THE NATIONAL REGULATIONS FOR MONITORING

AND CONTROLLING THE USE OF

OZONE DEPLETING SUBSTANCES IN INDIA
AND ISSUES RELATED TO
INDIAN COAST GUARD

CGBR 775

DIRECTORATE OF FISHERIES AND ENVIRONMENT

INDIAN COAST GUARD HEADQUARTERS, NEW DELHI
 (i)

ACKNOWLEDGEMENTS

The Handbook of the national regulations for monitoring and

controlling the use of ozone depleting substances (ODS) and
the role of the Indian Coast Guard was prepared in consonance
with the inputs obtained from the country Handbook on
National Regulations for monitoring and controlling of ODS in
India prepared by the Ozone Cell, Ministry of Environment &
Forests in 2005.

The Directorate of Fisheries and Environment of the Indian

Coast Guard would like to express the gratitude to National
Academy of Customs, Excise and Narcotics (NACEN) in
providing inputs while preparing this document.
 (ii)

FOREWORD

The Ozone layer, high in the stratosphere, is vital to life on Earth. It acts as a shield
to prevent harmful UV radiation from reaching the Earth. In the 1970s scientists discovered
that a number of man-made chemicals damage the ozone layer. These chemicals include
CFCs, HCFCs, halons, carbon tetrachloride and methyl chloroform.

In 1987, nations around the world concerned about the depletion of the ozone
layer signed the Montreal Protocol (MP) and established a timetable for the reduction and
eventual elimination of their production and consumption world-wide. India is a signatory
to the MP.

In July 1999, the first phase-out obligation applicable to developing countries

came into effect. India being one of the major manufacturers of Ozone Depleting Substances
(ODS) is now taking tremendous efforts to comply with or even exceed the phase out
schedules of the Montreal Protocol and has developed strategies and regulations to achieve
its goals.

Compliance with the ODS phase-out provisions requires action to address both
supply and demand. The supply of ODS will decrease once the major production plants
are closed down and effective trade control and stringent border monitoring are in place.
However there is a huge demand for ODS in the servicing sector for air conditioning and
freezers and the risk of illegal trade arises where there is over supply in the adjacent
countries and there is a scarcity in the local markets.

During the last three years, the land law enforcement agencies/Customs have seized
more than 100 metric tonnes of ODS which were illegally brought into out country.
 (iii)

demand for ODS will be huge and will become the second most profitable venture after
drug smuggling. Coast Guard being a law enforcement arm of the Government of India at
sea need to play an increasingly prominent role in the prevention of illegal trade of ODS.
Customs Act 1962 provides the basis under which the ODS being a banned substance can
be seized when it is brought into or taken out from India through sea illegaly.

This book of reference has been prepared as a self help guide and is expected to
provide useful assistance in ensuring enforcement at sea.

Based on the feedback and information recieved, the Directorate of Fisheries and
Environment will update this BR on periodic basic to reflect the latest developments.

(MA Thalha)
Deputy Inspector General
Director (Fisheries & Environment)

Coast Guard Headquarters

National Stadium Complex
New Delhi - 110 001

Dated Jun 2006

 (iv)

ABBREVIATIONS

CFC Chloroflurocarbon

CPCB Central Pollution control Board

CTC Carbontetrachloride

ESC Empowered Steering committee

GWP Global Warming Potential

HCFC Hydrochloroflurocarbon

HFC Hydroflurocarbon

MLF Multilateral Fund

MP Montreal Protocol

MOEF Ministry of Environment and Forests

ODS Ozone Depleting Substances

ODP Ozone Depleting Potential

SISI Small Industries Service Institute

SPCB State Pollution Control Board

UNEP United Nations Environment Programme

UNDP United Nations Development Programme

UNIDO United Nations Industrial Development Organisation

 (v)

CONTENTS
Page No.
Acknowledgement (i)
Foreword (ii)
Abbreviations (iv)

1. Introduction On The Ozone Layer & ODS 1-7

1.1 What is ozone? 1
1.2 What is ozone layer? 1
1.3 Why is the ozone layer so important? 2
1.4 How thick is the ozone layer? 2
1.5 How is the ozone layer measured? 2
1.6 What is the ozone hole? 3
1.7 How is ozone destroyed? 3
1.8 Ozone depletion is difference from climate change & 5
global warming.
1.9 What are ozone depleting substances? 5
1.10 How are ODS released into the Stratosphere 5
1.11 When will the ozone layer recover? 6
1.12 The effects of ozone layer depletion on human 6
health and the environment

2. Uses Of Ozone Depleting Substances 8-9

2.1 The common uses of ODS 8

3. International Response 10-15

3.1 International treaties for the protection of the ozone layer 10

3.2 Precautionary principle 10
3.3 International assessment panels 10
3.4 Article 5 and non-Article 5 countries 11
3.5 1992 Multilateral Fund (MLF) 11
3.6 ODS freeze & phase-out schedules 11
 (vi)

3.7 Base level consumption for ODS 11

3.8 Exemptions for use and production of ODS 12
3.9 Control of trade with non-Parties 12
3.10 Ban on imports from & exports to non-Parties 14
3.11 Control of trade with Parties 15

4. Halon 1301 16-17

4.1 Short History 16

4.2 HALON 1301 and Fire Fighting Systems with CG Vessels 16

4.3 Replacement of Halon 1301 16

5. ODS Production And Consumption Pattern In India 18-21

5.1 National Consumption Pattern 18

5.2 Production 20
5.3 CFC Production Plant in India 21

6. Strategies For ODS Phase-out In India 22-27

6.1 India’s Commitment 22

6.2 Coordinating Ministry 22
6.3 Institutional Setup 23
6.4 Control Measures for ODS in India 23
6.5 The Agencies Involved 24
6.6 ODS Phase Out Programme 26
6.7 Seized ODS & ODS-containing Products 27

7. Prevention Of Illegal Trade 28-33

7.1 Smuggling of ODS in Indian Context 28

7.2 Seizures in India 28
 (vii)

7.3 ODS Transportation 28

7.4 Identifying ODS 31
7.5 Indian Coast Guard Role 31
7.6 Information Exchange 32
7.7 ICG-ODS Checklist 32

References 33

Appendix A: Seized ODS Decision Matrix 34

Appendix B: Safety and ODS 36

 1
9

SECTION - 1
INTRODUCTION ON THE OZONE LAYER & ODS

1.1 What is Ozone?

Ozone is a gas composed of ozone molecules (O3) which consist of three atoms of
oxygen. The oxygen molecules (O2) contained in the air we are breathing consists of only two
atoms of oxygen. Ozone molecules are created in a photochemical reaction, which can be
described in a simplified way as follows:-

3 O2
2 O2 + 2 O 
2 O3

Oxygen molecules react to form ozone molecules and at the same time ozone molecules
react to form oxygen molecules. If the number of ozone molecules being created is the same as
the number of ozone molecules being broken down, the reaction is in its dynamic equilibrium.

