Quick answer
A leak creates three duties in sequence, and the third is the one that gets missed.
| Duty | Where | |
|---|---|---|
| 1 | Take all necessary precautions to prevent unintentional release, and all technically and economically feasible measures to minimise leakage. | Article 4(3) |
| 2 | Ensure the equipment or facility is repaired without undue delay. | Article 4(5) |
| 3 | Have the repair verified by a certified person — at the earliest after 24 hours of operating time, and no later than one month after the repair. | Article 4(5) |
That third step is a separate visit with its own window, its own qualification requirement and its own entry in the record. Closing the job at the moment the leak stops is closing it one step early.
How to make a leaking plant room safe — evacuation, ventilation, personal protection, first aid — is in the safety data sheet for that refrigerant, and it is written for that product. Sections 4, 5, 6 and 8, with the emergency number in 1.4. Nothing on this page replaces it.
Where the safety answer actually is
The F-gas Regulation is an environmental instrument. It does not tell a technician how to respond to a large release in a confined space, and reading it as if it did is a mistake with consequences.
The document that does is the safety data sheet for the specific refrigerant, in the fixed format set by Regulation (EU) 2020/878. Four of its sixteen sections carry the answer:
| Section | What it covers |
|---|---|
| 1.4 | Emergency telephone number |
| 4 | First aid measures — 4.1 the measures, 4.2 symptoms including delayed ones, 4.3 when immediate medical attention or special treatment is needed |
| 5 | Firefighting measures — extinguishing media, special hazards, advice for firefighters |
| 6 | Accidental release measures — 6.1 personal precautions, protective equipment and emergency procedures; 6.2 environmental precautions; 6.3 containment and cleaning up |
| 8 | Exposure controls and personal protection |
Because the order is fixed, these are findable in seconds — but only if the sheet is where the work is. A safety data sheet in the office filing cabinet answers nothing at two in the morning.
The repair clock, in full
Article 4(5) has two sentences, and both matter.
First: where a leakage of fluorinated greenhouse gases is detected, the operators and manufacturers of equipment, the operators of facilities where such gases are used, and the undertakings in possession of such equipment during its transport or storage, shall ensure that the equipment or facility is repaired without undue delay.
Second: where the equipment is subject to leak checks under Article 5(1) and a leak has been repaired, the operators shall ensure that the equipment is checked by a natural person who is certified in accordance with Article 10 — at the earliest after an operating time of 24 hours has elapsed, but not later than 1 month after the repair — to verify that the repair has been effective.
Too early is as wrong as too late. The 24 hours of operating time exist so the system has run under normal conditions before it is judged. A plant that has been off since the repair has not accumulated that time, whatever the calendar says.
Mobile equipment is different. For the mobile equipment listed in Article 5(3), points (a), (b) and (c) — refrigerated trucks and trailers, refrigerated light-duty vehicles, intermodal containers and train wagons, and air conditioning and heat pumps in heavy duty vehicles, vans, non-road mobile machinery, trains, metros, trams and aircraft — a leak check may be carried out directly after a repair.
Who is the duty on. Note the breadth of the first sentence: it is not only the operator. Manufacturers of equipment, operators of facilities where the gases are used, and undertakings holding the equipment during transport or storage all carry it.
What you may not do while dealing with it
- Vent the remaining charge to make the repair easier. Article 4(1) prohibits the intentional release of fluorinated greenhouse gases into the atmosphere where the release is not technically necessary for the intended use. Where an intentional release is technically necessary, operators must take all measures that are technically and economically feasible to prevent release as far as possible, including by recapturing the gases emitted.
- Recharge with gas that is off the servicing list. Article 13(3) prohibits a GWP of 2 500 or more for maintaining or servicing any refrigeration equipment; Article 13(4) does the same for air conditioning and heat pumps from 1 January 2026.
- Put the recovered charge straight back in. Article 8(6): recovered gases listed in Annex I and Section 1 of Annex II may not be used to fill or refill equipment unless the gas has been recycled or reclaimed.
- Be careless during transfer. Article 4(4) requires all necessary precautions to limit release during production, storage, transport and transfer from one container or system to another.
The gas that escaped was part of the charge. Recalculating the charge in tonnes of CO2 equivalent after a significant loss and a recharge is what keeps the leak-check interval under Article 5(6) and the detector question under Article 6 correct.
Leakage detection systems — and their own check
Article 6 is short and precise, and it is often quoted loosely. The exact thresholds:
| Paragraph | Equipment | Threshold |
|---|---|---|
| 6(1) | Stationary equipment in Article 5(2), points (a) to (d) | 500 tonnes of CO2 equivalent or more of Annex I gases, or 100 kg or more of Annex II Section 1 gases |
| 6(2) | Stationary equipment in Article 5(2), points (e) and (f), installed from 1 January 2017 | 500 tonnes of CO2 equivalent or more of Annex I gases |
In both cases the requirement is a leakage detection system which alerts the operator or a service company of any leakage. A sensor nobody is alerted by does not meet the description.
And the detectors themselves are checked:
- Article 6(3): for the equipment in Article 5(2), points (a) to (e), subject to paragraph 1 or 2 — leakage detection systems are checked at least once every 12 months to ensure their proper functioning.
- Article 6(4): for the equipment in Article 5(2), point (f), subject to paragraph 2 — at least once every 6 years.
Where a detection system is in place, Article 5(6) also doubles the leak-check interval: 24 months instead of 12, 12 instead of 6, and 6 instead of 3.
