Hydrochlorofluorocarbons Phase-out Management Plan (HPMP) Roadshow
The South African Constitution provides a legal foundation for government to undertake all the necessary efforts to ensure that the environment is safe and clean for all. Furthermore, Chapter 5 of the South African National Development Plan (NDP) which has targets to be achieved by the year 2030, is dedicated to Environmental Sustainability which can be achieved through protecting & enhancing our environmental assets and natural resources. South Africa is the most industrialised country within the African continent as a whole, and is also home to some of the continent’s advanced industries such as the automotive, mining, food distribution, leisure and hospitality, whereby the refrigeration and air conditioning sector are crucial for the success of these industries.
The government in collaboration with industry has taken strides towards carrying out the obligations of the Montreal Protocol on Ozone Depleting Substances, subsequently undertook the milestones in the South African HPMP signed on 11 September 2012 and provisions in the Regulations Regarding the Phasing-out and Management of Ozone Depleting Substances, 8 May 2014. These among others have been done in order to preserve the environment (i.e. ozone layer) and human health. In addition the government has placed other control mechanisms in order to curb illegal trade of the controlled substances.
However these efforts and other initiatives are unknown to various refrigeration and air-conditioning sectors of industry. This challenge was brought to the attention of our quarterly Stakeholder (both industry and government) Consultation meetings in the DEA. Among others but not limited to, the following concerns were raised;
- Does one need a permit to import HFCs (e.g. R-134A, R-404A etc)?
- Alternative technology certainty of HFCs in South Africa?
- Has the government phased-down HFCs (e.g. R-404A etc) already?
- What are the restrictions on HFCs?
- Whom can one contact for compliance monitoring issues?
- Refrigerant application process (e.g. R-22, R-404A, R-290 etc)
- May one still import HCFC (e.g. R-22) pre-charged equipments?
- What are the annual reporting requirements and time-frames?
- Has South Africa ratified the Kigali Amendment?
- Do we have an HFC legislation already?
- How far is the Amendment of Regulations Regarding the Phasing-out and Management of Ozone Depleting Substances, 8 May 2014?
- What is government doing concerning RAC Informal Service Technicians?
The Roadshow intends to create a platform do deliberate on these issues and enable information sessions for updating on progress made and new work or initiatives on the horizon.
- To raise awareness on the implementation of the Montreal Protocol on Ozone Depleting Substances and the Kigali Amendment/Agreement on global warming substances (i.e. HFCs such as among others R-404A)
- Looming legislation on the horizon
- Informing industry role players on South Africa’s progress in HCFC Phase-out Management Plan (HPMP), milestones reached
- To create an opportunity for stakeholders (industry and government) to come together share information, knowledge, experiences and mitigating solutions to potential challenges.
- New legislation including control on HCFC import and usage, as well as new HFC legislation in the horizon for the next years.
- To present alternative non-ODS technologies available in the market including discussions on the viable use of “traditional” refrigerants such as ammonia
- To engage stakeholders on challenges and economic viability of refrigerant recovery, recycling and reclamation.
- Highlight case studies in other Article 5 and/or non-article 5 countries and to afford opportunity for knowledge transfer and mitigating solutions for likely challenges (e.g. refrigerant leaks)
- To facilitate discussions with stakeholders and government with an aim of creating government and industry link and interaction for further cooperation in the future.
- To bridge the knowledge gap and to encourage a dialogue between Industry, technical experts, government, academia and other related Stakeholders
- To engage stakeholders on safe handling of refrigerants and to communicate DEA’s intensions to register RAC informal servicing technicians.
- To commemorate the 30th anniversary of the Montreal Protocol.
The HPMP Roadshow aims to strengthen collaboration among other government departments, academia and industry role players towards a successful implementation of the Montreal Protocol obligations. A couple of years ago the focus was only on ozone layer protection, however today we are now looking at both ozone and climate. Indeed the sector and technology has evolved over the years. It is therefore our responsibility as a collective, as a nation, government, industry and academia to not only think of today, but the future too. Roadshow also seeks to serve as a springboard towards execution of related initiatives going forward and underpin continued participation and increase of efforts among all towards establishing workable and sustainable solutions for today and generations to come.
The department in collaboration with United Nations Industrial Development Organisation (UNIDO) will be holding the Roadshows between 12th and 21st June 2018. Upon continued engagement with industry role players, a need was identified to communicate the milestones that the country has reached and strides undertaken towards the implementation of both the Montreal Protocol and South Africa Hydrochlorofluorocarbon Phase-out Management Plan (HPMP). In response to the need the Department in collaboration with UNIDO, industry role players and partner government departments resolved to undertake the HPMP Roadshow. The proposed Roadshows will be held at four Provinces at the following venues and dates:
- Midrand, Constantia Hotel - 12 June 2018
- Durban, Garden Court Marine Parade - 14 June 2018
- Port Elizabeth, Summerstrand - 19 June 2018
- Cape Town, Lagoon Beach Hotel - 21 June 2018
Activities of the HPMP Roadshow
What is the future of R-22? What is the future of R-404A? What does this all mean? When, how and who- these are the questions that the Roadshow intends to table, discuss and have thorough and meaningful discussions on. This Roadshow will be touching on aspects that relate the Refrigeration and Air-Conditioning sector in South Africa. The participants range from refrigerant traders or importers/exporters (including distributors/wholesalers), refrigerant users, maintenance and servicing technicians, policy makers, academia, traders and distributors of ODS (e.g. R-22) and non-ODS (R-404A) based equipments and other related stakeholders. The topics to be discussed will be touching on the future of R-22 globally and locally, alternative technologies, registration of servicing technicians, refrigerant reclamation, HFCs (e.g. R-404A) etc.