1.2 What is ozone layer?

The ozone layer is a term used to describe the presence of ozone molecules in the
stratosphere. The layer stretches around the entire globe of the Earth like a bubble and acts as
a filter for the harmful ultraviolet radiation (UV-B). UV-B radiation is a highly energetic light that
originates from the sun and which has severe impacts on human health and the environment.
 2
10

The stratosphere is that part of atmosphere which follows the troposphere. It starts at
10-20 km above ground level and continues up to 40-50 km height.

1.3 Why is the ozone layer so important?

The ozone layer is vital to life on the planet’s surface. It acts as a filter and prevents the
harmful ultraviolet radiation (UV-B) from reaching the earth.

If ozone molecules are depleted faster than they can be replaced by new ozone molecules
that nature produces the result is what could be called an ozone deficit. The depletion of the
ozone layer will lead to a reduction of its shielding capacity and thus an increased exposure to
UV-B radiation.

Scientists classify UV radiation into three types or bands-UV-A, UV-B and UV-C. UV-C does
not reach the Earth’s surface. UV-B is partially filtered by the ozone layer. UV-A is not filtered at
all by the ozone layer. However, it is the UV-B radiation which mainly is responsible for health
damages and negative impacts on the environment.

1.4 How thick is the ozone layer?

The ozone molecules are dispersed in the stratosphere and therefore the physical thickness
of the ozone layer is tens of kilometers. However, the pressure and thus the concentration of
molecules in the stratosphere are already very small composed to those at ground level.

Accordingly, the concentration of stratospheric ozone molecules is so small that if all ozone
molecules were extracted from the stratosphere and spread around the Earth at ground level,
they would form a layer of ozone gas of a couple of millimeters thick.

1.5 How is the ozone layer measured?

This theoretical thickness of the ozone layer at ground level is used as a measure for the
amount of ozone molecules in the stratosphere and measured in Dobson Units (DU). Each Dobson
Unit corresponds to 0.01 millimeter, therefore 300 Dobson Units correspond with a calculated
thickness of the ozone layer of 3 millimeters.
 3
11

1.6 What is the ozone hole?

In the 1970s scientists discovered that the released ODS damage the ozone layer. The
ozone concentration over Antarctica diminished between the 1970s and the 1990s by up to 70%
of the concentration normally found over Antarctica. This large-scale phenomenon is usually
referred to as the ozone hole. Scientists have observed declining ozone concentrations over the
whole globe.

Recent observations show that the upper atmospheric conditions in the Northern Hemisphere
are becoming similar to those of the Antarctic. The loss of ozone and the greenhouse effect are
causing the upper atmosphere to become colder, which facilitates ozone destruction. The result
of this could be the formation of an “Arctic Ozone Hole” or “low ozone event” within the next 20
years.

The alarming difference is that there are millions of people that live in the area that will be
exposed to the resulting increased UV-B radiation. An Arctic “low ozone event” could easily be
blown south by high-altitude winds, and appear over populated areas of the United States,
Canada, Europe and Asia.

1.7 How is ozone destroyed?

The dynamic equilibrium between creating and breaking down ozone molecules depends
on temperature, pressure, energetic conditions and molecule concentrations. The equilibrium
can be disturbed for instance by other molecules reacting with the ozone molecules, and thereby
destroying them. If this destruction process is fast and the creation of new ozone molecules is
too slow to replace the destroyed ozone molecules, the equilibrium will get out of balance. As a
result, the concentration of ozone molecules will be reduced.

Under the Montreal Protocol, a number of ozone depleting substances (ODS) have been
identified and their production and use controlled. Their destructive potential is huge because
they react in a photochemical chain reaction with ozone molecules. After one ozone molecule
has been destroyed, the ODS is available to destroy further ozone molecules.

2 ODS + 2 O3
2 ODS + 3 O3
The destructive lifetime of ODS may range between 100-400 years depending on the type
 4
12

of ODS. Therefore, one molecule of ODS may destroy hundred of thousands of ozone molecules.
U.V. Radiation

CFCl2

CFCl3 Chlorine Atom

 5
13

1.8 Ozone depletion is difference from climate change & global

warning.

Global warning & climate change is caused by the emission of greenhouse gases, which
trap the outgoing heat from the Earth causing the atmosphere to become warmer. Greenhouse
gases include carbon dioxide, methane, CFCs, HCFCs and halons.

The impacts of global climate change may include sea level rise resulting in loss of valuable
coastal areas and intrusion of seawater further inland as well as unpredictable effects on eco-
systems and natural disasters.

1.9 What are ozone depleting substances?

Ozone depleting substances (ODS) are chemical substances that have the potential to
react with ozone molecules in the stratosphere. The ODS are basically chlorinated, fluorinated or
brominated hydrocarbons and include:
Some ODS examples

Chlorofluorocarbons (CFCs),
CFC-II 1.0

Hydrochlorofluorocarbons (HCFCs),
CFC-12 1.0

Halons,
Halon-I 30 I 10.0

Hydrobromofluorocarbons (HBFCs),
Carbon tetrachloride 1.1

Bromochloromethane,
Methyl chloroform 0.1

Methyl chloroform,
HCFC-22 0.055

Carbon tetrachloride, and
HBFC-22I 0.74

Methyl bromide.
Bromochloromethane 0.12

Methyl bromide 0.6

1.10 How are ODS released into the Stratosphere

ODS are released to the atmosphere in a variety of ways including the:-

Traditional use of cleaning solvents, paint, fire extinguishing equipment and spray
cans;
 6
14

Venting and purging during servicing of refrigeration and air-conditioning systems;

Use of methyl bromide in soil fumigation and for quarantine and pre-shipment
applications.

Disposal of OSD-containing products and equipment such as foams or refrigerators,

and

Leaking refrigmerant circuits.

1.11 When will the ozone layer recover?

There are no exact forecasts for when the ozone layer will recover. Scientists assume that
the concentration of ozone molecules in the stratosphere will reach “normal” levels by the middle
of this century, if all Parties to the Montreal Protocol and its amendments comply with their
phase-out obligations. This is partly due to the long lifetime of ODS and the chain-type reaction
which destroys the ozone molecules.

1.12 The effects of ozone layer depletion on human health and the
environment

The major effects of increased exposure to UV-B radiation are:

Suppression of the immune system by damaging the DNA. This results in increased incidents
and occurrence of infectious disease as well as possible adverse effects on the inoculation
programmes. UV-B radiation is known to cause skin cancers – both non-melanoma (the less
dangerous) and the virulent cutaneous malignant melanoma. Increased UV-also causes damage
to the eyes including eye cataracts, which in many countries are a major cause of blindness.

