We have compared two points of view, one “environmentalist” and the other more “marketist”, asking Davide Sabbadin, Energy Efficiency Manager of Legambiente, and Vincenzo Scarano, wide horizons consultant and trainer in the field of refrigeration and air conditioning, the same questions. The resulting picture is similar: the short-term horizon is rather jagged but the future lends itself to more hopeful prospects.
On the 1st of January 2020, the phase down imposed by Regulation 517 completes another step and imposes a ban on the use of coolants with a GWP of more than 2500 in systems containing more than 40 tonns of CO2eq. of gas. The problem of the transition to new solutions resurfaces and reopens the debate that has engaged the market and operators of the supply chain since the publication of the Regulation. The increasingly complex panorama of solutions and operating procedures is of little help to either refrigeration technicians or end customers, because – while in the air conditioning sector the major international players have drawn up the possible directions to take – when it comes to cooling, the variety of alternatives is still all to be decided, despite the fact that trends have been outlined to a certain extent in some cases, such as that of commercial refrigeration.
In this context of unclear trends, we have made an attempt to define the state of the art and to draw up development guidelines together with two people with experiences which, while being different, are much less distant than they would seem if we look at their “appearances” and origin. Both Davide Sabbadin and Vincenzo Scarano agree on several points, which are in themselves sufficiently important to allow us to look confidently (at least in the medium term) at the world of refrigeration and its ability to overcome the stalemate generated over the past five years following the publication of the Regulation.
The “death” of standard solutions and gases that are valid everywhere is the first assumption made. This is followed by a qualification of the skills of refrigeration technicians which is, on the one hand, necessary to face the transition and, on the other hand, appropriate; because it is capable of bringing a substantial upgrade to the role of operators, who will become increasingly “technological” and “digital” in the future and who are preparing to take on important tasks and responsibilities in the sustainability value chain.
The perplexities of the interviewees in relation to the present situation are not hidden: fears of delays, of the exhausting resistance to a change that is necessary, acknowledgement of the considerable costs faced by the supply chain in order to cope with the transition (both to have solutions that are compatible with the regulations and to have the certified skills required to operate safely and in compliance with the new laws), the delicate position of the category of fitters and maintenance workers, which needs to evolve in order to continue doing its job or start doing a new one, be it 2.0 or 4.0.
This is a reading that we think can be useful to many, to understand the present and to choose a path towards a more challenging but also more professional and meritocratic future.
From the law on emissions to eco-responsible know-how
Davide Sabbadin, Energy Efficiency Manager at Legambiente, has clear ideas about the present and quite cautious hopes about the future of coolants. The reasons for this clarity and caution are many and this is why his analysis is very organic and starts from the beginning of the matter, from Regulation 517/2014
“The GWP has entered the professional world and we now know that this is the unit of measure of environmental impact and a point which we must acknowledge as standard, because this dissemination of knowledge and specific awareness is now an established fact. For end users, however, this is an unknown factor and there is little understanding of the relationship between the use of coolants and environmental impact among those who use temperature regulation machines, equipment and production systems.”
A worrying situation …
“To date, those who benefit from the effect produced by coolant gas know nothing about the GWP as a unit of measurement and do not relate the use of one coolant as opposed to another to the impact on the environment. The supply chain has developed attitudes to research practical solutions, designed to meet legal requirements, but certainly not proactive behaviour. On the contrary, in some cases it has tried to slow down evolution by requesting the deceleration of the transition process triggered by the European Regulation. No one has bothered to inform the public why they should pay an extra cost to reduce the environmental risk.”
But what are the obstacles that hinder smart growth in this direction?
“Fish rots from the head, or in this case from the rule: the Regulation is fundamentally flawed, lacking a mechanism that generates economic value in this transition. Consequently, it is perceived as generating costs, obligations, constraints and problems, but not opportunities. In the absence of a kind of carbon tax that would affirm the principle of “the polluter pays”, resources to generate rewarding incentives for behaviour that is compliant or even proactive with respect to the phase down are also missing, leaving operators in the supply chain in a position to treat the issue as a further aggravation of their intervention in the costs of the end user. Unfortunately, this situation has led to an insufficient number of virtuous behaviours by operators engaged in innovation, which has not, however, become a widespread trend. And this is where another task that no one seems to have carried out comes into play, that of communication.”
