F-Gas Regulation: Waste Disposal

Because of their environmental impact used fluorinated greenhouse gases have, according to Art 4 of regulation EC 842/2006 (the F Gas Regulation), to be recovered from systems before decommissioning or in cases when necessary maintenance work requires the removal of the refrigerant charge.

Systems explicitly mentioned under Art 4 of this regulation include the cooling circuits of refrigeration, air conditioning and heat pump equipment, equipment containing fluorinated greenhouse gas based solvents, fire protection systems and high voltage switchgear.

All other F gas containing systems should have the F gas recovered at the end of the system's useful life provided that this is technically feasible and does not entail disproportionate cost. Recovery means the capture and storage of the substance in a suitable pressure container. The requirement for recovery is to ensure the recycling, reclamation or destruction of fluorinated greenhouse gases.

In case where the recovered gas is subject for destruction, it is considered waste and has to be treated according to the respective European legislation.

Permits generally required for the storage and handling of non-domestic hazardous wastes are obtained from local government offices.

Discussion

The definition of what is "waste" is laid out in European Directives, the most recent of these being 2006/12/EC, which entered into force in May 2006. In simple terms "waste" is any substance which is not wanted by its owner. Domestic waste is excluded from this Directive and has a different legal treatment from other waste.

In terms of the F Gas Regulation (EC 842/2006 see article 4.1), which covers Fluorinated Greenhouse Gases, the onus is very clear - they must be recovered - that is to say transferred, into an appropriate pressure container when removed from equipment or systems in which they are used.

Waste fluorinated chemicals (liquids or gases liquefied under pressure) are generally considered to be among those waste substances classified as "hazardous waste" (article 14.06.01 of Commission Decision 2001/118/EC of January 2001). Hazardous wastes have a special control regime for storage and transport requiring specific permits for any transport or storage operation. These permits are issued and controlled on a local basis by the local environmental agency (or equivalent body).

When a fluorinated chemical is recovered four different possibilities for further treatment are available: (Note: The specific point at which the substance becomes defined as hazardous waste is defined under local regulations which are different in each Member State.)

• They are going to be reused on the site where they were recovered.
  In this case they are generally not considered to be waste since they are reused directly.
• They are going to be reused for servicing of other systems after having passed a recycling process .
  In this case they may not be considered as waste since it is intended by the service contractor to reuse them for the same purpose after they have been subjected to a recycling process to remove application-related impurities such as lubricant. In some EU Countries recovered refrigerants, held for future treatment, might fall into the hazardous waste permit scheme.
• They are going to be returned to the distributor for reclamation
  In this case they may not be considered as waste since they are returned by the service contractor to be further used after reclamation to original quality by a specialized company (can be also a producer of fluorinated gases). In other cases recovered refrigerants being transported to another location are considered to be hazardous waste and require the appropriate permits. Refrigerants which have been reclaimed are no longer treated as waste.
  In case an analysis carried out at the reclamation facility shows that a reclamation is impossible, the reclamation facility has to forward this gas to an incineration facility as hazardous waste.
• They are going to be disposed of by incineration.
  In this case they are immediately becoming hazardous waste. This designation means that the holding (storage) of and transport of these wastes requires the use of special permits.

Often recovered refrigerants, etc. cannot be reprocessed and have to be destroyed in an approved process/system. For fluorinated products some form of high temperature incineration is the acceptable technology for their destruction. Not every country has incineration facilities and waste refrigerants, etc. may have to be transported to another country for destruction, or in special cases for conversion to products (HF).

The international transportation of waste substances is regulated under the EU Regulation 1013/2006. This regulation defines the documentation needed for international transport of waste.

How does this affect me?

You need to be aware that you may be potentially involved in the handling/storage/processing of hazardous wastes

• If you are a refrigeration/air-conditioning service contractor;
• If your business involves the handling/disposal of insulation foams (or equipment which contains insulation foams);
• If your business handles fluorinated solvents;
• If your business is involved in the installation or servicing of fire suppression systems (or fire extinguishing equipment/systems);
• If your business handles SF₆;
• If your business receives recovered fluorinated refrigerants/solvents
• etc..

You might well need to be registered with your local authority and then will need to have an approved (local authority) documentation system (permit and record keeping) in place. Your fluorochemicals supplier should be able to give you more specific guidance concerning the local regulatory requirements where you carry out your business.