Ozone layer depletion causes serious adverse effects on agriculture and damage to forests.
The ultraviolet radiation changes in the chemical composition of several species of plants.
Experiments on crops have shown that the ones most vulnerable to UV-B include melons, mustard
and cabbage. Increased UV-B radiation also reduces the quality of certain types of tomatoes,
potatoes, sugar beets and soyabeans. Tests have also shown that seeds of conifers are also
adversely affected.

Damage to aquatic or organisms, in particular to the small creatures such as plankton,

aquatic plants and fish larvae, shrimp and crabs – all of which form the essential base of the
aquatic and marine food web. Hence, damage to fisheries result.
 7
15

Materials used in buildings, paints, rubber, wood and plastics and degraded by UV-B radiation,
particularly plastics and rubbers used outdoors. Damage would be severe in the tropical regions
where the effects are enhanced by high temperatures and levels of sunshine. Such damages
could run into billions of dollars each year.

UV-B radiation results in increased ground level smog, especially in the cities where car and
industry emission provide the basis for photochemical reactions. This has its own adverse
effects on human health and the environment.
 8
16

SECTION - 2
USES OF OZONE DEPLETING SUBSTANCES

2.1 The common uses of ODS

2.1.1 Use as refrigerants

In most developing countries, the largest remaining sector in which ODS are still used is
the refrigeration and air-conditioning servicing sector, where CFCs and HCFCs are used as
refrigerants for the cooling circuits.

ODS are also used as blowing agents for foam applications, as cleaning solvent in the
electronics industry, as propellants in aerosol applications, as sterilants, as fire fighting
agents, as fumigant for pest and disease control and for feedstock applications.

2.1.2 Use as Blowing agents

Prior to regulatory controls, CFC-11 was the most common foam blowing agent for the
manufacture of polyurethane, phenolic, polystyrene and polyolefin foam plastics. Foams
are used in a wide variety of products and for insulation purposes. CFC-11 is progressively
being replaced by HCFC-141 b or non-ODS alternatives.

2.1.3 Use as cleaning solvent

CFC-113 has been widely used as cleaning solvent in electronic assembly production
processes, precision cleaning and general metal degreasing during manufacture. It is also
used for dry-cleaning and spot cleaning in the textile industry. Other ozone depleting solvents
include methyl chloroform and carbon tetrachloride.

2.1.4 Use as propellants

CFC-11 and CFC-12 were widely used as aerosol propellants because they are non-
flammable, non-explosive and have non-toxic properties. CFC-114 was used to dispense
products containing alcohol. CFC-113 is and has been used in aerosols for cleaning purposes.
They could be produced in a highly pure form and they are good solvents.

The products dispensed by aerosols include lacquers, deodorants, shaving foam, perfume,
insecticides, window cleaners, oven cleaners, pharmaceutical products, veterinary products,
 9
17

paints, glues, lubricants and oils.

In the mid-1970s, the use of CFC propellants in aerosol products accounted for 60 per
cent of all CFC-11 and CFC-12 used worldwide. By the end of the 1970s, countries were
beginning to ban or restrict the use of CFCs in aerosol products.

2.1.5 Use as sterilants

Mixtures of CFC-12 and ethylene oxide are used for medical sterilisation purposes. The
CFC compound reduces the flammability and explosive risk from ethylene oxide. The most
common mixture contains 88 per cent CFC-12 by weight and is commonly known as 12/88.
Ethylene oxide is particularly useful for sterilising objects that are sensitive to heat and
moisture, such as catheters and medical equipment, which use fiber optics.

2.1.6 Use as fire extinguishers

Halons and HBFC were largely used as fire extinguishers and are in many instances
replaced by foam or carbon dioxide.

2.1.7 Use as fumigant

Methyl bromide has been and is widely used as a pesticide for soil fumigation in order to
protect crops and to prevent pests. It is also used for the exempted quarantine and pre-
shipment applications.

2.1.8 Use as feedstock

HCFC and carbon tetrachloride are commonly used as feedstock in chemical synthesis.
Carbon tetrachloride is also used as a process agent. ODS used for feedstock applications
are usually not released to the atmosphere and therefore do not contribute to ozone layer
depletion.
 10
18

SECTION - 3
INTERNATIONAL RESPONSE

3.1 International treaties for the protection of the ozone layer

3.1.1 1985 Vienna Convention for the Protection of the Ozone Layer

The Vienna Convention, held under the auspices of UNEP in 1985, was the first
attempt to provide the framework for cooperative activities related to the protection of the
ozone layer. The convention was signed by 21 states, including the European Union, in
March 1985. Parties to the Convention agreed to cooperate with each other in scientific
research in order to improve understanding of atmospheric processes, to share information
on ODS production and emission and to implement preventive measures to control ODS
emissions.

3.1.2 1987 Montreal Protocol on Substances that deplete the ozone layer

In 1987 governments adopted the Montreal Protocol to reduce and eventually eliminate
the emissions of manmade ozone depleting substances. The Protocol contained a list of
controlled ODS-5 CFCs and 3 Halons and defined the control measures to reduce production
and consumption of these ODS. The Protocol entered into force on 1 January 1989 and
today more than 185 countries world-wide have committed themselves under the Protocol
to phase out the consumption and production of ODS.

3.2 Precautionary principle

The Montreal Protocol is based on the “precautionary principle” that enables the world
community to take actions to address a major global environmental problem even before all
scientific, economic and technical questions have been fully resolved.

3.3 International assessment panels

To undertake regular assessments of the implementation of the Montreal protocol, the

Parties established three international panels of experts and/or scientists from industries, research
academies, governments and non-governmental organisations. The panels are the Scientific
Assessment Panel, the Environmental Effects Assessment Panel, and the Technology and
Economic Assessment Panel.
 11
19

3.4 Article 5 and non-Article 5 countries

3.4.1 Article 5 countries are developing countries using less than 0.3 kg ODP tonnes per
capita per year of controlled ODS.

3.4.2 Non-article 5 countries or Article 2 countries are all other Parties to the Montreal
Protocol, mainly developed countries.

3.5 1992 Multilateral Fund (MLF)

The Multilateral Fund for the implementation of the Montreal Protocol was created to help
developing countries finance the costs of meeting the Protocol requirements and to promote the
accelerated phase-out of ODS production and consumption. Funds from the Multilateral Fund
help finance projects targeted at phasing out ODS from production and consumption. The Fund
also helps Article 5 countries implement Country Programmes by establishing National Ozone
Units, a regulatory framework and appropriate laws, and organising training. The implementing
agencies of the Multilateral Fund are: The United Nations Environment Programme (UNEP), The
United Nations Development Programme (UNDP), The United Nations Industrial Development
Organisation (UNIDO), the World Bank and bilateral agencies from donor countries.