“The shortcomings related to this issue have been, once again, global and the absence of communication consistent with the ambitious goals set by the Regulation has caused serious difficulties for the market: on our part, we highlighted the need for an information campaign and its centrality in achieving the objectives, but in the drafting of the implementing decree we found ourselves faced with the need for this to be at zero cost to the public administration, which prevented any allocation of budgets to develop an informative project.”
A system of rules that doesn’t work?
“A necessary system of rules, the Montreal Protocol, in implementing the Kigali amendment, has put climate change on the plate not only of operators in the supply chain and end customers, but also on that of public opinion, and European and national rules have enforced the issue. What has failed is the link between everyday behaviour (the use of cooling cabinets, air conditioning) and this climate change and all we talk about is the impact of vehicle traffic, while the two issues must both be addressed in a structural manner and without losing sight of the specific importance of each of them.”
What should the rule have done?
“Our hope is that the laws will create not only a supply that complies with the parameters, but also a conscious and responsible demand. We hope that customers will turn to those who are certified (i.e. prepared and equipped) to carry out coolant management operations, and that they will be careful to choose the greenest product available in order to have a product that lasts longer than one which is perhaps cheaper but required by law to be replaced quickly. There is actually nothing farfetched about the objection raised by those in the supply chain who say that they are struggling, because demand is not consistent with the impact reduction parameters imposed by the legislation. The legislation has focused on creating restrictions for the supply chain, not on generating best practices on the consumer side. Of course, those who suffer are the operators, who are “forced” to impose additional costs, the benefits of which are not clear to the end user.”
But how is the market behaving?
“We need to make a clear distinction between the two segments: air conditioning and refrigeration. Italian companies operating in the refrigeration sector have recently been carrying out broader, more articulated experiments, in a lively and intelligent manner (let’s not forget that this is a sector in which Italy is internationally acknowledged for its excellence), making an effort to research and develop alternative solutions to “traditional” coolants, which has produced positive results, also at commercial level. Italian customers, particularly in the commercial refrigeration sector, have not been as diligent as those in other countries. Some chains have opted for system solutions, making a challenging but profitable transition on the strength of their critical mass, while others have stayed somewhat still, like the small retail sector, which has perhaps been the slowest to react. They are tending to take action here and there and, in some cases, are waiting too long.”
A scenario with a decidedly delicate configuration
“We are approaching a threshold, which we estimate to be around 2025, where all those who have not thought ahead will have to decide whether to pay huge amounts of money for “old” coolants or innovative refrigerants for retrofitting, or to face a replacement that will have the bottleneck on the numbers of machines available. We are talking about thousands and thousands of cooling cabinets to be replaced and this could be a moment in which the quantities produced and the demand for them really clash. A delicate situation to say the least.”
A situation which seems to be resolvable only in the long term
“It definitely requires investment: Regulation 517 originates from a compromise that places importance on a market, the synthetic coolants market, governed by just a few operators, but which opens up space for the use of natural coolants that create a more articulated, broad and “plural” market than that of the standard solutions that have dominated until recently. We need synthetic coolants that help with the transition, offering lower GWPs for all those machines that we want to continue using until the end of their life, which investigate the possibility of managing situations such as heat pumps. At the same time, however, we can look at natural products for their ability to address the matter from another angle – that of minimal impact.”
And this overall picture also includes recycling and regeneration
“This is a space that legislation has overseen and is preparing to oversee more fully thanks to the implementing decree that insists on the traceability of all existing machines and the monitoring of the gases used and their management, but what is missing is the infrastructure that gives life and space to this market. There is no well-organised supply chain which goes from traceability to organic and registered recovery, to the management of the gas storage and requalification phases and to its reintroduction onto the market with positive effects both on the containment of the gas released into the air and on the re-procurement of appliances and thermal power plants which require drop-ins that are in line with the installation system so that they are not too expensive in terms of safety with regard (for example) to the changes in pressure required by the new replacement gases. All this while waiting for replacement investments which will inevitably be required, at least in the medium-long term.”
In the absence of this “commercial” transmission chain, what can be assumed?
