Natural refrigerants: F-Gas certification does not replace workplace safety obligations.
The EU Commission clarifies: F-Gas certification does not replace workplace safety obligations for those working with natural refrigerants.
The spread of natural refrigerants in commercial and industrial refrigeration brings with it an increasingly timely reflection on the obligations of technicians, companies, and employers. A recent clarification from the European Commission helps clarify a sensitive issue: the certification required by the new F-Gas Regulation does not replace the obligations arising from European legislation on health and safety at work.
A step which, for those who design, install and maintain propane (R290), carbon dioxide (R744) and ammonia (R717) systems, has concrete operational implications.
Two regulatory levels that remain distinct
The issue was raised in a petition submitted to the European Parliament and addressed in a note published by the Commission in March 2026. The issue concerned the risk that F-Gas certified technicians, pursuant to Regulation (EU) 2024/573, could be automatically considered suitable for working with natural refrigerants even without meeting the obligations set out in the occupational safety directives.
The Commission has clarified that the two areas operate on complementary but distinct levels. F-Gas certification addresses aspects related to the management of refrigerants , including flammability, pressure, and toxicity, but does not incorporate the employer's obligations under the European safety framework, which remain fully applicable. These include:
- Framework Directive 89/391/EEC on safety at work
- Directive 98/24/EC on chemical agents
- Directive 2004/37/EC on carcinogens and mutagens
This means that risk assessment, worker training, health surveillance, and personal protective equipment remain separate obligations, not absorbed by environmental certification.
What this means for the cold chain
For companies in the sector, the practical consequence is direct: F-Gas certification confirms its centrality in the technical management of fluids, but it does not exhaust the qualification of personnel with respect to the specific risks of natural refrigerants . In the case of ammonia, for example, the technician must still possess the toxic gas certification required by Italian law, and the company is required to conduct a chemical and ATEX risk assessment specific to the substance handled.
For HVAC/R professionals, this means operating in a context where risk assessments, training, and company documentation must be tailored for each refrigerant used, integrating the environmental framework with the chemical and explosive atmospheres aspects.
The Commission's clarification is part of broader European work on safety in the maintenance of natural refrigerant systems, confirming a clear direction: the growth of CO₂, propane, and ammonia requires an integrated approach, in which environmental and safety dimensions move in parallel, without overlaps or regulatory gaps.
FAQ
No, F-Gas certification alone is not sufficient. The European Commission has clarified that the F-Gas Regulation and the European directives on occupational health and safety operate on distinct and complementary levels. The certification addresses aspects related to the technical management of refrigerants, including flammability, pressure, and toxicity, but does not replace employer obligations regarding risk assessment, training, health surveillance, and personal protective equipment. Therefore, for technicians working with propane, carbon dioxide, and ammonia, the occupational safety directives, starting with Framework Directive 89/391/EEC, remain fully applicable.
A company working with ammonia (R717) must ensure that the technician, in addition to the F-Gas certification, holds the toxic gas certification required by Italian law. The company is also required to conduct a chemical and ATEX risk assessment specific to the substance, taking into account the toxicity and potential explosive atmospheres that may arise during maintenance activities. Training, operating procedures, documentation, and protective devices must be tailored to the characteristics of the fluid being handled, with a view to integrating environmental, chemical, and explosive atmosphere management frameworks.
The spread of CO₂, propane, and ammonia requires an expansion of the training scope traditionally associated with F-Gas certification. Alongside refrigerant management skills, structured training on the specific risks of natural fluids, including flammability, high-pressure management, toxicity, and ATEX zone classification, is becoming crucial. At the European level, projects such as LIFE SKILLSAFE are working to develop a common competency framework for the safe maintenance of natural refrigerant systems, confirming that personnel qualifications are now a strategic element for the HVAC/R industry.
