When is Refrigerant Detection Required?

Many refrigeration stakeholders often ask the question: “When is Refrigerant Detection Required?” The answer to this question is a multi-faceted one, as owners / operators, installers, and technicians must comply with a vast array of legislation, codes and standards.

Not to mention, these requirements vary by region, which can seem equally as overwhelming. What’s comforting, however, is the fact refrigerant detection requirements tend to be similar across regions.

Such refrigeration regulations and standards include clauses requiring refrigerant leak detection systems to be installed when there is an environmental, health, and / or safety risk. Thus, in this article, we will provide an overview of the basic requirements for refrigerant detection to easily enable refrigerant compliance.

Leak Detection

Refrigerant Regulations

First and foremost, we are going to start with the refrigerant laws and regulations in various regions, namely Europe and the United States.

Specifically, in Europe, refrigeration stakeholders must comply with the F-gas refrigerant regulations. Meanwhile, in the United States, stakeholders must comply with EPA Section 608, and, if in California, the California Air Resources Board (CARB)’s own refrigerant management program.

More than a standard, these refrigerant regulations (discussed below) are a legal requirement in their own right.

EU F-gas

Article 4 of the EU F-gas Regulation 517 / 2014 contains refrigerant leak check and detection system requirements for refrigeration owners / operators.

In essence, Article 4 stipulates that those refrigeration systems with 5 tonnes of CO₂ equivalent (tCO₂e) or more must be checked for refrigerant leaks at certain intervals.

Specifically, these leak checks must be carried out at the following intervals:

Refrigeration Systems with Fluorinated Refrigerant

F-Gas Leak Checking

Tons of CO2 Equivalent	Frequency without ALD	Frequency with ALD
5 = tCO2e < 50	12 Months	24 Months
50 = tCO2e < 500	6 Months	12 Months
tCO2e = 500	3 Months	6 Months

•  Refrigerant in quantities of 5 tCO₂e or more but less than 50 tCO₂e — For equipment that contains fluorinated refrigerant in quantities of 5 tCO₂e or more but less than 50 tCO₂e, a leak check must be conducted at least every 12 months; if a leakage detection system is installed, then at least every 24 months
• Refrigerant in quantities of 50 tCO₂e or more but less than 500 tCO₂e — For equipment that contains fluorinated refrigerant in quantities of 50 tCO₂e or more but less than 500 tCO₂e, a leak check must be conducted at least every six months; if a leakage detection system is installed, at least every 12 months.
• Refrigerant in quantities of 500 tCO₂e or more — For equipment that contains fluorinated refrigerant in quantities of 500 tCO₂e or more, a leak check must be conducted at least every three months; if a leakage detection system is installed, at least every six months.

As you may have noted, the mandated intervals for conducting a refrigerant leak inspection are halved if a permanent leak detection system is installed.

U.S. EPA 608

Similar to the EU’s F-gas regulation, EPA Section 608 has mandated leak inspections as part of its leak repair requirements.

Here’s the leak inspections requirements an appliance has if you exceed the applicable refrigerant leak rate threshold(s):

Commercial Refrigeration and Industrial Process Refrigeration

EPA 608 Leak Inspections

Full Charge of System	Frequency without ALD	Frequency with ALD
50 = lbs < 500	12 Months	May Not Be Required
lbs > 500	3 Months	May Not Be Required

• Full charge is 500 pounds or more — For commercial refrigeration or industrial process refrigeration (IPR) appliances with a full charge of 500 or more pounds, leak inspections must be conducted once every 3 months.
• Full charge is between 50 and 500 pounds — For commercial refrigeration and IPR appliances with a full charge of 50 or more pounds but less than 500 pounds, leak inspections must be conducted once per calendar year.

It’s important to note that such inspections are not required on appliances, or portions of appliances, continuously monitored by an automatic leak detection (ALD) system that is audited or calibrated annually. (Providing an incentive to install an ALD, as seen in the F-gas regulation.)

Now, if a refrigeration system owner/operator is located in California, then one must be aware of California’s refrigerant management program as well.

California’s Refrigerant Management Program (RMP)

The California refrigerant management program has stringent leak detection and monitoring requirements for regulated facilities.

Here’s an overview of the leak inspection requirements for regulated refrigeration systems:

• Refrigerant charge above 50 but under 200 lbs — A leak inspection must be conducted every 12 months.
• Refrigerant charge with 200 or more lbs but less than 2,000 lbs — A leak inspection must be conducted every 3 months.
• Refrigerant charge of 2,000 lbs or more — An automatic leak detection (ALD) system may be required. More details here.

As you may already be aware, these refrigerant regulations are not the only refrigerant-related activities that one should adhere to; there’s also application safety standards.

Gas Detection

Application Safety Standards

Indeed, in Europe, there is the refrigeration safety standard EN (Euro-Norm) 378; and, along similar lines, in the United States, there is ASHRAE 15.

EN 378

Specifically, according to EN 378, systems with a charge of greater than 25 kg refrigerant shall be fitted with a refrigerant detection system in the machinery room, designed to trigger ventilation when concentrations reach 50% of the occupational exposure limit (OEL) or 25% of the lower flammability limit (LFL).

In addition, an alarm must be activated if the potential concentration of leaking refrigerant may exceed the practical limit.

Taking this into account, refrigeration stakeholders in Europe should be readily familiar with the F-gas refrigerant regulations as well as the EN 378 refrigeration safety standard.

ASHRAE 15

Likewise, ASHRAE 15 is the primary standard relating to refrigerant use in the United States. The stated scope of the standard is to establish safeguards for life, limb, health and property and prescribe safety requirements.

Typically, it must be referenced in conjunction with ASHRAE 34-2013, which establishes safety classifications for refrigerants and determines Refrigerant Concentration Limits (RCL) or the threshold at which the gas concentration presents an immediate danger to health.

The provisions outlined by ASHRAE 15 designate safety requirements for personnel who may be in the machinery room where a refrigerant may leak and where the total system charge of refrigerant may exceed the RCL.

Clause 8.11.2.1 states: “Each refrigerating machinery room shall contain a detector, located in an area where refrigerant from a leak will concentrate, that actuates an alarm and mechanical ventilation in accordance with Section 8.11.4 at a value not greater than the corresponding TLV-TWA (or toxicity measure consistent there with). The alarm shall annunciate visual and audible alarms inside the refrigerating machinery room and outside each entrance to the refrigerating machinery room. The alarms required in this section shall be of the manual reset type with the reset located inside the refrigerating machinery room.”

As such, refrigeration stakeholders in the United States should be readily familiar with EPA Section 608 as well as ASHRAE 15.

Refrigerant Detection Enables Compliance

That concludes our overview of the basic requirements for refrigerant detection.

As you can see, requirements vary across regions but such requirements also have notable similarities, and we hope this article made refrigerant compliance simpler for you.

Having said this, if you need further assistance navigating the complex world of refrigerant compliance, you can rely on Bacharach’s range of solutions to make refrigerant compliance simple and effective. ∎

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What refrigerant leak / gas detection requirements do you find most challenging? Let us know in the comments below or by emailing us at news@mybacharach.com.