Contrary to some suggestions, the use of extinguishing systems using fluorinated greenhouse gasses has not been banned. Keith Goodall guides us through the F-Gas regulations which require a responsible approach to their use.
There is evidence that fluorinated hydrocarbons (HFCs), when discharged, act as greenhouse gases such as CO2, which retain heat in the atmosphere rather than allowing it to escape. The Kyoto Protocol addresses these issues by providing targets for reductions in emission reductions into the atmosphere of CO2 and certain other gases, such as HFC’s. If not emitted, F-gases are useful materials which benefit mankind.
The Regulation (EC) No 842/2006 of the European Parliament and the Council of 17 May 2006 on certain fluorinated greenhouse gases, referred to here as the F-Gas Regulations, affects us all whether as consumers or businesses. We all use fluorinated hydrocarbons in some form or another with examples being:
– car air conditioning
– home, office and factory air conditioning
– refrigeration
– building foam blowing/foam sealants
– novelty aerosols
– fire protection
The regulation covers all uses of F-Gases and was not specifically written for fire protection. This article discusses the impact on the fire protection business and, in particular, gaseous extinguishing systems and portable fire extinguishers using so-called HFCs to protect high value risks. In practice there is little use, other than a few specialist applications, for portable fire extinguishers containing F-Gases.
The use of HFCs in fire protection systems is not banned. It is acknowledged that fire protection is one of the lowest emitters, and the European Commission has endorsed the discharge of HFCs onto a fire as a legitimate use. Systems installed can continue to be used and new systems may be installed if the unique characteristics of particular HFCs are required.
The Commission – through national governments and the European interested parties – have endeavoured to make the regulation as practical as possible for implementation. The fire trade has been an active participant in these discussions. Our initial stance was that the regulation was not applicable to us, because of the small use and emissions of Fluorinated Hydrocarbons in comparison with other sectors. In fire protection, there are very rigorous approval processes in place to ensure that the containers and discharge valves are leak free. This good housekeeping has been recognised by the Commission, which accepts that discharging HFCs onto a fire is a legitimate use of the gas, as it saves life and property. From an environmental point of view, extinguishing a fire early in its development prevents the pollution from an unchecked fire.
Now we come to the detail of the regulation which has been developed, with the European Commission and national governments, to be as practical as possible, while maintaining the objective of reducing emissions. The requirements for fire protection reflect ISO 14520, the international standard for gaseous fire extinguishing systems. So there are few differences from current best practice for users, installers and suppliers. The fire trade has not been given free reign but the regulation does reflect the requirements of ISO 14520 for fixed systems.
The gases affected are as shown in Table 1.
*The list of trade names in not exhaustive but reflects the most popular brands in use
The regulation came into effect in July 2007 with a phased introduction of particular requirements. The main provisions are:
– Article 3 – containment (leakage checking)
– Article 4 – recovery
– Article 5 – training and certification (companies & individuals)
– Article 6 – reporting
– Article 7 – labelling
– Article 8 – control of use (only affects SF6 which is not used for fire protection)
– Article 13 – penalties
Each of these elements will be discussed in more depth, some having what are termed Commission Regulations associated with them, which expand and support the requirements in the main regulation. To enforce these, all national governments are required to put in place enforcing legislation.
The details of the regulation and the obligations of the system/product supplier, installer, maintainer and user are not onerous, and reflect good practice for all fire protection systems and generally the requirements ISO 14520.
Leakage checking
As a minimum, containers shall be leak checked by a certified person as detailed below. In effect, ISO 14520 is more stringent in that all systems should be checked every six months, irrespective of their size. Applications containing the following quantities should be checked at the following intervals:
– 3kg up to 30kg – every 12 months
– 30kg up to 300kg – every six months
– 300kg and above – every six months
For 300kg and above, leakage detection must be fitted (not until 2010 for existing systems if leak checking is every three months). For nitrogen pressurised containers, this can be a leak detection pressure switch on the container.
