Consultation document on proposed revisions to Federal Halocarbon Regulations: chapter 4

Consultation Topics: Installation, Servicing, Leak Testing and Charging

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.

Installation, Servicing, Leak Testing and Charging

The purpose of the Installation, Servicing, Leak Testing and Charging provisions is to minimize releases of halocarbons to the environment by ensuring that refrigeration, air-conditioning and fire-extinguishing systems are properly maintained.

Issue 8 - Charging Halocarbons for Leak-Testing

Subsection 9(3) and section 23 prohibit charging a refrigeration, air-conditioning or fire-extinguishing system with a halocarbon listed in any of items 1-9 of Schedule 1 of the FHR 2003 for leak testing. Subsection 9(3) also provides for exceptions when the leak testing is recommended in the Refrigerant Code of Practice. Leak testing methods that do not use these substances can also be performed on systems using halocarbons listed in any of items 10-12 (HCFCs, HFCs and PFCs). Allowing leak testing with items 10-12 allows their unnecessary release to the environment.

Proposed Revision

• Revise subsection 9(3) and section 23 to prohibit the charging of any halocarbon for the purpose of leak-testing, unless recommended in the Refrigerant Code of Practice.

Question

• Are there irreplaceable leak-testing procedures that require HCFCs, HFCs or PFCs to be charged into a system?

Issue 9 - Leak-Test Notices

Section 10 requires that a leak-test notice be affixed to a refrigeration or air-conditioning system after performing a leak test. Many systems, especially air-conditioners, are located outside. Notices affixed to such systems are subject to the elements and are often difficult to read or are lost between leak tests. In addition, the information contained on a leak test notice is the same as that which is recorded in a service log, resulting in duplication of work and administrative burden.

Proposed Revision

• Remove the requirement to affix the leak test notice to a system.

Issue 10 - Annual Inspections

At the time the FHR 2003 was published, leak testing was determined to be the minimum requirement to maintain a system. A leak test alone, however, does not adequately maintain systems to minimize halocarbon leaks to the environment.

Proposed Revision

• Revise section 11 to require that an annual inspection, which will be outlined in the revised Refrigerant Code of Practice and will include a leak test requirement, is completed annually³.

Questions

• Are there other activities that can be completed on a regular basis to ensure that a system is well maintained?
• Are there other time frames that should be considered for completing a regular inspection or other maintenance activity (i.e., for seasonal systems, upon start up)?

Issue 11 - ICAO Amendments

The International Civil Aviation Organization (ICAO) has amended Annex 6 - Operation of Aircraft and Annex 8 - Airworthiness of Aircraft of the Convention on International Aviation to prohibit the use of certain halon fire extinguishers on newly manufactured or designed aircraft. As a member of the ICAO, Canada must comply with the Convention as amended. These uses are currently allowed under sections 29 and 30 and paragraph 34(1)(b) of the FHR 2003.

Proposed Revision

• Revise the FHR 2003 to prohibit the installation of the following systems that operate or are intended to operate with a halocarbon listed in any of items 4 to 6 of Schedule 1 of the Regulations:
  • fire-extinguishing systems in aircraft lavatories in aircraft manufactured after December 31, 2011,
  • fire-extinguishing systems in engines and auxiliary power units in aircraft designed after December 31, 2014, and
  • portable fire-extinguishing systems in aircraft manufactured after December 31, 2016.

Issue 12 - Charging Prohibitions

Between 2005 and 2010, prohibitions on charging with any halocarbon listed as item 1-9 of Schedule 1 of the FHR 2003 were phased in for refrigeration, air-conditioning and fire-extinguishing systems. With the 2010 date having past, the provisions for the prohibition phase in are unnecessarily complicated. Note that the charging prohibitions are currently found in sections 15-19 (refrigeration and air-conditioning systems) and 29-30 (fire-extinguishing systems) of the FHR 2003.

Proposed Revisions

• Consolidate the charging prohibitions into one section that prohibits charging of:
  • refrigeration or air-conditioning systems, and
  • fire-extinguishing systems, unless authorized by a permit.
• Exempt the following fire-extinguishing systems from the charging prohibition:
  • systems for use on a military vehicle or a military ship,
  • systems for use on an aircraft, except those that are prohibited by the ICAO Convention on International Aviation (see Issue 11), and
  • critical systems (see Issue 15).

³ Note that annual leak tests will still be required for fire-extinguishing systems under section 24 (no similar inspection procedure is currently available for those systems).