What goes into the record
A leak generates several separate entries in the Article 7(1) equipment record, and they are the entries an inspection reads first.
| Point | Entry |
|---|---|
| 7(1)(b) | The quantities of gases added due to leakage, including the date of each addition. |
| 7(1)(c) | The quantity of gases recovered. |
| 7(1)(d) | For gas added: quantity and type, whether recycled or reclaimed, and the facility's name, Union address and certificate number where applicable. |
| 7(1)(e) | The identity of the undertaking that repaired and checked for leaks, its certificate number where applicable, and — for a legal person — the natural person who performed the operations. |
| 7(1)(f) | The dates and results of the checks under Article 5(1), as well as the dates and results of any leak repairs. |
Point (f) is the one that closes the loop. The repair has a date and a result, and so does the verification check that follows it. Both belong in the record, and the operator keeps it for at least five years — as does the undertaking that did the work, in copy.
The sequence on the job
Make it safe using the safety data sheet, not the regulation
Sections 6.1 for personal precautions and evacuation, 4.1 for first aid, 1.4 for the emergency number.
Stop the loss and repair without undue delay
Article 4(5), first sentence — and the duty is not only on the operator.
Do not vent what is left
Article 4(1). Recover it if the repair requires the system to be emptied.
Recharge only with a gas the Article 13 thresholds allow
And not with the recovered charge unless it has been recycled or reclaimed.
Book the verification check before you leave
No earlier than 24 hours of operating time, no later than one month. Mobile equipment in Article 5(3)(a) to (c) may be checked directly.
Recalculate the charge in tonnes of CO2 equivalent
After a significant loss and recharge, the interval under Article 5(6) and the Article 6 detector question may both have moved.
Check the detection system if one is fitted
Article 6(3) requires a functioning check at least every 12 months for most equipment; Article 6(4) every 6 years for the equipment in Article 5(2)(f).
Write it all down
Quantity added and the date, quantity recovered, origin of the gas, who did the work, and the dates and results of both the repair and the verification check.
Common mistakes
- Closing the job when the leak stops. The verification check under Article 4(5) is a separate obligation with its own window.
- Doing the verification check too early. The earliest is after 24 hours of operating time, not 24 hours on the clock.
- Letting the month run out. The latest is one month after the repair.
- Sending an uncertified person to verify. Article 4(5) requires a natural person certified under Article 10.
- Venting the remaining charge to work more easily. Article 4(1) prohibits it where not technically necessary.
- Recharging with the gas that came out. Article 8(6) requires recycling or reclamation first.
- Recording the top-up without the date. Article 7(1)(b) requires the date of each addition.
- Recording the repair but not its result. Article 7(1)(f) asks for the dates and results of any leak repairs.
- Assuming a detector removes the check. It doubles the interval under Article 5(6); it does not remove it, and the detector itself is checked.
Checklist
- Safety data sheet consulted on siteSections 6, 4 and 8; emergency number from 1.4.
- Repair carried out without undue delayArticle 4(5), first sentence.
- Nothing vented that did not have to beArticle 4(1); remaining charge recovered where the repair required emptying.
- Recharge gas allowed under Article 13And not the recovered charge unless recycled or reclaimed.
- Verification check bookedBetween 24 hours of operating time and one month, by a certified person.
- Mobile equipment exception applied correctlyArticle 5(3), points (a), (b) and (c), may be checked directly after repair.
- Charge recalculated in tonnes of CO2 equivalentInterval under Article 5(6) and detector question under Article 6 re-answered.
- Detection system function check currentEvery 12 months, or every 6 years for Article 5(2)(f) equipment.
- Record completeQuantity and date added, quantity recovered, gas origin, undertaking and person, dates and results of repair and verification.
Frequently asked questions
Is repairing the leak enough?
No. Where the equipment is subject to leak checks under Article 5(1), Article 4(5) requires the operator to ensure the equipment is checked by a certified person to verify that the repair has been effective — at the earliest after 24 hours of operating time, and no later than one month after the repair.
Why 24 hours of operating time?
The regulation sets that as the earliest point. It is operating time, not elapsed time, so a system that has been switched off since the repair has not accumulated it.
What if the equipment is mobile?
For the mobile equipment listed in Article 5(3), points (a), (b) and (c), Article 4(5) states that a leak check may be carried out directly after a repair.
Who has to do the verification check?
A natural person who is certified in accordance with Article 10.
Can I vent the rest of the charge to do the repair?
Article 4(1) prohibits intentional release where it is not technically necessary for the intended use. Where it is technically necessary, all technically and economically feasible measures must be taken to prevent release as far as possible, including recapturing the gases emitted.
When is a leakage detection system mandatory?
Under Article 6(1), for the stationary equipment in Article 5(2), points (a) to (d), containing 500 tonnes of CO2 equivalent or more of Annex I gases or 100 kg or more of Annex II Section 1 gases. Article 6(2) adds the equipment in points (e) and (f) installed from 1 January 2017, at 500 tonnes of CO2 equivalent or more.
How often is the detection system itself checked?
At least once every 12 months for the equipment in Article 5(2), points (a) to (e), under Article 6(3); at least once every 6 years for the equipment in point (f), under Article 6(4).
What has to go in the record?
The quantity added due to leakage with the date, the quantity recovered, the origin of any added gas, the identity of the undertaking and the person who did the work, and the dates and results of the checks and of any leak repairs — Article 7(1), points (b) to (f).
Official sources
Articles 4, 5, 6, 7, 8 and 10 were read directly in the Official Journal text through the EU Publications Office.
Currency of this guide and limits of responsibility
This guide sets out the regulatory duties that follow a leak. It is not emergency guidance. The safety response for a specific refrigerant is in that product's safety data sheet and in your own emergency procedures, and both take precedence over anything here.
This is general information prepared by EgoLog from the regulation and official EU material. It is not legal or safety advice.
Workplace safety, confined space and fire legislation apply alongside the F-gas Regulation and are not covered here. Confirm them with your national competent authority.