3.6 ODS freeze & phase-out schedules

The freeze and phase-out obligations for Article 5 countries take into account that developing
countries usually do not have easy access to alternative technologies, know-how and capital
investment. Therefore, their freeze and phase-out schedules are later than those for developed
(non-Article 5) countries. This should allow sufficient time to provide technical and policy support
to Article 5 countries in order to ensure a smooth transition to non-ODS technologies. Developing
countries still use most ODS technologies. Developing countries still use most ODS in particular
CFCs and halons. India is a Article 5 Country.

3.7 Base level consumption for ODS

The base level depends on a country’s past consumption of certain ODS. In most cases, it
is defined as the average consumption level during a certain reference period, during which
consumption data were recorded.

For example, the first control measure in developing countries was the 1999 freeze concerning
the consumption of Annex A CFCs. The freeze level was set at the base level which has been
defined as a country’s average consumption between 1995-1997. After the freeze date
 20
12

(1 Jul 1999), the country’s annual consumption must not exceed its freeze level.

The table1 summarises the first control measures and the final phase-out dates for the
different ODS, applicable to developing countries. It does not refer to the different production
and use exemptions which may apply.

Annex ODS type First control measure Final phase-out for

For Article 5 countries Article 5 countries

A-1 CFC (5 main types) 1999 freeze 2010 phase-out

A-II Halons 2002 freeze 2010 phase-out

8-1 Other CFCs 2003 reduction 20% 2010 phase-out

8-11 Carbon tetrachloride 2005 reduction 85% 2010 phase-out

8-111 Methyl chloroform 2003 freeze 2015 phase-out

C-I HCFCs 2016 freeze 2040 phase-out

consumption

C-II HBFCs 1996 phase-out 1996 phase-out

C-III Bromochloromethane 2002 phase-out 2002 phase-out

E Methyl bromide 2002 freeze 2015 phase-out

Table 3-1 First control measures and the final phase-out dates for the different
ODS, applicable to developing countries

3.8 Exemptions for use and production of ODS

Exempted uses of ODS include essential uses, use as feedstock and use as process agents.
These uses do not count towards a country’s ODS consumption. Countries can also apply for
production allowances to satisfy basic domestic needs.

3.9 Control of trade with non-Parties

Article IV of the Montreal Protocol addresses control of trade with non-Parties. A non-
Party, with regard to particular ODS, is any country whose government has not ratified, accepted,
 21
13

approved, or accessed the Montreal Protocol, or the amendment which introduced this particular
ODS as a controlled substance. The table below details the countries that have not yet ratified
ozone treaties.

Countries that have not yet ratified the ozone treaties as of June 2000

African States Asian States Other States

Cape Verde Afghanistan Andorra

Eritrea Bhutan Bhutan Holy See

Guinea-Bissau Cambodia San Marino

Rwanda Cook islands

Sao Tome and Principle Iraq

Sierra Leon Nauru

Somalia Niue

Palau

Table 3-2 Countries that have not yet ratified the ozone treaties as of
June 2000

Each Party is discouraged from exporting to non-Parties technology for producing and utilizing
controlled substances in Annex A,B,C and E. An exception to this provisions is the export of
products, equipment, plants, or technology that improve the containment, recovery, recycling or
destruction of controlled substances, promote the development of alternative substances, or
otherwise contribute to the reduction of emissions of controlled substances in Annex A,B,C
and E.
 14
22

3.10 Ban on imports from & exports to non-Parties

A list of products containing controlled substances

1. Automobile and truck air conditioning units (whether incorporated in vehicles

or not).

2. Domestic and commercial refrigeration and air conditioning/heat pump

equipment e.g.:

Refrigerators

Freezers

Dehumidifiers

Water coolers

Ice machines

Air conditioning and heat pump units

3. Aerosol products, except medical aerosols

4. Portable fire extinguisher

5. Insulation boards, panels and pipe covers

6. Pre-polymers

Table 3-3 List of products containing controlled substances

(Source UNEP Handbook for International Treaties for the Protection of the
Ozone Layer, 2000)

There is also a provision in the Protocol that permits non-Parties, which are determined by
a Meeting of the Parties to be in full compliance with control measures for controlled substances,
trade provisions, and data reporting requirements, to import and export controlled substances
and products containing them as per the rules of the Montreal Protocol.
 15
23

3.11 Control of trade with Parties

Since there are so few non-Parties to the Montreal Protocol, the issue of trade with Parties
ultimately has a direct impact on progress towards the elimination of ODS and the protection of
the ozone layer.

Parties have adopted a wide variety of restrictions on trade through policies and regulations
to achieve reductions in consumption of ODS. These policies are regulations include:

agreements with industry to phase out imports; product labelling;

licensing of ODS trade;

duty reductions for ODS substitutes and non-ODS technologies;

excise taxes on ODS;

quantitative restrictions and ban on imports of ODS;

total or partial ban on import of ODS products or technologies.

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24

SECTION - 4
HALON 1301

4.1 Short History

Halon 1301 came into international market in the 1960s and was seen as the most
effective gaseous fire fighting agent ever developed. It found widespread application in the
protection of critical equipment, telecommunication system, art and historical collections,
process control room, aircraft and ship fire fighting systems. However, by the late 1980s a
great deal of scientific evidence indicated that the agent was an ODS and the Montreal Protocol
of 1987 required a phase out of new production.

4.2 Halon 1301 and Fire Fighting systems with CG Vessels

The OPVs numbering 4-10, which were commissioned from 1988 were fitted with Halon
1301 as main engine fire fighting systems. Besides six OPVs, six Singapore class IPVs and
seven FPVs commissioned until 1999 were fitted with Halon 1301 fire fighting systems. The
older ships were fitted with CO2 fire fighting systems and all ICG vessels commissioned after
1999 were fitted with new environment friendly and ODS free FM-200 fire fighting system.

4.3 Replacement of Halon 1301

4.3.1 The choice of replacement of the Halon systems in CG ships primarily depended
on cost factors and the length or balance of life of the ships which are fitted with Halon
1301 system. The Montreal protocol stipulates complete ban on production, consumption
and reuse by the year 1020. Developed countries have already stopped production by 1996
and have switched over to alternatives like FM 200,HFC2-227, HFC-23, CO2 and AFFF.

