How to Manage Ozone Depleting Substances at Your Workplace?

This guideline sets out an approach that will generally be sufficient to ensure compliance with the regulatory requirements related to the management of Ozone Depleting Substances.



 






What are Ozone Depleting Substances?

are man-made gases that destroy the ozone layer. The ozone layer, located high in the atmosphere, filters out some of the sun's most dangerous ultraviolet rays before they reach Earth. Both humans and the environment are vulnerable to damage from ultraviolet rays. For instance, it can cause cancer and cataracts in humans, alter plant growth, and harm the marine ecosystem.

Ozone-depleting substances include:

  • chlorofluorocarbons (CFCs)
  • hydrochlorofluorocarbons (HCFCs)
  • hydrobromoflurocarbons (HBFCs)
  • halons
  • methyl bromide
  • carbon tetrachloride
  • methyl chloroform.
They have been used as:
  • refrigerants in commercial, home, and vehicle air conditioners and refrigerators
  • foam blowing agents
  • components in electrical equipment
  • industrial solvents
  • solvents for cleaning (including dry cleaning)
  • aerosol spray propellants
  • fumigants.
On the US EPA website, you may find more details about the current condition of the ozone layer.

Why Should You be Concerned About Ozone Depleting Substances?

Besides the moral obligation to protect the environment, management of Ozone Depleting Substances is required under several laws & regulations. It is illegal to dispose of ozone-depleting substances by releasing them into the atmosphere. 

Every country on Earth is a signatory to the "Montreal Protocol on Substances that Deplete the Ozone Layer," which sets targets for reducing the production and consumption of ozone-depleting substances. The Montreal Protocol under the Vienna Convention (the protocol) was agreed upon in 1987. It facilitates global cooperation in reversing the rapid decline in atmospheric ozone concentrations. Under the protocol, countries agreed to phase out the production and consumption of certain chemicals that deplete ozone. Phase out of these substances is required by specific deadlines.

How Can You Manage Ozone Depleting Substances at Your Workplace?

Organizations should manage ozone-depleting substances systematically, ensuring compliance with company policy and local regulatory requirements.

1. Identify the ozone-depleting substances at your workplace

Each organization should identify processes and equipment that use or store Ozone Depleting Substances (ODS). A site survey is usually used to obtain an inventory of such processes and equipment. The initial list will require a liaison between HSE, engineering and procurement staff, and sometimes contractors or suppliers. For each process or item of equipment, the following information should be recorded:

  • Location of use
  • Purpose of use (e.g., air conditioning, fire extinguisher, refrigerant, solvent, fumigant)
  • Trade and chemical name of the substance
  • Type, make, and model of process or storage equipment
  • Age of equipment
  • Electrical rating and cooling duty of refrigeration equipment
  • ODS capacity of the equipment
  • Quantity of ODS in the equipment and in storage
  • Quantity of ODS used yearly (estimated or calculated from historical information)
Large installations may contain hundreds of ODS-containing small appliances. In such a circumstance, the inventory may aggregate minor appliances that are comparable into a single inventory item. This should be done only if the device is constructed, charged, and completely sealed in a factory with 2.5 kg or less refrigerant. Examples are refrigerators, freezers, cold boxes, room air conditioners, packaged terminal heat pumps, dehumidifiers, under-the-counter ice makers, vending machines, and drinking water coolers.

2. Develop a strategy to eliminate the ozone-depleting substances

The survey results should be used to develop a suitable strategy for eliminating all ozone-depleting substances from the workplace. The strategy should consider business needs, legal and economic considerations, and the HSE risks involved.  In general, processes and equipment using ozone-depleting substances with the highest ozone-depleting potential (ODP) and having the highest risk of release should be replaced first. However, the assessment should also take into account:

  • Maintenance history of the equipment
  • Age of the equipment
  • Quantities of ODSs involved
  • Strategic importance of the process or equipment
  • Any economic justification for replacement (a more efficient, more suitably sized, more reliable, or different type of equipment may provide cost savings)
  • Current and future requirements for cooling capacity or fire protection.
Maintain a schedule of phase-out dates applicable to the workplace for all ozone-depleting substances and review the schedule at a specific frequency to see any changes in the requirements. 

Following the assessment, prepare a plan showing the actions and target completion dates. Also, monitor the progress against the action plan to ensure that the elimination is achieved according to the established target dates.

3. Minimize release of ozone-depleting substances into the atmosphere 

Depending upon the nature of the facility, releases may arise from regular operation or maintenance of systems for refrigeration, fire suppression, or building and automobile air conditioning. Some manufacturing facilities may also have manufacturing processes that could release ozone-depleting substances into the environment.

All systems using ozone-depleting substances should be subject to routine inspections and appropriate preventive maintenance. Any existing air-conditioning, refrigeration, fire-extinguishing, or fumigation system that uses or contains ODSs should be converted or replaced when it reaches the end of its useful life. In addition, it should be ensured that:

  • Only people appropriately trained in minimizing emissions are allowed to work with ozone-depleting substances. (In many situations, this will require the use of specialist contractors)
  • ODS use and storage are conducted in a manner safe for people and the environment
  • Routine inspections and preventive maintenance are conducted on all ODS-containing equipment to prevent leaks and minimize loss of ODSs
  • ODSs should be removed and disposed of properly before decommissioning the equipment
  • ODSs emitted or removed from systems should be recovered for reuse or destroyed in an environmentally responsible manner
  • ODSs recovered for reuse or destroyed should be appropriately documented
  • Cross-checks should be carried out to determine whether the quantities of ODSs recovered match the amounts emitted or removed from systems
  • The causes of loss and types and amounts of ODS lost, removed, and added are adequately documented.

4. Avoid purchasing new equipment containing ozone-depleting substances

Every organization should ensure that no new ODS-containing equipment (e.g., refrigeration, air conditioning, and fire suppression systems) is purchased. The person selecting or specifying the equipment should verify and document that the equipment does not contain ODSs and check that this documentation is present before placing the order.

A variety of alternative substances can replace the ozone-depleting substances. However, some of these replacements are flammable or toxic. So those involved with the design, installation, operation, and maintenance of systems need to fully understand the health, safety and risks, and requirements associated with their use.  In addition, some replacements have a Global Warming Potential (GWP), and, in some cases, replacement refrigerants may result in increased energy consumption. For those reasons, a risk assessment should be conducted and documented before the final selection of an ODS alternative.

Sources:
1. “Ozone-Depleting Substances | US EPA.” US EPA, www.epa.gov/ozone-layer-protection/ozone-depleting-substances.
2. “Ozone Depleting Substances | Ministry for the Environment.” Ministry for the Environment, environment.govt.nz/acts-and-regulations/acts/ozone-layer-protection-act-1996/ozone-depleting-substances.
3. “About Montreal Protocol.” Ozonaction, www.unep.org/ozonaction/who-we-are/about-montreal-protocol.

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