Why are air conditioning inspections required?

As a result of the Energy Performance of Buildings Directive (EPBD) 2002 and the Energy Performance of Buildings Regulations 2007 , building owners and managers who control air-conditioning systems now have statutory obligations to have their air conditioning systems regularly inspected by a qualified air conditioning systems energy assessor.

The reasoning behind these inspections is to improve efficiency and reduce the electricity consumption, operating costs and carbon emissions for your system. Energy inspections will highlight improvements to the operation of your existing systems or opportunities to replace older, less energy efficient systems or oversized systems with new energy efficient systems.

When are air conditioning inspections required?

An air conditioning system refers to any system where refrigeration is used to provide cooling for the comfort of occupants. This excludes systems where the cooling is provided solely for process applications such as cold stores, pharmaceutical production etc.

The regulations require that:

  • For all systems first put into service on or after 1 January 2008, the first inspection must have taken place within five years of the date when it was first put into service
  • For other air-conditioning systems, where the effective rated output is more than 250kW the first inspection must have taken place by 4 January 2009
  • For other air-conditioning systems, where the effective rated output is more than 12kW the first inspection must have taken place by 4 January 2011

This means that if you have a system with an effective rated output of >12kW you already require an inspection and could be liable to a fine if you don’t have one.

The effective rated output is the maximum output (in kW) stated by the manufacturer of the system as deliverable during continuous operation while complying with the useful efficiency indicated by the manufacturer. One or more air-conditioning units within a building controlled by a single person are considered to comprise a single air-conditioning system for the purposes of the regulations.

How do I work out the size of my air conditioning system?

The effective output of an individual air conditioning unit or system may be given on the rating plate attached to the unit. It may also be stated in the operating and maintenance manual, if it can be located. Finally, the information may be available from the manufacturer’s website. Alternatively, where the system is covered by a maintenance contract, the capacity should be known by the contractor and should be reported in the maintenance records they supply.

Cooling requirements depend on a wide range of circumstances, including the fabric, location and orientation of the building towards the sun, as well as the activities and number of people in the building. Older systems are also likely to have higher rated outputs for a given floor area.

If it is not clear to you whether your building reaches the threshold you must determine the installed capacity of your system by appropriate inspection, calculation and enquiries. In other, more specialised, buildings, the wide range of factors which influence system capacity means that these systems should be determined by a suitably qualified person on a case by case basis if the information is not already available.

Activity Likely area requiring 12kW of cooling

  • Air-conditioned general office spaces (Assuming typical levels of electrical equipment and 8–10m2 per person) – 200m2
  • Air-conditioned offices with high levels of IT and electrical equipment – 100m2
  • Retail spaces with average levels of display lighting – 250m2
  • Retail spaces with high levels of display lighting and illuminated cabinets – 150m2

Office, call centre or dealing floors with high occupant densities of 6m2 or similar, and high levels of IT, communications or lighting loads may well fall within the scope at smaller areas.

For larger systems, a central cooling system serving an office building of 2,000m2 is likely to be 250kW rated output.

Cooling systems serving meeting rooms which may be used by large numbers of people, such as council chambers, may exceed the 250kW threshold for lower floor areas.

What does an air conditioning inspection cover?

The inspection will examine the refrigeration and air movement equipment that are part of air-conditioning systems, and their controls. It will also examine any documentation that helps to understand the systems, or indicates the extent to which the systems have been maintained.

Access will be required to equipment that may be located in plant rooms, or outside the building, including rooftops or other locations with limited provision for access. Some additional access is likely to be needed, for example to the inside of AHUs or ducts as well as components which may be hidden above suspended ceilings.

In all cases the building owner or manager should agree the means for safe access with the energy assessor, following a health and safety risk assessment of the individual situation. The energy assessor may need to be accompanied by the responsible building manager or maintenance agent at all times.

What can I expect in the report?

The purpose of the inspection and report is to ensure that building owners or managers are provided with basic information regarding the efficiency of the air-conditioning systems that they control, together with advice on how the energy efficiency or effectiveness of these systems might be improved.

Acting on the advice in the inspection report and rectifying faults or making appropriate improvements, where this is attractive and cost effective, may result in immediate improvements to the effectiveness of air-conditioning systems or reduce the operating costs. Most reports are likely to contain advice with a combination of simple low or no cost measures and measures where some investment may be required either to apply the measures, or to investigate the potential to apply measures in more detail.

Who is responsible for ensuring inspections are done?

If you control the operation of an air-conditioning system affected by the Regulations, it is your responsibility to ensure an inspection has been done in accordance with the requirements and timetable of the Regulations and keep the most recent inspection report made by an energy assessor

The person who controls the operation of the system is the person who controls the technical functioning of the system, not someone who can just alter the temperature.

The owner of the system will usually control the operation of the system even where day to day operation is contracted out to another. Where a tenant takes total responsibility for a building and its services (e.g. full repairing and insuring lease), then the tenant will control the system.

Where the operation and management of the system is carried out on a day-to-day management basis, or a servicing company provides routine servicing and maintenance, the contract may specify the management or servicing company as the controller of the system with responsibility for ensuring that inspections are carried out. Even in such cases, however, the landlord or tenant retains a parallel duty to ensure the air conditioning inspection has been done.

Where air-conditioning systems are installed locally by a tenant, the responsibility will lie with the tenant as they own the system.

Who is able to conduct an air conditioning inspection?

An energy inspection of an air-conditioning system must be carried out by an accredited energy assessor who is a current member of an approved accreditation scheme.

To become a member of an accreditation scheme, energy assessors will need to:

  • demonstrate their competence, either by having a recognised qualification from an awarding body or approved prior experience and learning equivalent to the National Occupational Standard requirements
  • maintain appropriate professional indemnity cover
  • update their skills and knowledge regularly
  • participate in the accreditation body’s quality assurance procedures
  • abide by the scheme’s advice and guidance

Companies should be wary of unqualified persons acting as data gatherers on behalf of an air conditioning energy assessor. The air conditioning energy assessor must attend the site in person to compile the report and if they do not do so the report will be invalid.

What are the penalties?

As legislation currently stands, you can be issued with a fixed penalty notice for non-compliance with the legislation. There are 2 main fines that can be levied

1. £300 for failure to ensure that a system has been inspected at regular intervals not exceeding 5 years (Regulation 21 (1))

2. £200 for failure to produce a valid air conditioning report within 7 days of being requested to do so by a Trading Standards officer (Regulation 39(4))

Fines are levied per site and can be repeated daily which can be a huge potential liability for multi-site operators.


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