Using flammable refrigerants

1. Importers and manufacturers of flammable refrigerant gases must ensure these are assigned the appropriate UN Class, Subsidiary Hazard and Packing Group in accordance with the Dangerous Goods (Transport by Road or Rail) Regulations 2018 or corresponding legislation or classify the substance in line with the Globally Harmonised System of Classification and Labelling (GHS3). You will find a card link below to the Safe Work Australia (SWA) Classifying Chemicals page.
2. Where a refrigerant gas is classified as a hazardous chemical, including a flammability hazard, the importer and manufacturer must prepare a compliant safety data sheet (SDS) and label. You will find the card link below to the SWA Model Code of Practice: Preparation of safety data sheets for hazardous chemicals. 
3. Importers and manufacturers of refrigerant gases may also classify the products in terms of flammability and toxicity using Australian Standards (AS) / New Zealand Standards (NZS) ISO 817:2016 Refrigerants – Designation and safety classification. You will find the card link to the AS in the card link below.
4. Importers and the manufacturers must correctly pack refrigerant gas classed as a hazardous chemical. For flammable gases or gases under pressure, they must comply with the Australian Dangerous Goods Code (ADG Code). You will find the card link below to the ADG Code.

1. Designers of plant, such as refrigeration systems, must eliminate risks associated with the system so far as is reasonably practicable. Where risks cannot be eliminated, the risks must be reduced so far as is reasonably practicable. This includes risks to people who install, maintain, construct, dispose of or use the system and those in the system's vicinity at a workplace.
2. Designers of refrigeration systems should refer to the Australian Standards (AS) / New Zealand Standards (NZS) ISO 817:2016 Refrigerants – Designation and safety classification for information on design measures to prevent the release of refrigerants and other controls. You will find the card link below to the Australian Standards.
3. Designers of mobile, portable or stationary refrigeration systems that use, or are compatible to use with flammable refrigerants need to control any flammability hazards and risks and any other hazards or risks associated with the refrigerant. Designers should have relevant experience and training, including accredited courses run by registered training institutes or equivalent where available.
4. Flammable refrigerants may be odourised to aid their detection.
5. The refrigerant gas quantity (charge size) need to be appropriate to the room or enclosure size and use. Refrigerant gases and gas blends which contain one or more flammable refrigerants must have a charge limit equal to the lowest charge limit applicable to any constituent. See AS/NZS 5149.1 for more information on charge limits.
6. Install detection equipment to detect leaks from larger stationary direct systems where a rupture or leak would cause refrigerant release to an occupied space, for example, machinery rooms or cold rooms. Where practicable, stationary air conditioning equipment using flammable refrigerants should use a flammable gas detector alarm system for the air leaving the cooling coil. Consider detection equipment for smaller systems where a flammable refrigerant release could cause a flammable atmosphere, such as where the room is small. Such detection systems can be interlocked to shut down the system in the event of a leak, if this is appropriate for the system. More information is available in AS/NZS 5149.3.
7. Designers of refrigeration systems should provide the following information to people who use, store, construct or maintain the system at a workplace:
   • specify one or more refrigerants compatible with the system;
   • any areas classified as hazardous areas in terms of fire risk as far as practicable (including documentation as per AS/NZS 60079 where the application is in the scope of that standard); and
   • instructions on the safe use and maintenance of the system.
8. Refrigeration systems need to include labelling or signs specifying the refrigerant used, and any hazards associated with that refrigerant. Refer to jurisdictional legislation for specific labelling or sign requirements.

1. Manufacturers, importers and suppliers of refrigeration equipment must eliminate risks associated with the system, so far as is reasonably practicable. Where risks cannot be eliminated, they must be minimised as far as is reasonably practicable. This includes risks to people who install, maintain, dispose of or use the system and those in the vicinity of the system at a workplace.
2. Manufacturers, importers and suppliers of refrigeration systems must provide adequate information to clients in relation to the refrigeration system, its potential hazards and instructions for safe installation and use. Details about the type of information to provide are available in AS/NZS 5149.2 (Section 5.4) and other applicable standards, for example the AS/NZS 60335 series covering vending machines, refrigerators, freezers, dryers, commercial refrigerating appliances, air conditioning and heat pumps.
3. Manufacturers, importers and suppliers of refrigeration systems for use in workplaces should have relevant experience and training, including completing relevant units of competency or equivalent.

