Consultation document on proposed revisions to Federal Halocarbon Regulations: chapter 2

Consultation Topics: Interpretation, Application and Prohibitions

This section is organized using the same headings as found in the Federal Halocarbon Regulations, 2003 (FHR 2003). For each heading, the purpose of the provisions is provided for context, followed by a summary of each issue, the proposed revision, and any targeted questions for which Environment Canada is seeking input.

Interpretation

The purpose of the Interpretation provisions is to define words used in the FHR 2003 for which the meaning must go beyond or restrict the dictionary definition.

Issue 1 - Definition of Charging

Sections 15-18, 29 and 30 of the FHR 2003 prohibit charging refrigeration, air-conditioning and fire-extinguishing systems with a halocarbon listed in any of items 1-9 of Schedule 1 of the Regulations (also listed in Annex 1 of this Document), including following preventative maintenance activities that require their removal.

Proposed Revision

• Ensure that charging prohibitions do not include preventative maintenance activities.

Question

• What service activities are likely to require halocarbon to be removed in order to complete the activity?

Issue 2 - Definition of Owner

The definition of “owner” is broad and includes both the traditional meaning of owner (i.e., proprietor), as well as those responsible for maintenance, operation and management of a system, including service technicians. This definition causes confusion for certain sections of the FHR 2003, such as section 12, which outline specific responsibilities for both the certified person (i.e., the service technician) and the owner (which also includes the service technician).

Proposed Revision

• Ensure that responsibilities of the owner and the service technician are clearly defined throughout the FHR 2003¹.

Issue 3 - Definition of Small System

The purpose of defining “small refrigeration systems” and “small air-conditioning systems” is to differentiate small domestic appliances, like household refrigerators, from large industrial systems. The refrigeration capacity, which is the current measure for establishing the size of a system, is not always labeled and therefore difficult to determine. The motor rating is used as the measure for establishing system size in many provincial regulations.

Proposed Revision

• Revise the threshold to a motor rating of less than 3 horsepower.

Questions

• Is the motor rating more often labeled on a system than the refrigeration capacity?
• Is the amount of refrigerant in a system a better measure for distinguishing domestic appliances from industrial systems? If so, what is an appropriate threshold (in kg or lb)?
• Are there other measures and thresholds that should be considered to distinguish domestic appliances from industrial systems?
• What systems, other than domestic refrigerators, freezers, air-conditioners and other similar goods, would be captured by the proposed threshold?

Application

The purpose of the Application provisions is to specify what systems the FHR 2003 apply to. No changes are proposed to these provisions at this time.

Prohibitions

The purpose of the Prohibitions provisions is to prohibit the activities that cause the most damage to the ozone layer and to climate.

Issue 4 - Prohibition of HCFC Solvent Systems

Solvent systems that use HCFCs are currently the only halocarbon solvent systems that can be installed or used without a permit. On January 1, 2015, HCFCs will only be permitted to be manufactured or imported into Canada for use as a refrigerant under Canada’s Ozone-depleting Substances Regulations, 1998 (ODSR 1998). Note that there are currently no known halocarbon solvent systems in Canada.

Proposed Revisions

• Revise section 4 to prohibit the installation of solvent systems² that use any halocarbon listed in Schedule 1 of the FHR 2003.
• Revise section 5 to prohibit the use of any halocarbon as a solvent in a solvent system, unless authorized by a permit.
• Allow permits, pursuant to section 34 of the FHR 2003 to be requested only for use of HCFCs, HFCs and PFCs as a solvent in a solvent system.

Question

• Do you know of any solvent systems using halocarbons in Canada?

¹For example, responsibilities of the owner would include ensuring that all work done on a refrigeration or air-conditioning system that may result in a halocarbon release is done by a certified person, and that leaks are repaired and reported. The responsibilities of the service technician would include doing all work on a refrigeration or air-conditioning system in accordance with the Environmental Code of Practice for the Elimination of Fluorocarbon Emissions from Refrigeration and Air-Conditioning Systems, immediately informing the owner of a system leak and isolating the leak or recovering the halocarbon from a leaking system until the owner authorizes its repair.

²While no restriction will be put in place in the FHR 2003 to install refrigeration, air-conditioning or fire-extinguishing systems that use HCFCs, these substances are also being phased-down in Canada under the ODSR 1998. Please consult the ODSR 1998 for further information on the upcoming prohibitions.