22 May 2017

Renewed Call to Ban Disposable Refrigerant Cylinders in SA

Following the banning of HFCs in disposable cylinders in the EU, Australia, India and Canada, A-Gas has renewed its call for disposable cylinders to be banned in the South African market.

The company submitted an official report to the Department of Environmental Affairs (DEA) in August 2015, entitled ‘Disposable Cylinders – it’s Time to Ban them’. These are specifically-manufactured ‘one-way’ containers charged with refrigerant, sold, used for servicing or commissioning equipment, and then discarded.

As these are pressure vessels, they must be cut or punctured before entering the waste stream. This results in the residual quantity of refrigerant, or ‘heel’, being emitted to the atmosphere. Where this procedure is not followed, the ‘heel’ remains until the container degrades, at which point the residual refrigerant is released.

The A-Gas report argues that ‘regulations and enforcement thereof are justified and required for matters of environmental and safety concern, and to ensure a level commercial playing field for all participants’.

Ozone depleting substances
The report sets out to quantify how much Ozone depleting substances (ODS) are being emitted unnecessarily into the atmosphere, to assess the landfill impact and to review related issues such as safety and illegal trade implications.

Despite clear guidelines on packaging and disposable cylinders, end users are circumventing the one-way valve and refilling them, which is not only illegal, but extremely dangerous. In many instances, this involves bypassing an integral safety device built into the disposable cylinder itself to prevent overpressure. This can result in explosions if the safe operating conditions are exceeded.

The A-Gas report reveals that an estimated 225 000 disposable cylinders are sold in South Africa every year, of 70% are thought to be filled with R22. Assuming a residue of 400g per cylinder, this equates to an estimated 63 tonnes of emissions into the environment a year. In some instances, the heel could be as high as 5% of the contents, which is 680g per cylinder, which equates to 107mt of ODS emitted into the atmosphere each year, together with 3 150m3 of waste going to landfill.

HCFC phase-out
‘This practice is clearly contrary to the primary objective of the Montreal Protocol and HCFC phase-out, which is to reduce emissions and thereby protect the ozone layer,’ the report highlights. It adds that the cost of remedying the pollution and subsequent environmental degradation ‘is not paid for by those responsible for discarding these cylinders,’ which is clearly not compliant with the National Environmental Management Act (NEMA) of 1998.

An added problem is that, with the phasedown of HCFCs, industry is introducing HFCs that, in many instances, have a higher Global Warming Potential (GWP) than R22 itself. If these are distributed via disposable cylinders, the negative environmental impact is even greater.

In South Africa, SANS 10019 states that disposable cylinders must conform to minimum design criteria such as DOT 39, the minimum standard for non-refillable cylinders in the US. However, many end users remain ignorant of such requirements, and hence do not comply. In addition, SABS 10147 declares that all necessary precautions must be taken to prevent discharge of refrigerants into the atmosphere.

Illegal trade in R12
Another problem facing the country is a replay of the increase of illegal trade in R12 when CFCs were banned. ‘There is a valid concern that this illegal trade may spiral again as soon as the phasedown of HCFCs tightens, and demand for HCFCs exceeds the maximum quantities allowed to be supplied under a country’s Montreal Protocol obligations,’ the A-Gas report cautions.

As HCFCs and HFCs are being phased out, some of the replacement products are flammable, which raises safety concerns for disposable cylinders, in particular. Incorrect labelling (such as declaring R600a or butane to be ‘non-flammable’), incorrect packaging, and even counterfeit product (such as a dangerous R22/R134a/R40 mixture), are also prevalent.

Another issue, according to A-Gas South Africa national sales manager Michael Labacher, is that “basically some importers in industry have been importing flammable gases in disposable cylinders, which is actually illegal.” Here the standard disposable cylinder with a 13ℓ capacity is used, when SANS 10229-1: 2010 states explicitly that ‘non-refillable receptacles shall … be of water capacity less than, or equal to, 1.25ℓ when filled with flammable or toxic gas.’

This clause is derived directly from ADR P200, the European Union standard, and is referenced in other SANS codes, as well as the Road Traffic Act. “In my opinion, you therefore cannot use the standard disposable cylinder of about 13ℓ for flammable gases,” Labacher stresses.

Call to ban disposable cylinders
The A-Gas report recommends to the DEA that the ban on disposable cylinders be introduced in two tranches: firstly, on imports, allowing for a 12-month period for existing stock to be depleted, followed by a ban on usage. This will ensure that no importer is left with stock that can’t be sold to the end user.

‘In so doing, government will be adopting an alternative distribution method that is a sustainable practice, compliant with existing regulations and codes of practice. At the same time, will substantially reduce the risk of illegal trade in ODS and counterfeit product. The usage ban will also make it substantially easier for government to police,’ the A-Gas report emphasises.

The banning of disposable cylinders will have a positive impact on product integrity, as most returnable cylinders are fitted with Refill Protection Devices (RPD) to prevent end users filling cylinders illegally with product that may be contaminated or out of specification.

“A-Gas has always promoted sustainable packaging such as environment-friendly returnable cylinders,” Labacher cites. For example, the company introduced returnable 12ℓ cylinders to the South African market a decade ago. “We have always been able to offer our customers a ‘green’ alternative over disposable cylinders. This is part of our policy to promote sustainable, safe and environmentally-sound practices,” he concludes.

As seen in HVAC&R Online