“A consortium that creates synergy between operators could streamline the mechanism, also imposing the commercial and operational value of recycling and regeneration through collective participation in the mechanism. This participation must allocate properly distributed charges and not dump the full weight of such a delicate operation, as important from an environmental point of view as it is from a plant engineering point of view, on a single link in the chain.”
This concerns the “old” fluorinated coolants, but we have natural coolants on the horizon along with certain complexities inherent in their management.
“If we refer to flammability, this is undoubtedly a delicate matter, to be tackled on several fronts: on the one hand, opening up technological horizons, including those at European level, to the use of these solutions, but even before that (and once again), radically reviewing a legislative approach which, particularly in the case of Italy, creates a series of considerable difficulties for those working in the sector. The topic of security is overseen by national legislation that is so stringent that those who try to work in this direction find themselves walking on a minefield. However, it should be noted that in commercial and industrial refrigeration, CO2 and NH3 have taken on a widespread form as future standards. Other European countries, where legislation on the matter is not so stringent, are definitely not areas where episodes of explosions or frequent fires involving systems containing coolants such as propane or ammonia occur all the time, so a standardisation of the regulatory profile would allow Italian manufacturers and fitters operating in this segment to adopt efficient solutions with less impact.”
You touched on the subject of efficiency and this is something of here a provocation: the GWP measures the impact of gas, not the impact of the plant (with the higher consumption and the higher emissions necessary to generate cold with gas with a lower refrigerating capacity) …
“That’ s true, but it’s also true that this is still a topic overseen by another line of legislation, the Ecodesign Directive and its rules of application on machines and equipment that generate temperature control. Compliance with Regulation 517 and the use of coolants in line with the established phase down does not exempt us from manufacturing machines that comply with the Energy Efficiency Directive, so while it is true that the Total Equivalent Warming Index measures the impact of the plant more correctly, it is also true that those who comply with the Regulation and the Directive can feel at ease in a market that combines these two restrictions to define the excellence of the result.”
But is the hope (rather than the expectation) of a single text so unrealistic and implausible?
“It would be necessary if common sense were to prevail, but a very clear political commitment and an investment of human resources and technical preparation would be necessary to tackle the problem. Taking the issue of coolants in hand requires a strong decision by government, which will lead to the address of these issues in a manner that is able to protect innovative and productive Italian excellence in this sector, with an attitude of positive and tangible surveillance of the issue. Unfortunately, this is not the case. We can see this in simple examples: the current dimensions of the work of the Ministry of the Environment make it difficult for the Ministry’s staff to keep up with all aspects, including the serious issue of imports, with consequences that make it easy for things to go wrong in plants that “swallow” uncertified drop-ins and are extremely risky.”
A consistent and also rather sharp destructive side: constructive elements?
“We are constantly working with operators and industry associations to propose interventions that are mutually beneficial, capable of generating positive results in a win-win logic. A situation that we have been working on for some time is that of linking energy efficiency incentives with the use of coolants with a lower environmental impact: with the same energy efficiency, it is much more sensible to encourage the adoption of appliances that use coolants with less impact rather than to generally encourage energy efficiency and this would also be a very strong incentive for promoting increasingly widespread industrialisation and the increasingly widespread marketing of machines that adopt systems with a reduced greenhouse effect. But this is simply an example. If we want to go back to what we said earlier, we are clearly in favour of the consortium’s approach to recycling, regeneration and controlled disposal and of other initiatives aimed at generating environmental benefits without harming the market, but rather promoting it commercially and culturally.”
So basically, you are proposing a broader concept of green marketing
“A decidedly broadened green marketing, which raises the question of which solution is most sustainable, not just in terms of consumption, but also in terms of the life cycle of the product, its final disposal costs and its environmental impact costs resulting from more or less environmentally friendly design and technology choices. The incentive that associates energy saving with the choice of coolants with less impact is one of the possible virtuous practices, because it would not trigger a race, but certainly attention to products that have higher industrial costs and therefore a higher final price that would be made accessible to more substantial market segments on the demand side thanks to incentives.”
Is this argument also applicable to the specifics of commercial refrigeration?
