UCL Estates Facilities & Infrastructure Air Conditioning Energy Inspection (TM 44) Policy EM&I C003 Version 2.0 15th May 2015 UCL Estates Engineering Maintenance & Infrastructure Contents Section Page 1.0 Introduction .............................................................................................................. 4 2.0 Purpose..................................................................................................................... 4 3.0 Scope ........................................................................................................................ 5 4.0 Management responsibilities .................................................................................. 6 4.1 Roles and Responsibilities .................................................................................. 7 4.1.1 UCL Council – Duty Holder ........................................................................... 7 4.1.2 The President and Provost ............................................................................ 7 4.1.3 Senior Management Team ............................................................................. 7 4.1.4 UCL Safety Services ...................................................................................... 7 4.1.5 UCL Director of Estates ................................................................................. 8 4.1.6 Director, Facilities & Infrastructure .............................................................. 8 4.1.7 Head of Engineering – Responsible Person - Air Conditioning and Ventilation Systems and Equipment – Governance ................................................ 8 4.1.8 Responsible Person - Air Conditioning and Ventilation Systems and Equipment – Operation .............................................................................................. 9 4.1.9 Responsible Person - Air Conditioning and Ventilation Systems and Equipment – Review & Change ................................................................................. 9 4.1.10 UCL Estates (Project Managers, University Project Officers and University Service Managers) .................................................................................. 10 4.1.11 Contractors (and managers employing contractors) ............................ 10 4.1.12 Heads of Departments (other than UCL Estates), Responsible Person – Air Conditioning and Ventilation Systems and Equipment – Governance .......... 11 4.1.13 Appointed Person – Statutory Testing .................................................... 12 4.2 Records ............................................................................................................... 12 4.3 Training and competence .................................................................................. 13 4.4 Monitoring & Review .......................................................................................... 14 5.0 References.............................................................................................................. 14 Page 3 of 15 Doc No: EM&I C003 Estates, Maintenance & Infrastructure Owner: Senior Programme and Performance Manager Author: Leon Markwell 12.12 Programmes & Performance\Compliance\Policies and Standards A/C Energy Inspection Policy Version 2.0 15/05/2015 Uncontrolled when printed UCL Estates Engineering Maintenance & Infrastructure 1.0 Introduction The University recognises its statutory obligations under the Energy Performance of Buildings (Certificates and Inspections) (England and Wales) Regulations 2007 to manage its air conditioning and ventilation systems safely and efficiently and to reduce energy consumption so far as is reasonably practicable. It aims to do this by having procedures in place which provide for the safe inspection, testing and maintenance of air conditioning and ventilation systems and equipment to safely reduce energy consumption so far as is reasonably practicable. This policy outlines systems and procedures to comply with the statutory requirement to safely reduce energy consumption, so far as is reasonably practicable, in the universities air conditioning and ventilation plant. For the purposes of this document an “air conditioning system” is defined in the legislation as a system with a cooling capacity of more than 12 kW, taken to mean the specified output under standard test conditions. In the UK the term ‘system’ also includes groups of units that are individually of less than 12 kW cooling capacity but have a combined cooling capacity greater than 12 kW. For regulatory purposes for this standard the cooling capacity of an air conditioning system is defined as ‘the sum of all individual cooling units under the control of one building owner or operator’. The term “air conditioning and ventilation systems and equipment” also includes heat pumps and any other related equipment. Air conditioning inspections are intended to identify ways in which the energy consumption of existing air conditioning systems and associated costs may be reduced. They differ from, for example, detailed energy audits by being essentially non-invasive and from analysis of energy consumption by being site-based. This policy identifies the UCL duty holders and utilises the guidance and methods proposed in the CIBSE Technical Memorandum TM 44 to comply with the statutory requirements. This policy must be read in conjunction with the relevant UCL Standard Operating Procedure. This policy does not cover other air conditioning and ventilation systems health and safety and statutory inspection requirements, such as the requirements for ductwork hygiene and fire safety, legionella control and management and F gas issues, as well as the general health and safety issues regarding persons working on plant and machenary. Other UCL Estates Policies and Standard Operating Procedures must also be consulted to cover these areas. 