Laws And Regulations: Notes

The effects of climate change can be seen worldwide. Protecting the climate is one of the most important responsibilities. However, this responsibility presents enormous challenges to all involved.

The Kyoto Protocol outlines worldwide goals regarding climate protection, among other things. In addition to target reductions of carbon dioxide, this protocol also outlines target reductions for fluorinated greenhouse gases such as refrigerant R134a due to their high potential of contributing to the greenhouse effect.

Numerous laws have been created for the automotive industry, for example at the European level. For example, chemical-climate protection regulations were put into effect on 08/01/2008 in Germany in order to define the European legislation in more detail.

• Provision (EU) number 1005/2009
• Provision (EU) number 2037/2000
• Provision (EU) number 517/2014
• Provision (EU) number 706/2007
• Provision (EU) number 307/2008
• Guideline 2006/40/EU
• Chemical-climate protection regulations, laws on life-cycle management

Maintenance and Repair Work on the A/C System Refrigerant Circuit 

All individuals performing maintenance and repair work on vehicle A/C systems must have completed a training program and be competent in the work required. Other regulations may apply in addition to those of the European Union.

The Following General Information Applies:

Operation, repair, decommissioning, take-back obligation 

• When operating, repairing and decommissioning items that contain refrigerant, allowing the refrigerant to vent into the air is prohibited.
• It is therefore recommended to keep a record of the quantities used during operation and maintenance, so they can be presented to the authorities upon request. A record sheet no longer needs to be kept in the EU due to a provision by the European Parliament in 2005. Other provisions may apply in countries that are not members of the EU.
• Distributors of the substances and preparations discussed above are obligated to accept these items back after use or to ensure they are accepted by a third party of their choosing.
• Maintenance and decommissioning of items containing refrigerant that are named in the legislation Substances and preparations named in this legislation may only be accepted by those with the necessary expertise and technical equipment.

Criminal offenses and infringements of the law 

• Infringement of the law in regard to the regulations and laws mentioned above. Willfully or negligently venting refrigerant into the air when operating, repairing or decommissioning items that contain refrigerant constitutes a violation of the laws and legislation described above.

Observe the different technical regulations for handling and filling compressed gases in other compressed-gas canisters (for example TRGS 400, TRGS 402, TRGS 407, TRGS 510, TRGS 725, TRBS 3145).

• TRGS 400 (hazard assessment for activities with hazardous substances).
• TRGS 402 (determining and evaluating the danger of activities with hazardous substances: exposure through inhalation).
• TRGS 407 (activities with gases - hazard assessment).
• TRGS 510 (storage of hazardous substances in transportable tanks).
• TRBS 3145 / TRGS 725 (transportable tanks - filling, keeping ready, internal transportation, emptying).

Observe the different technical regulations for handling and filling compressed gases in other compressed-gas canisters (for example TRGS 400, TRGS 402, TRGS 407, TRGS 510, TRGS 725, TRBS 3145).

• General provisions for charging systems.
• Definition of terms and explanatory note.
• Build and operation of charging systems.

Charging systems

• Does not apply to vehicle manufacturers or workshops.
• Charging systems are systems for filling mobile compressed-gas canisters. The charging system includes the premises and facilities concerned.
• Charging systems requiring a permit are ones used to transfer compressed gases to mobile compressed-gas canisters for supplying to third parties.
• Charging systems not requiring a permit are ones used for transferring compressed gases to mobile compressed-gas canisters for internal use only.

Employees and employee instruction

Employees are to be given instruction on the following topics before beginning work and at regular, appropriate intervals, however at least once a year:

• Hazards specifically associated with handling compressed gases
• The safety regulations, especially the applicable TRGS and TRBS.
• Procedures in the event of malfunction, damage and accidents
• The use of fire-extinguishing and protective equipment
• Operation and maintenance of the charging system according to the operating instructions.

Charging systems are only to be operated and maintained by personnel

• who are 18 years of age and older,
• who possess the necessary technical knowledge
• who can be relied upon to work diligently.

Filling of pressure canisters (separate technical regulations apply to canisters from other countries and their charging, that are not mentioned here).

• A compressed-gas canister may only be filled with the compressed gas declared on it and the quantity must comply with the stipulated pressure, weight or volume data (refer to pressure canister regulations).
• In the case of canisters approved for use with several types of compressed gas, the compressed gas with which it is to be filled and - if the compressed gas has a tc ≥ -10 °C (tc = critical temperature) - the maximum permissible charging weight in line with TRGS must be marked on the canister prior to connection for filling.
• Compressed-gas canisters marked with the maximum permissible charge pressure in bar at 15 °C (59 °F) must be filled manometrically. If the temperature is not 15 °C (59 °F) at the time of filling, the pressure corresponding to the differing temperature must be established; it must be ensured that the permissible charge pressure at 15 °C (59 °F) is not exceeded in the compressed-gas canister. The charged canisters are to be checked by way of random pressure measurements to determine possible overfilling.
• Compressed-gas canisters on which the maximum permissible capacity is indicated by the net weight (filling weight, permissible weight of fill) in kilograms must be filled gravimetrically. The canisters are to be weighed during filling and subsequently subjected to a weight check on special scales to check for possible overfilling. Scales used for this purpose must be calibrated.
• Under certain conditions, gases with a tc greater than or equal to +70 °C (158 °F) may be transferred volumetrically from compressed-gas canisters with a maximum volume of 150 L to compressed-gas canisters with a volume of maximum 1000 ccm. The TRGS conditions apply to the transfer of liquefied gas to cylinders used by workmen.
• Different TRGS apply to reservoirs in vehicles:

-- For gas with tc greater than or equal to +70 °C (158 °F).

-- For industrial gas with tc greater than or equal to +70 °C (158 °F).

-- Liquefied extremely low-temperature compressed gases may, contrary to item 4, be filled volumetrically if the charging system and/or the canisters is/are equipped with devices for measuring or limiting the volume of the charge and - with the exception of motor vehicle canisters as per item 3 - for measuring the temperature of the charge. When filling volumetrically, the permissible charge weight indicated on the canister must not be exceeded. To determine possible overfilling, the filled containers are to be checked gravimetrically on a calibrated scale or - provided that the pressurized gases are not highly toxic - volumetrically. Volumetric checking requires the use of appropriate equipment with completely separate charging and checking devices.

• Charging and check measurements are to be performed by different people. Check measurements must be performed immediately upon completion of the filling process.
• Overfilled canisters must be discharged immediately and in a safe manner until the permissible fill is attained. The compressed-gas fill is then to be determined again.
• Specific TRGS 407 parts do not or only partially apply to canisters for liquefied, extremely low-temperature compressed gases which are neither flammable nor toxic; this does not affect the provisions of road traffic legislation.
• When filling compressed gas canisters with liquefied gases at charging temperatures ≤ -20 °C (68 °F), the compressed gas canister (if the canister material has not been tested for temperatures ≤ -20 °C (68 °F)) is not to be released from the charging system for transport until the canister wall temperature is ≥ +20 °C (68 °F).