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Halai40648  
#1 Posted : 07 June 2017 07:55:53(UTC)
Rank: New forum user
Halai40648

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!

Granlund40055  
#2 Posted : 07 June 2017 08:30:51(UTC)
Rank: Forum user
Granlund40055

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.

thanks 1 user thanked Granlund40055 for this useful post.
Halai40648 on 07/06/2017(UTC)
Halai40648  
#3 Posted : 07 June 2017 08:51:12(UTC)
Rank: New forum user
Halai40648

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.

Halai40648  
#4 Posted : 08 June 2017 06:33:20(UTC)
Rank: New forum user
Halai40648

I have just found out that the business does has a current F-Gas Certificate.

But more specifcailly, will this Client need any formal waste license/registration to transport the reclaimed gas from the site back to the yard?

Thanks!

Granlund40055  
#5 Posted : 08 June 2017 12:33:52(UTC)
Rank: Forum user
Granlund40055

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

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Halai40648 on 08/06/2017(UTC)
chris42  
#6 Posted : 08 June 2017 13:03:59(UTC)
Rank: Super forum user
chris42

Originally Posted by: Granlund40055 Go to Quoted Post

 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?).   /quote]

Not sure about that, I believe the responsible person is the person whose activities create the waste; therefore, the waste is produced by the servicing company and so they can carry their waste with a lower tier licence.

Not easy to check this one online, but if you call the EA they will say the same.

Chris

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Halai40648 on 08/06/2017(UTC)
Granlund40055  
#7 Posted : 08 June 2017 14:07:46(UTC)
Rank: Forum user
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 1 user thanked Granlund40055 for this useful post.
Halai40648 on 08/06/2017(UTC)
Halai40648  
#8 Posted : 08 June 2017 14:12:55(UTC)
Rank: New forum user
Halai40648

Originally Posted by: Granlund40055 Go to Quoted Post

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

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.

Edited by user 08 June 2017 14:26:26(UTC)  | Reason: BRA Fact Sheet number was wrong - not 10 but 20!

Halai40648  
#9 Posted : 08 June 2017 14:25:19(UTC)
Rank: New forum user
Halai40648

Originally Posted by: Granlund40055 Go to Quoted Post

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.

chris42  
#10 Posted : 08 June 2017 14:35:30(UTC)
Rank: Super forum user
chris42

I looked into this a while ago and ended up on the phone to Natural Resources Wales (Welsh EA, they had just split so should be the same advice). After a large amount of errs and umms regarding some of their guidance notes at the time, we concluded that if say a builder came and cut a hole in the wall of your building and put a window in, the bricks would be their waste. If a gardening company cut your grass and trimmed the hedges then again it is now their waste. Technically you own the bricks and dead grass, but they produced the waste. If the company accidentally hits down a small wall and just wants shot of the bricks they then are the producer even if they get someone to build a new wall at a later date. This was the simple discussion we had.

So, someone coming to service something, anything they remove is generally their problem but anything created as waste by your company is yours. This can be altered via contract to an extent so it is up to people to agree. As I said very difficult to find any actual guidance on this despite this being a common occurrence. Then again normal waste companies are generally hard work and provide rubbish paperwork (excuse the pun). The good EA site has gone to be replaced by the .GOV site, for which all words I would like to use to describe would be banned on this site.

Think of it this way, when you have your company car serviced do they give you the old oil and filters back? You just try and get your old battery back :o)

Chris

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Halai40648 on 08/06/2017(UTC)
chris42  
#11 Posted : 08 June 2017 14:57:47(UTC)
Rank: Super forum user
chris42

Originally Posted by: Halai40648 Go to Quoted Post
Originally Posted by: Granlund40055 Go to Quoted Post

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

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Halai40648 on 08/06/2017(UTC)
chris42  
#12 Posted : 08 June 2017 16:01:07(UTC)
Rank: Super forum user
chris42

https://naturalresources.wales/media/1129/waste-carriers-fact-sheet.pdf

page 3 item 3

Chris

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Halai40648 on 08/06/2017(UTC)
Halai40648  
#13 Posted : 08 June 2017 17:00:32(UTC)
Rank: New forum user
Halai40648

Originally Posted by: chris42 Go to Quoted Post

https://naturalresources.wales/media/1129/waste-carriers-fact-sheet.pdf

page 3 item 3

Chris

Oh golly gosh - more really useful information! My client does not like to read much so I tend to summarise stuff for him but on this occasion I think I will just send him the Factshet and await his next question! Thanks for this though - really appreciated!

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