Changes to regulatory inspections for equipment containing refrigerants

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An update on the evolution of regulatory checks for equipment containing refrigerant fluids.

I- Leak-tightness checks for refrigeration, air conditioning, and thermodynamic equipment containing

Commissioning checks

The owner of equipment with an HCFC charge (e.g., R22) exceeding 3 kg, or an HFC (e.g., R134a) or PFC (e.g., CF4) charge exceeding five tonnes of CO2 equivalent, must have a leak-tightness check performed upon commissioning on the components ensuring the containment of refrigerant fluids (seals, valves, hoses, gaskets, parts of the system subject to vibration, and connections to safety or operating devices) by an operator holding a certificate of capacity.

Periodic checks

The equipment owner must have the following performed by an operator holding a certificate of capacity:

• a leak-tightness check (direct or indirect measurements, or pressure drop testing);
• a systematic inspection of the equipment (seals, valves, hoses, gaskets, parts of the system subject to vibration, and connections to safety or operating devices);
• a review of service records.

According to the following intervals:

• annually for equipment containing more than 2 kg of HCFCs or more than 5 tonnes of CO2 equivalent of HFCs or PFCs
• every 6 months for equipment containing more than 30 kg of HCFCs or more than 50 tonnes of CO2 equivalent of HFCs or PFCs
• every 3 months for equipment containing more than 300 kg of HCFCs or more than 500 tonnes of CO2 equivalent of HFCs or PFCs

If a leak detector is installed on equipment containing PFCs or HFCs, the inspection frequency is halved compared to the intervals mentioned above. This inspection must also be repeated whenever any modifications are made that affect the circuit containing the refrigerants.

Inspection methods

Inspections must be carried out either by direct measurement using a measuring detector, an electronic detector, a foaming agent, soapy water, or a fluorescent fluid and a UV lamp, or by indirect measurement using a leak detection system. A leak detection system is a permanent device that monitors at least one of the following parameters:

a) Pressure;

b) Temperature;

c) Compressor current;

d) Liquid levels;

e) Volume of the recharged quantity.

The device is connected to an alarm that notifies the operator of any detected leaks. Any suspected refrigerant leak must be investigated using direct measurement methods as soon as possible. Leak detection systems must have a detection threshold of at least thirty grams per year. They must be checked at least once every twelve months to ensure the accuracy of the information provided regarding the refrigerant charge in the equipment circuits.

Intervention record and inspection labels (NEW)

Following an inspection, the results must be documented on the intervention record (see specific section below) and an inspection label must be affixed to the equipment. If repairs are required, the operator must affix a removable label to the component needing repair. This label must be different from the inspection label. Labels must comply with the templates set out in the annex to the decree of February 29, 2016.

II- Sale of refrigerants and pre-charged equipment

Distributors of refrigerants and distributors of pre-charged equipment must maintain a register documenting the sale of such fluids or equipment. The contents of these registers, which may be kept in electronic format, are defined in this decree. Whenever the assembly or commissioning of pre-charged equipment requires the services of an operator holding a capacity certificate, distributors may only sell such equipment to the following parties:

• other equipment distributors;
• operators holding a capacity certificate;
• individuals who, at the time of purchase, provide proof of having entered into a contract for the assembly and commissioning of the equipment with an operator holding a capacity certificate. The content of the contract must be established in accordance with the new Cerfa form no. 15498.

III- Content and terms of use for the service report

A standard service report template has been established: the new CERFA form no. 15497.

It must be used if the service falls under category I, II, III, or IV activities*. This service report also serves as a Hazardous Waste Tracking Slip (BSD) in the event of fluid disposal, regardless of the amount of fluid in the equipment. This new document, common to all stakeholders, consolidates information regarding service on equipment containing refrigerants and data related to waste traceability as required by the BSD into a single document. The report must be signed by the equipment owner, regardless of the refrigerant charge. The CERFA form includes, in particular:

• the contact details of the operator and the equipment owner
• the operator's capacity certificate number
• the date and nature of the service performed
• the type, quantity, and destination of the recovered fluid (destination, carrier, treatment facility)
• where applicable, the quantity of fluid reintroduced into the equipment
• the waste code (14 06 01*) and the ADR designation (UN1078) for the disposed fluids, as well as specific sections for the various signatures of the parties involved:
  
  • operator,
  • owner, and,
  • treatment facility.

The BSD is returned to the operator by the treatment facility.

(*) The categories of activities are defined by the decree of June 30, 2008:

• Category I:
  leak checking, maintenance and servicing, assembly, commissioning, and refrigerant recovery for all refrigeration, air conditioning, and heat pump equipment.
• Category II:
  maintenance and servicing, assembly, commissioning, and refrigerant recovery for refrigeration, air conditioning, and heat pump equipment containing less than 2 kg of refrigerant, as well as leak checking for refrigeration, air conditioning, and heat pump equipment.
• Category III:
  Refrigerant recovery for refrigeration, air conditioning, and heat pump equipment containing less than 2 kg of refrigerant;
• Category IV:
  Leak checking for refrigeration, air conditioning, and heat pump equipment;
• Category V:
  leak checking, maintenance and servicing, assembly, commissioning, and refrigerant recovery for air conditioning systems in vehicles, machinery, and equipment as specified in Article R. 311-1 of the Highway Code.