A Guide to TM44 Air Conditioning Inspections
Having an air conditioning system inspected by an accredited air conditioning energy assessor is designed to improve efficiency, reduce energy consumption, operating costs and the carbon emissions of the system. The energy assessor will highlight improvements to the operation of existing systems or opportunities to replace older, less energy efficient systems or over-sized systems with new energy efficient systems.
As the replacement of refrigerant is restricted in older systems (as established in other legislation), there is an additional incentive to improve or replace older systems with more modern energy efficient units.
The person who controls the operation of the system, such as the building owner or manager, has statutory obligations and duties of care in the operation and maintenance of air conditioning systems. The inspections referred to in this guide are in addition to the normal activities associated with the ownership and operation of air conditioning systems.
Inspection, maintenance and cleaning programmes maintain the ability of the system to provide healthy and comfortable environments for building occupants, limiting the escape of refrigerant gases and ensuring the safety of equipment. The practices and procedures needed to achieve these aims should be applied more frequently than the assessment for energy efficiency described here. It is outside the scope of this document to describe such procedures in detail.
When air conditioning inspections are required
All air conditioning systems with an effective rated output of more than 12kw must be regularly inspected by an energy assessor.
The inspections must be no more than five years apart. The regulations require the first inspection of the affected air conditioning systems to be carried out as follows:
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 the system 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
Systems requiring an air conditioning inspection Only air conditioning systems with an effective rated output of more than 12kW are affected by these regulations. This will include systems consisting of individual units which are less than 12kW but whose combined effective rated output is more than 12kW.
The effective rated output is the maximum calorific 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.
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 adjust the temperature or whose only responsibility is to adjust the controls. For the purposes of the regulations, a building is defined as ’a roofed construction having walls, for which energy is used to condition the indoor climate’, and ’building unit’ means a section, floor or apartment within a building which is designed or altered to be used separately.
A building designed or altered to be used separately is where the accommodation is made or adapted for separate occupation. This could be indicated by the accommodation having its own access, separate provision of heating and ventilation or shared heating and ventilation, but with the ability by the occupier to independently control those services.
For a non-dwelling the part could be deemed to be separate even if some facilities (e.g. kitchen and toilet facilities) were shared. An air conditioning system is defined as ‘a combination of all components required to provide a form of air treatment in which the temperature is controlled, or can be lowered, and includes systems which combine such air treatment with the control of ventilation, humidity and air cleanliness’. This includes both fixed self contained systems, such as split systems and centralized systems.
Mechanical ventilation systems that provide no mechanical cooling themselves, but serve spaces that are cooled by other means are included. Any components contained in air conditioning systems that are only intended to provide heating are excluded.
Air conditioning systems that provide refrigeration for process applications, such as server rooms, would also require an inspection if that part of the system allows an inspection to be carried out. Fluorinated greenhouse gas inspections Fluorinated greenhouse gases are among the Kyoto Protocol groups of gases for which the EU has committed itself to reduce emissions.
European Community Regulation 842/2006 on certain fluorinated greenhouse gases (the F-Gas Regulation) is the legal instrument by which emissions reductions are to be delivered. The framework set out by the regulation and its supplementary European Community Regulations is underpinned in Great Britain by the Fluorinated Greenhouse Gases Regulations 2009 (SI 2009/261). Northern Ireland has similar regulations.
The aim of the fluorinated greenhouse gases regulatory framework is to minimise emissions mainly through leak prevention and repair. Specific provisions include leak checking obligations and the requirement that personnel and companies must be appropriately certificated if they undertake work on equipment, such as air conditioning.
Full details of all of the obligations can be found in the information sheets provided by the Department for Environment, Food and Rural Affairs (Defra) business support unit.
F-Gas support, a government sponsored unit, provides guidance to organisations and individuals affected by the framework. The information sheets and other F-Gas guidance can be found on the Defra website at: www.defra.gov.uk/environment/quality/air/fgas
What does an air conditioning inspection cover?
The inspection will examine the refrigeration and air moving equipment that are part of air conditioning systems and their controls. It will also examine any documentation that helps to understand the system, or indicates the extent to which the system has been maintained.
