Using flammable refrigerants
Guidance for the occupier of premises and for other duty holders to help manage the risks associated with gases containing class 2.1 flammable refrigerants in refrigeration and air conditioning systems.
Flammable gases
Flammable refrigerant gases are refrigerant gases classified as Division 2.1 flammable gases under the Australian Dangerous Goods Code or classified as Flammable Gas Category 1 using the Globally Harmonized System (GHS).
The risks
Flammable gases can easily ignite and be potentially explosive. Workplace incidents involving flammable refrigerant gas have caused death, serious injury and property damage.
Leaks
Small gas leaks can cause catastrophic events. Leaking compressed gases can quickly fill a room or confined space, with the accumulated gas remaining within its explosive range.
Flammable gases that are denser than air are dangerous because they can travel considerable distances to ignition sources.
Damaged cylinders
Cylinders dropped, struck, impacted or ignited can cause gases to disperse or rupture and explode. Treat cylinders carefully and do not roll along the ground, drop or throw them when loading.
Toxic mix
Combustion products of some refrigerants and mixtures are toxic. For example, halogenated refrigerants can release two dangerous chemicals hydrogen fluoride or carbonyl dichloride (phosgene) in a fire.
Some refrigerants are a blend of gases called zeotropic mixtures. When there is a leak, the composition of these refrigerants can change because they have different boiling points and can create unpredictable hazard properties.
How to manage the risks
Mark and label systems
Mark and label service access points, refrigeration systems and machinery room entries containing flammable refrigerants.
Mark and label with warning signs stating that these systems contain class 2.1 flammable refrigerants.
Clearly mark flammable refrigerants in gas cylinders with one of the class 2.1 flammable gas labels.
Manage equipment location
Managing the location of equipment containing flammable refrigerants can help reduce the risks associated with flammable refrigerants. This can be done by:
- putting refrigeration and air conditioning equipment in a well-ventilated area outdoors and above ground
- using additional risk controls to prevent the dangerous accumulation of leaked refrigerant in any space when its unavoidable to store refrigeration and air conditioning equipment outdoors
- limiting the quantity of refrigerant in a refrigeration or air conditioning system confined, or ducted into, a building. If this limited quantity of the refrigerant leaked into the space, it would not create a concentration in air above 20% of lower flammable limit (LFL).
Use compatible refrigerant gases
Refrigerant gases should be compatible with the refrigerant system. A person with training and experience in refrigerant gases should decide if refrigerant gases are compatible. For example, when deciding if flammable refrigerants can replace non-flammable refrigerants.
A qualified or registered engineer can also complete an assessment to decide if a system can be converted to use a flammable refrigerant.
Use refrigerant odourants
Refrigerant odourants, such as mercaptan, can provide a warning of refrigerant leaks by emitting an unpleasant smell when released.
Risk control measures to reduce fire and explosions
Limit the quantity of flammable refrigerant injected into refrigeration or air-conditioning systems within a confined area, ducted into a building or an enclosed space.
Ensure a concentration of RFG does not reach above 20 of its lower flammable limit (LFL). Use the following Flammable refrigerant charge table to decide when to put these additional risk controls in place.
Flammable refrigerant charge table
Refrigerant (Click to sort descending) | Charge limit* (Click to clear sorting) | Maximum allowable charge^ (Click to clear sorting) | Control measures# (Click to clear sorting) |
|---|---|---|---|
R32 | 61.4 | 11.97 | Yes |
R142b | 65.8 | 12.83 | No |
R143a | 56.4 | 11.00 | Yes |
R152 | 26.0 | 5.07 | No |
R290 | 7.6 | 1.50 | No |
R600a | 8.6 | 1.50 | No |
R1234yf | 57.8 | 11.27 | Yes |
R1234ze(E) | 60.6 | 11.82 | Yes |
R1270 | 9.2 | 1.50 | No |
Table notes:
* Charge room limit g/m3 of net room volume (based on LFL)
^ Maximum allowable charge per system in the enclosed space (kg)
# Can the charge limit in either column be exceeded if risk control measures are used
Additional risk control measures could include using detectors such as:
Gas detectors in air conditioning spaces
Use gas detectors inside the space being air-conditioned. These gas detectors should be alarmed and interlocked to ensure a failsafe isolation shutdown of the air-conditioning system if there is a flammable gas leak.
