ACRIB News Update
UK Response to European Commission F Gas Reports
ACRIB representatives met with DEFRA officials in November to share the industry initial response to the European Commission review on F Gas Regulation effectiveness and future policy options. ACRIB is drafting a formal response on behalf of the UK industry to this important consultation, the conclusions of which will shape revisions to the F Gas regulations due to be proposed next year. DEFRA welcomed the opportunity to discuss the ACRIB position more fully and expressed a desire to continue working with ACRIB on future UK policy developments and implementation issues.
F Gas Regulation Effectiveness
A review published by the commission last month was based on assumptions on effectiveness Europe-wide. ACRIB is concerned that these assumptions do not accurately reflect the impact of successful implementation in the UK which is estimated to have halved refrigerant leakage. The UK is one of the few members of states to have established training schemes, company registers and new end user obligations at an early stage. DEFRA officials confirmed that they recognise UK industry’s achievements in meeting these regulations, and in voluntary actions as retailer commitments and the IOR’s REAL Skills programme.
ACRIB emphasised however that there is still much more that could be achieved with a more rigorous enforcement regime. A number of enforcement related concerns will be highlighted in the ACRIB response to the consultation, including:
- The need for a single database of full F Gas certified companies and a register of all technicians who hold F gas Qualifications.
- The need for more substantial auditing of compliance by company certification bodies. Some bodies are reporting 50% failure rates in their limited auditing activity.
- New Restrictions on F Gas refrigerant sales. Current legislation places the onus solely on the purchaser to ensure that refrigerant is used by those with the necessary qualifications. If wholesalers were also responsible for selling only to representatives of certified companies’ compliance would be improved.
- Additional requirements for member states to accurately report compliance levels, enforcement activity and non-compliance prosecutions. Whilst around 22,000 operatives have achieved the F Gas Category 1 qualification in the UK, there is no information about the numbers of those who are not yet qualified or may be working illegally.
The Commission’s consultation seeks comments on measures to achieve additional Greenhouse Gas emissions reductions, such as phase down and use restrictions on use of HFCs. ACRIB has confirmed to DEFRA the view put forward that its F Gas position paper published last year, that the most suitable refrigerant for the application should be used to achieve the most efficient and safe systems. In some cases this will be an alternative refrigerant and the industry is moving towards the more wide spread adoption of new refrigerant solutions as they become technically feasible. Rather than introducing new legislation to restrict use of HFCs, ACRIB will be suggesting that the Commission should be tightening the existing regulations to ensure that the opportunities to reduce direct emissions and indirect emissions are achieved across all member states.
Your Opportunity to influence policy
The draft ACRIB response on behalf of the UK industry is now available for comment at www.acrib.org.uk. ACRIB welcomes comments on this draft. Individuals and representatives organisations are also encouraged to respond to the Commission consultation with their own view or they may use extracts from the ACRIB response. The deadline for responding is 19th December ad details of the consultation can be found on the ACRIB website
The Commission is planning to move quickly on the results of the consultation with proposals due to be issued early 2012.