14.06.2007
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Discussion Document
IMPLEMENTATION OF REGULATION (EC) N° 842/2006 ON CERTAIN FLUORINATED
GREENHOUSE GASES
MINIMUM REQUIREMENTS IN RESPECT OF TRAINING PROGRAMMES AND CERTIFICATION
Recovery of fluorinated greenhouse gases from equipment containing
fluorinated greenhouse gas-based solvents
1.
BACKGROUND
Equipment which contains fluorinated greenhouse gas-based solvents is covered by Article 4(1)
of the Regulation which places the responsibility on operators to put in place arrangements for
the proper recovery by certified personnel of fluorinated greenhouse gases to ensure their
recycling, reclamation or destruction.
Some HFCs, which are included in Annex I of the Regulation (EC) No. 842/2006, have been
used as solvents to replace ODS solvents. Although HFCs do not have the correct solvent
properties for the traditional area covered by HCFC solvents (cleaning /degreasing) they possess
some very specific properties that make them attractive for some specialised small scale
applications such as in the extraction of natural products, in the preservation of rare books etc.
Thus the use of F-gases is believed to be very limited in the EU.
According to Article 5(1) of the Regulation, the Commission shall establish minimum
requirements in respect of training programmes and certification requirements for personnel by 4
July 2007.
In order to prepare this decision, the Commission contracted out a study on "Minimum
qualification requirements for personnel in the EC, involved in the containment and recovery of
fluorinated greenhouse gases (F-gases) and ozone depleting substances (ODS)" (ICF Consulting,
September 2006). The study, amongst other sectors, examined current qualifications in the F-gasbased solvent sector in the EU Member States and recommended EU-wide minimum
qualification requirements and programmes. It should be noted that in a survey conducted within
the context of this study, of the 19 Member States that responded to the survey, three States
reported zero use of F-gases in the solvent sector and, therefore, had no need for minimum
qualification requirements or training programmes and three other Member States indicated only
very limited use of F-gas solvents, which they contended negated the need for minimum
qualifications or programmes. One Member State indicated that they currently have minimum
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requirements in place for personnel handling F-gases in the solvents sector, whereas all other
Member States reported no minimum qualification requirements for personnel working with FGas solvents, although six Member States are in the process of developing such qualifications
and/or are prepared to adopt legislation as appropriate.
2.
LEGAL PROVISIONS
Article 5 (1) requires the Commission to adopt minimum requirements in respect of training
programmes and certification:

“for the personnel involved in the activities provided for in Article 4” (proper recovery
of F-gases to ensure their recycling, reclamation or destruction). This activity has to be
carried out by certified personnel.
In addition,
 Article 5 (1) requires the Commission to set down the conditions for mutual recognition
of minimum requirements
 Article 5 (2) requires Member States to establish or adapt their own training and
certification requirements on the basis of the Community minimum requirements by 4
July 2008. Member States can adopt stricter requirements but shall recognise certificates
issued in other Member States based on EC minimum requirements
 By 4 July 2009, the companies involved in carrying out leakage checking and recovery
shall only take delivery of fluorinated gases where their personnel hold the relevant
certificates. There is no such prohibition for companies involved in installation,
maintenance and servicing.
3.
MINIMUM
CONDITION FOR GRANTING PERSONNEL CERTIFICATION AND CONDITION FOR
MUTUAL RECOGNITION
The minimum condition for granting a certificate to personnel to undertake recovery of
fluorinated greenhouse gases from equipment containing fluorinated greenhouse gas-based
solvents should be the successful completion of a theoretical and practical examination by the
applicant that meets the standards referred to in section 3.2.
This appears to be the only practical way to ensure mutual recognition, as an examination is the
most objective way to check the qualification of a person.
The Member States are competent for organizing the examination system.
The Member States should remain free to maintain or adopt additional criteria (compared to
those mentioned in the first paragraph of this section) for granting certification, such as a
minimum number of hours of training or a minimum number of years of professional experience.
However, these criteria should not be taken into consideration for the mutual recognition of
certificates issued by another Member State. No condition additional to the one specified in
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section 3.1 should be adopted by a Member State to consider valid a certificate granted in
another Member State.
3.1. Conditions for mutual recognition
Each Member State should notify the Commission of the personnel certification programmes, in
accordance with Article 5(2) of Regulation 842/2006. The notification format will be established
by the Commission in accordance with Article 5(5). The Commission should communicate the
documents to all the other Member States.
A Member State shall give recognition to the new certificates issued in other Member States in
accordance with the notified national requirements, provided that the certificate:
 clearly mentions the name of the certification body in a form that enables the authorities
and companies of other Member States to authenticate the certificate, the full name of the
holder, a registration number and the date of expiry if any;
 is dated and signed.
Member States may require holders of certificates issued in another Member State to provide a
certified translation of the certificate in their official language.
3.2. Minimum standards pertaining to the examination upon which certification can be
granted
The examination should comprise one or several theoretical tests and one or several practical
tests where the ability of the applicant to perform the recovery task for which certification is
required will be evaluated.
Member States should ensure that evaluation bodies are objective and ensure that the
examinations meet the minimum requirements as defined in Annex I, which lists the minimum
set of skills that should be tested by the evaluation bodies.
3.3. Personnel certification
Member States should remain free to designate the “certification bodies” which are allowed to
grant personnel certificates according to the national legislation. The certification bodies should
be identified by law or regulation, or designated by competent authorities, or other entities
entitled to do so according to the national legislation.
Member States should remain free to authorise undertakings or establishments engaged in
recovery of fluorinated greenhouse gases from equipment containing fluorinated greenhouse gasbased solvents to organize examinations for their own personnel, evaluate persons and/or grant
certificates to these persons (“in-house certification”). The holders of such certificates should be
allowed to use them if they change employers, start their own business etc.
The companies entitled to perform evaluation and/or certification functions should be authorised
individually by the competent authorities of the MS or any other body entitled to grant such
authorisation according to the national legislation.
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Member States should notify the Commission and all the other Member States of the name and
contact details of each certification body (see section 3.1).
Member States should ensure that certification bodies are objective and ensure that the evaluation
bodies comply with the minimum skills as defined in Annex I.
Certification bodies, including "in-house-certification" schemes, shall retain records so as to:
• Identify the training content;
• Identify those personnel who have been certified for recovery from equipment containing
fluorinated greenhouse gas-based solvents;
• Restrict performance of gas recovery to appropriately trained personnel;
• Sustain a high level of expertise.
4.
TRAINING REQUIREMENTS
Training programmes, sessions and courses should include the content of Annex I.
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Annex I
Minimum set of skills that should be tested by the evaluation bodies
No
Skills
1.
Basic knowledge of relevant environment issues (climate change,
Kyoto Protocol, GWP)
Physical, chemical and environmental characteristics of HFCs used as
solvents
Use of HFCs as solvents
Recovery and purification of fluorinated greenhouse gas-based solvents
Storage and transportation of fluorinated greenhouse gas-based solvents
Operation of recovery equipment for basic applications of fluorinated
greenhouse gas-based solvents
2
3
4
5
6
Checked through
theoretical/
practical tests
Theoretical
Theoretical
Theoretical
Practical
Theoretical
Practical