The product or system operator shall keep records of the quantities of F-Gas and maintenance as detailed below for portables and systems with more than 3kg:
– Quantity and type of fluorinated ‘greenhouse’ gas
– Any quantities added
– The quantity recovered during maintenance, service and final disposal
– The identity of the service company or technician
– Dates and results of leakage inspections
In practice, the system installer and maintenance companies will be able to supply suitable log books, and these will be checked and updated by the certified personnel installing or maintaining the system or portable fire extinguisher.
All gases must be recovered at their end of life by certified personnel to ensure their recycling, reclamation or destruction. These obligations extend to those transporting F-Gases, who are responsible for putting in place arrangements to ensure proper recovery by recycling, reclamation or destruction.
Training and certification
In summary, all users of systems – termed ‘operator’ under the regulations – are required to use certified personnel:
– Installation by certified personnel
– Leakage inspections by certified personnel
– Repairs by certified personnel
All systems must be installed and maintained by competent persons to ensure that they operate correctly when required. Skilled personnel currently servicing systems will now be able to demonstrate their competence with an independently awarded competence certificate.
In the UK, the structure for managing the training and certification is shown below. Unfortunately due to timings, the UK legislation enabling the certification bodies to award the certificates will not be in place until early 2009. Prior to that date, installation and service personnel will need to be able to demonstrate adequate training from their employer.
For personnel training and certification, the plans are that the Fire Industry Association (FIA) will prepare the training course and train the trainers. This will allow companies to train in house, and the FIA will run open training courses. Following a course, each candidate will sit a written and practical examination which will be independently marked by either the FIA or BAFE. Successful candidates will be awarded certificates and their names entered on a verifiable register. For installation and maintenance companies, the procedure for certification is as below and applies to the FIA/BAFE. As before, the legislation to authorise the FIA/BAFE will come into effect early 2009.
Reporting
Importers and exporters of any F-Gas are required to report annual quantities shipped and any material destroyed. This will not have any impact on most users, installers and maintainers as it applies to:
– bulk supplies not in filled containers.
– quantities over 1 tonne per year
Labelling
The product supplier shall provide the label and the ‘operator’ shall ensure that all information is provided. In practice, most installed systems are already well labelled in accordance with ISO 14520. The additional wording will be allied to new installations by the supplier and existing systems should have the words as detailed below added:
– label must contain wording ‘contains fluorinated greenhouse gases covered by the Kyoto Protocol’
– chemical designation of the agent
– quantity of agent contained in kg
Penalties
These have already been set but the UK Government wants to encourage compliance rather than using penalties to drive compliance. The UK Government has established F-Gas Support to facilitate compliance . This organisation will provide guidance in the form of ‘guidance notes’ and a telephone and email enquiry service. All information may be downloaded from the web site.
F-Gas Support has a co-ordinating role with the devolved governments, environment agencies and local government to assist in the training and guidance of the enforcers. Linked with this is liaison with users, trade organisations, suppliers and the press.
FIA support
The FIA has been proactive in working with the European Commission and the UK Government in the development of the regulation. All have endeavoured to make the regulation practical and workable, and to reflect best practice in the industry. FIA and BAFE have been nominated as certifying authorities.
Support from the FIA for end users, specifiers, contractors and members includes:
– impartial guidance
– training materials
– feedback from the continued dialogue with the UK Government and the European Commission.
– company and personnel certification.
Conclusion
The regulation is intended to reduce emissions of F-Gases into the atmosphere. The fire protection industry is already a responsible user of HFCs and only discharges the gas to save life and property. This is recognised by the regulation in allowing the use of HFCs in fire fighting. Owners (‘operator’ in the regulation terminology), suppliers, installers and maintainers have certain obligations which are manageable and reflect good practice in the industry already. The requirements of the F-Gas Regulation reflect best practice in the industry and are a model for all gaseous extinguishing products and systems. Industry can achieve compliance at reasonable cost. For the fire trade, this is an opportunity to promote the use of trained and certified personnel and companies for the installation and servicing of all fire protection systems.
Keith Goodall is member of the FIA Extinguishing Council
