Filling portable vessels above 350 cm³ in light of F-gas certification

Under the Regulation of the Minister of Economy on the procedure for verifying qualifications required for the operation and maintenance of technical equipment, persons involved in filling portable vessels with a capacity above 350 cm³ must hold the appropriate qualifications. Holding an F-gas certificate of the appropriate category authorises recovery of refrigerant (i.e. transfer of refrigerant from an installation into a cylinder). How should these authorisations be linked with a personal certificate related to work on installations containing F-gases? When recovering refrigerant from equipment, do we need both a “filler” certificate and F-gas authorisations? You are invited to read the article below, in which you will find answers to these questions.

Filler authorisations versus the F-gas certificate

Persons who have obtained a personal certificate for activities covered by the F-gas Act (Journal of Laws 2015, item 881) are authorised to perform the following activities:

• leak checking of equipment containing fluorinated greenhouse gases not contained in foams, in a quantity of 5 tonnes of CO₂ equivalent or more, unless such equipment is hermetically sealed, labelled as such and contains fluorinated greenhouse gases in quantities of less than 10 tonnes of CO₂ equivalent,
• recovery,
• installation,
• repair, maintenance or servicing,
• decommissioning of equipment,

with the detailed scope of authorisations defined by four categories, as follows:

• holding category I we may perform all of the above activities without restrictions related to the charge of the installation,
• category II authorises recovery, installation, repair, maintenance and servicing, and decommissioning, but limited to installations containing less than 3 kg of refrigerant (or 6 kg if dealing with hermetically sealed equipment), and leak checking of installations provided that such checking does not involve opening the refrigeration circuit,
• category III authorises recovery of refrigerant from installations containing less than 3 kg of refrigerant (or 6 kg if dealing with hermetically sealed equipment),
• category IV authorises leak checking of installations provided that such checking does not involve opening the refrigeration circuit.

Analysing the scope of authorisations, we can conclude that persons holding category I, II or III may perform refrigerant recovery from installations. Does this mean that F-gas authorisations alone are sufficient to recover refrigerant? The F-gas Act sets out procedures and obligations arising inter alia from Regulation (EU) No 517/2014, whose aim is to protect the environment by reducing emissions of fluorinated greenhouse gases, establishing in particular rules on containment, use, recovery and destruction of fluorinated greenhouse gases. Under the F-gas Act, authorised personnel should have knowledge of emission reduction in the scope of activities for which they hold authorisations. The Regulation of the Minister of Economy on the procedure for verifying qualifications required for the operation and maintenance of technical equipment concerns safety issues related to work on equipment covered by the Regulation and refers to the Technical Inspection Act (Journal of Laws No. 122, item 1321). Under that Act: “Technical inspection means activities specified by the Act aimed at ensuring the safe operation of technical equipment and equipment for recovery of fuel vapours, as well as activities aimed at ensuring public safety in those areas.” In summary, the F-gas Act (and certificates compliant with the Act) concerns aspects related to limiting emissions to the atmosphere, i.e. environmental protection, whereas authorisations arising from the Regulation consistent with the Technical Inspection Act concern persons working on technical equipment and are related to ensuring safety during its operation. Going further, when recovering refrigerant we should therefore hold both F-gas authorisations and qualifications for persons filling portable vessels.

How to obtain filler authorisations?

Filling portable pressure vessels with a capacity above 350 cm³ with fluorinated greenhouse gases – performed during recovery of refrigerant from refrigeration, air-conditioning or heat-pump installations – requires obtaining the appropriate authorisations confirmed by a positive examination result. The examination consists of a theoretical and a practical part. During the theoretical part the candidate answers orally questions asked by the board. Board members ask 2 general questions and 3 specialist questions from the scope of a specific group of gases. To pass the theoretical examination, the candidate must correctly answer at least one question from the general part and two questions from the specialist part. The practical part of the examination consists of filling a vessel, during which the candidate must demonstrate knowledge of identifying vessel markings and assessing its technical condition, connecting the vessel, assessing correct filling and post-filling activities, and applying the appropriate labels that should be placed on the vessel being filled. A candidate seeking authorisations should be at least 18 years of age and possess theoretical and practical knowledge related to filling portable vessels. With regard to filling vessels with fluorinated greenhouse gases (F-gases), a personal certificate of the appropriate category is also required (the categories were described earlier).

Where can filler authorisations be obtained?

The Central Refrigeration Centre “COCH” in Kraków Sp. z o.o. runs training for persons seeking authorisations to fill portable pressure vessels with a capacity above 350 cm3 with fluorinated greenhouse gases. The trainers delivering the course have theoretical and practical knowledge consistent with the examination scope. Immediately after the training, a UDT examination board convenes and candidates may sit the examination, which is also held at the COCH facility. Candidates take the practical examination on a specialised station intended for refrigerant recovery, on which the training is previously conducted. This arrangement significantly facilitates obtaining authorisations, because knowledge is assessed in the same place as the training, and the technical equipment used during training is also used during the practical examination. Sources:

• COMMISSION IMPLEMENTING REGULATION (EU) 2015/2067 of 17 November 2015 establishing, pursuant to Regulation (EU) No 517/2014 of the European Parliament and of the Council, minimum requirements and the conditions for mutual recognition for the certification of natural persons as regards stationary refrigeration, air conditioning and heat pump equipment, and refrigeration units of refrigerated trucks and trailers, containing fluorinated greenhouse gases and for the certification of companies as regards stationary refrigeration, air conditioning and heat pump equipment, containing fluorinated greenhouse gases.
• REGULATION OF THE MINISTER OF ECONOMY of 18 July 2001 on the procedure for verifying qualifications required for the operation and maintenance of technical equipment.
• ACT of 15 May 2015 on substances that deplete the ozone layer and on certain fluorinated greenhouse gases.
• REGULATION (EU) No 517/2014 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 April 2014 on fluorinated greenhouse gases and repealing Regulation (EC) No 842/2006.
• ACT of 21 December 2000 on technical inspection.
• www.udt.gov.pl

Author: Andrzej Chmaj