This length of time might seem difficult to defend in a time when refrigerant requirements are changing very rapidly, but the task has been complex and required the balancing of numerous competing requests for change (or in some cases no change). It is difficult to see how the process could be significantly shortened without thoroughly exploring the technical implications of all viewpoints.
Too complicated and stringent?
No doubt over time we can expect to see extension of strategies currently only permitted “for human comfort” to other systems and a general rationalisation of the requirements. In particular the wider use of A2Ls in supermarkets, chillers and other small to medium-sized systems will lead to further work by the International drafting teams to make the standard is easy to use while still ensuring high safety levels.
Will it mean system design changes?
A guidance note on the use of DSEAR for ammonia systems is being prepared by the Food Storage and Distribution Federation with input from the IOR, and a version of this for hydrocarbon and possibly for HFO refrigerants may be called for in the future.
The main issues that designers may find with this revision of the European safety standard do not lie with the text of the standard itself, but in the other regulations which will apply if companies are encouraged by the introduction of the new flammability class to adopt the new “lower flammability” refrigerants. This does not make their use impossible, but it is an extra layer of difficulty to be overcome.