CFC-REFRIGERANTS

Frequently Asked Questions

Note: These are the European Commission's responses to questions that have been raised and discussed in the Management Committee. The responses are a guide for the implementation of EC2037/00 by the Competent Authorities in the Member States. Q1: What is the definition of "insignificant" mentioned in Article 2 "Definitions"? A: No such definition exists and MS would need to make best-judgement. TEAP could be requested to suggest best practice or range according to where ODS are used.

Q2: Is installed ODS considered 'use'? Reference: Article 2 Definitions A: No. The continued operation of equipment containing the controlled substance is not considered to be 'use'. Refilling is any servicing or topping-up that includes topping up a reservoir that was not part of the original refrigeration equipment but was added onto the original equipment before 1 January 2001. Refrigerant that leaks over time could be refilled automatically from such a reservoir and is not considered 'use' in the case of CFCs. Removing CFCs to repair a refrigerator, and then refilling with the same CFCs, would not be compliant with Regulation EC2037/00. This is because Article 4(1) bans the use of CFCs, and use is defined as "...the utilisation of controlled substances in the production or maintenance, in particular refilling, of products or equipment or in other processes...". Article 2 of EC2037/00 particularly refers to 'refilling' and since the refrigerator is being 'refilled' this would constitute 'use' and is banned.

Q3: Can CFCs be used for Metered Dose Inhalers and for laboratory uses? Reference: Article 4 (4)(i)(b); A rticle 3.1; MOP Dec IV/25; and Article 4(1) A: Yes. The use of CFCs from stocks or from authorised suppliers for laboratory uses is permitted. CFCs for MDIs and for laboratory uses are granted under Essential Uses as described in Art 3(1). Note that 'Essential Use' is usually from 'Production' based but it can also be from recycled ODS.

Q4: What is covered by the exemption for use of HCFCs in precision cleaning of electrical and other components in the aerospace and aeronautics industry? Reference: HCFCs Article 5(1)(b)(ii) A: Precision cleaning is an action that is undertaken to remove small amounts of impurities to meet strict requirements for a high degree of purity. Precision cleaning could take place during development, testing, manufacturing and maintenance stages but only of electrical and other components in aerospace and aeronautics applications. Users will have to satisfy the relevant competent authority that their use of HCFCs as a solvent falls within this derogation, and like any derogation under EU law, it should be interpreted narrowly.

Q5: What is meant by "refrigeration and air-conditioning equipment produced after 31 December 2000"? Reference: HCFCs Article 5(1)(c)(iv) A: The pupose of this provision is to prevent the installation of new refrigeration and air-conditioning equipment that depends on hydrochlorofluorocarbons (HCFCs). Repairing existing HCFC refrigeration and air-conditioning equipment by replacing a vital part would meet the requirements of Article 5 and Article 17, provided that it does not increase the total refrigerant charge or lead to an increase in emissions.

Q6: How does one determine for which equipment HCFCs are banned? Reference: HCFCs Article 5(1)(c)(iii-iv) A: A 150 kw shaft power input at an average efficiency of 90 % is equivalent to 150/0,9 or 166,67 kw electrical input at standard test conditions. Given that it can be difficult to measure the shaft power and cooling capacity of a refrigerating/airconditioning system, it is acceptable use electrical rating as the reference point rather than kw size since electrical rating is more easily measurable than kw capacity.

Q7: How is 'fixed' and 'mobile' air-conditioning defined? Reference: HCFCs Article 5(1)(c)(iv) A: Mobile A/C equipment includes equipment that is installed in cars, lorries, trucks,

railway, aircraft, trains and other machines that move. Fixed A/C equipment includes equipment that is designed to be used in stationary applications in buildings. A/C equipment on wheels in a room is considered fixed if it connects via a pipe or duct to the exterior and remains stationary in order to function. It is not entirely clear exactly what is covered by the term fixed. Any clarification would need to be consistent with the intention of the Council during the negotiations of the new Regulation in Council. Consider: "Room air-conditioning equipment of less than 12kW capacity that must be connected to the exterior by a pipe or duct and must remain stationary in order to function". This would include room units of the 'split system' and 'portable air conditioning units, but exclude mobile A/C equipment.

Q8: What is reversible air-conditioning equipment? Reference: HCFCs Article 5(1)(c)(iv) A: Reversible air-conditioning and heat-pump systems are those that are designed to cool and heat (reversible). Systems that need any adaptation of the design to operate in both modes are not to be considered as reversible.

