Government Confirms F-Gas Will Continue in ‘No Deal’ Brexit
On 13th September 2018, a technical notice was published for using and trading in fluorinated gases (F-Gas) and ozone depleting substances (ODS) if there is no Brexit deal when the UK leaves the EU in March 2019. In the commercial real estate sector, such substances are commonly used in refrigerants – for purposes such as air-conditioning and refrigeration – but are also found in feedstocks for the manufacture of chemicals and fire extinguishers, amongst a range of different applications.
In the EU, the control of F-Gas is regulated under the EU Fluorinated Greenhouse Gases Regulation (517/2014), which aims to phase down the use of F-Gas through a removal from the market of the most destructive Hydrofluorocarbons (HFCs), the requirement for mandatory leak testing and the use of contractor competency schemes. Additionally, ODS are largely regulated by the EU Ozone Depleting Substances Regulation (1005/2009), which aims to phase out ODS completely. The EU Regulations have been created to put into force the terms of the Montreal Protocol. However, it is important to note that the EU Regulations go further and relate to a wider number of HFCs and ODS.
If there is ‘no deal’ after March 2019, the UK Government express that they will continue to implement most of the EU ODS and F-Gas Regulations requirements in the same way; enabling the UK to continue to phase down the use of F-Gas and ODS.
Under a ‘no deal’ scenario there is the potential for changes to the contractor competency certification schemes. Although this will not impact the use of EU certificated contractors for purposes of F-Gas equipment maintenance, there is the potential that technicians certified by UK bodies will need to be re-certified by a body in an EU country if they wished to work in the EU, unless the EU decides to continue recognising such certificates.
Data management systems, such as RiskWise, the S2 Partnership’s online property risk management software platform, enable the collection and analysis of environmental data such as F-Gas-related assets. New functionality within RiskWise’s Environmental Management module allows users to help ensure and demonstrate their compliance with all EU or UK fluorinated greenhouse gas regulations. F-Gas readings, visible in a new ‘F-Gas Register’, can be categorised by Installation, Planned Service and Reactive maintenance. The Gas Type, Gas R Number and Global warming potential (GWP) are stored alongside the Gas added, to automatically calculate the CO2 equivalent. This shows data captured from F-Gas readings made on all assets for record keeping purposes – either on a specific property or across a portfolio.
Once data has been captured, Dashboard reports can be configured to provide reporting on F-Gas details for any of the information recorded across the portfolio, properties or assets to increase visibility.
The S2 Partnership supports clients with ongoing advancement of health, safety and environmental risk management. Working closely with global clients, the S2 Partnership provides consultancy, training and software to the commercial real estate sector. To find out more, please contact us.