Consultation invitation: halocarbon emissions from refrigeration and air conditioning systems

Gatineau, November 15, 2013

Subject: Consultation on the draft update to the Environmental code of practice for elimination of halocarbon emissions from refrigeration and air conditioning systems.

Sir,
Madam,

The current Environmental Code of Practice for Elimination of Halocarbon Emissions from Refrigeration and Air Conditioning Systems was published in 1996. Environment Canada is updating it to ensure that new technologies and present-day best practices are reflected in the document.

In October 2011, Environment Canada published on its website a draft update for a first round of public consultation. The document was sent to about 3000 individuals, companies and associations listed in Environment Canada’s ozone database. It was also shared with federal departments and with representatives from every province and territory.

Many valuable comments and suggestions were received following this consultation and we would like to take this opportunity to thank those who took the time to review this technical document. Your input allowed us to reconsider some aspects of the document. We recognize that some information contained in the 2011 draft update went beyond the scope of the current code. We therefore focused our attention on what we believe is essential information and structured the code like a reference document.

We intend to use the same consultative process for this second round of consultations. We encourage you to circulate the document and to provide us with comments and suggestions.

Considerable changes have been made to the 2011 draft update to the Code of Practice. Please find below some of the main considerations that guided us throughout the development of this revised draft update:

Approach

We chose to restructure the document by separating the stationary refrigeration and air conditioning systems (stationary cooling systems) from the mobile refrigeration and air conditioning systems (mobile cooling systems). We believe it will be easier to consult the document in that format.

Scope

The scope of the draft update has not changed from the current Environmental Code of Practice for Elimination of Halocarbon Emissions from Refrigeration and Air Conditioning Systems. It does not cover the purchasing of refrigerant.

Terminology

Terms and expressions are aligned to the extent possible with the Federal Halocarbon Regulations, 2003.

We no longer see a need for a glossary and a list of abbreviations at this time. Acronyms are limited to a minimum.

The expression “natural refrigerant” was removed as it is not used consistently.

We did not include a list of refrigerants as substances change from time to time.

References

We removed all references to external documents. We believe individuals in the cooling sectors already have mechanisms in place to ensure compliance with all other pertinent requirements.

Regulatory requirement

All regulatory requirements are aligned with the current Federal Halocarbons Regulations, 2003 (leak testing frequency, reporting, etc.). We recognize that future amendments to these Regulations could lead to amendments to the Code of Practice.

We specified that each province and territory may have distinct and additional requirements and that individual need to be familiar with the requirements to which the system is subject to. A provincial or territorial contact person as well as link to other control measures are listed on Environment Canada’s Website.

Training

We highlighted that the current federal regulations, the Federal Halocarbon Regulations, 2003, require the successful completion of an environmental awareness course in recycling, recovery and handling procedures with respect to halocarbon refrigerants. This requirement does not supersede or replace any obligation which may exist with respect to trade qualification or certification.

System design

As suggested by several stakeholders, we chose to condense the design section. We recognize that the information found in the design section of the 2011 draft update to the Code of Practice did not necessary target the same audience as the rest of the document.

Forms

We removed the reporting forms as they are easily accessible on Environment Canada’s website.

Environment Canada would like to encourage stakeholders to review the draft update to the Environmental Code of Practice for Elimination of Halocarbon Emissions from Refrigeration and Air Conditioning Systems and send any comments by January 17, 2014 to:

Ozone Layer Protection and Export Controls Section
Chemical Production Division
Environment Canada
351 St. Joseph Boulevard, 11th Floor
Gatineau, QC  K1A 0H3
Fax: (819) 994-5030
E-mail: OzoneProtectionPrograms@ec.gc.ca

Please contact Ms. Dominique Dore by e-mail at OzoneProtectionPrograms@ec.gc.ca or by phone at 819-994-4034, if you have questions regarding this consultation.

Once all comments have been reviewed and considered, the revised code will be published in the Canada Gazette, Part I and will replace the current Environmental Code of Practice for Elimination of Halocarbon Emissions from Refrigeration and Air Conditioning Systems.

Lucie Desforges

Director, Chemical Production Division

Att: Draft Environmental code of practice for the elimination of halocarbon emissions from refrigeration and air conditioning systems (revision September 2013)

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