1. Legislation + Regulations = Change
David Blackhurst
Director – Star Technical Solutions
In early 1990 just before I entered the refrigeration industry my then boss warned about the dangers involved.
I had been working in a marine engineering environment and he was concerned that I was about to leave a dynamic and interesting industry sector to work in a quiet backwater that was “very narrow and relatively dull.” Little did he or I know just how different the reality was compared to his perception.
For the refrigeration industry, the reality of the past 25 years has been one of continuous change; primarily driven by international agreements, international & national legislation and the associated codes of practice, standards and guidelines that have come about as realisation has grown of the impact of human activity on our environment.

2. Ozone Depletion
Ozone Depletion
The indiscriminate use of stable, chlorine & bromine containing compounds from the 1930’s onwards led to a breakdown of the Ozone Layer which protects the surface of the planet from UV-B radiation. The breakdown was theorised in the early 1970’s by Rowland & Molina and in 1985 the British Antarctic Survey confirmed that it had identified abnormally low ozone concentrations above Halley Bay near the South Pole. Without this protection an increase in skin cancer rates and damage to crops and ocean phytoplankton were anticipated.
International action in the form of the Montreal Protocol was enacted to phase out the use of the chemical compounds that were identified as contributing to the problem.
Primary among them were the CFC and HCFC compounds, widely used in foam blowing, fire suppression systems and domestic, commercial and industrial refrigeration applications.
The outcome was the signing in 1987 of the Montreal Protocol, which committed the signatories to timetable for phase out of these refrigerants.
Largest observed hole in the Ozone Layer over Antarctica
September 2006

3. Greenhouse Gases Greenhouse Gases - Carbon Dioxide
Running alongside the issue of Ozone Depletion, but initially somewhat more hidden to the general public, was the growing realisation that we were also entering a period in the planets history, at least in relatively recent history (last 500,000 years), that is without precedent.
Since the start of the industrial revolution in the late 18th Century the levels of carbon dioxide in the atmosphere had been growing at an exponential rate. Carbon dioxide is classified as a “greenhouse gas” as it has the property of absorbing infrared radiation that would normally be radiated back from the earth. It is this property that makes the relentless rise of carbon dioxide concentrations an environmental concern.
May 2013 saw the passing of a profound milestone, when measurements indicated that the background level had reached 400ppm. We are, to paraphrase Captain Kirk, “where no man has been before.”
Refrigeration systems are indirectly complicit in this - in that the most of them run on electricity and most of our electricity is still generated from fossil fuels.

4. Greenhouse Gases Kyoto Protocol Status
Greenhouse Gases - Carbon Dioxide
International attempts to manage this issue has been through UN Framework Convention on Climate Change (UNFCCC), and in particular the Kyoto Protocol, which was adopted by Parties to the UNFCCC in 1997 and entered into force in However this protocol has not been without its problems – not all industrialised countries (eg USA, Canada) signed up to it and presently only those countries in dark green have binding targets.
Kyoto Protocol Status
Dark Green – binding reduction targets
Other Colours – no binding reduction targets

5. Greenhouse Gases – Refrigerants GWP
CO2
GWP = 1
R134a
GWP = 1300
R22
& R407F
1700
R410A
GWP = 1980
R404A
&
R507A
3800
Greenhouse Gases – Refrigerants GWP
As well as targeting direct carbon dioxide emissions, the Kyoto Protocol included a basket of other chemicals that also contribute to global warming. Among these are the hydrofluorocarbon (HFC) chemicals that were developed as zero ODP refrigerants to replace the CFCs and HCFCs that were phased out as a result of the Montreal Protocol.
The HFCs were included because their direct global warming impact is in most cases thousands of times greater than that of carbon dioxide.
Note: The GWP number is based on a 100 year time horizon.

6. Greenhouse Gases – HFC Emissions
Greenhouse Gases – Refrigerants GWP
The release of HFCs into the atmosphere has also grown exponentially since the early 1990’s.

7. Greenhouse Gases – HFC Emissions
Greenhouse Gases – Refrigerants GWP
While still not agreeing to binding reduction targets on the release of CO2 to the atmosphere, there is now a much wider international consensus on the need for managing the use of HFCs.
June the USA and China agreed to work together with other countries to use the expertise and institutions of the Montreal Protocol to phase down consumption and production of HFCs.

