Hello. A client wants to recovers a small amount (not sure of the quantities yet) of R22 and R410 from air conditioning units, put the gas into bottles and take back to their yard for collection by the Climate Centre for reclaiming or disposal. Havig never come across this question before, will this client need any formal license or registration for this operation? Thanks!

Many thanks for that and I will check but I am sure that they do have that Cert.

They need to be qualified.  Recovery of refrigerant gases can only legally be carried out by persons holding specific F-gas qualifications. 

See https://www.gov.uk/guidance/qualifications-required-to-work-on-equipment-containing-f-gas

Working on air conditioning systems without the qualification is an offence.

If they have a current F-gas certificate then I assume they are air con/refrig engineers.

The person who recovers the gas must also hold certain qualifications.

Details of the F-gas & ozone depleting gas requirements can be found on the gov.uk website - try:

https://www.gov.uk/government/collections/eu-f-gas-regulation-guidance-for-users-producers-and-traders

Anyone who transports waste must be registered as a waste carrier.  If it is their own waste then a lower tier registration is free and does not need to be renewed.  If they carry other people's waste (eg customer's gas for disposal) then they need an upper tier registration which has a fee and must be renewed (3 years?).   They must also produce and complete a hazardous waste consignent note which tracks the waste from production to eventual disposal.  See

https://www.gov.uk/dispose-hazardous-waste, and

https://www.gov.uk/guidance/hazardous-waste-consignment-note-supplementary-guidance

Edited by user 08 June 2017 12:34:50(UTC)  | Reason: Not specified

Thanks Chris - good point.  If they recover the gas from the equipment as the OP has stated - then lower tier.  If they just collect the gas cylinders - upper tier.

But would they need an upper tier registration if they also removed and disposed of the redundant equipment? (If so that may explain why our contractors are upper tier.  Or they made the same interpretation as I did.)

Ian

Originally Posted by: Granlund40055

Thanks Chris - good point.  If they recover the gas from the equipment as the OP has stated - then lower tier.  If they just collect the gas cylinders - upper tier.

But would they need an upper tier registration if they also removed and disposed of the redundant equipment? (If so that may explain why our contractors are upper tier.  Or they made the same interpretation as I did.)

Ian

Thanks - I have also had an email from the BRA and they have a great Fact Sheet No. 20 on this matter with some useful hyperlinks so all sorted! Each single movement of recovered refrigerant must be accompanied by a Consignment Note. The need for a Carriers licence to transport the refrigerant will vary depending on whether the recovered refrigerant belongs to the company which has recovered the refrigerant or a third party.

Originally Posted by: Halai40648

Originally Posted by: Granlund40055

Thanks Chris - good point.  If they recover the gas from the equipment as the OP has stated - then lower tier.  If they just collect the gas cylinders - upper tier.

But would they need an upper tier registration if they also removed and disposed of the redundant equipment? (If so that may explain why our contractors are upper tier.  Or they made the same interpretation as I did.)

Ian

Thanks - I have also had an email from the BRA and they have a great Fact Sheet No. 20 on this matter with some useful hyperlinks so all sorted! Each single movement of recovered refrigerant must be accompanied by a Consignment Note. The need for a Carriers licence to transport the refrigerant will vary depending on whether the recovered refrigerant belongs to the company which has recovered the refrigerant or a third party.

Surprising, because if you create a consignment note to take your waste, back to your premises, then I assume you legally have to send yourself a quarterly part E return to confirm to yourself, you delivered it to yourself and that you the carrier didn’t chuck it in a field etc on route. If it is not your waste then fair enough you send the part E to the company that you take the stuff from.

Probably more detail of the actual work may have been helpful, but you seem happy now.

Chris