2.0 Purpose The purpose of this document is to detail the UCL management arrangements to be followed to ensure compliance with its legal duty to have its air conditioning and ventilation systems inspected and covers the following: Roles and responsibilities Records Training Page 4 of 15 Doc No: EM&I C003 Estates, Maintenance & Infrastructure Owner: Senior Programme and Performance Manager Author: Leon Markwell 12.12 Programmes & Performance\Compliance\Policies and Standards A/C Energy Inspection Policy Version 2.0 15/05/2015 Uncontrolled when printed UCL Estates Engineering Maintenance & Infrastructure Monitoring & review 3.0 Scope This document details how UCL will address the issue of the statutory duty to have its air conditioning and ventilation systems regularly inspected by an accredited inspector to identify any possible ways to reduce energy consumption. The University has a duty of care to all Students, Staff and Visitors across its entire Estate and as such, this Policy shall be applicable to all UCL UK buildings, as listed on the UCL Building Register. The only exception to this is with regards to leasehold buildings, where UCL does not hold the maintenance or repair obligations, where these have air conditioning and ventilation systems installed. In such areas the UCL Responsible Person – (Air Conditioning) - shall ensure that the Landlord is carrying out such inspections to the same level of conformity and diligence as detailed in CIBSE Technical Memorandum 44 and in this policy. Page 5 of 15 Doc No: EM&I C003 Estates, Maintenance & Infrastructure Owner: Senior Programme and Performance Manager Author: Leon Markwell 12.12 Programmes & Performance\Compliance\Policies and Standards A/C Energy Inspection Policy Version 2.0 15/05/2015 Uncontrolled when printed UCL Estates Engineering Maintenance & Infrastructure 4.0 Management responsibilities A box of this format denotes a requirement for the role holder to be competent with respect to AC Energy Inspection and relevant to the level of responsibility UCL Council President & Provost Duty Holder Information flow Line Management control & delegation of duty Senior Management Team (SMT) UCL Safety Services support Director of UCL Estates Director, Facilities & Infrastructure Head of Engineering Head of Department Responsible Person Governance Responsible Person Governance AC Energy Inspection AC Energy Inspection Responsible Person Responsible Person Appointed Person Operation Review & Change Maintenance Management Team Leader Team Leader (Mechanical) Administrative Function (Statutory Testing) Responsible Person Landlord Leasehold Buildings Competent Person AC Energy Inspection Service Providers UCL Maintenance Staff or Contractor The Competent Person has the necessary knowledge, training, experience and abilities to carry out the control measures & PPM tasks Page 6 of 15 Doc No: EM&I C003 Competent Person AC Energy Inspection Professional Advisor UCL Maintenance Staff or Contractor The Competent Person has the necessary knowledge, training, experience and abilities to provide such advice to UCL, Contractors, Consultants, Partners & Third Parties Estates, Maintenance & Infrastructure Owner: Senior Programme and Performance Manager Author: Leon Markwell 12.12 Programmes & Performance\Compliance\Policies and Standards Appointed by Department Competent Person AC Energy Inspection Inspectors and/or Installers UCL Staff, Consultant or Contractor Including Capital Projects Consultants & Contractor s The Competent Person has the necessary knowledge, training, experience and abilities to carry out the Design and / or Installation A/C Energy Inspection Policy Version 2.0 15/05/2015 Uncontrolled when printed UCL Estates Engineering Maintenance & Infrastructure 4.1 Roles and Responsibilities The principal responsibilities for the management of health and safety and statutory compliance are stated in the UCL Safety Policy. Specific responsibilities relating to the management and safety of air conditioning and ventilation systems are stated below. 4.1.1 UCL Council – Duty Holder UCL Council, as the employer, has the ultimate responsibility for health and safety and is the duty holder for UCL. UCL Council has delegated the duty of the day-to-day running of UCL, which includes the management of health and safety and statutory compliance to the President and Provost. 