The energy assessor is also required to estimate whether the system is suitably sized for the cooling loads in the treated spaces and to provide advice on ways in which the performance of the system might be improved. 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. In all cases the building owner or manager must agree the means for safe access with the energy assessor.
The energy assessor may need to be accompanied by the responsible building manager or maintenance agent at all times. Some additional access is likely to be needed, for example to the inside of air handling units or ducts. This must be provided and supervised by the responsible building manager or maintenance agent with due regard to the safety of the energy assessor and to building occupants. This would require the system to be turned off to allow safe access, so arrangements may need to be made for this outside working hours to avoid disruption to business.
Similarly, the energy assessor may need to access a sample of components, such as fan coil units, which may be hidden above suspended ceilings. Again, access should be provided by the building manager or maintenance agent.
The building owner or manager should not expect the air conditioning inspection to identify hazards or unsafe aspects of the installation, operation or maintenance of systems that should be identified and addressed by other arrangements, nor should they expect the energy assessor to fix any problem identified as part of the inspection.
If the building owner or manager requires this service then they must ensure that the need is clearly specified in the invitation to undertake the work, must assure themselves that the energy assessor is competent to undertake such additional work and must ensure that such aspects are clearly expressed in their contract or agreement with the energy assessor.
Air conditioning inspections carried out for the purposes of the Energy Performance of Buildings Regulations are not specifically designed to assess the risks to public health, although the energy assessor is required to inform the building owner or manager, of a potential issue.
The aim of the air conditioning inspection is to address energy performance, but the energy assessor is also required to confirm that the relevant person has undertaken the necessary checks to ensure there is no Legionella risk as required by the Health (Legionella) Regulations 2001.
The purpose of the inspection report is to ensure that the building owner or manager is provided with information regarding the efficiency of the air conditioning systems that they control, together with advice on how to improve the energy efficiency of the system, to identify opportunities to save energy and to reduce operating costs.
The air conditioning inspection report will include at least the following details:
the likely efficiency of the system and any suggestions made for improvement
any faults identified during the inspection and suggested actions
the adequacy of equipment maintenance and any suggestions for improvement
the adequacy of the installed controls and control settings and any suggestions made for improvement.
the current size of the installed system in relation to the cooling load any suggestions for improvement.
summary of the findings and the key recommendations
There is no legal requirement to act on the recommendations. Acting on the advice and key recommendations in the inspection report and rectifying faults or making appropriate improvements, where this is attractive and cost effective, will contribute to the efficient running of air conditioning system, which will contribute to a reduction in carbon emissions and reduce the operating costs for the building occupants.
In some cases the costs of providing both heating and cooling may be reduced, in cases where these two systems are unnecessarily in use at the same time due to inappropriate controls or settings.
In many cases it will be clear that the building and systems are already well understood, documented and commissioned, with records available showing that the equipment has been regularly maintained to a good standard. In such cases, the scope of an energy inspection could be reduced in extent and the inspection report brief, with the main content advising on opportunities for load reduction or on alternative solutions not previously considered.
In other cases the energy assessor may find it necessary to suggest relatively basic maintenance, such as cleaning or repairs, to equipment whose efficiency has evidently suffered through neglect. Cleaning operations or adjustments to controls do not form part of the inspection procedure, even where they might be carried out simply and with significant immediate effect to improve efficiency.
The inspection is not intended, or expected, to involve any physical work of this nature as this could change the level of professional risk to the energy assessor. Authority to carry out such work would need to be given as part of a separate arrangement by the building owner or manager provided the energy assessor has the necessary competence to do this work. However, the building owner, manager or their representative may well be able to carry out some alterations themselves as the energy inspection is carried out, provided they agree with the assessor’s observations.
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.
The building owner or manager should also be provided with, or informed of how to obtain, access to advice on the ongoing management of the systems. What a report must contain The inspection report must include an assessment of the efficiency of the system and its size compared to the cooling requirements of the building.