During the Roadshow the programme (see Appendix A) will start at 08:00 and end at 15:00 at all venues. It will be a formal programme characterised with robust engagements, discussions, active participation and feedback sessions. There will be plenary sessions and commissions/ break-away sessions to enable focused discussions and thorough engagement to respective topics. Presentations will be done by among others NOUs (South Africa, DEA and Namibia), UNIDO and RAC expert, Registration of Service Technicians, Refrigerant Reclamation et al. The Roadshow will be coupled with Exhibition stands displaying materials/ equipment from various industry role players and government respectively.
What are hydrochlorofluorocarbons (HCFCs) are ozone depleting substances (ODSs)
Hydrochlorofluorocarbons (HCFCs) are ozone depleting substances (ODSs) that deplete the ozone layer are widely used in refrigeration and air conditioning, foam blowing and solvent applications. Action on HCFCs is important in that these chemicals have an impact on both ozone depletion and climate change. In terms of direct impact, the most commonly-used HCFCs have ozone depleting potentials (ODPs) ranging from 0.02 (HCFC-123 or R-123) to 0.11 (HCFC-141b or R-141b) and global warming potentials (GWPs) ranging from 76 (HCFC-123) to 2270 (HCFC-142b or R-142b). Equipment can also indirectly cause the greenhouse gases (GHGs) through its consumption of energy. Prior to Chlorofluorocarbon (CFC) phase-out (1 January 2010) the refrigeration and air conditioning (RAC) sector was the biggest consumer of CFCs, and today the sector has become one of the primary consumers HCFCs.
Many countries recognized that increasing their consumption of HCFCs is building an HCFC-based infrastructure that creates a future servicing demand, while the supply of HCFCs is being gradually decreased through a national quota system, and supply is expected to decrease over time. Therefore the installation of such equipment, while slightly higher in cost, will lead to additional energy savings in the long run.
Ozone depleting substance regulations
To ensure full phase-out of ODSs, South Africa has developed the Regulations regarding the Phasing-out and Management of Ozone-Depleting Substances, Regulation 351 of 8 May 2014.This regulations were promulgated by the Minister of the Department of Environmental Affairs (DEA) to monitor and control consumption of ODSs in the country. Processes to amend this Regulation are underway to among other things include the phase-out or ban the use of disposacans. The International Trade Administration Commission (ITAC) issues a permit upon recommendation by the DEA National Ozone Unit (NOU). The Department of Agriculture Forestry & Fisheries (DAFF), the DEA NOU and ITAC work together for importation of methyl bromide and issuance of permit(s). In addition, Customs and Excise have allocated tariff codes to identify ODSs. The same tariff codes are used by DEA NOU for recommendations to ITAC and when issuing import and export permits. Therefore, by controlling and monitoring the imports/exports into the country ODSs consumption is expected to decrease.
South Africa does not produce ODSs within the country, however all these refrigerants are imported into the country and exported out to other African countries. The import of these refrigerants comes in through customs ports of entries and they also exit the country via the ports and/or land borders. For this reason consumption within the country is then calculated as follows;
- Consumption = production + import - export
- As mentioned above, South Africa does not produce ODSs and therefore, consumption= import-export.
The following are the ODSs imported and exported from 2005 to 2016.
- HCFC-22 (R-22)
- HCFC-123 (R-123)
- HCFC-124 (R-124)
- HCFC-133a (R-133a)
- HCFC-141b (R-141b)
HCFC-142b (R-142b) Noting that R141-b was phased-out in January 2016.
ODSs consumption trends
From the table and graph above consumption was at its lowest in 2005 as 1932.2 Metric tonnes (MT). Consumption increased and was at the highest of 8630.6 MT in 2007. Between 2008 and 2012 consumption has been fluctuating and in 2013, there was a tremendous drop in the consumption to 3821.1 MT. From 2014 to 2016 there has been a consistence drop in HCFC consumption with 2014 consumption at 3558.5 MT, 2015 at 3155.6 MT, and 2016 at 2581.4 MT. This can be attributed to the existing management and controls through the Regulations Regarding the Phasing-out and Management of Ozone Depleting Substances and provisions set out by Montreal Protocol for parties with an ultimate target of a complete phase-out of use of HCFC (e.g. refrigerant, R-22) by 2040.
Hydrofluorocarbon (HFC) Management
In South Africa, HFCs are mostly used in the RAC sector as replacement for ODSs and currently there is no law that prohibits nor restricts quantities of HFCs that are being imported into or exported out of South Africa. However general imports and exports of HFCs are controlled through ITAC Import and Export Regulations of 2012. To obtain such permit from ITAC one requires a recommendation issued by the Department of Environmental Affairs (DEA).Considering the fact that, South Africa is in the process of ratifying the Kigali Amendment on HFC phase-down, it is imperative that all role players are updated in regards to looming legislations on the horizon.