4.3.2 India has already stopped production of Halon 1301 and 1211 and the “Ozone
cell” have provided guidelines for phase out plan of Halon 1301 and other Halon derivaties
by 2010. However, in view of large usage by the Indian armed forces like IAF, IN and ICG in
their fire fighting systems, MoD constituted a committee under the chairmanship of Director,
Centre for Environment and explosive safety (CEES), DRDO in Jun 2001 to identify the
critical requirement and to recommend suitable strategy for Halon banking in Indian
Defence services. The anticipated requirement of Halon for next 25 years have been
collated by the committee from all armed forces including the Indian Coast Guard.
 17
25

10 tonnes of Halon 1301 have been catered for as the future requirement for the 19 ICG
vessels.

4.3.3 As a follow up to the recommendations of the CEES, Indian Navy through the
controller of materials has set up Halon recovery and recycling facility at Mumbai and Vizag
which would be extended to ICG for effective utilization and recycling in accordance to the
phase out plan.
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26

SECTION - 5
ODS PRODUCTION AND CONSUMPTION PATTERN IN INDIA

5.1 National Consumption pattern

India is a vast country with a highly diversified structure of ODS consuming industries. India
per capita consumption of ODS is less than 3 grams, which is much below the 300 grams limit
permitted under the Montreal Protocol for Article 5 countries, which makes it eligible for receiving
financial assistance to conversion projects from the Multilateral Fund. A brief overview of the
end-user industries is given below:

5.1.1 Refrigeration and Air-conditioning (RAC)

The RAC sector primarily includes:

Refrigerated cabinets (deep freezers, ice cream cabinets, bottle coolers, visi coolers)

Mobile air-conditioners (built in-systems for cars, vans or other vehicles),

Refrigerated road transports,

Central air-conditioning plants,

Process chillers and

Room and packaged air-conditioners.

While domestic refrigerators are manufactured by the organised sector manufacturers,

commercial refrigeration equipment are manufactured by both organised and unorganised
manufacturers. Process chillers, room and packaged air-conditioners and central air-
conditioned equipment are produced by organised manufactured and assembled by medium
scale and informal sectors in India.

Mobile air conditioners and refrigerated road transport vehicles are primarily produced
by the organised sector manufacturers. The refrigerated road transportation sector is expected
to grow with the growth in food processing sector in India.

The demand for these equipment have been increasing in the past account of increasing
penetration of these equipment due to general increase in affluence, industrial growth and
demand by organizations selling food products and beverages like Hindustan Lever Limited,
 19
27

Mother Dairy, Nestle, Coke, Pepsi etc. Further, there are additional initiatives taken by the
Government in enhancing storage capacity of perishable items, which results in higher
refrigeration and air conditioning requirement.

5.1.2 Foams

CFC – 11 and CFC – 12 are used as foam-blowing agent in rigid and flexible foams
applications. Refrigeration insulation forms a significant share in the total demand for foams,
followed by other foam applications namely stab stock, moulded, general insulation,
thermoware, thermoplastics and phenolic foams etc. These foam applications are found as
insulations to refrigeration and air conditioning equipment, cushions for beds, chairs
thermoware plastics. Today, construction foam materials are increasingly being used to
enhance the efficiency of air–conditioning systems.

5.1.3 Aerosols

The aerosol products are manufactured in the large, medium and small scale industry
concentrated in the Western and Northern part of the country. Most of the aerosol
manufactures have switched over to hydrocarbon based alternatives, which are non-ODS,
primarily due to their lower costs compared to CFCs.

However, the use of CFCs in pharmaceutical inhalation therapy, Metered Dose Inhalers
(MDIs), is considered essential and has been given a deferred phase out schedule. While
CFC use in aerosols has to stop by 1 January 03, the use in MDIs can continue to
2010.

5.1.4 Solvents

This segment has a wide range of industrial applications including:

Textile cleaning,

Pharmaceutical,

Pesticide industry,

Chlorinated rubber,

Metal cleaning and precision cleaning, etc.

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28

Both methyl chloroform and CTCs are used in these applications. Methyl chloroform use
is currently very limited. It is CTC that is largely used in solvent applications in the country.

5.1.5 Fire Fighting Sector

Fire extinguishers and fire extinguishing systems based on halons are no longer
manufactured in India. Currently, halon is only used for servicing the old systems that are
already available in the country.

5.2 Production

5.2.1 India had production capacities for producing 8 of the 20

substances controlled under the Montreal protocol and these include:

CFC-11,

CFC-12,

CFC-113,

Halon-1211,

Halon-1301,

Carbon tetrachloride (CTC),

Methyl Chloroform (MCF), and

Methyl Bromide.

With respect to CFCs, currently, India is the second largest CFC producer in the world,
after China. Today, India is self sufficient in CFC and to a large extent, in CTC. It has
stopped production of MCF and Halons since 1992 and 1998, respectively. Recently, India
has also entered into an agreement to stop production of CTC.
 21
29

5.2.2 The production levels of ODS in India for 2003: (In metric tones)

ODS 2003

CFC – 11 2,609

CFC – 12 12,373

CFC – 113 32

Halon – 1211 Nil

Halon – 1301 Nil

CTC 18,239

MCF Nil

Methyl Bromide Nil

Total 33,253

5.3 CFC Production plants in India

There are four plants producing CFC in India. There are:

SRF Limited,

Gujarat Fluorocarbons Limited,

Navin Fluorine Industries and

Chemplast Sanmar Limited.

Halons were produced by Navin Fluorine industries and SRF Limited. As mentioned earlier,
the production of halons was discontinued since 1998. A phase-out project was approved in the
34th meeting at the Executive Committee held at Montreal in July 2001 for closure of production
of halons and assistance to end-users to convert to alternatives for US $2.60 million.

CTC is produced by SRF Limited, Chemplast, Sanmar Limited and Gujarat Alkalies Limited.
They produce annually about 16500 MT, a national phase-out plan to phase out production and
consumption of CTC is prepared by India and submitted at the 40th meeting of the Executive
Committee held in July 2003. CTC production sector phase out project has been approved for
gradual reduction of CTC production in India.
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30

SECTION - 6
STRATEGIES FOR ODS PHASE-OUT IN INDIA

6.1 India’s Commitment

India signed the Montreal Protocol on 17 September 1992. In 1993, the Country Program
was prepared to phase out ODS in accordance with its national industrial development strategy.

The country Program was developed through a unique co-operation of the industry and the
Government, with assistance from the United Nations Development Programme (UNDP) the
views of the corporate sector was incorporate through extensive consultations with six industry
groups namely aerosols, foams, halons refrigeration and air-conditioning, solvents and chemicals
producing sector.

6.2 Coordinating Ministry

The Ministry of Environment and Forests (MoEF) constituted an Inter-Ministerial Group to

review and bring forth the view and inputs of Government departments such as the Department
of Industrial Development, Department of Electronics, Department of Telecommunications, etc.
on the ODS phase out and other related issues.