Q9: What products are included or excluded in the HCFC foam production controls? Reference: HCFCs Article 5(1)(d) TECHNICAL DEFINITION OF PIR Polyisocyanurate (PIR) foams are low-density rigid foams which exhibit superior thermal stability and lower combustibility when compared to polyurethane (PUR) foams. They are prepared by reacting a polyol component with a polyisocyanate component in the presence of suitable additives and blowing agents, and in a ratio such that at least 80% more isocyanate groups are present than the theoretical amount required to react with all the reactive species in the polyol component. The excess isocyanate groups react together to form isocyanurate rings which are characterised by their good thermal stability. The excess polyisocyanate may also be described using the isocyanate index where: Isocyanate index equals the actual amount of isocyanate used divided by the amount of isocyanate required to react all reactive species in the polyol component

multiplied by 100 A PIR foam may thus be defined as one having an isocyanate index of 180 or greater. Explanation Flexible-faced laminate is based on polyurethane (PUR) or polyisocyanurate (PIR) foam in a range of thickness between 30 and 120 mm. The flexible facing materials, supplied in rolls, include glass fleece, aluminium foil, kraft paper and combinations of these. The continuous production process involves the pouring of the foam chemicals onto the lower facing material which is carried by a conveyor belt, the chemicals react, the foam is formed and the upper facing is unrolled to meet the upper surface of the foam. The whole is conveyed into a curing tunnel and, at the end of the process the product is cut into the size to be used in buildings, usually 2.4 x 1.2m. The uses are in the insulation of the walls and roofs of buildings. In walls they can be used in the cavity between bricks, on the outside with a cover (e.g. a "ventilated" faade) or on the inside of a structure. In roofs they are used over concrete, steel or other decks and cover with a "weather" protective cover such as bitumenised-felt. Sandwich panels are of similar importance to the above and are made of a PUR or PIR foam core of thickness 30 to 200 mm and faced with rigid materials. The most common is profiled steel and the production process is similar to the above except that the steel is supplied in rolls and fed through profiling rollers just before the polyurethane is applied. Other facing materials include copper, aluminium and gypsum board. The metal-faced products are cut into lengths of up to 15-20m and the gypsum board-faced products into panels of size 2.4 x 1.2m. The metal-faced panels are used to construct many types of buildings including factories and stores, especially those which need hygienic, temperature-controlled environments such as food processing and electronics and pharmaceuticals manufacturing. Their uses also include food cold stores (hence the 200mm thick products), schools, sports halls and in the conversion of existing buildings the new uses. The gypsum-faced products are used as internal linings for walls and ceilings in many types of buildings including houses and are especially useful in retrofitting existing buildings. Discontinuous panels are similar to the continuously produced variety in appearance but are produced by injecting the pur or pir foam chemicals in-between pre-cut steel sheets. They are used in a variety of applications including cold rooms for food stores for supermarkets. Block foams of section about 1.5 by 1.0m are produced either discontinuously in blocks of length about 2m or produced continuously. They are cut into shapes such as pipe sections or sheets. The latter are glued to facing materials to make panels. The production process can be strongly exothermic and the temperature in the middle of the block can reach over 200C and the block will take a long time to cool after manufacture. Both pur and pir foams can be produced by this technique.

Spray foams are usually applied in situ to walls roofs, tanks and pipes. Most applications are external but some are inside buildings. It is a very versatile method which can be applied over uneven surfaces and can be used, for example, to repair and insulate damaged roofs. The applicators are small companies and want to avoid the use of flammable materials which would be hazardous to apply by a spray technique. Spray foams are PUR and never PIR. Injected foam is a general term, widely used in the usa, to describe a general foam process where the foam is injected into a cavity in a discontinuous process. Thus, it is used for making domestic and commercial refrigerators and freezers, discontinuous sandwich panels, pipe-in-pipe products and several others. PIR (polyisocyanurate foam) Rigid foams made from polyisocyanates are generally described as polyurethane, urethane or polyisocyanurate rigid foams. The principle linkages formed during the polymerisation may be urethane, isocyanurate or urea groups, depending on the foam system. The so-called polyisocyanurate (PIR) foams are particularly important because of their resistance to high temperatures and their relatively low combustibility. In PIR foams a high percentage of the isocyanate groups are polymerised to form the isocyanurate ring structures which are characterised by their good thermal stability. Complete polymerisation to isocyanurate, however, results in products which are extremely brittle, very difficult to process and consequently of no practical use. Therefore, established pir systems are generally polyurethane-modified and contain both isocyanurate and urethane linkages. The existence of both chemical groups in PIR foam necessitates a precise definition to clarify whether a foam should be classified as a polyurethane or a polyisocyanurate. Q10: What is virtually impermeable film? Reference: Art 17: Leakages of controlled substances A: Article 17(2): All precautionary measures practicable shall be taken to prevent and minimise leakages of methyl bromide from fumigation installations and operations in which methyl bromide is used. Whenever methyl bromide is used in soil fumigation, the use of virtually impermeable films for a sufficient time, or other techniques ensuring at least the same level of environmental protection shall be mandatory. Virtually impermeable film (VIF) consists of either 1) multi-layer laminates with outer layers of low-density polyethylene and a barrier layer of polyamide or ethylene vinyl alcohol, or 2) a mixture of these materials, often call an "alloy". Field research has shown that the use of VIF agricultural films can reduce emissions to less than 4% of applied MB, versus emissions of 68% of applied MB when using PEF/HDPE under similar conditions. In general, VIF can reduce MB emissions from soil fumigation by keeping the MB in the soil to allow for degradation. VIF is inefficient (if not entirely ineffectual) at

reducing MB emissions from soil fumigation (Rice et al. 1996; Thomas 1998; Wang et al.1999) when:

Any of the film strip over-laps become unglued or are otherwise unsealed;
Any of the film edges anywhere around the field become unsealed; The film seal is broken before 10 to 20 days have passed; and Soil temperature, moisture, organic matter are in any way sub-optimal - hot, soil dry or very wet with little organic matter.