8. Refrigeration - Key Legislation & Regulations
The Montreal Protocol
EU Regulations (EC) No 2037 / 2000 & No 1005 / 2009
On Substances that Deplete
the Ozone Layer
The Environmental Protection
(Controls on Ozone Depleting Substances) Regulations 2011
Refrigeration - Key Legislation & Regulations
Ozone Depleting Substances
The international agreement, The Montreal Protocol, led to EU Regulations (EC) No 2037 / 2000 and its update No 1005 / 2009 and their most recent enactment in UK legislation through The Environmental Protection (Controls on Ozone Depleting Substances) Regulations 2011 & Ozone Depleting Substances (Qualifications) Regulations 2009.
The final stage of these regulations will be enacted on the 31st December 2014, after which it will be illegal to use recycled or reclaimed HCFCs, ie R22 or blends containing R22, to service RAC equipment.
Ozone Depleting Substances
(Qualifications) Regulations 2009

9. Refrigeration - Key Legislation & Regulations
The Kyoto Protocol
UK Obligations to meeting its
Global Greenhouse Gas (GHG) Emissions Target
Climate Change Act 2008
Refrigeration - Key Legislation & Regulations
Global Warming Gases
The primary gas identified with the issue of global warming & climate change is Carbon Dioxide, released into the atmosphere by the burning of fossil fuels. As part of its obligations under the Kyoto Protocol; which it signed in 1998 and then ratified in May 2002; the UK Climate Change Act 2008 established the world’s first legally binding climate change target. Its aim is to reduce the UK’s greenhouse gas emissions by at least 80% (from the 1990 baseline) by 2050.
Aims to reduce the UKs GHG
emissions by at least 80%, from 1990 baseline, by 2050

10. Refrigeration - Key Legislation & Regulations
Climate Change Act 2008
5 Key Activities:
Setting national policy and strategy
Reducing the demand for energy and helping people and
businesses to use energy more efficiently
Investing in low-carbon technologies
Publicly reporting carbon emissions from businesses
and the public sector
Taking international action
Refrigeration - Key Legislation & Regulations
Global Warming Gases
The 5 key actions of the Climate Change Act 2008.

11. Refrigeration - Key Legislation & Regulations
Climate Change Act 2008
Initiatives associated with the Act that impact particularly with industry and those operating energy intensive plant such as refrigeration systems include:
EU Emissions Trading System
Climate Change Agreements (CCA) Incorporating CCL
Carbon Reduction Commitment (CRC) Energy Efficiency Scheme
Refrigeration - Key Legislation & Regulations
Global Warming Gases
A list of initiatives that impact particularly with industry and those operating energy intensive plant such as refrigeration systems.

12. Refrigeration - Key Legislation & Regulations
The Kyoto Protocol
EU Regulation (EC) No 842/2006
On Certain Fluorinated
Greenhouse Gases
Refrigeration - Key Legislation & Regulations
Global Warming Gases
As HFCs were included in the basket of GHGs the Kyoto Protocol has also driven another set of regulations associated with containing & reducing their emissions.
Fluorinated Greenhouse Gas
Regulations 2009

13. Refrigeration - Key Legislation & Regulations
Fluorinated Greenhouse Gas
Regulations 2009
Prevent leakage, and repair any leaks as soon as possible
Arrange proper refrigerant recovery by certified personnel during
servicing and disposal
Carry out scheduled leak checks
Ensure that only certified competent personnel carry out leakage
checks
Maintain records of refrigerants and of servicing
Refrigeration - Key Legislation & Regulations
Global Warming Gases
The list of key strategies of the EU and UK regulations to contain and reduce the emissions of HFCs to the atmosphere.

14. Refrigeration - Key Legislation & Regulations
EU Regulation (EC) No 842/2006
On Certain Fluorinated Greenhouse Gases
UPDATE
ANNOUNCED
7TH NOVEMBER 2012
Key Proposal
A phase-down measure that from 2015 will limit the total amount of HFCs that can be sold in the EU and reduces this in steps to 1/5th of today’s sales by 2030.
On 7th November 2012 the European Commission (EC) published a news release stating that the proposed update to the existing F-Gas Regulations (European Regulation 842/20006, On Certain Fluorinated Greenhouse Gases) was aiming to ensure a reduction in F-Gas emissions by 80% of today’s levels by 2030.
The proposed update is a reflection of the findings of an interim statement published by the EC in late 2011 which in essence stated that the jury was still out with regard to the true impact of the F-Gas Regulations, but that it appeared that stabilisation of emissions was an achievable goal. However, the statement also made the point that merely stabilising emissions at today’s levels was not compatible with the EC emissions reduction targets. Consequently alongside strengthening the existing legislation to maximise its impact the EC was also considering other policy options.
The 7th of November 2012 news release clarified which of the various policy options under consideration were being proposed for implementation. The key proposal is for the introduction of a phase-down measure that from 2015 will limit the total amount of HFCs that can be sold in the EU and reduces this in steps to 1/5th of today’s sales by The measure is intended to build on the successful phasing out of ozone-depleting substances which was achieved in the EU 10 years ahead of the schedule agreed internationally under the Montreal Protocol. The phase-down is to be measured not in tonnes of any particular HFC sold but rather in tonnes equivalent of CO2.

