02 March 2020
The Federation of Environmental Trade Associations (FETA) has issued a warning to facilities managers to ensure they have the necessary DSEAR risk assessments in place for all air conditioning, refrigeration and heat pumps installed on their premises.
The Dangerous Substances and Explosive Atmospheres Regulations were designed to protect people from risks to their safety in the workplace, and to members of the public who may be put at risk by work activity.
The introduction of the EU F-Gas regulation and the HFC phasedown process has forced end users to move away from using high GWP refrigerants to more environmentally friendly gases in stationary refrigeration, air conditioning and heat pump equipment. This has increased the use of A2L and other flammable refrigerants, but has subsequently led to concerns that ‘employers’, as defined within the Regulation, may not be fully aware of their legal responsibilities under DSEAR, with regard to risk assessments.
When originally written in 2002, DSEAR only applied to those refrigerants defined as flammable (hazard classes H220 and H221). This referred to refrigerant classes A2 and A3, but with the introduction of class A2L refrigerants they also come under the scope of this regulation. However, the regulation was amended in 2015 to include gases under pressure (hazard class H280), which means all classes of refrigerant are within the scope of DSEAR, and hence ALL refrigeration, air conditioning and heat pump (RACHP) installations need to be compliant.
Martyn Cooper, FETA Commercial Manager, said: “It has come to FETA’s attention that there may be facilities managers in the UK unaware that following revisions to the regulation a DSEAR risk assessment is a legal requirement that applies where any air conditioning, refrigeration or heat pump is installed and is required in any situation where there is gas under pressure (not only when the refrigerant is A2L or flammable). The facilities management company therefore has a responsibility to ensure the DSEAR risk assessment exists where appropriate.”
FETA has produced a full guidance document on risk assessments for compliance with DSEAR which can be downloaded here.