4.1.2 The President and Provost The President and Provost is the duty holder responsible to UCL Council for the day-to-day duty holder responsibilities of UCL in all of its activities, including the management and safety of air conditioning and ventilation systems. The role takes overall responsibility to ensure that the policy for the management of air conditioning and ventilation systems is implemented and that appropriate funding is made available to carry out works. The Council has constituted the Health & Safety Committee (HSC) to determine a policy framework for health and safety and statutory compliance and the executive arrangements therein, which includes the management of air conditioning and ventilation systems. 4.1.3 Senior Management Team The SMT are responsible to the Council for the planning, consultation and dissemination of the arrangements made within this policy and shall maintain details of appointees with responsibilities for the management of air conditioning and ventilation systems within RiskNET and the reporting of relevant information to UCL Estates. 4.1.4 UCL Safety Services UCL Safety Services are responsible for the provision of independent competent safety advice and for reviewing departmental organisation and arrangements. Page 7 of 15 Doc No: EM&I C003 Estates, Maintenance & Infrastructure Owner: Senior Programme and Performance Manager Author: Leon Markwell 12.12 Programmes & Performance\Compliance\Policies and Standards A/C Energy Inspection Policy Version 2.0 15/05/2015 Uncontrolled when printed UCL Estates Engineering Maintenance & Infrastructure 4.1.5 UCL Director of Estates The Director of UCL Estates has responsibility for the strategy and budget allocation for the management and statutory compliance of air conditioning and ventilation systems at UCL. The Director of UCL Estates through the Director of Engineering and Faculty Directors is responsible for day-to-day management control of air conditioning and ventilation systems with technical support from Safety Services. 4.1.6 Director, Facilities & Infrastructure The Director, Facilities & Infrastructure is responsible for the allocation of finances and resources for the assets under the Directors control which are subject to statutory requirements for maintenance and inspection. The Director, Facilities & Infrastructure allocates resources to ensure that training and competency is sufficient for the responsible persons to undertake their duty. 4.1.7 Head of Engineering – Responsible Person - Air Conditioning and Ventilation Systems and Equipment – Governance In all instances the term ‘Responsible Person’, and the associated duties, applies equally to any nominated Deputy formally appointed to act on all occasions when the nominated Responsible Person is unavailable. The Head of Engineering has managerial responsibility for the governance of air conditioning and ventilation systems equipment statutory compliance risk and providing supervision for implementation of the precautions through: Managerial responsibility for the UCL Estates Policy and SOP for the management of UCL’s air conditioning and ventilation systems equipment health and safety and compliance risks. Appointing, in writing, ‘Responsible Persons’ to be responsible for the dayto-day management of UCL’s air conditioning and ventilation systems equipment risks and compliance with current statutory legislation and regulations, UCL policy and the UCL Standard Operating Procedure. Ensuring that the Responsible Persons are aware of their roles and responsibilities and that they are competent to carry them out. The full details, expectations and requirements of this role are contained within the UCL Air Conditioning and Ventilation Systems Equipment Standard Operating Procedure (SOP), which is controlled by UCL Engineering, Page 8 of 15 Doc No: EM&I C003 Estates, Maintenance & Infrastructure Owner: Senior Programme and Performance Manager Author: Leon Markwell 12.12 Programmes & Performance\Compliance\Policies and Standards A/C Energy Inspection Policy Version 2.0 15/05/2015 Uncontrolled when printed UCL Estates Engineering Maintenance & Infrastructure Maintenance and Infrastructure. The Standard Operating Procedure forms part of this policy. 4.1.8 Responsible Person - Air Conditioning and Ventilation Systems and Equipment – Operation The Responsible Person – Air Conditioning and Ventilation Systems Equipment - is a duty holder and has been delegated the primary role to act as administrator in the management of air conditioning and ventilation systems equipment in accordance with the UCL policy and standard operating procedure, and has managerial responsibility for supervising the implementation of this policy, the SOP, and the management of the air conditioning and ventilation systems and equipment under the control of UCL Estates. The full details, expectations and requirements of this role are contained within the UCL Air Conditioning and Ventilation Systems Equipment Standard Operating Procedure, which is controlled by UCL Engineering, Maintenance and Infrastructure. The Standard Operating Procedure forms part of this policy. To comply with the statutory requirement the energy consumption inspection of the air conditioning and ventilation systems equipment must be carried out by a trained accredited inspector and the report issued must be registered with the appropriate authority, See the UCL Air Conditioning and Ventilation Systems Equipment Standard Operating Procedure for guidance on these requirements. In leasehold buildings (or areas), where UCL does not hold the maintenance or repair obligations, the UCL ‘Responsible Person – Legionella – Operation’ shall ensure that the Landlord is carrying out such tasks to the same level of conformity and diligence as defined in this policy and standard operating procedure. 