Floor level flammable gas detectors
Use floor-level flammable gas detectors when refrigeration equipment is within a building. These gas detectors should be interlocked with a floor-level mechanical extraction system and have an alarm that activates when there is a gas leak.
The detection and extraction system should be at floor level because most flammable refrigerants are heavier than air. Operate the mechanical extraction system continuously if there are no gas detectors installed. Other risk control measures could include:
- eliminating ignition sources where possible
- having emergency procedures for a gas leak
- keeping equipment maintenance and repair records, including date, contractor's details and other relevant information, use of ultrasonic leak detectors to detect the ultrasonic sound of a leak
Refrigeration engineers, technicians, service persons and emergency responders need to be aware of the hazards associated with flammable refrigerants, including the need to use appropriate gas detection equipment.
If uncertain about how the system is charged, proceed with extreme caution and identify the refrigerant, by testing if necessary, before engaging with the system.
Legal duties
Occupiers of premises must identify all hazards and use appropriate risk controls to comply with the Dangerous Goods Act 1985 and the Dangerous Goods (Storage and Handling) Regulations 2022 (Regulations).
Under the Regulations, occupiers must obtain current material safety data sheets (MSDS) or safety data sheets (SDS) from the supplier of the refrigerant on or before the first supply to the workplace.
An occupier of premises where dangerous goods are stored and handled must ensure that the current SDS is readily accessible to persons engaged by the occupier to work at the premises, the emergency services authority and any other person on the premises and ensure that the information in the SDS is only altered if permitted or required by these Regulations.
Other duty holders include:
- Importers and manufacturers of flammable refrigerant gases
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).
Safe Work Australia (SWA) Classifying Chemicals
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) before it is first supplied for use and label.
Model Code of Practice: Preparation of safety data sheets for hazardous chemicals
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.
Importers and the manufacturers must correctly pack refrigerant gas classed as a hazardous chemical in compliance with the Dangerous Goods (Transport by Road or Rail) Regulations 2018. For flammable gases or gases under pressure, they must comply with the Australian Dangerous Goods Code (ADG Code).
- Designers of refrigeration systems
Under Occupational Health and Safety (OHS) legislation, designers of plant, such as refrigeration systems, intended for use in the workplace, must ensure so far as is reasonably practicable, that it is designed to be safe and without risks to health if it is used for a purpose for which it was designed.
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.
Designers of mobile, portable or stationary refrigeration systems that use, or are compatible to use with flammable refrigerants must ensure that it is designed to control any flammability hazards and risks and any other hazards or risks associated with the refrigerant, so far as is reasonably practicable. Designers should have relevant experience and training, including accredited courses run by registered training institutes or equivalent where available.
Flammable refrigerants may be odourised to aid their detection.
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.
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.
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.
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.
- Manufacturers and suppliers of refrigeration equipment used in workplaces
Under OHS legislation:
- Manufacturers and suppliers of refrigeration equipment must ensure, so far as is reasonably practicable, that it is manufactured to be safe and without risks to health if it is used for a purpose for which it was manufactured.
- Manufacturers and suppliers of refrigeration systems must give adequate information to each person to whom the supplier supplies the plant or substance. 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.
- Manufacturers and suppliers of refrigeration systems for use in workplaces should have relevant experience and training, including completing relevant units of competency or equivalent.
- Refrigeration technicians, engineers and businesses that install or maintain workplace refrigeration systems
Under OHS legislation, the installer of a stationary or mobile workplace refrigeration system must eliminate risks associated with the installation of 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.
