Find out about flammable refrigerants and your responsibilities for storing and handling them.
Refrigerants used in refrigeration and air conditioning systems in Australia have usually been non-flammable, non-toxic, synthetic greenhouse gases (SGGs) with a high global warming potential (GWP). These include chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs). Due to the concern over the impact of SGGs in the atmosphere, the use of alternative refrigerants with low GWP is increasing. These include natural alternatives to HFCs such as ammonia, carbon dioxide and hydrocarbons. As there are a range of hazards associated with refrigerant gases, they are classified as hazardous chemicals and regulated under the Work Health and Safety Act 2011 (WHS Act) and Work Health and Safety Regulation 2011 (WHS Regulation).
Each of these natural alternatives have hazard characteristics that are different from those of the commonly used HFCs, ranging from high toxicity to highly flammable. Significant consequences may arise if converting or modifying a system where a flammable refrigerant is involved if a person conducting a business or undertaking (PCBU) fails to:
- recognise the associated hazards
- follow appropriate installation, servicing, maintenance or decommissioning practices
- properly address safety considerations.
Such failures could result in fires, injury to persons, and/or damage to property. Equipment and systems designed for use with flammable refrigerants require additional safety features, beyond those normally required when using non-flammable refrigerants.
Refrigerant gas classifications
Under the WHS Regulation, hazardous chemicals (including gases) are classified according to the Globally Harmonised System for the Classification and Labelling of Chemicals (GHS).
The GHS is designed to provide information for the safe storage, handling and use of a hazardous chemical independent of the refrigerant gas classifications of A1/A2/B2/A3 and A2L as described in industry standards. These industry-developed systems are designed to provide a more tailored approach to the specific uses within that industry (i.e. wide ranging refrigeration installation types, sizes and locations). This further assists designers in selecting a suitable refrigerant for a particular situation taking account of flammability and toxicity hazards.
Safety data sheets
A refrigerant gas is required to have a safety data sheet (SDS) developed and supplied by the manufacturer or importer which describes the hazard classification/s. The SDS provides the chemical hazard information of a product as a basis for safely managing the associated use, storage, and handling risks.
For example, GHS classification of R32 (Difluoromethane) is Flammable gas Category 1. According to this classification, the SDS and labels are required to provide specific information under the GHS such as the Signal Word: DANGER and Hazard Statement: Extremely Flammable (code:H220). This must be shown on the product SDS and package labels.
The SDS does not address specific workplace hazards where variations will occur in the volume involved, the size and type of system containing the refrigerant gas, or the way it is being used, stored or handled. The hazards associated with the work environment and work activity must be identified by the PCBU and the appropriate risk controls must be implemented to reduce the risks so far as reasonably practical.
The SDS is required to be provided by a Queensland manufacturer/importer or supplier and must meet the requirements of Schedule 7 of the WHS Regulation. Preparation of safety data sheets for hazardous chemicals code of practice 2021 (PDF, 1.05 MB) provides further guidance on the content to be included in an SDS.
Under Work Health and Safety (WHS) laws, designers, manufacturers, importers, suppliers and installers of plant must ensure, so far as is reasonably practicable, that flammable refrigerant-based systems or plant they design, manufacture, import, or supply, eliminate or minimise the risks associated with flammable refrigerants to the health and safety of a person. This duty includes meeting the relevant standards, carrying out testing and analysis as well as providing specific information about the plant.
A PCBU who manages or controls refrigeration or air conditioning plant at a workplace must ensure, so far as is reasonably practicable, that flammable refrigerant-based systems eliminate or minimise the risks associated with flammable refrigerants to the health and safety of a person.
Queensland hydrocarbon refrigerants legislation
While all refrigerant gases are regulated as hazardous chemicals under the WHS laws, highly flammable hydrocarbon refrigerants have additional safety requirements under the Petroleum and Gas (Production and Safety) Act 2004. This includes approval of the refrigerating device and licence to undertake gas work on the refrigeration device.
Hydrocarbon refrigerants include:
Anyone changing systems using these gasses in Queensland must get a gas works authorisation from the Chief Inspector Petroleum and Gas to carry out the work.
Refer to the Petroleum and gas safety health for more information.
The Electrical Safety Act 2002 (ES Act) sets out specific requirements about electrical equipment and installations.
In addition to the product safety standards, the requirements of AS/NZS 3000 apply to all installations and to the detailed design of all systems built on site. AS/NZS 3000 also requires compliance with AS/NZS 60079.10.1 and AS/NZS 60079.14 for any installations involving the use of a flammable gas that may require Hazardous Area Classification.
Electrical safety regulators advice on converting systems and equipment is:
- If equipment has not been confirmed as being designed, manufactured and tested to be compliant to relevant electrical safety standards for use with the proposed refrigerant then conversion of the equipment or use of the proposed refrigerant should not occur.
- All domestic electrical appliances must be shown to comply with the relevant electrical safety product standard for use with the proposed refrigerant.
- For commercial and industrial situations all the equipment used, and the complete installation, shall have appropriate certification, assessment, and evidence of compliance with the applicable electrical safety standards.
Conversion of a system to flammable refrigerants should not be carried out unless the modifier possesses:
- competence in the design of refrigerating equipment (competence to carry out routine service and maintenance alone is usually insufficient)
- knowledge of the additional or changed legal requirements which may be engaged as a result of using flammable refrigerants in the particular application
- the competence to recognise when additional engineering controls are necessary and how to implement them
- detailed knowledge of the electrical safety standards applicable to the system.
As with any modification that deviates from the original manufacturer's instructions, the modifier is responsible for continued compliance with legislation and is obliged to inform the end user and/or owner of the system of any considerations (e.g. health and safety, changes to operating procedures) that should be considered.
Find out more about electrical safety regulations and product compliance.
The Australian Institute of Refrigeration, Air Conditioning and Heating (AIRAH) have published the industry guide Flammable Refrigerants Safety Guide 2013 about managing the health and safety risks associated with the safe design, manufacture, supply, installation, conversion, commissioning, operation, maintenance, decommissioning, dismantling and disposal of refrigeration and air conditioning equipment and systems that use a flammable refrigerant.
The Heads of Workplace Safety Authorities (HWSA) have developed Flammable refrigerant gases – position paper (PDF) which provides information on the obligations of work health and safety duty holders with respect to the use of flammable refrigerant gases at workplaces.
Technical guidance for refrigeration systems is available in various Australian Standards including AS/NZS 5149 series for refrigerating systems and heat pumps.