4.1.9 Responsible Person - Air Conditioning and Ventilation Systems and Equipment – Review & Change The Responsible Person - Air Conditioning and Ventilation Systems Equipment – Review & Change is a duty holder and has been delegated the managerial responsibility for reviewing the compliance and performance against this standard. The Responsible Person - Air Conditioning and Ventilation Systems Equipment – Review & Change produces and develops the policy and standard operating procedures for the management of air conditioning and ventilation systems equipment risks and statutory compliance on behalf of the Head of Engineering, and periodically audits their implementation. The Responsible Person – Air Conditioning and Ventilation Systems Equipment – Review & Change has also been delegated the managerial responsibility for Page 9 of 15 Doc No: EM&I C003 Estates, Maintenance & Infrastructure Owner: Senior Programme and Performance Manager Author: Leon Markwell 12.12 Programmes & Performance\Compliance\Policies and Standards A/C Energy Inspection Policy Version 2.0 15/05/2015 Uncontrolled when printed UCL Estates Engineering Maintenance & Infrastructure supervising the implementation of this policy into the management of any changes, modifications of or additions to, or replacements of existing systems or equipment, or into any new installations of air conditioning and ventilation systems equipment under the control of UCL Estates. The full details, expectations and requirements of this role are contained within the UCL Air Conditioning and Ventilation Systems Equipment Standard Operating Procedure, which is controlled by UCL Engineering, Maintenance and Infrastructure. The Standard Operating Procedure forms part of this policy. 4.1.10 UCL Estates (Project Managers, University Project Officers and University Service Managers) Relevance to TM 44 works: Project Managers, University Project Officers and the consultants they appoint are responsible for ensuring systems are designed and installed in compliance with the documents contained in the Reference section of this document, and the UCL Standard Operating Procedure. The Responsible Person – Air Conditioning and Ventilation Systems Equipment – Review & Change is to approve each stage of the design and acceptance. The Project Manager and University Project Officers will be responsible for ensuring that plant and services are capable of meeting any increased demand where a system is extended and for the provision of as fitted drawings at the time of handover together with all commissioning data. No system will be accepted unless the Responsible Person – Air Conditioning and Ventilation Systems Equipment – Review & Change has given the final written approval. 4.1.11 Contractors (and managers employing contractors) Those who employ contractors to work on air conditioning and ventilation systems equipment shall be responsible for ensuring the work complies with the requirements of this policy and the associated Standard Operating Procedure and that the works comply with relevant statutory legislation and regulations, and that the requirements of CIBSE and HVCA (B&ES) standards and relevant HSE guidance are applied so far as is reasonably practicable. Reasonable enquiries are to be made to confirm the competency and training of contractors and their staff in the proposed types of work, before entering into contracts for the installation of new air conditioning and ventilation systems equipment or the replacement, repair maintenance or inspection and testing of existing systems and equipment. To comply with the statutory requirement the energy consumption inspection of the air conditioning and ventilation systems equipment must be carried out by a Page 10 of 15 Doc No: EM&I C003 Estates, Maintenance & Infrastructure Owner: Senior Programme and Performance Manager Author: Leon Markwell 12.12 Programmes & Performance\Compliance\Policies and Standards A/C Energy Inspection Policy Version 2.0 15/05/2015 Uncontrolled when printed UCL Estates Engineering Maintenance & Infrastructure trained accredited inspector. See the UCL Air Conditioning and Ventilation Systems Equipment Standard Operating Procedure for guidance on this requirement. Contractors are to be made fully aware of the duties and responsibilities assigned to them, and are to be familiar with the UCL Standards. Only UCL Approved Contractors are permitted to work on UCL air conditioning and ventilation systems and equipment. Contractors are to have completed the necessary UCL Safety Questionnaires and that their responses have been accepted. http://www.ucl.ac.uk/estates/procedures/new-project-management/forms/ Contractors are to comply with the UCL Safety Policy ‘Safety Rules for Contractors employed on UCL Premises’, and sign the document accordingly. 