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.
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.
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.
If plant such as registerable pressure vessels is involved, re-registration by the WHS/OHS regulator may be required.
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.
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.
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 to manage risks to health and safety.
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.
- Installers of complex refrigeration systems may hold relevant tertiary qualifications
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.
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.
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
Businesses employing refrigeration technicians must, so far as is reasonably practicable, develop and maintain safe systems of work for working with flammable refrigerants.
The following are examples of safe work procedures for businesses:
- Confirm the type of refrigerant present.
- Do not top up a refrigeration system without first checking for and fixing any leaks.
- 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.
- Whenever a flammable refrigerant is placed in a vehicle air-conditioning system, display 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.
- 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.
- An occupier of premises where dangerous goods are stored and handled must ensure that any risk associated with any atmospheric conditions that are flammable, explosive or asphyxiantis is eliminated or if it is not reasonably practicable to eliminate the risk, is reduced so far as is reasonably practicable.
- 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. 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.
- 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 and maintenance and the details of the competent person who conducted the inspection and maintenance.
- Flammable refrigerant gases are used in refrigeration or air-conditioning systems
The occupier or person in charge of premises 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.
The occupier or person in charge of premises should ensure that only competent workers work on air-conditioners and other refrigeration systems, particularly those containing flammable refrigerants.
Regulation 25(1) of the Dangerous Goods (Storage and Handling) Regulations 2022 imposes a duty on the occupier. The occupier must ensure that workers and any health and safety representatives (HSRs) are provided with induction, information, training and supervision on the hazards and safe use of the specific refrigerants to which they could be exposed.
Gas detection equipment should be installed to manage the risk of leaks from larger systems.
Before using flammable refrigerants as a substitute to re-gas a refrigeration system designed for less flammable refrigerants, the occupier or person in charge of premises needs to obtain written advice from a competent person. The competent person, preferably the system’s designer, manufacturer or supplier, needs to provide written advice about the suitability of the specific refrigerant for the system and the required safety controls or system modifications.
An occupier of premises where dangerous goods are stored and handled must ensure that the risk associated with chemical and physical reactions between the dangerous goods and other substances or articles at the premises is eliminated or, if it is not reasonably practicable to eliminate the risk, is reduced so far as is reasonably practicable. That includes having systems in place to ensure that if additional refrigerant is required in the system, the same type of refrigerant as is in the system is used to eliminate the interaction of non-compatible dangerous goods.
The occupier or person in charge of premises 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.
The occupier or person in charge of premises 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.
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.
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 occupier or person in charge of premises 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.
The occupier or person in charge of premises 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.
The occupier or person in charge of premises 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.
- The recovery, reclamation or disposal of refrigerant gases
The occupier or person in charge of premises 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.
The occupier or person in charge of premises 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.
The occupier or person in charge of the premises must ensure that workers undertaking recovery, reclamation or disposal activities and any HSRs are provided with relevant information and training on the hazards and safe handling of the specific refrigerants they handle.
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.
The occupier or person in charge of premises 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.
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.
It is good practice to recover all synthetic refrigerants, including those for which recovery is not mandatory, for example R1234yf.
The occupier or person in charge of premises should have recovery units and cylinders suitably rated and labelled for refrigerants likely to be encountered.
The occupier or person in charge of premises involved in recovery, reclamation or disposal of refrigerant gases should refer to relevant standards and guides for information on requirements under other legislation.
Australian Standards
- AS ISO 817:2016 Refrigerants - Designation and safety classification
- AS 5149.1:2016 Refrigerating systems and heat pumps - Safety and environmental requirements
- AS 60079.10.1:2009 Explosive atmospheres - Classification of Areas - Explosive gas atmospheres
- AS 60079.14:2009 Explosive atmospheres - Electrical installations design, selection and erection
- AS 60079.17: 2017 Explosive atmospheres Electrical installations inspection and maintenance