“Certainly: it is plausible to assume that the over-amortisation granted for the replacement of plants according to criteria of energy efficiency is applied in combination with the adoption of rewarding coolants in terms of limiting the greenhouse effect and of lower GWP, an instrument that would align our country with Germany, which has already regulated incentives in this area, creating conditions of reasoned staggering of the replacement of plants and avoiding the risk of finding ourselves, as we said before, facing a dangerous bottleneck.”
What are the risks of this bottle neck?
“Simple: those who have not replaced the systems will have to choose whether to buy new generation synthetic coolants for drop-ins at costs imposed by the offer or to wait for cooling cabinets equipped with sustainable, natural or innovative refrigeration technologies. Both conditions are disadvantageous, because they put the end user in a position to depend on the offer in terms of prices, delivery times and so on. An experience that the replacement of R404 has already anticipated and which we believe nobody wants to undergo.”
And then there is the question of competence: is the market ready to use the new solutions available?
“This is perhaps the most fragile aspect of the transition: while those producing synthetic gases are making considerable efforts to present increasingly interesting mixtures to support those who are adopting this line – particularly in the area of HFOs – fitters and maintenance technicians who are certified to handle natural coolants account for just 2 or 3% of the operators on the market. Today this is the crux of the matter, we are talking about an enormous amount of work to be carried out in order to have professionals capable of using the variety of solutions available, going beyond the standard solutions that marked the period prior to Regulation 517.”
But what prevents a significant category from making this transition of technological skills that legislation and the market have now written as necessary?
“There are two concurrent phenomena: the first is the lack of space, opportunities, specific training resources, lack of schools for new recruits and test benches to certify existing skills. On the other hand, the category has a demographic problem, which is also very important for the conformation of the typical company, individual or with very few employees, and linked to often “traditional” skills related to the law of “it has always been done like this” and where professional updating is seen, sometimes, as oppressive and imposed. Two factors that end up generating the risk that supermarket managers will be unable to find technicians capable of replacing cooling cabinets with state of the arts cabinets and then managing and maintaining them.”
And then there is another factor of methodological innovation, digitalisation, which is available at an increasingly lower cost, but implicates the cost of learning …
“Digitalisation is also a challenging skill, because it requires professionals with an open mind that only a generational change can perhaps make available to the end user, but another possible phenomenon is that of aggregation or integration into networks, in which the thermodynamic sensitivity of the “traditional” refrigerator technician is combined with the digital management ability of the new operator in possession of these new techniques. This is a desirable scenario, because it would safeguard employment and generate a space for professional qualification, destined to become a carbon footprint manager, a manager of the overall impact of the plant, who installs and maintains it.”
The laborious start of a virtuous path
Vincenzo Scarano, on the other hand, is worried about the present, but confident in the future. His vision is undoubtedly more operational and closer to the everyday problems of companies in the supply chain and what he illustrates is a scenario in which the present moment, delicate and full of uncertainties, can be overcome successfully thanks to the excellence of Italian intellectual capital in the sector
“The GWP has introduced the issue of the greenhouse effect into the dictionary of refrigeration technicians once again, but in a peremptory way. A situation that was previously out of control now sees the refrigeration and air conditioning sector at the forefront in reducing the environmental impact of its work. This is an undeniable and important result of Regulation 517 and we can say that the goal has been achieved: the instigators of the Regulation wanted to put the subject at the centre of the work and they have succeeded.”
But is it a “positive” index or just a restriction?
“It is a restriction that primarily affects the manufacturers of machines who are engaged in releasing onto the market equipment that is destined for a “serene” life and not involved with drop- in “substitutes” from the very beginning. It also effects maintenance operators, who will have to deal with a fleet of coolants that are different from the old standard solutions.”
But maintenance operators already have to cope with the need to bring machines and systems with coolants that are no longer usable and often no longer available on the market to the end of their life.
“And here we enter a very delicate area: on 1 January 2020, it will no longer be possible to use coolant gases with GWP in excess of 2500 in service or maintenance activities in systems with a total charge of more than 40 tCO2 equivalent. This deadline is going to be very hard to meet and there seems to be a widespread hope that the deadline will be postponed, allowing a less drastic transition.”
But what’s stopping us from dealing with the problem right now?
