Why Disposable Refrigerant Cylinders Pose an Environmental Risk and How to Make the Switch

Why Disposable

Refrigerant Cylinders Pose an Environmental Risk and How to Make the Switch

By Francis Lai Head of Product Management

Introduction

In the world of marine refrigeration, the choices we make have far-reaching consequences for our environment, our ships, and the safety of our crew and passengers.

Hydrofluorocarbons (HFCs) are the most commonly used refrigerants in the maritime industry today, and some of them have very high Global Warming Potential (GWP) values, for instance, 3922 (R-404A) and 3985 (R-507). To minimise greenhouse gas emissions from the refrigeration system, we need to adopt and implement low GWP refrigerants. Moreover, it is equally crucial for us to be mindful of the impact of type of cylinders used to store these refrigerants.

The use of disposable cylinders for refrigerants has been a long-standing practice in the maritime industry, which is now being viewed as an unethical option that poses a risk to the environment

This technical article explores the risks, environmental impacts, and regulatory changes surrounding these cylinders. Furthermore, we will delve into the recent rise of illegal and counterfeit refrigerants as a direct result of the HFC phase down, which can be a danger to vessel crew. We will conclude with a clear course of action for vessels to ensure compliance with the regulatory landscape.

The Hidden Danger of Disposable Cylinders

1. Improper Disposal and HFC release

Disposable cylinders are single-use containers, typically made of steel and used to store and transport refrigerant gases, such as HFCs which are potent greenhouse gases (GHGs). Improper disposal of these cylinders is an increasing issue in the maritime industry. These cylinders are often discarded with “heel”, which refers to the residual amount of refrigerant left in a cylinder after it has been partially used. They often end up in landfills or left to corrode in scrapyards, leading to the release of HFCs into the atmosphere

2. Safety Concerns

The use of disposable cylinders also raises crew safety concerns. These cylinders are constructed with a thin wall meant for one-time use, making them more prone to corrosion than a returnable cylinder. In a highly corrosive marine environment, the corrosion could weaken the structural integrity of the cylinder, making it more prone to cracks and leaks.

3. Illegal and Counterfeit Refrigerants

Refrigerant leaks can cause several health and safety problems for the crew, including asphyxiation, frostbite, and toxic poisoning. Explosions due to weakened cylinder walls can result in serious injuries.

The EU F-Gas Regulation and the Kigali Amendment to the Montreal Protocol aim to reduce the production and consumption of high-global warming potential (GWP) HFCs. However, these regulations also bring challenges, and unintended consequences like illegal trade.

Here is How the Global Phase Down is Related to the Rise in Illegal Trade of HFC Refrigerants:

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Production and Import Quotas: The F-Gas Regulation and Kigali Amendment impose production and import quotas on HFCs, gradually reducing their availability in the market. This limitation can lead to shortages in legal supply, driving up prices and creating an incentive for illegal trading.

Higher Prices: The phase-down is making it more difficult and expensive to obtain HFCs legally. These create opportunities to smugglers for the sales of illegal refrigerants at lower prices to unsuspecting businesses .3

Enforcement Challenges: Illegal trade often involves the production of HFCs that do not comply with environmental standards and smuggling of HFCs without the necessary quota / license. Law enforcement faces difficulties in monitoring and enforcing regulations on a global scale. Illicit trading networks can operate across borders, making it challenging to detect and prosecute those involved.

Counterfeit Products: The rise in illegal trade can lead to counterfeit refrigerants entering the market. These products may not meet safety or quality standards, posing a risk to the environment due to the uncontrolled release of HFCs.

What Are the Risks of Using Counterfeit Refrigerants?

Spoiled Food and Goods

Counterfeit refrigerants may lack the required quality and chemical composition of purity, which can lead to a decreased cooling capacity. This, in turn, can affect the quality of the temperature sensitive food and goods that are being transported onboard vessels.

Damage to Equipment Health, Safety and Environment

Counterfeit refrigerants may contain impurities or contaminants that can damage compressors and other components of refrigeration systems. This may result in costly repairs or replacements.

Counterfeit refrigerants can contain banned substances which are toxic and flammable, putting end users and refrigeration plants at risk. Additionally, banned substances with high ozone depleting and global warming potentials will cause environmental harm when not being disposed properly.

Using disposable cylinders increases the risk of obtaining counterfeit refrigerants.

Disposable cylinders can be obtained at a relatively low price and are untraceable – becoming the container of choice for counterfeiters to store counterfeit refrigerants. The risk of acquiring counterfeits is therefore higher when choosing disposables over returnable cylinders.