15. Refrigeration - Key Legislation & Regulations
UPDATE
7/11/12
EU Regulation (EC) No 842/2006
On Certain Fluorinated Greenhouse Gases
Products and Equipment
Date of Prohibition
Use of HFC-23 in fire protection systems and fire extinguishers
1 January 2015
Domestic refrigerators and freezers with HFCs with GWP of 150 or more
Refrigerators and freezers for commercial use (hermetically sealed systems)
1 January 2017 for HFCs with GWP of 2500 or more
1 January 2020 for HFCs with GWP of 150 or more
Movable room air-conditioning appliances (hermetically sealed) with HFCs with GWP of 150 or more
1 January 2020
Summary overview of new equipment restrictions

16. Refrigeration - Key Legislation & Regulations
UPDATE
7/11/12
EU Regulation (EC) No 842/2006
On Certain Fluorinated Greenhouse Gases
Recharging of existing refrigeration equipment with a charge size over 5 tonnes of CO2 equivalent with HFC of very high GWP (>2500) will not be permitted from 2020
onwards………
…………as more adequate and energy efficient drop-in refrigerants of lower GWP are already widely available on the market.
The proposals also call for servicing bans on those HFCs deemed as having particularly high direct Global Warming Potential (GWP), with the intent of a complete servicing ban for those with GWPs >2,500 by Included in this criterion are widely used refrigerants such as R404A and R507. Assuming that the proposals are implemented it probably leaves dead in the water new installations proposing the use of these high direct GWP refrigerants.
Note: For R404A, 5 tonnes of CO2 equivalent is a system charge of 1.32kg. A very low charge for any refrigeration system beyond a small commercial one.
Note: For R404A, 5 tonnes of CO2 equivalent is a
system charge of 1.32kg.

17. ? ? Refrigerants Status Bitzer Refrigerants Report 16
Refrigerant Status
The impact of the proposed update to EU Regulations (EC) No 842/2006 on refrigerant options is profound. On the Bitzer Refrigerants Report 16 example table of options we can see:
All HCFC/HFC partly chlorinated options, that have been used as transition / service refrigerants for the past 15 / 20 years will be banned from 31st December 2014.
For single substance HFCs or HFC blends the proposal drastically reduces the options, leaving only a limited number presently standing – and even some these may still be vulnerable depending on the final recommendations made.
The low GWP options, eg HFO 1234yf / 1234ze, are to some extent developed and tested but not yet in wide usage. Questions remain about their flammability & their long term stability, and some in the car industry – for which initial development was the spur – is reticent to use them.
That then leaves “natural refrigerants” such ammonia, hydrocarbons & CO2, which are unaffected by the proposed changes to the F-Gas Regulations. ? ?

18. The Perfect Refrigerant
Chemically stable and inert
Suitable for cooling applications from -75OC to +20OC
Good thermodynamic characteristics
Non-toxic
Non-flammable
Zero ozone depletion potential (ODP)
Low global warming potential (GWP)
Low cost
Available
A definition of the attributes of the perfect refrigerant.

19. The Perfect Refrigerant
Ammonia (R717)?
Among the earliest of refrigerants, its positive attributes include:
Chemically stable and inert
Wide operating range
Excellent thermodynamic properties
Zero ODP
Zero direct GWP
Low cost: refrigerant and oils
Available
Good safety record
The positive attributes of ammonia (R717) as a refrigerant

20. The Perfect Refrigerant
Ammonia (R717)?
Its challenging attributes include:
Toxic
Flammable at certain concentrations in air (15% to 28%
by vol.)
Not compatible with copper or copper alloys
High discharge temperatures - limiting single stage
operation, particularly with reciprocating compressors
Non-miscible with lubricating oils
Poor public perception
Management of H&S at Work Regs 1999
Control of Substances Hazardous to Health Regs 2002
Dangerous Substances & Explosive Atmosphere Regs 2002
The challenging attributes of ammonia (R717) as a refrigerant
The management of the primary risks associated with the use of ammonia in refrigeration systems, ie toxicity and flammability, is defined in 3 sets of regulations:
The Management of Health & Safety at Work Regulations 1999
The Control of Substances Hazardous to Health Regulations 2002
The Dangerous Substances & Explosive Atmosphere Regulations 2002