“The big companies I meet are already working, but below a certain threshold people are waiting to see what’s going to happen and are not yet taking action. They are disorientated, as are the technicians in the cold sector, by the plethora of solutions and alternatives available on a market which, until just a few years ago, had unquestionable milestones, such as R22. And another important player in the supply chain, the component manufacturer, has also had to deal with this explosion of alternatives, finding himself needing to approve components no longer for a limited number of coolant gases, but for a much larger quantity, with extremely high certification costs for each individual approval. These costs are often hard to amortise because a model of compressor approved for three gases, for example, is more interesting from a “general” point of view but is actually sold to be used with one gas and not with all three alternately.”
Must we face the situation with bated breath?
“Many manufacturers of machinery today are waiting to know which gas they can use because they will have to deal with the availability of components required to introduce these gases into the circuit. The situation is starting to improve, but at the moment (this interview takes place at the beginning of June) there is still a lot of caution and hesitation in making decisions. It might turn out that I am wrong and I would be happy to discover that the market has what it takes to cope with this demanding phase down. To date, this is not yet clear.”
Is there a “macro” cause of this phenomenon?
“The obligation to have a lower GWP has led to a search for solutions. As we have already said, this search might have been excessively accentuated, causing real confusion, but there is more: for the moment, research has introduced onto the market products that largely comply with the GWP thresholds but which also introduce another delicate problem to manage, flammability. In this case, the transition is expanding, no longer “simply” limited to the product and its refrigerating characteristics, but involving system and installation choices that focus on the aspect of safety, an essential element when it comes to gases, included those classified as just A2L.”
In this sense, the world of synthetic gas has “aligned” itself with that of natural gas…
“Yes, if before we were able to distinguish between different problems with – on the one hand – natural coolants like propane, isobutane and ammonia, which have considerable cooling capacities but are flammable, and, on the other hand, synthetic solutions that did not have this problem, the situation has now been rebalanced, so to speak: many of the synthetic products available are slightly flammable meaning that fitters and maintenance technicians are forced to observe stricter, more stringent working methods and rules. The only coolant with no flammability problems is CO2 but it has other problematic characteristics so we have to deal with system sealing and pressure requirements that are different from those found traditionally. And it doesn’t end there: the change of coolant in the system introduces the obligation to change the technical file and to check the need for a new PED marking; another workload that the maintenance technician has to undertake in order to certify the safety of the system.”
A scenario in which machine manufacturers are moving forward “strongly” too
“There are those (and we are talking about very large companies, particularly in the air conditioning sector) who have opted for R32, and those who have chosen other options for reasons of commercial differentiation or for more specifically technological reasons… The choice of coolants take place on a global scale and this introduces a further element of characterisation of the market, which in some way combines the oligopoly of gas producers with the power of influence of the big players over all their competitors. This is a sphere within which the technicians in the refrigeration sector, downstream, are responsible for making the best use of technology that the market ends up imposing on them.”
But this is a more specific aspect of air conditioning, while in refrigeration the panorama of possible solutions is more articulate. Returning to GWP, as we have already said, this is an index that measures the low specific impact of the gas, not the overall impact of the coolant…
“The debate is definitely wide open: a low GWP can also be connected to a lower cooling capacity, which requires more work by compressor, evaporator and so on, and, in some cases, higher energy consumption (and higher total environmental cost). The attempt to escape from the dependence on synthetic gases or patented products owned by big groups sometimes leads us to underestimate the energy costs of alternative choices, which are attractive, thanks to their “green” label, but ultimately offer poorer performance and are less efficient which all the figures have been taken into consideration – by the TEWI. Transcritical CO2 has been and continues to be one of the most flourishing areas of discussion on this point: we are talking about a non-flammable gas but a technology that had inefficiency problems that have been solved by some market leaders who are now taking advantage of the effort made in terms of R&D to ensure that this gas is handled gas properly. All this shows that the situation is far from standardised and the horizon is extremely jagged, with no univocal solutions.”
But solutions can be compared and decisions can be made.
“Yes, but the comparison must be made on the basis of fair comparability: today we have to compare “modern” plants or applications with natural gases like transcritical CO2 with equally modern and technically advanced plants or applications that base their operation on the use of synthetic gases. Only by making this comparison in these terms are we really in a position to choose the right solution. Comparing “old” systems with synthetic coolants with modern structures and equipment is as unfair in form as it is in substance. If we want to make correct calculations on revamping, we must not compare the old R404 plant with a new ammonia plant, but analyse (and perhaps even choose) ammonia from among a range of technologically “current” solutions.”