Q11: Can recycled CFCs be exported? Reference: CFCs Articles 2, 11 A : Article 2 of EC2037/00 includes in the definition of 'controlled substances' '...recovered, recycled or reclaimed...'. Article 11 prohibits the export of controlled substances except those produced for BDN , produced for essential or critical uses, or controlled substances to be used as feedstock or process agents. Essential use authorisation is always based on production. The Commission is not aware of feedstock uses for CFCs except for CFC-113. There may be a possibility of very limited volumes of CFCs for process agent or for feedstock uses if the recovered and reclaimed CFCs meet the requirements of the importer.

Q12: Can CFCs be exported? A: Yes. To developing countries for Basic Domestic Needs, providing they have been specifically produced. CFCs that are not from production authorised by the MS in which they were produced and approved by the Commission cannot be exported for BDN. Producers are restricted on how much they can produce for BDNs each year. An EAN is required for export. Exports of CFCs can also be exported to countries where CFCs are still allowed to be produced/consumed if they are to be used for laboratory and feedstock purposes. They must be specifically produced for this purpose. Amendment EC2038/2000 on metered dose inhalers and medical drug pumps allows the export of CFCs when contained in MDIs and medical drug pumps.

Q13: What is included in 'personal effects'? Reference: Article 11 (1) A: Article 11 (1) bans the exports from the Community of chlorofluorocarbons, other

fully halogenated chlorofluorocarbons, halons, carbon tetrachloride, 1,1,1 trichloroethane and hydrobromofluorocarbons or products and equipment other than personal effects containing those substances or whose continuing function relies on supply of those substances. The Committee agreed that 'personal effects' could include one or two personal belongings that are moved across a border such as refrigerators that contain CFCs, but any more would be considered commercial and prohibited. Temporary movement of personal belongings is difficult to monitor. The small size of problem does not appear to warrant any special effort, but Member States are responsible for collaboration with their customs agencies to determine the appropriate measures.

Q14: Does the recovery obligation on refrigeration, AC and heat pump equipment include any CFCs/HCFCs in insulating foams, especially domestic fridges and freezers? Reference: CFCs/HCFCs Article 16(1) & (2) A: Yes - ODS must be recovered from foam in refrigerators and destroyed. The requirement under 16(1) is that ODS "shall be recovered.during the servicing and maintenance of equipment or before the dismantling or disposal of equipment.". Technologies exist which can recover the ODS from the foam as the appliance is being dismantled for recovery of components. Article 16(2) also requires the recovery of ODS from the cooling circuit of domestic refrigerators and 16(3) from the foam as foam is not a product mentioned in 16(1) or 16(2).

Q15: What are environmentally acceptable destruction methods Reference: All ODS Article 17(1) A: Member States should review the TEAP and UNEP reports; the Incineration Directive; and the Report of the Canadian Workshop, Geneva, 10 July 2000; and Decision XIV/6 : Status of destruction technologies of ozone-depleting substances, including an assessment of their environmental and economic performance, as well as their commercial viability .

Q16: What is considered to be "practicable" Reference: Article 16(3)

A: This is a term used in the previous EC Regulation. The practicability of recovering ODS from products, installations and equipment not referred to in Article 16(1)&(2) should be assessed on a case by case basis. Such assessments need not take into account the costs and benefits of utilising whatever technologies are available. The priority should be to ensure that the mandatory recovery takes place.

Q17: How should the inspection of systems with greater than 3kg refrigerant be carried out A: Review CEN documents.

Q18: In Annex VII, what are the definitions of key terms? Reference: Annex VII A: In items 1(i) and 2(ii), "crew compartments" includes passenger compartments, and "engine nacelles" includes engines. Amongst the equipment used in passenger spaces are fire extinguishers fitted to rubbish bins in aircraft lavatories (see 5.3.1 below). In item 1(i), "dry bays" refers to the spaces in military aircraft which separate the fuel tanks from the outer skin of the aircraft. In item 1(ii), "engine compartments" refers only to spaces occupied or potentially occupied by personnel. In items 1(iii), 1(iv) and 1(v), "making inert" refers to the pre-emptive release of a substance into an occupied space that will render the atmosphere within the enclosure incapable of supporting combustion. In items 1(iii), 1(iv) and 1(v), "making inert" refers to the pre-emptive release of halon in response to a potential fire or explosion into an occupied space in which a flammable, hazardous condition prevails and at a concentration which will render the atmosphere within the enclosure incapable of supporting combustion. Item 1(v) refers to control rooms of nuclear installations which cannot be evacuated because of the risk of release of radioactive material if they are unattended. Halons are not released into the spaces where there is a risk that radioactive material may be dispersed. Item 1(vi) refers only to key fixed installations either within the underground section of the Channel Tunnel or on locomotives and rolling stock. In item 2(i), "hand-held fire extinguishers" are those used in crew and passenger compartments.

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