The Country Programme adopted a multi-prolonged approach to develop a comprehensive

and achievable plan to phase-out the ODS technologies without undue economic burden on
customers and industry. Other related objectives include:-

Minimise economic dislocation as a result of conversion to non-ODS technology.

Maximise indigenous production of the ODS technology.

Emphasise decentralised management and

Minimize obsolescence.

The Country Programme lays down, in detail, steps that need to be undertaken to meet
the ODS phase out commitment by 2010 and provides indicative categories of projects, which
have to be considered.
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31

6.3 Institutional Setup

The Government of India has entrusted the task of implementation of the Country
Programme to the MoEF. Subsequently, the MoEF established a national unit called the
‘Ozone Cell’ which is the national focal point for the implementation of the Montreal Protocol.
The Ozone Cell is guided by Empowered Steering Committee (ESC) on MP implementation
issues and activities to be undertaken to facilitate phase out of ODS.

6.3.1 The institutional structure for implementation of Montreal Protocol in

India is presented below:-

Ministry of Environment & Forests

Ozone Cell Empowered Steering Committee


* Technology & Finance Standing Committee.
* Standing Committee for small scale, tiny and un-organised industries.
* Monitoring and Evaluation committee.
* Implementation Sub-Committee.

6.4 Control measures for ODS in India

India has provided for protection and improvement of the environment in its constitution.
The constitution provisions are implemented through Environment Protection Laws of the Country.
Environment is a concurrent subject thus allowing control of both the state government and the
central government on policies, regulations and action plans on specific matters.

6.4.1 Rules and Regulations

6.4.1.1 Environment protection Act 1986

Environment protection Act, 1986 gives powers to the central government to take
necessary measures for protecting and improving environment as well as prevention,
control and abatement of environment pollution. The ODS Rules 2000 have been
issued by the central government under the environment protection Act 1986.

6.4.1.2 Ozone depleting substances (Regulation and Control) Rules 2000

Ozone depleting substances (Regulation and Control) Rules 2000 provide

comprehensive control and monitoring regulations for production and use of ODS in
 24
32

India. Some salient points of the rules are

All producers of ODS in India are to be registered

All exports and imports is restricted to parties to the MP

All wholesale and retail dealers of ODS are to be registered and sales controlled

Regulations on labeling

Prohibition of new investments on ODS

6.4.1.3 Petroleum Act 1934 and petroleum rules

Safe use of hydrocarbons is regulated by petroleum laws in India. The Petroleum

Act 1934 and petroleum rules 1976 has provisions relating to handling of various
classes of petro products.

6.4.1.4 Gas Cylinder Rules 1981

The Gas Cylinder rules which has provisions relating to filling , possession, import
and transportation of cylinders. Filling, possession import and transportation of cylinders
require a license.

6.4.1.5 Customs Act 1963

Chapter XIII of the Customs Act provides details of powers and details and
procedures that shall be followed by ICG for searches, seizure and arrest. Section 111
to 114 of chapter XV provide details of rules relating to confiscation of and penalty for
improperly imported and exported goods. Section 115 to 119 of chapter XV provide
details of rules relating to confiscation of goods.

6.5 The agencies involved

Licensing Agencies The licensing agency may be different from the NOU. Two or
three different agencies may be responsible for licensing ODS. For example, the Ministry of
Trade may license CFCs, while the Pesticide or Toxic Chemicals Board may licence methyl
bromide. The appropriate licensing agency or agencies will offer or deny licences to importers or
exporters of ODS.
 25
33

Min of Trade, Industry or Commerce The Ministry of Trade, Industry or Commerce

is a key stakeholder in the implementation of the licensing system. This Ministry often requires a
licence to import goods. This licence may be one of many required by the licensing system.
Under national law, the Ministry has certain powers to limit or ban the import or export of certain
goods. This may include establishing a “negative list” of goods not allowed to enter the country.

Pesticides/Pollution Control Board The Pesticide Board may issue licences for the
import of methyl bromide. Depending or national regulations, the Pesticide Board may also issue
a “negative list” to ban the import of specified goods. They may ban the use of certain pesticides
or prescribe safety precautions, specific modes of use or storage requirements.

Bureau of Standards The Bureau of Standards may check imports for proper labelling.
Under national law the Bureau of Standards may have the authority to specify compulsory
labelling standards for virgin, recovered, recycled or reclaimed ODS, ODS-based equipment or
retrofitted equipment.

Ministry of Law and Justice The Ministry of Justice or Attorney General is another key
stakeholder in the enforcement of the licensing system. This Ministry works in conjunction with
other agencies to prosecute and sentence illegal traders.

Government Laboratory The Government Laboratory provides scientific analysis of

evidence in cases of suspect ODS shipments. Such evidence is required for court cases. Their
trained staff may take samples when ODS cylinders cannot be transported to the laboratory.
There may be other accredited laboratories which can validate evidence.

BSF & Coast Guard The BSF and Coast Guard is part of the ODS enforcement team
apart from the Customs. Working in conjunction with other agencies, they can gather intelligence
information and conduct inspections of suspicious shipment in cooperation with the Customs
Department.

Industry & trade representatives or associations Industry associations may inform

the licensing authority if the black market for ODS is increasing, consequently diminishing their
legal sales. The customs broker association, air-conditioning and refrigeration technicians
association or other similar groups are others who may be helpful in ensuring the effective
operation of the licensing system. The support and cooperation of industry should be ensured by
involving it early in the process. Industry may play a role on how to deal with seized products
 26
34

and ODS, be involved in public awareness raising, or disseminating information to importers,

service technicians and end users. Industry networks of contacts may be extremely helpful.

National ozone or climate committees Many national organisations and NGOs have
established national committees to discuss and agree on appropriate policies, strategies and
actions to protect the ozone layer and to combat climate change. These committees include
relevant stakeholders from the public and private sectors who meet regularly to review progress
and make new proposals. An important function of these committees is to serve as a platform for
discussion and decision-making to ensure the involvement and support of relevant
stakeholders.

General Public The general public can also be a useful ally in the effective operation of
the ODS import/export licensing system. If the public is educated about ozone issues, consumers
may be less likely to bring ODS-based refrigerators and air conditioners into the country. As
educated consumers they may choose to retrofit to ODS alternatives and not to purchase old
ODS equipment.

6.6 ODS Phase Out Programme

In accordance with the provisions of the Montreal Protocol, India has set a framework of
phasing out both production and consumption of ODS. The ODS phase out compliance began in
1999 and India has committed to phase out ODS in a phased manner with production and
consumption of CFC to be completely phased out by 2010, Methyl Bromide by 2015 and HCFCs
by 2040.

The specific phased out dates for phasing out ODSs from production and consumption in
India are given in Schedule II, Schedule III and Schedule IV of Ozone Depleting Substances
(Regulations and Control) Rules, 2000.