Are there any units of measurement that take these factors into account sensibly?
“They exist and are used, but on very large scales: we are talking about LCCP, Life Cycle Climate Performance, which goes so far as to include the costs and impact determined by the production of the plant, but we are talking about a level which has no reason to exist, at least not right now, below certain thresholds of critical mass, while comparative reasoning on the technologies currently available already pushes us towards greater feasibility and applicability of these working methods.”
In short, the work of those operating in the sector is becoming more and more complex.
“A few years ago, refrigeration technicians used to travel in a van with just one type of coolant. Nowadays, the range of products available, the variety of systems, end users with increasing demands for customisation, the need to work under exceptional economic pressure and (albeit lower) pressure at environmental level, make the use of one type of coolant impossible. The watchword is diversification, not at commercial level but in relation to a need, a design and plant engineering need, consubstantial to the current market which no longer accepts standardisation because it creates considerable diseconomies, even on the smallest scales. We are moving towards a universe made up of small niches, of system models that will somehow end up differing clearly from each other even if the same size is used, because it will no longer be the size or the coolant that guides the system, but the temperature, humidity and quality of performance that the system must achieve in a precise environmental and production context.”
An almost total downsizing and transformation of the working style of the recent past.
“Today in the synthetic gas sector there is no killer application and in the natural gas sector, too, it seems possible to find a product capable of solving all the problems. The outcome? That – as in many other fields of technology – we have to reason in terms of goals and this makes the role of technicians, fitters and maintenance operators essential. They have to learn how to deal with flammable gases that they have never come into contact with before. The flammability of coolants has generated the need for specific training, which also serves as a method for exemplifying the potential transformation of this role epoch: they have the potential to become carriers of skills that are currently “confined” in the world of research and development of manufacturers of machinery, components, gas.”
But how long will this “cultural transition” take? How long will it be before the end user embraces these ideas?
“For this cultural transition to take place, we have to reach a point when end users become aware of at least the minimum set of variables involved: as long as they see the legislation as a barrier to be overcome or as an increasingly recurrent fixed cost, they aren’t interested. This is a far-reaching goal because it means that the fitter is no longer a supplier to the end customer but a consultant, an ally in the informed choice and awareness of the solution best suited to their goals, to be clearly defined before operation, whether it is a new construction, a revamping, a retrofit or a simple drop in. The maintenance technician will not only have to do what is asked of him, he will also have to propose smart solutions to guide the end customer towards a correct use of the tool that the fitter installs.”
It seems almost the best possible world …
“This is not a dream or an ambition that can be reserved for the few. It is not a law that obliges us to choose the most far-sighted approach in terms of environmental impact, it is a rule that relates the plant to the use and calculation of the total cost of its implementation and maintenance for its expected life: if we want something that works for the next five years and are aware of the fact that we are going to dismantle it in five years’ time, then there is no point in investing with costs that can be reasonably amortised over the long-term. The real discrimination will be the serious and clear sharing of customer goals and the use of appropriate solutions by refrigeration technicians to achieve these goals.”
“The solutions that the market is unveiling are increasingly positive in overall terms but require systemic and non-isolated management. Meeting Regulation 517 or the Ecodesign Directive must not become a burden but a tool for assessing the best opportunities available to fully affirm the meaning of the word “sustainable”. Today, sustainable means environmentally sustainable and I hope that sustainable also means economically sustainable, without having an impact or at worst having only the slightest impact. This word must become a union of needs that are only apparently different, because – we mustn’t forget – the costs of failing to contain the impact are economically tangible both in terms of health and of the loss of efficiency of the workforce.”
Is there a way out of this moment of great confusion, of this foggy situation?
“The way out can emerge from the fact that our country has an important cultural and technical leadership in the production of equipment and machinery, a leadership that can become a key factor in guiding the market towards a smart approach to the problem and towards an intelligent and applied way of using technology that takes advantage of the increasingly wide range of possible solutions and makes them available in a targeted manner and in accordance with the goals and requirements of users. We have a proven capital of know-how, which can make our production sector a promoter of a technical and plant culture that takes us beyond this fog of gas.”