Recovery Rules Can Create Confusion
October 1, 2007
The 11th Commandment, as far as the HVACR industry is concerned, is Thou Shalt Remove Refrigerants From a Piece of Equipment Being Junked.
In the messy reality of refrigerants, that is much easier said than done. Some equipment, especially smaller appliances, mysteriously end up in dumps or on the side of the road, with no indication as to what refrigerants might still be in the system. Even proper recovery procedures are not 100 percent perfect; not all refrigerant may come out of the equipment in the recovery process, and that which does come out may not totally go into the recovery tank. Some refrigerant may leak into the atmosphere.
Then, of course, some less-than-honorable techs simply blow a charge of CFCs or HCFCs into the atmosphere, skipping the recovery process altogether.
Enforcement of such matters in the United States is in the hands of the Environmental Protection Agency and those willing to be whistle-blowers when they notice questionable practices. Enforcement usually consists of fines, which over the years has mainly consisted of a few well-publicized, big-bucks levees against high-profile names. The idea is to instill the “fear of God” into the fellow who’s dealing with an old refrigerator in an isolated locale, hundreds of miles from the nearest major highway.
Dealing with leaks is not just an issue in the United States. It is a topic among all developed countries. In fact, in Europe it is part of an equation of ever-evolving regulations. Taking a brief overview of one of the most recent developments in Europe can be helpful in a couple of ways. First, it can show statesiders how really complicated things can get. And, since many of the regulatory pressures affecting CFCs and HCFCs first came from Europe, there is always the possibility that such complex rulings and regulations could reach North America in some form.
The recently published “Life Cycle Assessment Of The Treatment And Recycling Of Refrigeration Equipment Containing CFCs And Hydrocarbons,” commissioned by the German organization RAL Quality Assurance Association for the Demanufacture of Refrigeration Equipment, says both the German CFC/Halon Prohibition Ordinance and the European Union directive on Waste Electrical and Electronic Equipment (WEEE) require the removal of CFCs from waste appliances and destroyed “in a nonharmful way.”
In Germany, the WEEE was implemented as part of the Electrical and Electronic Equipment Act in combination with the Waste Avoidance, Recycling and Disposal Act, the later of which requires that CFCs, HCFCs, HFCs, and HCs (hydrocarbons) “must be removed from end-of-life appliances and then destroyed or recovered.”
CHANGES COMING?If all those titles aren’t confusing enough, there may be changes coming. Those HCs - which aren’t all that common in North America because of flammability issues - are quite common in Europe. In fact, a lot of the newer domestic refrigeration equipment use HCs. As they wear out, there will be a lot more of such equipment to get rid of. The study says maybe 10-20 percent of waste refrigeration appliances currently use HCs, but that number could rise to 50 percent over the next five to 10 years.
There also is some talk in Europe about not requiring the removal of HCs from equipment in the future. The reason has to do with the fact that HCs are neither ozone depleting nor global warming refrigerants. So why do they have to undergo costly and time-consuming recovery and destruction? Ask those folks advocating the change. After all, they say, those cost savings may motivate even greater attention to equipment using HCs and not the ozone-depleting CFCs/HCFCs and the global-warming HFCs.
Here’s how the RAL study summarizes the situation:
“The question of whether this requirement should be omitted in the next round of changes to the WEEE legislation is currently the subject of controversy.
“For practical purposes, this would mean that such appliances would be processed directly into auto shredder facilities or in refrigerator recycling plants without the complete prior removal of the hydrocarbons.”
The real concern here is over the uncertainty of what is actually in a system - something U.S. and Canadian service techs are very familiar with.
“It is to be expected that numerous missorted CFC-containing appliances, especially those with inadequate labeling, would find their way directly into shredders without having undergone proper prior treatment by refrigerator disposal specialists,” the report said. “In such cases, it can be assumed that the CFCs would not be safely removed in advance, and that most of the CFCs in these appliances would be emitted into the environment.”
VOLATILE ISSUESThe seemingly simple effort in Europe to classify HCs differently than CFCs, HCFCs, or HFCs has the potential of adding yet another layer of uncertainty into the disposal of older refrigeration equipment.
The process also has to sort itself out through a labyrinth of regulations.
For every North American technician trying to figure out exactly the right thing to do when it comes to recovery of refrigerants and the destruction of both aged equipment and potentially no-longer-usable refrigerant, rest assured that that tech has an even more confused and frustrated counterpart in Europe.
Publication Date: 10/01/2007