1. The installer of a stationary or mobile workplace refrigeration system must eliminate risks associated with the system, so far as reasonably practicable. Where risks cannot be eliminated, they must be minimised as far as is reasonably practicable. This includes risks to people who install, maintain, dispose of or use the system and those in the vicinity of the system at a workplace.
2. Businesses that install or maintain refrigeration systems need to ensure the refrigerant is compatible with the system and that this compatibility is documented. For example, the specifications for the system should document the compatible refrigerant/s.
3. Where an alternative refrigerant is being considered, the compatibility of this refrigerant with the system need to be assessed and documented by a competent person before the substitution. A person changing a refrigerant to a more flammable refrigerant takes on a role similar to that of a designer of a refrigeration system. For example, for a fixed system a refrigeration engineer must assess the suitability of the system for use with the alternative refrigerant. The engineer needs to  ensure compliance with relevant standards including AS/NZS 5149 series, AS/NZS 3000 and other electrical standards.
4. Specific conditions apply if the system falls under the scope of AS/NZS 3000 (the "Wiring Rules") generally and specifically Clause 7.7 "Hazardous Areas (Explosive Gas or Combustible Dusts)" and compliance with AS/NZS 3000 is mandatory via the applicable jurisdiction's electrical regulations. In these cases, the person in control of the installation needs to classify the hazardous areas in accordance with Clause 7.7 which invokes the hazardous area standard AN/NZS 60079.10.1.
5. If plant such as registerable pressure vessels is involved, re-registration by the WHS/OHS regulator may be required.
6. The business operating the workplace or vehicle should also be consulted before substituting a refrigerant and should approve the substitution before it proceeds. In the absence of written confirmation from a competent person on the suitability of an alternative refrigerant, the alternative refrigerant should not be used.
7. Systems for leak detection and emergency management need to suit the refrigerant and proportionate to the risks. Further information is provided in AS/NZS 5149 series.
8. Provide technicians with information and training on the hazards and safe use of the specific refrigerants they use or are likely to encounter in their work. The employer of a refrigeration technician has a duty to ensure the technician has been informed and trained, so far as practicable, to manage risks to health and safety.
9. Refrigeration technicians need to be competent to manage any foreseeable hazard, including a flammability hazard, during installation or maintenance work. They must have relevant experience and training, and where flammable refrigerants are or may be used, this should include relevant units of competency or equivalent.

1. There is a voluntary national accreditation scheme available to help refrigeration technicians upskill in relation to key refrigerants not covered by a national licence, including hydrocarbons and HFO 1234yf.
2. Guidance in relation to vehicle air-conditioning is available in the Department of the Environment, Water, Heritage and the Arts (DEWHA) Code of Practice Control of refrigerant gases during manufacture, installation, servicing or de-commissioning of motor vehicle air-conditioners.  The current edition does not cover flammable refrigerants.
3. Note: Any person who handles refrigerant gases containing scheduled ozone depleting substances or synthetic greenhouse gases, or carries out work on refrigeration and air conditioning equipment containing these gases, must hold a national refrigerant handling licence under the Ozone Protection and Synthetic Greenhouse Gas management Regulations 1995. You will find a card link to the Ozone Protection Regulations below.

Businesses employing refrigeration technicians should develop safe work procedures for working with flammable refrigerants. The following are examples of safe work procedures businesses should include:

1. Confirm the type of refrigerant present.
2. Do not top up a refrigeration system without first checking for and fixing any leaks.
3. Only use electrical equipment that is rated for hazardous area use. For example, equipment that is flame-proof or intrinsically safe near sources of flammable refrigerant where there may be a leak or release. The hazardous area classification document developed in accordance with AS 60079.10 provides specific requirements, for example on the use of electrical equipment suitable for use in the hazardous area as described in AS 60079.14.
4. Whenever a flammable refrigerant is placed in a vehicle air-conditioning system, affix a label in a prominent place in the engine bay to make it clear what refrigerant is used, and how much is used. The label, or tag, should incorporate a flammable gas (Division 2.1) class label or GHS pictogram.
5. Information needs to be provided whenever a flammable refrigerant is used in a stationary system, including appropriate labelling and/or signs. Placards may be required depending on quantities. The system owner must be provided with the SDS for the substance and provision should be made for leak detection and emergency management on a risk basis.
6. For jurisdictions using Work Health and Safety legislation, Regulation 51 of the model WHS regulations has specific requirements for a person conducting a business or undertaking at a workplace. The person must manage risks to health and safety from a hazardous atmosphere wherever the atmospheres include flammable gases at more than 5% lower explosive limit (LEL).
7. Businesses installing or maintaining refrigeration systems should consider the purchase of portable gas detection and identification systems. Note: These systems rely on regular maintenance and calibration and operator training and environmental factors results may be affected by environmental factors results. Alternatively, portable gas detection and identification equipment may be hired, or safe work methods that minimise risks from all potential refrigerant hazards, so far as is reasonably practicable, may be developed and implemented.
8. Certification, inspections and maintenance records should be available for apparatus in hazardous areas. These records should include the suitability of the equipment for hazardous areas, details of all inspection/maintenance and the details of the competent person who conducted the inspection/maintenance.