4.1.12 Heads of Departments (other than UCL Estates), Responsible Person – Air Conditioning and Ventilation Systems and Equipment – Governance Relevance to TM 44 Heads of Departments are responsible for identifying, assessing and controlling the risks from air conditioning and ventilation systems equipment installed within their department, and/or departmental equipment. In addition, subject to agreement by the Responsible Person (Operation), UCL Estates may also be responsible for certain identified items of department equipment, upon acknowledged receipt of a UCL Estates Data Collection Sheet (Asset Register request). Where departmental equipment is not managed by Estates, a local inventory of both specific items and types of equipment should be maintained by the Appointed Person (Statutory Testing) to ensure that all equipment is assessed and subject to appropriate controls and statutory inspections. Departments are responsible for reporting to the Facilities Customer Services Help Desk when any permanent or temporary installations (ie Experimental Rigs) are installed that may give rise to danger, or when there is any change of use of any existing air conditioning and ventilation systems equipment (eg the change of use of a room from a store to an office) or any system or equipment is taken out of use or disposed of. The UCL Estates Responsible Person (Operation) will be responsible for arranging the isolation and removal of air conditioning and ventilation systems equipment within any areas that are no longer required. Page 11 of 15 Doc No: EM&I C003 Estates, Maintenance & Infrastructure Owner: Senior Programme and Performance Manager Author: Leon Markwell 12.12 Programmes & Performance\Compliance\Policies and Standards A/C Energy Inspection Policy Version 2.0 15/05/2015 Uncontrolled when printed UCL Estates Engineering Maintenance & Infrastructure The identification and management of air conditioning and ventilation systems equipment within common areas e.g. entrance areas, toilets will remain the responsibility of UCL Estates Facilities & Infrastructure department. UCL Estates will be responsible for amending the schematic drawings and any other records as appropriate. 4.1.13 Appointed Person – Statutory Testing There are no specific statutory or regulatory time periods set for the inspection of air conditioning and ventilation systems or equipment, only that the initial inspection is carried out by a specified date, and further inspections are carried out within specified maximum periods. Written reports are to be provided. There are minimum requirements given in the legislation and accepted guidance as what the inspection and report should cover. See the UCL Air Conditioning and Ventilation Systems Equipment Standard Operating Procedure for guidance on this inspection. CIBSE Technical Memorandum TM 44 is based on the proposals given in BS EN 15240: 2007 and provides guidance on the minimum requirements for the accredited inspectors’ qualifications depending on the system construction and components, along with requirements for energy consumption statutory inspections. Applying the TM 44 guidance along with the application of equipment manufacturers’ guidance should provide statutory energy consumption inspection compliance, but it is for a competent person to assess and decide on any requirements for overall energy consumption and other relevant air conditioning system statutory compliances that may be required, along with any necessary health and safety provisions to prevent danger during the inspection and any works, and in some cases more than the minimum requirements may be necessary. It must be noted however that the statutory inspection assessment advice provided by a report complying with the Energy Performance of Buildings (Certificates and Inspections) (England and Wales) Regulations 2007 is only proposed for general plant efficiency and energy saving and further air conditioning and ventilation systems equipment maintenance may also be found to be necessary. 