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IRI June 27, 2011 0 Comments

In line with their commitment to step up enforcement of the Fgas Regulations, the EPA has once again tendered for an “Enforcement Support Contract – ODS and FGas”. This follows similar tenders in 2009 and 2010 that were awarded to Enviros and URS respectively.

According to the tender document, which is available on the etenders website, “…as part of its enforcement responsibilities under the ODS and F-gas Regulations, the EPA carries out, or arranges to have carried out on its behalf, inspections at end-user premises, as well as inspections of contractors handling ODS and f-gases. In order to broaden the extent and reach of these inspections and intelligence gathering work, assistance is being sought through an Enforcement Support Contract for ODS and F-gases. “

The tender document provides an interesting insight into the EPA’s plans for inspection of RAC end-users:

a) Inspections at end-user premises –

the Contractor [inspector] will be required to organise, schedule and carry out a total 30 inspections at end-user premises to gather intelligence and to determine compliance with the ODS and F-gas Regulations as follows:

  • 10 end-users in the Retail sector;
  • 10 end-users in the Hospitality & Leisure sector;
  • 5 end-users in the Industry sector;
  • 5 end-users in the Offices & Public Buildings sector.

The scope of the inspections at end-user premises will include the following as a minimum:

  • Compliance with leak checking requirements;
  • Examination of practices relating to waste refrigerant gases; and,
  • Certification of companies and personnel used.

The document also includes a “Sample Inspection Report Format for End User Premises” (see Appendix 7). This sets out in great detail the type of questions that must be addressed during the opening meeting, site tour and closing meeting as well as the documentation that must be supplied by the end-user.

In terms of what an RAC contractor might expect from the next round of enforcement activity, the tender document has this to say:

b) Inspections of contractors –

the Contractor [inspector] will be required to organise, schedule and carry out a total of 30 inspections at contractor premises to gather intelligence and to determine compliance with the ODS and F-gas Regulations and waste legislation as follows:

  • 15 Refrigeration and Air Conditioning contractors (RAC);
  • 5 Heat pump contractors;
  • 5 Fire protection contractors; and,
  • 5 Companies servicing/dismantling Mobile Air Conditioning systems.

The scope of the inspections at contractor premises will include the following as a minimum:

  • Examination of the refrigerant gas types, and their sources, in use by the contractor;
  • Examination of documentation to demonstrate minimum qualifications of personnel and company certification;
  • Examination of practices relating to waste refrigerant gases; and,
  • Examination of documentation relating to waste refrigerant gases, including Prior Annual Notification to the EPA, TFS records where applicable.

The tender states that “the planned inspections should be regionally representative” and that tenderers “should specifically and explicitly address health and safety considerations in their response.”

The timeframe for completion of the contract is four months from the date of the award of the contract. The deadline for submission of tenders is, appropriately enough, 4th July 2011.

See www.etenders.ie for more details.