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Auditing the F-Gas Regulations
Given the prevalence of cooling systems, air-conditioning units and related facilities equipment for building management systems, it is surprising how often these are neglected from the management system perspective. Internal EMS auditors may be required to investigate the Fluorinated Greenhouse Gas Regulations 2008 as part of the overall audit programme and therefore should provide an accurate assessment of the applicability and, if appropriate, assess the degree of compliance with the requirements.
Firstly, the auditor should become familiar with the type of operations that take place at the site. There are significant requirements for process cooling within commerce (there are many industries that require this capability such as plastic extrusion, clean-room facilities, office temperature control). Often cooling systems are hidden away at the back of buildings and away from people due to aesthetics and noise nuisance issues.
In planning for the audit, guidance on this topic can be found in documents such as F-gas Support, or the Supplementary Guidance Document issued in May 2007 from DEFRA.
The next task is to check the aspect register to see if any reference is made to the use of fluorinated greenhouse gases as a coolant. There should be information detailing the type of coolant and quantity used in any single unit, and from there an assessment of the significance made. If not there may be a nonconformity relating to the inadequacy of the register.
The key information is to find out if the cooling unit contains more than 3 kg of refrigerant and to identify the type of coolant used. Also check the Legal register - the aspect register is often combined and any missing information on the legal applicability should be treated as a finding. Understand also the issue of global warming potential – a refrigerant with over 150 units means the regulation may apply.
Aside from the more complex issues surrounding the applicability, the auditor should then determine the degree of control of the maintenance process (sub-contractor management). Is the aircon maintenance company using trained staff? Have the certificates been checked by the person responsible within your company? Are records kept which provide details of the amounts of refrigerant supplied? Based on these sorts of questions, the EMS auditor can then prepare audit findings based on the outcome of these investigations against the specific element of ISO 14001. Add value to the audit by pinpointing areas where the regulations are not understood or where actions relating to compliance are not met.
Often, awareness of the type of refrigerant involved can be missing or unclear, even though the contractors employed to maintain the chillers may ensure that the F-Gas regulations are complied with. Certificates of persons doing the work should be seen by the company and copies of certificates help with meeting the rigorous training and competency requirements.
By carrying out careful planning, the auditor can help improve the company’s environmental performance as well as help maintain legal compliance in this important piece of environmental legislation that has wide applicability throughout commerce and industry.
John Marsden (FIEMA)
info@marsden-international.com
John is an independent management system auditor who works for a number of international certification bodies.
