The release of the Flammable Refrigerants Review Project last month has ignited a safety debate about the level of training provided to refrigeration and air conditioning technicians.
Industry groups across the globe are calling for more training to accompany the increased use of flammable refrigerants.
While the United States is set to introduce a flammable licensing regime of its own, the European Union is reviewing mandatory training and certification for A2L refrigerants.
In Australia the review project provided an overview of the regulatory and quasi-regulatory instruments which control the use and handling of flammable refrigerants in the different jurisdictions around the country.
It identified gaps within the regulatory landscape.
“The need to regulate the use of flammable refrigerants has been recognised globally as important because the substances can ignite, causing injury or damage to property. There are a wide range of laws and other instruments that regulate flammable refrigerants in Australia. However, the laws are fragmented and disjointed as there is no one framework that governs their use,” the report said.
“Instead, flammable refrigerants are regulated by a range of laws that primarily relate to WHS / OHS, dangerous goods and electrical safety. While there is a significant amount of consistency in the applicable laws around the country, there are some variations between jurisdictions.
“As a result, the regulatory landscape is confusing. Not only is it potentially difficult to understand and comply with, there are multiple regulators which is likely to make coordinated and effective enforcement of laws challenging,” the report said.
“Although the likelihood of ignition associated with flammable refrigerant may be low, the consequence when ignition occurs can be high. Increasing knowledge of these risks and mitigation through reducing the likelihood of ignition can be managed through the setting of standards, training to ensure knowledge of standards and required competencies, and effective regulation.”
The report recommends licensing and accreditation schemes but points out that the current regime is too disjointed. For example, in some states technicians need to hold two or three licenses.
“In some jurisdictions, air conditioning and refrigeration technicians are required to hold three licences – an air conditioning and refrigeration licence, a restricted electrical licence and the ARCtick licence,” the report said.
“Motor vehicle repairers may also be required to hold an industry specific licence or registration in addition to an ARCtick licence. The requirement to hold multiple licences or registrations imposes a regulatory burden on participants.
“They must apply and pay for multiple licenses and potentially also bear indirect costs associated with managing their compliance with regulatory requirements, such as training, systems and processes.
“It also creates confusion, both for participants and consumers. Further, given none of the licensing requirements beyond those in Queensland have a direct correlation to the handling of flammable refrigerants there is a potential, or at least a perception, that they do not adequately ensure those licensed have the required competencies and knowledge to mitigate risks associated with the use of flammable refrigerants.”
The report also points out that substituting refrigerants and retrofitting equipment to incorporate flammable refrigerant raises clear safety issues.
On issues relating to competency there are a number of training courses available covering flammable refrigerants.
In addition to training provided by TAFE and RTO’s there is Green Scheme Accreditation available from the Australian Refrigeration Council (ARC).
The ARC Green Scheme Accreditation program provides a pathway for technicians to upskill in the use of new refrigerants.
It is voluntary, and incorporates key refrigerants not covered by the ARCTick scheme specifically hydrocarbons, C02 (R744), Ammonia and HFO 1234yf.
ARC CEO, Glenn Evans, said the scheme provides a national framework for refrigeration and air conditioning technicians to demonstrate they are qualified to work with low GWP (flammable) refrigerants.
He said the Green Scheme program as one way for companies in this space to identify the competence of technicians.
“OHS obligations state that refrigeration and air conditioning employees working with flammable refrigerants must be competent to do so.,” he said.
“While it is voluntary, the framework is already in place so it is a logical, effective and efficient way for licensing of flammable refrigerants to be made mandatory, all that needs to happen is for the states and territories to adopt the ARC Green Scheme program.”
Commenting on the Flammable Refrigerants Review Project, HyChill Australia general manager, Mario Balen, said there seems to be an obsessive need to regulate flammable refrigerants which has become a regular feature of the Australian HVACR landscape.
“The basic flaw in this approach is that it ignores the need for all refrigerants to be adequately licensed,” he said.
“Singling out any group should be called out for what it is – a blatant attempt to pervert the market and deny Australia the benefits of using hydrocarbon refrigerant which is vastly superior when it comes to energy efficiency, lower cost and negligible environmental damage.”
Balen said the rest of the world is on a completely different path adopting hydrocarbons for domestic fridges and freezers.
He said Europe has just increased the charge limits for commercial freezers and displays to 500 g per unit and is about to do the same for stationary air conditioners.
“India and China are powering ahead with stationary ACs with hundreds of thousands of propane R290 units installed,” he said.
“Licensing by itself does not improve efficiency or cost outcomes, these elements can only be improved by developing national standards and codes of practice, only then can a licensing regime be successful in driving progress.”
Balen said any scheme relating to refrigerants would need to satisfy the following criteria:
1. Enhance and protect safety and wellbeing of the trade, customers and public
2. Be, on balance, in the general interest of the public and society
3. Improve, rather than merely regulate the outcomes
4. Be outcome-based and technology/materials agnostic.
Balen said a licensing scheme should be tiered to cater to different levels of technical sophistication.
He said it should take into account size, cost and complexity of installation.
“It makes little sense to require someone performing a relatively routine task of installing self-contained, highly engineered domestic AC machines to be under the same licensing onus as a designer or installer of an industrial-size refrigeration plant,” Balen said.
“Any licensing regime should also pass a cost/benefit analysis to ensure that red tape does not stifle innovation or unnecessarily add to the cost of doing business.”
Federal Treasurer, Josh Frydenberg, last year announced plans to introduce a national framework for occupational licensing.
Currently, registration and licensing requirements vary significantly across jurisdictions, with some scopes of work entirely unregulated, while others are subject to strict requirements that reflect their level of specialisation.
The Air Conditioning Mechanical Contractors Association (AMCA) CEO Scott Williams said previous attempts to introduce national occupational licensing failed because of an inclination towards the recognition of lower standards of competency.
“Even in jurisdictions where trade disciplines—for example, mechanical services plumbing and refrigerated air conditioning—share similar scopes of work, the qualification and experience requirements are different,” he said.
“As a result, the specific competencies of trade practitioners operating in different states and territories can vary significantly, despite the fact that the scope of work appears to be the same.”
According to the Australian Institute of Refrigeration, Air Conditioning and Heating (AIRAH) there is overwhelming support for a national licensing model that covers all refrigerants.
AIRAH did an industry-wide survey last year and more than 900 respondents completed the survey with technicians accounting for 75 per cent of the total, 10 per cent were engineers and the remainder were a mix of apprentices, educators, representatives from government and industry groups, manufacturers and wholesalers.
A nationally harmonised approach to licensing that covers all refrigerants was supported by 94.21 per cent of respondents while support for a Certificate III qualification (or equivalent) as the minimum qualification for installing, commissioning, maintaining and decommissioning stationary HVACR systems was 95.39 per cent.
There was also support (92.38 per cent) for more professional development including pathways to bridge the skills gap.
Safety was a big concern with fears untrained technicians are working with new-generation refrigerants without the correct training.