Canada refrigerant rules: GWP limits, SOR/2016-137 and CSA B52

Responsibility is shared between the federal government and the provinces

In Canada responsibility for refrigerants is shared between the federal level and the provinces. The federal Ozone-depleting Substances and Halocarbon Alternatives Regulations (SOR/2016-137) are made under the Canadian Environmental Protection Act and implement Canada's commitments under the Montreal Protocol and the Kigali Amendment ^[1]. They govern the import, export and manufacture of ozone-depleting substances and HFCs and which new products may be manufactured and imported. The work with refrigerants itself, that is technician certification, the venting prohibition, leak repair and records, is largely regulated by the provinces and territories. Federal facilities and federal lands are the exception: the Federal Halocarbon Regulations, 2022 (SOR/2022-110) apply there ^[5].

The HFC phase-down

Since 2019 HFC consumption has been limited through allowances allocated to importers and manufacturers. The limit is lowered in steps according to the Kigali Amendment for developed countries: 10 % below the baseline from 2019, 40 % below from 2024, 70 % from 2029, 80 % from 2034 and 85 % from 2036 ^[1]. A smaller supply makes older high-GWP refrigerants more expensive, even where there is no direct ban.

GWP limits for new equipment

The regulations prohibit the manufacture and import of certain products that contain HFCs or blends with HFCs above a set GWP limit, with different limits and dates for each product type ^[1]. Some examples for refrigeration and air conditioning:

The bans apply to products manufactured or imported after the date. Existing equipment may still be used and serviced. Read the table in the regulations for the exact definitions and exemptions, and check the current version. The regulations have been amended several times ^[1]. The same schedule also sets a limit for mobile refrigeration systems (maximum GWP 2,200 from 1 January 2025), and the regulations limit the refrigerant in the air conditioning of new light-duty vehicles to a GWP of 150 from model year 2021.

Provincial rules: the example of Ontario

Each province has its own rules on how refrigerants are handled. In Ontario, Regulation O. Reg. 463/10, Ozone Depleting Substances and Other Halocarbons, applies and covers both ozone-depleting refrigerants and HFCs ^[4]. Anyone who works on refrigeration and air conditioning equipment containing such substances must hold a certificate, often called an ODP card. It is obtained after an approved course and an exam. Technicians certified in another province can apply for an Ontario certificate for a fee ^[3]. Four requirements of O. Reg. 463/10 matter in daily work ^[4]:

• Refilling is allowed only if the person is certified and a notice no more than six months old, affixed to the equipment, shows that it has no leaks. There is an exception where there is no reasonable alternative and failing to refill would cause immediate danger to life, health, crops or foodstuffs (s. 25).
• A certificate is valid for five years (s. 34(7)).
• Service and test records and the leak test notices must be kept for two years (s. 23(7)).
• A discharge of 100 kg or more of refrigerant must be reported to the ministry as soon as reasonably possible (s. 19(2)).

The provincial rules generally include a venting prohibition, requirements to recover the refrigerant during service and disposal, requirements for leak testing after repair and requirements for records. The details differ between provinces. Always check the rules in the province where the plant is located.

Federal facilities and lands: SOR/2022-110

The Federal Halocarbon Regulations, 2022 (SOR/2022-110) apply to air-conditioning and refrigeration systems owned by the Crown, a federal agency or a Crown corporation, belonging to a federal work or undertaking, or located on aboriginal lands or federal lands (s. 2(1)). Provincial rules do not govern these systems. Main requirements ^[5]:

• Only a certified person may install, service or recover halocarbon from a system (s. 14).
• Large systems (more than 10 kg of halocarbon) must be leak tested at least once every calendar year and no more than 15 months after the previous test (s. 17).
• A detected leak must be repaired, the leaking part isolated and its halocarbon recovered, or the halocarbon recovered, as soon as possible and within seven days (s. 18).
• Charging a system with halocarbon in order to leak test it is prohibited (s. 9).
• A release of 100 kg or more, or of more than 10 kg but less than 100 kg, must be reported to the Minister (ss. 24 and 25).

Safety: the CSA B52 Mechanical refrigeration code

The safety code for refrigeration systems in Canada is CSA B52. The 13th edition, CSA B52:23, was published in December 2023. Among other things it includes the groups A2L (lower toxicity, lower flammability) and B2L (higher toxicity, lower flammability) and rules for using them ^[2]. The code becomes binding when a province adopts it. Ontario, where TSSA is responsible, and Manitoba have adopted B52:23 ^[2]. Like EN 378 and ISO 5149, the code sets, among other things, the maximum refrigerant quantity in relation to the size of the room, requirements for machinery rooms, pressure relief and pressure testing.

Points to consider when designing in Canada

• Check the GWP limit for the product type in SOR/2016-137 before you choose a refrigerant for new equipment.
• Find out which edition of CSA B52 the province has adopted and whether it has added its own requirements.
• Make sure the technicians hold a valid certificate in that particular province.
• Plan for high-GWP HFCs becoming more expensive as the phase-down progresses.