R410a fluids) exceeds 5 tonnes CO equivalent2, the equipment owner must nevertheless jointly sign the form and keep a copy for at least 5 years.

  • For a single piece of equipment AND a single refrigerant

=> This means that if two pieces of equipment containing the same refrigerant are emptied, two forms must be completed. This applies even if all the recovered fluid is collected in the same recovery cylinder.

After used refrigerants have been processed, the copy of the form endorsed by the operator of the treatment facility is sent only to the refrigeration technician. Equipment owners should therefore not expect to receive a copy of the form to certify the handling and treatment of their waste refrigerants.

N.B.: Even if the BSD (Waste Tracking Slip) is prepared by the refrigeration technician responsible for the work on the equipment and returned exclusively to them, the removal of used refrigerants must always be recorded in the outgoing waste registers of refrigeration and air conditioning equipment owners. As such, it is advisable to systematically obtain a copy of the Cerfa form from refrigeration service providers, even for equipment containing less than 2 kg of HCFC or 5 tCO2 of HFC.

How should the BSD section of Cerfa form 15497 be completed?

BSD fluides frigorigènes usagés

Boxes 11 to 15 of Cerfa form 15497 must be completed when recovering used refrigerants. Here's the procedure to follow:

    1. Box 11 is used to indicate the total quantity of recovered refrigerant intended for treatment.
    2. The waste code (14 06 01* - Chlorofluorocarbons, HCFC, HFC) is pre-filled on the form, as are the ADR provisions. Surprisingly, these do not fully comply with ADR requirements. Firstly, the word "WASTE" does not appear between UN code 1078 and the designation "Refrigerant gas N.O.S.". Secondly, some refrigerants have specific UN codes. These codes should be used preferentially over the generic UN code 1078:
      • R22 => UN 1018, WASTE CHLORODIFLUOROMETHANE (REFRIGERANT GAS R 22), 2.2 (C/E)
      • R134a => UN 3159, WASTE 1,1,1,2-TETRAFLUOROETHANE (REFRIGERANT GAS R 134a), 2.2
      • R407c => UN 3340, WASTE REFRIGERANT GAS R 407C, 2.2
      Otherwise, the chemical name of the fluid should be able to be added in parentheses immediately after the designation "Refrigerant gas N.O.S.". This is not permitted by the pre-filled box 11.
      Ultimately, box 14 (Observations) allows for the inclusion of alternative remarks. All this is in compliance with ADR requirements for transport documents.
    3. Box 12 is for indicating the name and address of the receiving treatment facility.
    4. Box 13 is used to enter the name and address of a carrier. This applies when the transport is not carried out by the refrigeration technician themselves.
    5. Box 15 is completed by the operator of the treatment facility. The R or D code corresponding to the recovery or disposal operation performed on the received refrigerant fluid must be specified. This will generally be code R2 (Regeneration) or D10 (Incineration).

Used refrigerant fluids, in summary

Ultimately, with the implementation of Cerfa form 15497, the issuance of a Waste Tracking Slip (BSD) during the recovery and removal of used refrigerant fluids should no longer be a neglected formality. This is good news considering the penalties incurred. Failure to provide a BSD is punishable by a maximum fine of €750. Indeed, the absence of a transport document under ADR regulations exposes the sender to a penalty of 1 year imprisonment and a €30,000 fine.

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