4.2 Records Reports must be uploaded to the statutory authority as required by The Energy Performance of Buildings (Certificates and Inspections) (England and Wales) (Amendment) Regulations 2011 and site records must be kept to confirm compliance with the statutory regulations and the requirements of this standard, and retained for the periods stated. Page 12 of 15 Doc No: EM&I C003 Estates, Maintenance & Infrastructure Owner: Senior Programme and Performance Manager Author: Leon Markwell 12.12 Programmes & Performance\Compliance\Policies and Standards A/C Energy Inspection Policy Version 2.0 15/05/2015 Uncontrolled when printed UCL Estates Engineering Maintenance & Infrastructure Job specific H&S risk assessments and method statements must be completed to conform to statutory requirements for both access to, and inspection of, the system and equipment and for any maintenance, inspection or testing works upon it. The documents will categorise the level of risk of the building the systems and equipment and the appropriate management control necessary for the risks in that building. The person responsible for conducting the air conditioning and ventilation systems must be a trained accredited inspector and the details of this person must be recorded. The person or persons responsible for conducting the air conditioning and ventilation systems and equipment management must have sufficient information and documentation available to comply with the requirements of CIBSE TM 44 guidance as a minimum. Any significant findings and action points of the inspection must be prioritised and actioned accordingly as required. These records must be retained throughout the period for which they remain current and for at least two years after that period. The results of any monitoring, inspection, test or check carried out, and the dates should include details of the state of operation of the system i.e. in use / not in use. All maintenance, inspections and testing must be recorded on the appropriate forms and the data should be reviewed periodically to assess trends. 4.3 Training and competence (See also UCL Authorisation of Technical Competence) Formal air conditioning and ventilation systems and equipment energy inspections for compliance with the Energy Performance of Buildings (Certificates and Inspections) (England and Wales) Regulations 2007 are to be carried out by formally accredited inspectors or assessors, properly trained and accredited by a recognised third party organisation. The inspector or assessor can be an independent contractor or a member of the UCL staff as long as he has been properly trained and accredited. AC energy awareness training will be provided at 3 levels to suit the different roles of staff: Management – as required for supervision Technical/maintenance staff – for maintenance, repairs or inspection and testing as required. Operator/user training - as required to implement energy conservation guidance as required Page 13 of 15 Doc No: EM&I C003 Estates, Maintenance & Infrastructure Owner: Senior Programme and Performance Manager Author: Leon Markwell 12.12 Programmes & Performance\Compliance\Policies and Standards A/C Energy Inspection Policy Version 2.0 15/05/2015 Uncontrolled when printed UCL Estates Engineering Maintenance & Infrastructure The training for technical/maintenance staff shall ensure that they are aware of the correct operation of the system or equipment and its maintenance requirements. Records of training and competence shall be maintained on a UCL records system file. Training records/evidence of competence must be provided by contractors. All training must be recorded and records must be retained throughout the period for which they remain current and for at least two years after that period. Records of training and competence shall be maintained on a UCL records system file. 4.4 Monitoring & Review The Estates Standard Operating Procedure(s) and Risk Assessments detail the procedures for preventing, monitoring and controlling risk. These documents along with this standard shall be annually reviewed to ensure they remain up to date. 5.0 References Health & Safety at Work etc. Act 1974. Management of Health and Safety at Work Regulations 1999. The Energy Performance of Buildings (Certificates and Inspections) (England and Wales) Regulations 2007 (SI 2007/991). The Energy Performance of Buildings (Certificates and Inspections) (England and Wales) (Amendment) Regulations 2011(A1.2) introduce the requirement for the statutory lodgement of air conditioning inspection reports in England and Wales. The Pressure Systems Safety Regulations 2000 may apply to systems with an input power in excess of 25 kW (SI 2000/128). Control of Substances Hazardous to Health Regulations 2002 (COSHH). BS EN 15240: 2007: Ventilation for buildings. Energy performance of buildings. Guidelines for inspection of air-conditioning systems. BS EN 15780:2011 ‘Ventilation for Buildings - Ductwork - Cleanliness of Ventilation Systems’. HSE Five Steps to Risk Assessment (INDG163) 2011. UCL Design Brief for Mechanical, Electrical & Vertical Transport Services. Page 14 of 15 Doc No: EM&I C003 Estates, Maintenance & Infrastructure Owner: Senior Programme and Performance Manager Author: Leon Markwell 12.12 Programmes & Performance\Compliance\Policies and Standards A/C Energy Inspection Policy Version 2.0 15/05/2015 Uncontrolled when printed UCL Estates Engineering Maintenance & Infrastructure CIBSE Technical Memorandum TM44. CIBSE Guide M on Maintenance. Safety Services References Author(s) HSC Approval First Published Next Review Version Page 15 of 15 Doc No: EM&I C003 Estates, Maintenance & Infrastructure Owner: Senior Programme and Performance Manager Author: Leon Markwell 12.12 Programmes & Performance\Compliance\Policies and Standards A/C Energy Inspection Policy Version 2.0 15/05/2015 Uncontrolled when printed