It must also contain appropriate advice on possible improvements to the system. The inspection report must include, but is not limited to, the following information:
the address of the building in which the system is located
the name of the accredited air conditioning energy assessor
the name and address of the energy assessor’s employer, or the name under which a self employed assessor trades and his address
the date on which the inspection occurred
the name of the government approved air conditioning accreditation scheme2 of which the accredited air conditioning energy assessor is a member
All inspection reports produced on or after the 6 April 2012 must contain a valid report reference number. This number can only be generated once the report has been lodged on the central register.
Responsibilities for ensuring inspections are done
The person who controls the operation of an air conditioning system must:
ensure an inspection has been done in accordance with the requirements and timetable of the regulations
keep the most recent inspection report provided by an energy assessor
give any inspection report to any person taking over responsibilities with respect to the control of the air conditioning system If the control of an air conditioning system is passed to another person and that person has not been given an inspection report by the previous operator of the system, the system must be inspected within three months of the new operator of the system taking over such control.
Control of air conditioning systems
The person who controls the operation of the system is the person who controls the technical functioning of the system, not someone who does no more than adjust the temperature or whose only responsibility is to adjust the controls.
The owner of the system will usually control the operation of the system even where day to day operation is contracted out to another person or organisation. 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 facilities management basis, or a servicing company provides routine servicing and maintenance, the contract may specify the facilities management or servicing company as the controller of the system with responsibility for ensuring that inspections are carried out.
Depending on the terms of such a contract the facilities management or servicing company may accordingly become responsible under the regulations also.
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.
Responsibilities for conducting air conditioning inspections
An energy inspection of an air conditioning system must be carried out by an accredited air conditioning energy assessor who is a current member of an accreditation scheme. The energy assessor must make a copy of the inspection report available to the client, or to the person who controls the operation of the system, as soon as practicable after the inspection date but only after the report is entered on the central register.
Only inspection reports which have been produced and lodged by accredited air conditioning energy assessors are valid reports. In certain circumstances, data gatherers, working under the supervision of the energy assessor, enable the assessor to produce the reports for larger and sometimes more complex buildings and portfolios of buildings. Data gatherers must have a contractual relationship with an assessor, or the company employing the assessor, to provide professional assistance to gather the information needed to carry out an energy assessment of a building for the purpose of issuing an air conditioning inspection report.
The assessor must be in the position to verify the data and supervise how and by whom it is collected. For the purposes of effective quality control and assurance, the energy assessor must not sanction any practice that is contrary to the quality of the air conditioning report.
Air conditioning energy assessor accreditation
Accreditation schemes are responsible for managing air conditioning energy assessors and for the quality of air conditioning inspections by ensuring their energy assessors are competent and possess the appropriate skills to conduct energy assessments. To become a member of an accreditation scheme, the energy assessor 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 schemes quality assurance procedures
abide by accreditation scheme advice and guidance.
Responsibilities with respect to other inspection or certification procedures The air conditioning inspection report must be kept in a safe place so that it can be used to inform subsequent inspections. It is recommended that the inspection report should be kept in the building log book, together with ongoing maintenance and/or energy records.
More recent buildings may already be provided with a building log book satisfying the requirements of Part L of the Building Regulations to provide the building owner or manager with information about the building, its fixed services and their maintenance requirements.
Building log book toolkits providing guidance and example templates for the preparation of the log book and on its subsequent use are available from a variety of sources. The building log book would be the most suitable place to keep records of the air conditioning inspection, together with other such inspection results e.g. fluorinated greenhouse gas inspections.
Where a log book does not exist, it would be useful to begin a file to keep these records.
The information that it would be helpful to keep in the building log book, or in a separate file if a formal log book is not available, includes:
the preparatory details for packaged cooling systems or for centralised cooling systems. Further information can be found in sections 2.2 and 2.3 of the Chartered Institution of Building Service Engineers TM44, Inspection of air conditioning systems: a guide to EPBD compliance, guidance.
a copy of the full signed report of the air conditioning inspection produced by the energy assessor • the recommendation report and any data used to prepare an EPC for the building (where one has been produced)
the advisory report produced to accompany a display energy certificate (if one is required)
the reports from any other regular inspections, such as inspections for refrigerant leakage, involving the building’s air conditioning or heating systems This information can then be provided for subsequent energy inspections and it may help to minimise the time needed to carry out the inspections.