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How air conditioning law affects GPs

The battle to save the ozone layer means surgeries must comply with EC law. By Andrew Cooper

Scientists believe artificial refrigerants, as used in some air conditioning units, contribute to global warming and European legislation has been passed to reduce this effect (Photograph: Istock)
Scientists believe artificial refrigerants, as used in some air conditioning units, contribute to global warming and European legislation has been passed to reduce this effect (Photograph: Istock)

GP surgeries with air conditioning or heat pumps may be forced to replace them under European legislation.

As of January this year, certain types of refrigerants are being phased out and GPs will need to ensure their systems are compliant.

Refrigerants fall under two categories, natural and artificial. Natural refrigerants can be volatile, toxic or inefficient, so artificial refrigerants, such as chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs), are more commonly used.

However, artificial refrigerants have helped deplete the ozone layer and, most scientists believe, contributed towards global warming. European legislation has been passed to try to reduce this effect.

EC regulations on substances that deplete the ozone layer
Under EC regulations, CFCs are now banned and HCFCs are being phased out. The most commonly used HCFC in the UK is R22 refrigerant.

Virgin HCFCs cannot be used for servicing systems as of January 2010. Recycled HCFCs can be used until January 2015, after which they can no longer be used.

EC regulations on certain fluorinated greenhouse gases (F-Gas Regulations)
Systems with more than 3kg of ozone depleting substances, including HCFCs and HFCs, must be checked annually for leakage.

F-Gas Regulations contain requirements for labelling, leak checking, record keeping and maintenance staff qualifications.

Systems employing HFCs should also have clear labelling stating that they contain fluorinated greenhouse gases covered by the Kyoto Protocol, the type of refrigerant, and how much is in the system (the charge). If the system is hermetically sealed, this should also be stated.

Normal systems with a HFC charge of less then 3kg are not covered by F-Gas Regulations, while hermetically sealed system are not covered if the charge is less than 6kg.

If your system meets these criteria then, depending on the charge, it must be checked annually, biannually or quarterly.

Compliance for both of these EC regulations is policed by the Environment Agency (or Scottish Environment Protection Agency) and local authorities who have wide ranging powers including enforcement and prohibition notices.

GP practices will fall under the auspices of local authorities, which are likely to delegate the powers to local trading standards or environmental health.

Non-compliance could lead to a criminal prosecution.

European Performance of Buildings Directive (EPBD)
The EPBD requires all air conditioning systems to have an air conditioning energy assessment (ACEA) at least once every five years.

Systems with an output of at least 12kW power must have their first ACEA before 4 January 2011 (4 January 2013 in Scotland). Systems with an output of more than 250kW should have been assessed by 4 January 2009.

The exception are systems installed on or after 1 January 2008 with an output of at least 12kW, which must have their first assessment within five years from installation.

A system includes a collection of units under the technical control of a single person.

Therefore a practice with multiple cassettes or wall-mounted units with a combined power output of greater then 12kW will almost certainly require an ACEA.

The legislation is enforced by trading standards and a fine of £300 can be levied for non-compliance.

While the fine is unlikely to ensure compliance on its own, the purpose of the assessment is to identify if there are low/no cost ways of making systems run more efficiently and it may be prudent to appoint an accredited assessor with this in mind.


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