People conducting a business or undertaking (PCBU), employers and people with management or control of workplaces

1. The person conducting a business or undertaking involved in the storage or handling of hazardous chemicals must eliminate risks associated with this storage or handling, so far as reasonably practicable. Where risks cannot be eliminated, they must be minimised as far as is reasonably practicable. The duty to control these risks includes risks to people who install, maintain, dispose of or use the system, and those in the vicinity of the system at a workplace. Minimising risks as far as is reasonably practicable means that more controls will be required for larger or higher-risk refrigeration systems, for example a commercial cool room, compared with small, low-risk refrigeration systems such as a domestic-type refrigerator.
2. PCBUs should ensure that only competent workers work on air-conditioners and other refrigeration systems, particularly those containing flammable refrigerants.
3. Workers must be provided with information and training on the hazards and safe use of the specific refrigerants to which they could be exposed.
4. Gas detection equipment should be installed to manage the risk of leaks from larger systems.
5. Before using flammable refrigerants as a substitute to re-gas a refrigeration system designed for less flammable refrigerants, the PCBU needs to obtain written advice from a competent person. The competent person, preferably the system’s designer, manufacturer or supplier, must provide written advice about the suitability of the specific refrigerant for the system and the required safety controls or system modifications.
6. The PCBU should have systems in place to ensure that if a system needs additional refrigerant, the same type of refrigerant as is in the system should be used to avoid creating a refrigerant mixture with unknown hazards.
7. The PCBU should implement a preventative maintenance program for the refrigeration system in accordance with the manufacturer’s instructions or to an equivalent standard and should ensure maintenance and inspection records are kept.
8. The PCBU needs to use information from refrigeration system’s designer to identify hazardous areas, and ensure safe systems of work, for example hot work permits, are in place for hazardous areas.
9. If using a flammable refrigerant in a mobile system, the system should be labelled in a prominent place such as the engine bay to make it clear what refrigerant is used, and how much is used, the charge size. The label should incorporate a flammable gas (Division 2.1) class label or GHS pictogram.
10. Adequate information should be provided whenever a flammable refrigerant is used in a stationary system, including appropriate labelling and signs. Placarding may be required depending upon quantities. The PCBU must obtain the SDS for the refrigerant, include it in the hazardous chemicals register and make the SDS available to workers who may be exposed to the substance. Provision must be made for emergency management.
11. The PCBU may require placards and manifests and, in some jurisdictions, may need to notify the regulator of the use of the refrigerant, depending on the hazard classification and quantity of the refrigerant.
12. The PCBU should check conditions in equipment warranties and insurance policies before using alternative refrigerants, including whether the use of an alternative refrigerant should be disclosed to the insurer.

People conducting a business or undertaking (PCBU), including employers

1. PCBUs involved in the recovery, reclamation or disposal of hazardous chemicals must eliminate risks associated with this work, so far as reasonably practicable. Where risks cannot be eliminated, they must be minimised as far as is reasonably practicable. This includes risks to people who conduct the work or others in the vicinity of the work.
2. PCBUs must ensure that only competent workers handle flammable refrigerants. Note: Any person who handles prescribed refrigerant gases or carries out work on refrigeration and air conditioning equipment which may contain these gases must hold a national Refrigerant Handling Licence under the Ozone protection and Synthetic Greenhouse Gas Management Regulations 1995.
3. Workers undertaking recovery, reclamation or disposal activities must be provided with information and training on the hazards and safe handling of the specific refrigerants they handle.
4. Businesses reclaiming or disposing of refrigerants should use appropriate gas detection and identification systems. Note: these systems rely on regular maintenance and calibration and on operator training and results may be affected by environmental factors.
5. PCBUs involved in the recovery, reclamation or disposal of refrigerant gases should ensure there is a procedure in place to identify the refrigerant and a safe disposal procedure appropriate to each type of refrigerant.
6. It is an offence to discharge ozone-depleting substances and synthetic greenhouse gases to the atmosphere whether in a mixture with other gases or not.
7. It is good practice to recover all synthetic refrigerants, including those for which recovery is not mandatory, for example R1234yf.
8. PCBUs should have recovery units and cylinders suitably rated and labelled for refrigerants likely to be encountered.
9. PCBUs involved in recovery, reclamation or disposal of refrigerant gases should refer to relevant standards and guides for information on requirements under other legislation.