- Francis Lai, Head of Product Management, Wilhelmsen Ships Service

Compliance Regulations and Limitations for Disposable Cylinders

Across the globe, nations are taking decisive actions to address the danger of disposable cylinders mentioned above as part of their efforts to reduce greenhouse gas emissions and protect the environment.

In 2007, The European Union banned the use of refrigerants in disposable cylinders. Additionally, disposable cylinders or non-refillable cylinders are also banned in countries such as Australia, Canada, India and Turkey. A clampdown on the supply of refrigerant in illegal disposable cylinders has created a new illicit market in refrigerant being sold in fake refillable cylinders with no provision for their return for refilling. However, such practice is in contravention of the F-Gas regulation.

Article 11 (4) of the New F-Gas Regulation (EU) 2024/573 specifically addresses the requirement that when a refillable container is placed on the market, binding arrangements must be in place for its return for refilling purposes. In practice, this means that manufacturers and distributors of refillable containers intended for F-gases must establish systems and procedures to facilitate the safe and efficient return of these containers for refilling. This requirement helps reduce GHG emissions by promoting the re-use of containers rather than their disposal after use.

Did You Know?

The ban on disposable cylinders in the United States, initially scheduled for 2025, was overturned by the D.C. Court of Appeals in June 2023. As a result, the EPA has put forward a proposal that mandates new tracking rules for disposable cylinders. Furthermore, all used disposable cylinders must now be sent to an EPA-certified reclaimer for proper evacuation before recycling or disposal. The EPA has set a compliance date of January 1, 2025, for these new requirements.

How to Make the Switch to Returnable Cylinders

As we are navigating the regulatory landscape, environmental impact of disposable cylinders, and the risk of counterfeit refrigerants, it is clear that the industry needs to change.

What should ship owners do?

• Obtain refrigerants from reliable and reputable sources.

• Avoid buying refrigerant in disposable cylinders by utilising a returnable program.

• Verify the source and authenticity of the refrigerants, especially if the price seems too good to be true.

• Report to the appropriate authorities immediately if the refrigerants are suspected to be illegal or counterfeit.

• Ensure the refrigerant cylinders are properly maintained and inspected to reduce the risk of leaks and explosions.

• Ensure any empty or used cylinders are properly disposed in accordance with local regulations.

• More importantly, ship owners should prioritise the use of returnable cylinders obtained through a reliable Cylinder Exchange Program.

The Recommended Solution:

Returnable Cylinders and the Global Cylinder Exchange Program

Here is how the program can enhance the safety of your systems and reduce emissions from your refrigerants:

Traceable cylinders

The program provides traceability from production to the end-user by scanning barcodes for each cylinder at the point of transaction. This ensures the authenticity of the refrigerants and allows vessels to exchange the empty cylinders for refilled ones in all the major ports in the world.

Refillability

These cylinders are designed to be returned, refilled, and re-used over 20 times in its life cycle, thereby reducing waste and the environmental impact of residue refrigerants from the heel released into the atmosphere.

Quality and Safety

The program guarantees the purity and quality of the refrigerants, safeguarding your systems from harmful substances. Additionally, the cylinders are regularly inspected and tested to ensure their quality, reducing the risk of accidents.

In light of these challenges , ship owners must arm themselves with knowledge and vigilance. Recognising and avoiding illegal or counterfeit refrigerants are essential for their safety and the efficiency of their refrigeration systems. Transitioning to a returnable cylinder program offers a solution for these challenges, providing peace of mind.

Conclusion

The use of refrigerant in disposable cylinders poses significant risks and dangers to the environment and the safety of people handling these cylinders. By using returnable cylinders, ship owners can reduce waste, energy consumption, and the risk of leaks and explosions. Governments around the world are recognising the need to regulate the use of disposable cylinders, and ship owners should take steps to ensure they are staying compliant and not contributing to environmental damage.

We urge you to prioritise the use of returnable cylinders through a trusted exchange program. By doing so, you not only protect your ship's performance and the safety of your crew and passengers but also contribute to a circular economy in the maritime industry.

Stay Compliant with your Cylinder Choices and Responsible Refrigeration

Choosing returnable cylinders under a cylinder exchange program over disposable cylinders can significantly reduce the environmental impact of your refrigeration system. To further minimise emissions and future-proof your system, we recommend adopting the Responsible Refrigeration approach.

For more information, please visit our landing page at https://www.wilhelmsen.com/ships-service/responsible-refrigeration/ or reach out to your WSS sales representative.

Wilhelmsen Ships Service

Phone: (+47) 67 58 40 00

Fax: (+47) 67 58 40 80

Postal Address: PO Box 33, NO-1324 Lysaker, Norway

wilhelmsen.com

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