In 2019, Logicool Managing Director Karl Richardson proposed an initiative to REFCOM to improve professionalism within the supply chain, specifically to propose better management and understanding of F-Gas Regulations amongst wholesalers, distributors and resellers.
Logicool have, for several years attempted to interpret and implement the F-Gas regulation professionally and accurately. This has involved a lot of education amongst staff and customers as well as the implementation of numerous systems to build the business based on a ‘what if’ scenario. This ‘what if’ scenario was essentially based on the assumption that an inspection from The Environment Agency and/or Refcom may one day happen. Whilst we understood that installers were required to hold a Company F-Gas certificate there was confusion and potential ‘grey areas’ over whether the reseller should hold the same qualification. In addition, there were additional questions about whether the actual purchaser required the certification or whether evidence of the certification was adequate. If the latter was acceptable within the scope of the regulation, was this required in advance and was an engineer’s F-Gas qualification adequate? An example being a homeowner purchasing a system for a ‘jobbing engineer’. Is this legal? What is the impact to the purchaser, the engineer and the reseller?
Despite this confusion, Logicool have held Company F-Gas for over four years because we felt that it was the ‘professional thing to do’ despite not engaging directly with refrigerant. Whilst this was the case, we were acutely aware that we offered technical support with regards to information such as charging systems with refrigerant and similar technical support as well as onsite commissioning assistance. Was it ethical to not hold the same certificate as the installer due to the wording and potential interpretation of the regulation?
We also understood that it was essential that records of who we were selling to were retained and that we could report this in line with the requirements of the regulations. The internal systems required to manage this are not simple. They require a lot of daily management and a ‘will to implement’ from all staff. An employee cannot simply take an order for a system without knowing that the purchaser holds a Company F-Gas Certificate. The employee has a requirement to understand the difference between a Certificate and a Qualification as well as understand when and how to implement the regulation depending on what product is being sold and to whom. For example, a one-off sale for an electronic spare for a system does not require this additional information whilst a similar one-off sale for a service valve does. That sale, for possibly as little as £20.00 requires documentary evidence in the form of Company F-Gas and, more importantly, the employee must demonstrate the will to obtain this information from the client. These documents are then recorded internally and produced on internal daily reports, quotations, order confirmations and invoices as well as being retained within additional GDPR regulations in the event of future repeat sales to the same customer.
Earlier this year it became apparent to the Managing Director that Logicool may well either be working to these principles alone or within a very small minority. What was also apparent was the Logicool seemed to be the only reseller talking about the subject on Social Media. Whilst other Companies clearly appeared to be supporting F-Gas allegiance it was abundantly clear that there was confusion over Certification and Qualification (an F-Gas qualification for handling refrigerants is not adequate evidence) there was additional evidence that some of these companies did not actually hold the certification themselves because there was not necessarily a legislative need to do so.
Conversations between Karl Richardson of Logicool and Graeme Fox of Refcom over a very long period led to the conversation topic of ‘the spirit of the regulation’. It was this that formed the idea by Karl Richardson to Graeme Fox that there should be a new level of certification. Additional conversations with Environment Agency showed that their primary focus was larger end-users of refrigerants and control of illegal imports. Richardson’s argument was that trying to regulate from the bottom was tougher than regulating from the top of the supply chain. Whilst new regulation cannot be forced quickly and effectively, self-regulation could be proposed so that all suppliers in the UK would have the option of proving to the trade that they were above the regulations and intended to be better than they were expected to be.
The idea was proposed at a seminar hosted by Logicool where customers and suppliers were all invited. Inviting suppliers came as a direct result of Mr. Richardson’s involvement on Social Media. ‘Are you sure you want to attend, you are a competitor’ resulted in a number of resellers and manufacturers attending the same seminar as a number of installers, all with a common interest to improve the industry. Attendees including Daikin, MELCO, Panasonic, Fujitsu and Hitachi were joined by FSW, Hawco, Thermofrost, CDL, Wolsely, AMP and more. Ultimately it was more evident as to who was not attending and joining the conversation as opposed to who was attending. One major distributor went so far as to beginning immediate work on re-educating their entire business with regards to complying with the current regulations and one manufacturer in attendance went on to do similar as well as then invite all of their distributors to a similar event, also co-hosted by REFCOM.
The result of this effort saw the idea of a new type of certification by REFCOM with Logicool being the first recipient.
The next step is to continue the education, fight against illegal online sales and bring this conversation to a wider audience. Logicool have gone one step further already in refusing to sell equipment to those we know also sell online, despite the client legally holding Company F-Gas. This has caused financial loss but we believe that the knowledge that someone else is in breach of the regulations goes against our fight to ask our competitors to self-regulate.