If you manage a commercial premises with air conditioning, refrigeration or heat pump equipment installed, you may be unknowingly breaking the law – and it’s a mistake that’s more common than you might think.
The Federation of Environmental Trade Associations (FETA) has issued a stark warning to facilities managers across the UK, urging them to ensure their DSEAR Risk Assessments are in place. Here’s what you need to know.
What is DSEAR?
DSEAR stands for the Dangerous Substances and Explosive Atmospheres Regulations.
Introduced to protect both employees and members of the public from safety risks in the workplace, DSEAR places clear legal obligations on employers to identify and manage risks posed by dangerous substances on their premises.
For the official government guidance on DSEAR, visit: https://www.hse.gov.uk/fireandexplosion/dsear.htm
Why Is This Suddenly Relevant to Air Conditioning and Refrigeration?
The short answer is that the regulations have evolved – and many facilities managers haven’t kept up.
The EU F-Gas Regulation and the ongoing HFC Phase Down process have pushed businesses away from high global warming potential (GWP) gases toward more environmentally friendly alternatives.
This shift has increased the use of A2L and other flammable refrigerants in air conditioning, refrigeration, and heat pump systems.
While this is better for the planet, it has created a compliance blind spot for many employers.
When DSEAR was originally introduced in 2002, it only applied to refrigerants classified as flammable under hazard classes H220 and H221 — essentially A2 and A3 refrigerant classes.
However, a 2015 amendment extended the scope of the regulation to include gases under pressure (hazard class H280).
This is the critical point: that change means every single refrigeration, air conditioning, and heat pump installation in the UK now falls within the scope of DSEAR — not just those using flammable refrigerants.
For a full breakdown of the DSEAR regulations and how the 2015 amendment affects your responsibilities, the HSE provides detailed guidance here: https://www.hse.gov.uk/risk/theory/alarpglance.htm
What Does This Mean for You as a Facilities Manager?
Put simply, if your building has any refrigeration, air conditioning, or heat pump equipment, you are legally required to have a DSEAR Risk Assessment in place.
There are no exceptions based on the size of the installation or the type of refrigerant used.
As FETA’s Commercial Manager Martyn Cooper explained, many facilities managers remain unaware that the 2015 amendment significantly broadened the regulation’s reach. The responsibility for ensuring a compliant DSEAR Risk Assessment exists sits firmly with the facilities management company.
Failure to have one in place isn’t just a paperwork oversight — it’s a breach of health and safety law that could have serious consequences for your business, your employees, and the public.
FETA has produced a comprehensive guidance document on DSEAR Risk Assessments specifically for the refrigeration, air conditioning and heat pump industry.
Download it here: https://www.feta.co.uk/publications/feta-publications
Need a DSEAR Risk Assessment for Your Surrey Premises?
Don’t wait until an inspection — or worse, an incident — forces the issue. At Fire Risk Assessment Surrey, we carry out thorough, compliant DSEAR Risk Assessments for commercial properties across Surrey and the surrounding areas.
Our assessments cover all RACHP installations and are carried out by qualified, experienced assessors who understand both the technical and legal requirements of DSEAR compliance.
Get in touch today for a free, no-obligation quote.
Or use our simple online enquiry form to tell us about your premises and we’ll get back to you promptly: https://www.fireriskassessmentsurrey.co.uk/contact
Further Resources on DSEAR Compliance
If you’d like to read more before getting in touch, the following resources are a good starting point:
- HSE DSEAR Overview: https://www.hse.gov.uk/fireandexplosion/dsear.htm
- HSE DSEAR Approved Code of Practice: https://www.hse.gov.uk/pubns/priced/l138.pdf
- FETA DSEAR Guidance Document: https://www.feta.co.uk/publications/feta-publications
- Health & Safety at Work Act 1974 Overview: https://www.hse.gov.uk/legislation/hswa.htm