6.6.1 The phase out schedule for the production and consumption of CFCs
has been set by the Montreal Protocol.

The following phase out schedule for both consumption and production of CFCs:

(i) Starting on July 1, 1999 to freeze annual consumption and production at levels
not exceeding the annual average of 1995-97.

(ii) By January 1, 2005, to reduce to less than 50% of the freeze level.
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35

(iii) by January 1, 2007, to reduce to less than 15% of the freeze level; and

(iv) by January 1, 2010, to stop production and consumption of all CFCs.

Total CFC production in India is currently regulated through a Government Order, which
prescribes the quantities of CFCs that can be produced by the CFC producing enterprises in
a year.

6.6.2 Key action areas for the future

The phase out of ODS holds several challenges for the Indian economy. This would call
for maintaining momentum and exceeding past achievements. In order to successfully
meet the targets set out for 2010, the country’s evolving needs would have to be taken into
account on a regular basis.

Major challenges that need to be addressed in the near future, include:

ODS phase out in the small and medium sector especially the CFC and CTC consumption.

Inflow of old equipment using ODS and its impact on country’s early phase out
achievements.

Control of increase illegal trade of ODSs.

Destruction and recycling of ODSs.

6.7 Seized ODS & ODS-containing products

The decision matrix placed at Appendix A presents options for seized ODs and ODS
based products/equipment. The bold fields indicate the environmentally preferably options.
However, the most appropriate option will depend on country specific situations and costs.
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36

SECTION - 7
PREVENTION OF ILLEGAL TRADE

7.1 Smuggling of ODS in Indian context

The reason for smuggling of ODS in Indian context are as under:-

Huge demand for non-ODS servicing.

Economics – high profit margins available in illegal market.

Inflated quota and imports in neighboring countries.

Ships clandestinely importing ODS as ships stores and diverting in Indian

market.

Porous border with Nepal/Bangladesh

Relatively lower level of awareness in the enforcement agencies.

7.2 Seizures in India

Between the year 1999-2003 the customs have seized 43 metric tones of ODS carried
through 3160 cylinders and Border security force has seized 57.5 metric tones carried through
4181 cylinders. These seizures were made predominantly from the north and the eastern borders.
It is estimated in the year 2007, when the production levels dips to 15 percent of the original
1999 level, the demand for ODS will be huge and will become the second most profitable venture
after drug smuggling variety of modus operandi and entry points being used by smugglers to
bring ODS into India. As the land borders gets sealed through increased surveillance and effective
enforcement there is a likely prospect that the smugglers will attempt to smuggle ODS in large
bulk through sea as the risks are few and the profit margin will be high. Coast guard being a law
enforcement arm of the government of India at sea need to play an increasingly prominent role
in the prevention of illegal trade of ODS.

7.3 ODS transportation

There are a variety of containers that ODS may be stored, transported and sold in. Some
refrigerants are packaged in disposable containers. Disposable containers are manufactured in
sizes from 1 to 50 pound capacities. Often cylinders as well as drums, cans and bottles are
 29
37

protected by transport packaging. The following photos illustrate :

Nothing in these Pictures is intended to suggest that any of the companies whose Products
are shown is involved in any illegal trading activity.

Photo 9: Cardboard Photo 10: Cardboard Photo 11: 1 lb. Canisters

Packaging & 30 lb. Packaging for 30 lb. Cardboard Packaging
Cylinder Cylinder

Photo 12: Cardboard Photo 13: Cardboard

Packaging for 30 lb. Packaging for 30 lb.
Cylinder Cylinder top view.

Photo 14: Pallet Photo 15: Pallet Photo 16: Traditional

of CFC- 12 of CFC- 12 reusable Cylinder
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38

Photo 17: Photo 18: “Re- Photo 19:

Example of covered” Various low
CFC- 12 R-502, mixture Pressure
cylinder of 49% HCFC-22 containers.
dichlorodi & 51% CFC-
fluoromethane 115, cylinder

Photo 20: 50 & 30 lb Photo 21:

reusable cylinder; Modern Photo 22: Various size
30lb. Disposable reusable of Recoverable
cylinder cylinders containers.

Photo 24:
ISO tal(S allow for multi
Photo 23: modal Transport of large
Stac(ed ISO containers quantities of refrigerants.
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7.4 Identifying ODS

This subsection focuses on the different methods of identifying and analysing chemical
substances, which are potentially mislabeled ODS or illegal ODS imports. The different smuggling
schemes and methods to detect illegal trade are described in next sub section.

Random testing sampling is advised to verify the contents of both large and small containers
of all types of gas and chemicals as well as ODS equipment and products.

The safety precautions to be taken by the ICG during the identification process of ODS are
listed in Appendix B

ODS can be found in containers and also in equipment and products. The container will vary
depending on the type of ODS. For example, liquefied compressed gases are contained in
pressurised cylinders. Liquid ODS are contained in pressure-less drums, barrels, bottles or other
standard containers as they are used for all types of liquid chemicals.

7.5 Indian Coast Guard role

The Coast Guard should be made aware of the banned ODS substance and the legal provisions
and licensing system involved in the import and export of ODS. Training is very vital and this
handbook will become essential guideline for the enforcement aspects of the Customs Act by the
Indian Coast Guard.

The Coast Guard should interact with Customs and Department of Revenue Intelligence
(DRI) regularly to gather information regarding the illegal movement of ODs through the sea
and study the basic smuggling schemes used to traffic ODS.

Identification of ODS is very vital component and the coast guard whenever locate any
cylinders containing gaseous material and not sure whether it contains ODS or not has to carry
out following checks:

Check the labeling. (The details on labbelling is placed in appendix)

Check the chemical names

Check Trade names

Check UN names
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Do not take samples, seize the entire container if in doubt and send it to
customsdepartment who will in turn transport it to the government laboratory for
identification

Hand held mass spectrometers and gas chromatographs will be available with all the
custom commissioner offices for checking the ODS

Carefully check the shipping documents

Any usually large imports of non- ODS refrigerants should be closely examined as
consumption of non-ODS refrigerants is small compared to that of CFC

ODS may be hidden with other cargo or disguised as non-regulated substances

If in doubt contact the nearest customs office to ascertain whether the suspicious
goods are transported under bonafide regulations

7.6 Information Exchange

In future, the national ozone unit will coordinate information exchange regarding the information
on licensed exporters and importers, quota in force, information on end users, consumption
pattern and demand level and other information networked with Customs, Directorate of Foreign
Trade, DRI, MOEF, Central and State pollution control boards and Law enforcement agencies like
Coast Guard and Border Security Force.

The establishment of a database of relevant data will allow to improve tracking of the
routes of illegal shipments to identify the major transhipment harbours in the region and the
existing smuggling schemes, and to check whether exports from a specific country of origin
match with the imports into the country of destination.

