Update on TM44 inspections and the revised F-Gas Regulations
Helping our clients stay abreast of the statutory landscape affecting the inspection of air conditioning systems and delivering quality TM44 inspections.
Air Conditioning Inspections - TM44
The EU EPBD (Energy Performance of Buildings Directive) 2010 required that member states implement the necessary measures to establish regular air conditioning inspections. Part 4 of The Energy Performance of Buildings (Certificates and Inspections) (England and Wales) Regulations 2012, as amended, sets out the requirements for air conditioning inspections in England and Wales.
All air conditioning systems commissioned on or after 1 January 2008 with a total rated cooling output of more than 12kW, required a first inspection within five years of commissioning date, and every 5 years thereafter.
CIBSE Technical Manual (TM) 44 was published by The Chartered Institute of Building Services Engineers (CIBSE), describes the statutory requirements for air conditioning inspections in the UK and Republic of Ireland, and provides guidance on practical inspection procedures.
The procedures focus on assessing how well the system is maintained, controlled and operated, and whether it is compliant with the F-Gas Regulations and fit for purpose.
From 6 April 2012, all TM44 air conditioning inspections need to be lodged on the national Government Landmark register, where after a report and certificate is generated. Inspections must be undertaken by suitably qualified and accredited persons. In England, Wales and Northern Ireland they are formally ‘Air Conditioning Energy Assessors’, and need to be a current member of an approved accreditation scheme.
Statement: I only have split type units installed and each have a rated cooling capacity of less than 12 kW, so this Regulation does not apply to my building!
The facts: For these regulations, all air conditioning units within a building controlled by a single person count as a single air-conditioning system. Only air-conditioning systems with an effective rated output of more than 12kW are affected by these regulations, but if the building has 5 individual 3kW units, the total combined cooling capacity of the system under single control is 15 kW, and therefor the system would require a TM44 Inspection.
Statement: I have a maintenance contract in place that covers the routine inspection and maintenance of my air conditioning system, which makes my system compliant!
The facts: TM44 air conditioning inspections are in addition to the normal activities associated with the ownership, operation and maintenance of air conditioning systems.
Statement: I only have split/VRF type units installed and fresh air is provided by an Air Handling Unit (AHU) which does not have any cooling capability, so the AHU is not included in the TM44 inspection!
The facts: Any central AHU plant which does not directly deliver cooling but is a part of a system which can deliver cooling, also forms part of the TM44 inspection. A minimum of 10 central air handling plant or 30%, whichever is the greater must be inspected.
HCFCs (R22) in new equipment was banned in 2001, and from 1 January 2015 under the EC (ODS) Regulation 2037/2000 it is illegal to supply, or use recycled or recovered HCFC (R22) for the servicing of existing equipment. After 1 January 2015, equipment that uses R22 can still be in use, but your engineer cannot do any work that involves breaking into the refrigerant circuits and/or refilling of the refrigerant to operate.
The EU has introduced revised Regulation (EU) No. 517/2014 on the use of fluorinated greenhouse gases (F-Gases) such as hydrofluorocarbons (HFCs), perfluorocarbons (PFCs) and sulphur hexafluoride (SF6).
Regulation (EU) No. 517/2014 became effective on 1 Jan 2015 and aims at reducing emissions of these gases through a variety of measures.
These include rules on containment, use, recovery and destruction of fluorinated greenhouse gases, conditions on the placing on the market of certain types of products or equipment containing or relying upon fluorinated greenhouse gases (bans), specific uses of these gases (service ban), quantitative limits for the placing on the market of HFC’s (phase-down).
Below we explore some of the key areas of this Regulation.
Prevention of emissions
The revised Regulation carries the operator’s duty to take precautions to prevent leakages.The operator shall also take all technically and economically feasible measures to minimise leakages.
When a leak is detected, it is now an obligation to have it repaired without due delay, whereas the previous version of the Regulation limited this obligation to ‘technical feasibility’ and ‘lack of’ disproportionate costs, the revised Regulation does not make the repair obligation subject to any economic or technical condition.
