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An update on regulatory controls on equipment containing refrigerants .
I- Leak testing of refrigeration, air-conditioning and thermodynamic equipment containing fluids
Commissioning check
The owner of equipment with an HCFC (e.g. R22) charge in excess of 3 kg, or with an HFC (e.g. R134a) or PFC (e.g. CF4) charge in excess of five tonnes CF4) is greater than five tonnes of CO2 equivalent, has the components ensuring refrigerant containment (seals, valves, hoses, gaskets, parts of the system subject to vibration, connections to safety or operating devices) checked for leaks by a certified operator.
Periodic inspections
The owner of a piece of equipment must have a certified operator carry out :
- Leak testing (direct or indirect measurements or pressure drop testing);
- systematic inspection of equipment (seals, valves, hoses, gaskets, parts of the system subject to vibration, connections to safety or operating devices);
- a check of intervention sheets.
At the following intervals:
- every year for equipment containing more than 2 kg of HCFCs or more than 5 teqCO2 of HFCs or PFCs
- every 6 months for equipment containing more than 30 kg of HCFCs or more than 50 teqCO2 of HFCs or PFCs
- every 3 months for equipment containing more than 300 kg of HCFCs or more than 500 teqCO2 of HFCs or PFCs
If a leak detector is installed on equipment containing PFCs or HFCs, the inspection frequency is halved compared with the previous frequency. The inspection is also repeated each time the refrigerant circuit is modified.
Control methods
Testing is carried out either by direct measurement using a measuring detector, electronic detector, foaming agent, soapy water or fluorescent fluid and UV lamp, or by indirect measurement using a leak detector. The leak detector is a permanent device that analyzes at least one of the following parameters:
a) Pressure ;
b) Temperature ;
c) Compressor current ;
d) Liquid levels ;
e) The volume of the refilled quantity.
The device is linked to an alarm that informs the operator of any leak detected. Any suspected refrigerant leak will be investigated by direct measurement as soon as possible. Leak detection devices have a detection threshold equivalent to thirty grams per year. They are checked at least once every twelve months to ensure the accuracy of the information they provide on the fluid charge in the equipment circuits.
Intervention sheet and control marks (NEW)
After an inspection, the results are formalized on the inspection sheet (see specific § below) and an inspection mark is affixed to the equipment. If repairs are necessary, the operator must affix a removable mark to the component to be repaired. This mark is different from the inspection mark. The markings must comply with the models set out in the appendix to the Order of February 29, 2016.
II- Disposal of refrigerants and pre-charged equipment
Distributors of refrigerants and distributors of pre-charged equipment must keep a register showing the transfer of fluids or equipment. The contents of these registers, which may be drawn up in electronic form, are defined in this order. Where the assembly or commissioning of pre-charged equipment requires the use of a certified operator, distributors of such equipment may only sell to the following persons:
- other equipment distributors ;
- operators with a certificate of competence ;
- persons who can prove, at the time of transfer of the equipment, that they have signed a contract for assembly and commissioning of the equipment with an operator holding a certificate of competence. The content of the contract is set out in the new Cerfa n°15498 form.
III- Content and use of the intervention form
The new CERFA form n°15497 is now available.
It must be used if the intervention falls within a category I, II, III or IV* activity. This intervention sheet also serves as a Bordereau de Suivi des Déchets Dangereux (BSD) for fluid disposal, whatever the quantity of fluid in the equipment. This new document, common to all players, provides a single record of information relating to work carried out on equipment containing refrigerants, as well as that relating to waste traceability, as set out in the BSD. The form will be signed by the equipment owner, whatever the refrigerant charge. The CERFA contains in particular:
- contact details for the operator and equipment owner
- the operator's capacity certificate number
- date and nature of work carried out
- nature, quantity and destination of recovered fluid (destination, carrier, treatment)
- if applicable, the quantity of fluid reintroduced into the equipment
- the waste code (14 06 01*) and ADR designation (UN1078) of the fluids to be disposed of, as well as specific fields for the various signatures of the parties involved:
- operator,
- holder and,
- treatment facility.
The BSD is returned to the operator by the treatment facility.
(*) The categories of activities are set out in the Order of June 30, 2008:
- Category I:
leak testing, maintenance and servicing, assembly, commissioning, fluid recovery for all refrigeration, air conditioning and heat pump equipment. - Category II:
maintenance and servicing, assembly, commissioning, fluid recovery of refrigeration, air-conditioning and heat pump equipment containing less than 2 kg of refrigerant, and leak testing of refrigeration, air-conditioning and heat pump equipment. - Category III:
Recovery of fluids from refrigeration, air conditioning and heat pump equipment containing less than 2 kg of refrigerant; - Category IV:
Leak testing of refrigeration, air conditioning and heat pump equipment; - Category V:
leak testing, maintenance and servicing, assembly, commissioning, fluid recovery for air-conditioning systems on vehicles, machines and equipment mentioned in article R. 311-1 of the Highway Code.