Stakeholders debate whether to ban disposas

By Ilana Koegelenberg

The room was packed at the 6 December HCFC stakeholder meeting where a proposed disposable refrigerant cylinder ban was to be discussed for possible inclusion in the updated ODS regulations. 

The quarterly HCFC stakeholder meeting took place at the Sierra Burgers Park Hotel in Pretoria instead of the usual meeting room at the Department of Environment Affairs (DEA). The meeting was very well attended and various stakeholders flew in from all over the country to have their voices heard, particularly on the issue of disposable refrigerant cylinders. This was to form part on the discussion of the update currently in progress for the Ozone Depleting Substances (ODS) regulations.

HCFC00 1Margaret Molefe of DEA asks a question during the stakeholder meeting about whether the country could look into locally manufacturing disposable refrigerant canisters.

But first, a few other formalities and agenda items. The meeting was chaired by Obed Baloyi, chief director: Chemicals Management at DEA who passed around a microphone for all stakeholders present to introduce themselves and clarify which companies they represented. There were a few new faces in attendance.

The first order of business was to adopt the agenda and then to work through the minutes of the previous meeting as well as the action points identified to see if it had been done.

Reclamation machine updates

Before the HCFC stakeholder meeting, a small task team met to discuss the reclamation machine pilot project and iron out some of the logistics and details required for these four machines to be put in the field and used.

The four sites have been selected and the reclamation machines, which were donated by the United Nations Industrial Development Organisation (UNIDO), should arrive at their new homes in the first quarter of 2019. They are currently being housed at Acon in KwaZulu-Natal still.

One machine will remain in KZN at Acon and the rest will be transported to: Afrox in Port Elizabeth, Refrimate in Gauteng, and Capricorn Technical and Vocational Education and Training (TVET) College in Limpopo.

The task team discussed the training done for each of the companies housing the machines, as well as the pending memorandum of understanding (MOU) that was still to be signed between the companies, DEA and UNIDO.

It was confirmed that an air quality licence wouldn’t be needed to operate the machines, however, feedback on whether a waste licence is required, is still pending.

An official launch of the pilot project is expected in the beginning of 2019.

ODS regulation amendment

As proposed in the previous meeting, a discussion was tabled investigating the pros and cons of the proposed phasedown of disposable cylinders. This was to allow DEA to consider all aspects before making a choice.

As such, Lutendo Ndlovu of DEA presented a collation of all the comments received by stakeholders on this point, highlighting the advantages and disadvantages of banning the use of disposable cylinders as refrigerant containers.

The presentation first looked at the environmental, economic and social benefits, and costs if disposables were to be banned. It then looked at the disadvantages under the same headings.

Ndlovu read out all the comments as is, with the section opposed to the disposa ban being significantly lengthier with pages and pages of comments addressing how such a move would negatively affect not only industry but the country as a whole, and even the environment.

Baloyi proposed that for the next meeting the comments be edited and presented in a tabulated manner as to better compare the arguments.

In the meantime, the floor was opened to discuss the points, Baloyi kicking things off with the question ‘what is the problem with disposa cans?’

The proposed ban on disposables stemmed from the 2017 Phakisa where it was proposed that phasing them out would allow the establishment of an SMME to manufacture refillable cylinders locally and create jobs. The concern of the heels remaining in emptied disposas being vented and destroying the environment was also highlighted.

Most of the wholesalers were represented at the meeting, including Beijer Ref, Eurocool and Kovco. The majority of stakeholders were against the proposed ban.

Various neutral parties also got involved and John Ackermann of the Southern African Refrigerated Distribution Association (SARDA) made the point that we don’t know how long disposable cylinders will still be produced globally. We cannot produce these locally and are wholly dependent on imports. Should there be a global ban, we would not be prepared for the situation.

Dr Pieter Aucamp, who serves on the United Nations Environment Programme (UNEP)’s Environmental Effects Assessment Panel (EEAP), suggested that rather at looking at banning disposas, which obviously is being met with too much resistance, it should rather be consider how to dispose of them safely without harming the environment and releasing harmful substances into the atmosphere.

Baloyi assured everyone that the government doesn’t want to take decisions that will have a negative impact on the industry or the country.

Ackermann then asked whether the ODS regulation amendment will be held up until this very controversial issue was resolved as it was critical that other updates such as the requirement for log books for plant rooms be added to the ODS regulations as soon as possible. The ODS regulation update was already long overdue. “We are overlooking the very important issue of safety,” Ackermann said.

Baloyi indicated that perhaps they should go ahead with the amendment and deal with this point in a future update rather as to not hold up the regulation. He then closed the floor for comments on this matter.

HCFC consumption figures

Ndlovu then presented the HCFC import figures of January 2018 to current (6 December 2018), based on recommendation made by DEA to the International Trade Administration Commission (ITAC) for the issuance of the import and export permits in 2018. These figures thus show the permits issued and not necessarily the actual amounts imported / exported.

R22 consumption (imports minus exports) was at 138.6 ozone depleting potential (ODP) tonnes or 2 519.5 metric tonnes with other HCFCs being significantly lower.

The total HCFC consumption for 2018 looked as follows:





Metric tonnes

3 062.086


2 572.71

ODP tonnes




Our baseline was set at 326 ODP tonnes, which means that for 2018, where a 25% reduction was required, we had to consume less than 244.5 ODP tonnes to make our target. Our consumption was only 140.83, which leaves us well within our phase-out target as stipulated by the Montreal Protocol.

The team said that they will be able to present the exact, actual figures at the next meeting, as collated by the South Africa Revenue Service (SARS).

Use of 134a in automotive industry

A representative from National Association of Automobile Manufacturers of South Africa (NAAMSA) then gave feedback in terms of the use of refrigerants in the automotive industry, speaking on behalf of manufacturers and importers of new vehicles only (excluding refrigerated transport units).

He mentioned that although R1234yf was presented as an alternative to HFC134a almost 15 years ago already, the uptake has been slow locally – mainly due to cost. It was confirmed that more than 90% of local vehicles manufactured locally and exported into Africa still use R134a as refrigerant.

Kigali Amendment ratification

DEA advised that we are still waiting for a date to take up the matter in parliament. Until then, South Africa cannot ratify the Kigali Amendment to the Montreal Protocol.

HCFC00 2The HCFC stakeholder meeting in progress at the Burgers Park Hotel in Pretoria CBD in December.

HFC consumption and tariff codes

As the revised tariff codes for HFCs is still in progress, it’s not yet possible to track the imports of these refrigerants. As such, DEA has requested the figures from importers and will present it at the next meeting in March 2019.

According to SARS, the tariff code document is currently with the deputy minister of finance and if approved, it will be gazetted.

Meetings and training

In terms of the progress for the training of informal service technicians, a project steering committee has been formed and will meet again early in 2019 to discuss training materials and curriculums.

Compliance monitoring for the ODS regulations are busy compiling a report from a tipoff they received and will feedback in the next meeting. They also did various training presentations around the country to try and improve compliance. 

DEA then gave feedback briefly on other recent events such as the 30th Meeting of the Parties (MOP 30) to the Montreal Protocol on Substances that Deplete the Ozone Layer which took place in November 2018 in Ecuador as well as the local National Ozone Unit and Customs Twinning workshop and Border Dialogues for countries of the SADC region which took place in October in Johannesburg.

There was also another meeting with the Department of Energy to try and work together on mutual causes.

The next HCFC stakeholder meeting will take place on 6 March 2019. 



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