21. The Perfect Refrigerant
Ammonia (R717)?
Management of H&S at Work Regs 1999
Control of Substances Hazardous to Health Regs 2002
Dangerous Substances & Explosive Atmosphere Regs 2002
Similar general requirements:
Assessment of the risk to H&S
Prevention or control of exposure
Use of control measures
Information and training
Dealing with accidents and emergencies
While the various regulations are addressing different aspects of risk, they all have generally similar requirements:
Assessment of the risk to H&S
Prevention or control of exposure
Use of control measures
Information and training
Dealing with accidents and emergencies

22. The Perfect Refrigerant
Carbon Dioxide (R744)?
An early refrigerant which has seen a renaissance in applications over the past 10 years, Carbon Dioxide’s positive attributes include:
Chemically stable and inert
Wide operating range
Non-toxic
Non-flammable
Positive pressures across complete operating range
High efficiency at low temperature
Cheap refrigerant
The positive attributes of carbon dioxide (R744) as a refrigerant

23. The Perfect Refrigerant
Carbon Dioxide (R744)?
Carbon Dioxide’s positive attributes provide the following potential benefits:
Significantly enhanced performance
Smaller & fewer components, ie compressors, heat
exchangers & pipework
Potential for lower cost installation
Potential for lower cost operation
No recovery and “safe” disposal problems
The potential benefits of carbon dioxide (R744) as a refrigerant

24. The Perfect Refrigerant
Carbon Dioxide (R744)?
Carbon Dioxide’s challenging attributes include:
Relatively high operating pressures
Sat Temp (oC) Pressure (bar(g)) R R
R404A R R
R404A
The challenging attributes of carbon dioxide (R744) as a refrigerant . Although high pressure is somewhat of a double edged sword as it does mean that at low temperatures there is little likelihood of air and water vapour ingress, contaminants that can be a big problem over the longer term.

25. The Perfect Refrigerant
Carbon Dioxide (R744)?
Carbon Dioxide’s challenging attributes include:
Relatively high operating pressures
Low critical temperature
R oC
R oC
R404A oC
The challenging attributes of carbon dioxide (R744) as a refrigerant .

26. The Perfect Refrigerant
Carbon Dioxide (R744)?
Carbon Dioxide’s challenging attributes include:
Relatively high operating pressures
Low critical temperature
Affects breathing reflex at concentrations > 2%
Similar issues affect synthetic
refrigerants, eg HFCs & HCFCs
Management of H&S at Work Regs 1999
Control of Substances Hazardous to Health Regs 2002
The challenging attributes of carbon dioxide (R744) as a refrigerant .
The synthetic refrigerants, ie HCFCs & HFCs will asphyxiate at high enough concentrations.

27. The Perfect Refrigerant
Does not presently exist!
The application of all refrigerant options – and associated refrigeration system designs – is a compromise, each carrying its benefits and challenges
Regulations, Standards & Guidelines provide the framework for ensuring the safe and appropriate application of all refrigerants
The reality is that there is no simple solution to the issue of refrigerant and refrigeration system selection. There is no silver bullet presently – or ever likely to be – available.
The regulations, standards and guidelines provide the framework for safe and appropriate application of refrigerants and associated systems. They should be seen as supportive and informative in terms of making investment decisions that in most cases will impact a business for years if not decades ahead. There is certainly no escaping them!

28. One Size – does not – Fit All
The decision on which direction to take will depend on a range of criteria and the relative weighting given to each by those making the assessment. One size - does not - fit all.
The criteria that must be taken account of when deciding on which refrigerant and refrigeration system option to invest in are varied. They will include issues such as:
Process requirements, ie load size, load profile, operating temperature
Infrastructure constraints, ie power or water or space limitations
Site location
New refrigeration system installation or an upgrade / retrofit of an existing one
Project funding basis
Project programme requirements
Investment cycle, eg <5 years, < 10 years or 20+ years
Payback periods, eg <1 year, <3 years, <5years for efficiency improvements
Business attitude to innovation (risk)
Business attitude to sustainability
Opportunities for sustainability upgrades, ie heat recovery / heat generation from
heat pumps
The relative weighting of each for different projects will drive and deliver quite different solutions.
Good advice should be sought!