ABN: 93160514616  PO Box 2006, Research, Victoria 3095 Phone: 0400 180 998
E-Mail: Criag.Fox@rresa.com.au Web: www.rresa.com.au
RTA:
AU30472
Destruction of waste ozone depleting
substances and synthetic greenhouse
gases program consultation paper.
Having read the destruction of waste ozone depleting substances and synthetic
greenhouse gases consultation paper and attending the relevant meeting, I found the
issues under consultation are really based upon the extended pricing for the demolition or
destruction of refrigerants.
If we look at all the relevant changes they are based on increasing the rebate/pricing at
the top end. I work at the coalface of the industry in which my company recovers
refrigerant on behalf of companies. These companies engage us as they see the
recovery/reclaim of refrigerants as economically unviable for their own refrigeration
company or companies (not related to the refrigeration industry such as demolition
companies) that must recover/reclaim refrigerants due to the fact that they must do so
under the relevant legislation.
In my position I see very little of the money flowing down to the end user. I currently
receive three dollars ($ 3.00) for the recovered refrigerant. Where is the rest of the
money? Is it with R.R.A, transport, wholesalers and others in the queue?
I believe the money/investment should be put into organizations such as Arctick to carry
out better education programs and alternative enforcement and licensing. Enforcement
processes can be put in place so that individuals or companies who are currently purging
(refrigerants) ozone depleting substances to the atmosphere can be suitably punished, as
it currently stands the only people who are scrutinized are the one’s who are abiding by
the legislation.
If you don’t have a refrigerant trading license you can’t be found.
The fact that a company or person can do a two day course to learn how to recover
refrigerants is misleading and in no way can the person be competent to perform this
type of procedure.
I believe only fully qualified Refrigeration Technicians should be allowed to recover
ozone-depleting substance as the training we receive is intensive and many hours of
study is undertaken to preform this task correctly.
Plumber & Electricians who hold a Cert 2 or split course qualifications ARE currently
performing recoveries on system well outside their limited abilities and the legislation,
consequently are losing many kilos of ozone depleting substances to the atmosphere
each year. (If they are recovering/reclaiming the refrigerant at all)
ABN: 93160514616  PO Box 2006, Research, Victoria 3095 Phone: 0400 180 998
E-Mail: Criag.Fox@rresa.com.au Web: www.rresa.com.au
RTA:
AU30472
Tightening up this loophole and legislating that ONLY Cert 3 qualified Refrigeration
Technicians be able to recover/reclaim ozone depleting substances would clear up the
current confusion and in the process more ozone depleting gases would be captured.
Having properly trained recovery technicians would go some of the way to insure
refrigerant sent back for destruction was labeled and branded correctly and if there are
systems that have refrigerant cocktails in them the recovered refrigerant could be suitably
labeled so as not to cause accidents down the line.
With the recovery company keeping suitable records this would go a long way to ensuring
that the bulk of the recovered ozone depleting substances would be captured correctly
and either disposed of or in the future recycled.
I also have situations with local government not recovering ozone depleting substances
from refrigeration systems that are taken to transfer stations or to landfill site’s due to the
fact and l Quote “it will cost us money”.
As in Japan, legislation needs to be brought in to make all “end- of- life” Refrigeration &
Air conditioning systems have mandatory reports kept on all the systems that are being
demolished or destroyed.
We currently provide this service to our customers at the moment, but many of the
companies do it due to the fact they are trying to promote their companies as green, but it
is a hard slog uphill when the company down the road simply lets the Ozone depleting
substance escape into the atmosphere.
There is currently little to no recycling happening within the industry (regardless of what
you are being told) at this stage partly due to the fact there in no way to make sure the
refrigerant is without any contaminants in it. With a recycling process in place it would
help companies understand the advantages that this would bring in prolonging the used
by dates for some systems that are incompatible with the new refrigerants and very
expensive to retrofit.
The change over to hydrocarbons is the case in point as yet there is NO legislation in
place to address all the issues this refrigerant has bought up so the industry are very
reluctant to use it and customers are saying they are unable to insure the systems with
hydrocarbons in them. Again only fully qualified Refrigeration Technicians should be
able to perform retrofits on all Refrigeration & Air conditioning plants and systems.
I believe that the proposed reclamation rates increase will have little to no effect on the
quantity of ozone depleting substances captured and sent back for destruction. Again the
bulk of the money will simply stay with the top end of the process.
ABN: 93160514616  PO Box 2006, Research, Victoria 3095 Phone: 0400 180 998
E-Mail: Criag.Fox@rresa.com.au Web: www.rresa.com.au
RTA:
AU30472
Obviously much more work and more relevant information is needed to provide adequate
process where the bulk amounts of ozone deleting substances are being captured at the
coal face or front end.
The companies that are legally reclaiming refrigerant should be targeted with this
investment as a way of reducing the amount of ozone depleting substances that are
released into the atmosphere.
If l can be of any further assistance or you have any question please call on the number
below.
Craig Fox
Managing Director
M: 0400 180 998