F-Gas compliance and leak testing

The duty is yours

The F-Gas regime places obligations on the operator of the equipment – the person or business with actual control over its technical functioning. In practice that is usually the occupier or the building owner, not the maintenance contractor.

You can and should appoint certified contractors to do the work, but the legal responsibility for it happening, and for the records existing, stays with you. A regulator asking questions will ask you, not your contractor. There is more on the distinction in operator or contractor.

Enforcement in England sits with the Environment Agency, and the penalties are real. The more common practical consequence is a compliance gap discovered during a building sale, a lease negotiation or an insurance review, at a point where it cannot be quietly corrected.

Working out your obligation

The leak check frequency is not set by the equipment type or its age. It is set by the CO2e of the charge – the quantity of refrigerant multiplied by that refrigerant’s global warming potential.

1. Identify the refrigerant typeFrom the equipment nameplate or the commissioning records. R410A, R32, R134a and R407C all have different GWPs, and the difference is very large.
2. Identify the charge quantityIn kilograms, from the nameplate or commissioning data. Where neither exists, it has to be established from the equipment documentation.
3. MultiplyCharge in kg x GWP = CO2e in tonnes. This single figure determines everything that follows.
4. Apply the thresholdsBelow the lowest threshold, no mandatory leak checking. Above it, checking at a set interval, with the interval shortening as CO2e increases.
5. Check whether leak detection is requiredAbove a higher threshold, a fixed automatic leak detection system is required, and it must itself be checked periodically.
6. Halve the interval if there is no leak detection, or extend it where there isThe regulations adjust the interval where an automatic leak detection system is fitted.

The practical consequence: two systems of similar physical size can have completely different obligations because one uses a high-GWP refrigerant and the other does not. A system that fell below the threshold on an old refrigerant may sit above it, or vice versa, after a change. The calculation is worked through with an example in leak check frequency.

What we do

• Asset survey and CO2e calculation for every system on site, producing the actual schedule rather than an assumption.
• Leak checking at the required frequency, by qualified engineers, with the results recorded.
• Logbook setup and maintenance, so the records exist in a form that satisfies an inspection.
• Leak repair and verification, including the follow-up check the regulations require after a repair.
• Automatic leak detection installation and periodic checking where the charge requires it.
• Refrigerant recovery and decommissioning at end of life, with the records that must accompany it.
• Advice on refrigerant transition as the phase-down reduces availability of higher-GWP gases.

Individual engineers handling refrigerant require a personal handling qualification, and the business employing them requires company certification. Both are required – employing qualified engineers is not sufficient on its own, which is a distinction that catches out a surprising number of organisations.

Records, which is where most failures actually occur

Equipment above the leak check threshold must have records maintained, and they must contain specific information:

• The quantity and type of refrigerant installed.
• Any quantity added during servicing, maintenance or repair, and the reason.
• Any quantity recovered.
• The identity of the company and, where required, the engineer carrying out the work.
• The dates and results of every leak check.
• Where equipment is decommissioned, the measures taken to recover and dispose of the refrigerant.

Records must be retained for the required period and made available to the regulator on request. The common failures are: records that exist only in a contractor’s system rather than the operator’s, records that were never started because nobody knew they were required, and records lost when a maintenance contractor changed.

Keep your own copy. The obligation is yours, and a contractor who has your only records is a compliance risk regardless of how good they are.

The phase-down, and why it affects you

The quantity of higher-GWP refrigerant permitted to be placed on the market reduces on a defined schedule. The practical effects arrive well before any ban:

1. Price. Reduced supply of high-GWP refrigerants pushes cost up, sometimes sharply, well ahead of restriction dates.
2. Availability. A top-up that was routine becomes a lead time, then becomes reclaimed-only, then becomes impractical.
3. Repair economics. A leak on a system using a scarce refrigerant becomes harder to justify repairing, because recharging it is expensive and may not be repeatable.
4. Asset planning. Equipment on obsolescent refrigerant has a shorter economic life than its mechanical condition suggests, and that should be in your replacement plan rather than a surprise.

This is worth knowing in advance because it changes capital planning. See the refrigerant phase-down.