This information exchange will facilitate checking the credentials of the smugglers and other
particulars of the ODS which are encountered at sea.

7.7 ICG- ODS CHECKLIST

Compare the packing list, bill of entry, and the country of origin to make sure they
match.

Compare the invoice and the bill of lading to the outward bound ship manifest.

Verify the country of origin. Is the country a Party to the Montreal Protocol and its
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41

amendments? (the information can be ascertained from the Ozone Cell)

Verify that the importer and place of business actually exist.

Contact the licensing agency to verify that importer is licensed to import that specific
material. (Directorate General Foreign Trade)

Note the quantity, source and destination of ODS. These will serve as important clues
that may provide indicators to prohibit illegal importations.

Verify that the container number actually exists. Discovery of fictitious container
numbers have led to the disclosure of illegal trade.

Review all the necessary documents, if there is something that doesn’t match, it may
be an illegal shipment.

Inspect the merchandise.

Check packaging, size and shape and label on container.

Identify the name and description of the chemical, which should match ALL paperwork.

Seize the material if the importer does not have an import/export license.

Coordinate this seizure with the customs officer, environment agency and the
prosecution agency. Anyone involved with the seizure may be called to testify in
court, so take good notes.

References:

1. Country Handbook on National Regulations for monitoring and controlling

production and use of ODS in India 2005, prepared by Ozone Cell of Ministry of Environment
and Forests, Government of India.

2. UNEP Handbook for International Treaties for the Protection of the Ozone Layer
2000, United Nations Environment Programme, Geneva.

3. National Academy of Customs, Excise and Narcotics 2005 – Phase II training on

substances depleting the ozone layer for Enforcement agencies in India.
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Appendix A
(refer para 6.7)

Seized ODS and ODS based products/equipment decision matrix

Ozone-depleting Products Equipment based

Options
substances, eg. containing on ODS, eg.
CFC refrigerants ODS, eg. Aerosol refrigerators,
methyl bromide, cans, foams, air-conditioners,
etc. paints, etc. etc.

Re-export Cost for re-export Cost for re-export Cost for re-export
To the country of to be borne by to be borne by to be borne by
origin or to any importer importer importer
country that is
risks to be
risks to be
risks to be
legally entitled to smuggled smuggled smuggled
import the seized again again again
goods and wishes
to do so
if auctioning
if disposal
if
off and is not retrofitting
disposal are possible and
not possible disposals
are not
possible

Anchoring Off If the import of If the import of ODS If the import of

to a licensed ODS is not - containing products ODS-based equip
importer and banned is not banned ment is not banned

usually there
deducting the
replaces
usually there
are
quantity from the legal imports are no no
importer’s allowance for allowances
allowance imports of for imports
of equipment
products
based on
containing ODS
ODS to be

increases the
avoided
country’s
dependency
on ODS to be
avoided
 35
43

Mandatory Not applicable Not applicable Cost for retrofitting

retrofitting to be borne by
Of ODS-based illegal importer or
equipment by by licensed importer
certified service who bought the
company equipment from
Customs

Disposal or If Montreal Recover ODS Recover ODS and

destruction Protocol approved before disposal other working
of the seized goods destruction for re-use or fluids before

Cast to be technologies are disposal (not disposal for re-
born by available possible for paints use of disposal
illegal
if auctioning or foams)
if
importer or off is not retrofitting
customs possible is not
possible

proper
waste
management
practices
should be
applied

Long-term storage If re-export, If re-export If re-export,

Intermediate option auctioning or disposal auctioning or auctioning,
1
disposal is not
which is costly for is not possible retrofitting or
customs and
to be avoided possible disposal is not
requires final
to be possible
solution avoided
to be
avoided
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44

Appendix B
(refers to para 7.4)
Safety & ODS

Use of refrigerant identifiers & analysers

Chemical analysis. Only trained and designated customs officers should use refrigerant
identifiers, the temperature / pressure method or leak detectors to check the contents of
refrigerant containers. Local safety regulations must be observed.

Sampling for chemical analysis. If chemical analysis in an accredited laboratory is

required, for instance to prepare court cases, a specially trained and authorised technical
expert from the Government or other designated laboratories should be consulted. ICG
officers should not take samples. Smaller refrigerant cylinders can be transported
directly to the laboratory.

Inspection. When inspecting the compressors of refrigeration & air-conditioning systems

for labels to determine the refrigerant type and charge, the power supply should be
disconnected. For example, refrigerators should be unplugged and vehicle motors turned
off.

Safety check list for ICG officers

Handling, transport, storage and identification of ODS refrigerators

DOs

Do observe local regulations and industry-recommended procedures for the

handling, tranport and storage of virgin, recovered, recycled or contaminated
refrigerants.

Do use protective clothing, including safety goggles and gloves when handling
refrigerants. Refrigerants can cause frostbite and other damaging effects to the skin
and eyes.

Do equip storage areas with appropriate fire extinguishing systems to reduce the
risk of fire. CFC refrigerants are not combustible but produce irritating or toxic fumes
in a fire.
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45

Do use electronic leak detectors to inspect storage areas and access valves for
leakage if available.

Do check the contents of refrigerant cylinders using the temperature/pressure

method or electronic refrigerant identifiers – but only if you are trained and authorised
to do so under local regulations.

Do inspect access valves for leaking glands and effective gaskets. Protective caps
should prevent valve damage.

Do secure storage areas for ODS and ensure that they are only accessible by
authorised personnel and that they are protected against theft.

Do properly label ODS and storage areas and show appropriate warnings if
necessary.

Do store seized ODS until further action determines what will be done with the
substances. They should be clearly labelled and safety stored. The Country Handbook
on ODS Regulations should detail storage requirements for seized ODS.

Do disconnect the power supply when inspecting or testing equipment e.g.

refrigerators should be unplugged and vehicle motors turned off.

Do respect local requirements and standards for pressure vessel with low and
high pressure refrigerants. In many countries safety inspections are mandatory.

Do store and transport ODS cylinders carefully in an upright position (this does
not apply to ISO containers) and prevent dropping them.

DONT’S

Do not eat drink or smoke in storage areas or near ODS or ODS products/equiment.

Do not vent ODS into the atmosphere knowingly. Do not dispose of any ODS by
using methods other than R&R, reclaim, reuse, adequate storage or approved destruction
methods.
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46

Do not handle or store ODS in confined spaces which lack ventilation since some
ODS can accumulate in confined spaces. This increases the risk of inhalation and may
cause unconsciousness or suffocation resulting in death. Use breathing protection if
appropriate.

Do not store ODS cylinders in direct sun light or near hot surfaces. A rise in
temperature will cause an increased pressure with the risk of bursting.