Select Committee on Environment, Food and Rural Affairs Minutes of Evidence



  In my capacity as co-chair of the UNEP Technical Options Committee on foams you asked me at the last UK Foam Sector Group meeting to provide comment on the correct interpretation of sub-clauses 1 and 2 of Article 15 of the Revised European Regulation on Ozone Depleting Substances which relates to the recovery for destruction of Controlled Substances from, amongst other items, "refrigeration, air-conditioning and heat pump equipment, except domestic refrigerators and freezers" (clause 1) and "domestic refrigerators and freezers" (clause 2). In particular, you were interested to know whether insulating foam within refrigeration and air conditioning equipment should be included within the scope of clauses 1 and 2.

  Having consulted with members of the TOC, I can advise that they have confirmed my own view as follows:

    Clause 1 specifically highlights applications where access to significant quantities of controlled substances is relatively easy (eg equipment containing solvents, fire protection systems and fire extinguishers). This would also apply to refrigerators contained in commercial refrigeration, air conditioning and heat pump equipment—but not, of course, to Controlled Substances contained in foams within the cabinets.

    Explicit reference is also made to service and maintenance of equipment as being a point during which such recovery could take place. No such service and maintenance takes place for foams.

    The other alternative point offered for recovery of Controlled Substances is "before the dismantling or disposal of equipment". It should be noted that it is not possible to remove foam from a cabinet "before the dismantling" of it, although "before disposal" is, of course, a possibility.

  In assessing the overall text, it appears that the intent was never to include foams within the scope of clause   1. A similar argument exists in the case of domestic refrigerators and freezers in clause 2.

  Experience of recovering and destroying Controlled Substances from domestic appliances across Europe has, at best, been mixed and it would surely be premature to be making this mandatory—even at 31 December 2001. There has been even less experience with commercial equipment which tends to be more varied in design.

  In conclusion, it is our view that recovery and destruction of Controlled Substances should be encouraged "if practicable" as set out in Clause 3 but should not be mandated at this stage of technology development.

  I hope that this clarifies the situation.

Paul Ashford

Co-chair of UNEP Technical Options Committee on Foams

6 September 2000

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