Guide
F gas duties on a commercial heat pump: what the owner carries
Updated
Most of the F gas conversation happens between installers. The duties, and the penalties, land on whoever operates the equipment.
You are responsible for leak checks
gov.uk lists stationary heat pumps among the equipment whose user is responsible for getting it checked for F gas leaks, alongside stationary refrigeration, air conditioning, fire protection equipment, refrigeration units on refrigerated trucks and trailers, electrical switchgear and organic Rankine cycles. It adds that where equipment is rented, responsibility can fall on the owner rather than the end user depending on the rental agreement (gov.uk).
How often
Frequency depends on the amount of F gas and its global warming potential, expressed as tonnes of carbon dioxide equivalent:
| Frequency of leak checks | CO2 equivalent the equipment contains |
|---|---|
| At least once every 12 months | 5 to less than 50 tonnes |
| At least once every 6 months | 50 to less than 500 tonnes |
| At least every 3 months | 500 tonnes or more, for electrical switchgear and organic Rankine cycles installed before 1 January 2017 |
| With automatic leak detection | 500 tonnes or more, all other equipment |
gov.uk adds two useful reliefs: hermetically sealed refrigeration and air conditioning systems have no maximum period between checks unless they contain F gas equivalent to 10 tonnes of carbon dioxide, and fitting automatic leak detection doubles the permitted interval, so equipment at 5 tonnes CO2 equivalent moves from annual to every 2 years.
Who is allowed to touch it
- Company certification. A company, including a sole trader, must be certified by an approved body to service stationary equipment containing F gas operated by others. A company servicing only its own equipment does not need certification: gov.uk's own example is a supermarket employing someone to service its own refrigeration.
- Personal qualifications. "You must have your own qualifications to work on equipment containing F gas, even if you work for someone else. It is against the law to work with F gas if you do not have the correct qualifications." Category 1 covers all activities; category 2 is limited by charge size.
- Penalties. Working without the right certification or qualifications can attract a civil penalty under the Environment Agency's enforcement sanctions policy.
What to put in the maintenance contract
Ask for the refrigerant type and charge in kilograms and in tonnes of CO2 equivalent at handover, the resulting check interval, who holds the record, and confirmation that the servicing company holds current certification. Ask too what happens at end of life: recovery of refrigerant is a regulated activity in its own right, and it belongs in the whole-life cost of the plant rather than as a surprise fifteen years out.
The refrigerant charge should be in the quote. If it is not, that is a fair question to ask before you compare prices.