Regulation (EU) No. 517/2014 replaces thresholds expressed in weight (kg) of fluorinated gases by thresholds expressed in tonnes of CO2-equivalent. Tonnes CO2-eq is calculated by multiplying the Global Warming Potential (GWP) of the refrigerant by the weight of the refrigerant and dividing by 1000 i.e. R134A has a GWP of 1430, and a 100kg refrigerant charge will provide 143 tonnes CO2-equivalent of refrigerant = 6 monthly leakage checks
Equipment with more than 3kg but less than 5 tonnes CO2-equivalent of refrigerant no longer must be leak checked from 1 January 2015 vs annually previously for refrigerant charges of 3 to 30kg.
Equipment with less than 3kg but more than 5 tonnes CO2-equivalent of refrigerant now needs to be leak checked from 1 January 2017 vs no leak test requirements previously for refrigerant charges of less than 3kg.
Systems with between 5 and 50 tonnes CO2-equivalent of refrigerant with no fixed leak detection require leak checks every 12 months.
Systems with between 50 and 500 tonnes CO2-equivalent of refrigerant with no fixed leak detection require leak checks every 6 months.
Systems with more than 500 tonnes CO2-equivalent of refrigerant must have fixed leak detection systems fitted and require leak checks every 6 months. Leak detection equipment must alert the operator or a service company of any leakage.
Training and certification
Only trained engineers can carry out work on equipment containing F gases, including the installation, repair, servicing, maintenance, leakage checking and de-commissioning of stationary air conditioning systems.
be appropriately qualified, trained and experienced to work on the relevant equipment
be qualified as an individual (have a personal qualification certificate) even if they work for someone else.
Records of the engineers and company F-Gas qualifications should be kept in the on-site F-Gas register.
Labelling of equipment
F-Gas labels need to be fitted to refrigeration, fire protection or air conditioning equipment that contain F-Gas refrigerants when it is being installed, repaired or maintained.
The label must state:
that the equipment contains an F-Gas
the industry name for the F-Gas, or the chemical name if there is not an accepted industry name
From 2017 the label must also state the:
mass of F-Gas in the equipment (in kg) carbon dioxide (CO2) equivalent mass of F-Gas in the equipment (in tonnes)
the global warming potential of the F-Gas
The operator of equipment, and the company that services it, must maintain a F-Gas register with the following records about any equipment that has to be checked for leaks (i.e. any equipment that contains F-Gas equivalent to more than 5 tonnes of CO2):
quantity and type of gas in the equipment when it was installed
quantity and type of gas added during any maintenance (eg. leak repairs)
details (name, address and certificate number if relevant) of any companies that install, service or decommission the equipment
dates and results of all mandatory leak checks
measures taken to recover and dispose of gases when you dispose of the equipment (eg disposing of it through a registered waste carrier)
You must also record if the gas used in the equipment has been recycled or reclaimed and if so the:
details of the recycling or reclamation facility (name, address and certificate number if it has one)
quantity of any gases recovered
Records must be kept for 5 years by the operator and contractor and made available to government officials if they ask for them.
F-Gas phase down
The EU is cutting the availability of HFCs by 79% between 2015 and 2030.
Equipment containing HFCs, particularly those with high global warming potentials, is likely to become more expensive to buy and maintain.
It is important to note that this is a phase down not a phase out, as 21% of the average consumption of HFCs on the EU market during the baseline years from 2009 to 2012 can be placed on the market after 2030. This is because there are some end uses where there are currently no safe, cost-effective or environmentally beneficial alternatives to HFCs.
The phase down is based on a series of cuts in supply from the baseline periods. It is based on a GWP- weighted process, which will encourage the rapid phase down of the highest GWP HFCs. A quota system will be introduced to control sales in the EU market.
On 1 January 2018 the phase down was 63% of the baseline, with the next phase down to 45% of baseline due on I January 2021.
Commonly used HFC refrigerants in air conditioning systems such as R134A, R407C and R410A are all effected by the HFC phase down, and it is expected that the combination of the phase down, increasing prices and the planned bans will result in an increase in the use of alternative, natural and Hydrocarbon refrigerants and technologies.
Low GWP HFC alternatives include R32 and natural refrigerants include Ammonia (NH3) and Carbon Dioxide (CO2), which all have significantly lower GWP than HFC refrigerants.
From 1 January 2025 a ban on the installation of single split air conditioning systems containing less than 3kg of fluorinated greenhouse gases, that contain, or that rely upon for their functioning, fluorinated greenhouse gases with a GWP of 750 or more. R32 with a GWP of 675 is exempted.