This LAP indicates if hydrogen has to follow specific requirements when transported, and if the regulations are different from the transport of other types of gas. It identifes the competent authorities to allocate the routes.
Road Planning provide the municipalities with a clear understanding of the maximum risks that the transport of hazardous substances may cause. Baseline goals are: Transport hazardous substances between major industrial sites and abroad, including in the future, keeping risks for locals along the routes within legal limits, provide clarity to municipalities about what may / may not be built.
Hydrogen is considered as any other flammable gas or dangerous good for its transportation. The Agreement of transport of Dangerous Goods by Road applies.
Is it a barrier?
Safety regulation to protect people and environment from harmful substances, fires and explosions. Not a barrier: hydrogen is a dangerous good when transported in large quantities, so ADR restrictions apply as they should. There are no hydrogen-specific restrictions.
Question 1 Are there any specific regulations or restrictions on the road transport of hydrogen? A) Does hydrogen have to follow specific requirements when transported? (e.g. specific types of roads, specific route)
No, there are no particular hydrogen-specific requirements. The ADR requirements have to be followed as with other types of flammable gasses transported in container vehicles. Transportation of hydrogen is allowed everywhere except in routes marked with traffic signs that prohibit the carriage of dangerous goods. Local prohibited areas can be proposed by municipalities but they need to be set by the Finnish Transport and Communications Agency (Traficom). In general the ADR regulation follows EU regulation, but there is one national addition: classification of A and B zones, marked with separate traffic signs under the general ADR traffic sign. Zone A means full prohibition of transport, a “no–go–zone”. Zone B means drive–through prohibition: in a B zone driving to the target via the shortest route, loading and unloading of cargo is allowed.
Question 1 Are there any specific regulations or restrictions on the road transport of hydrogen? B) Please specify the requirements regarding tunnels, bridges, parking, others
There are no tunnel restrictions for road transport of dangerous goods. There can be imposed local prohibitions in parking areas set by the owner/operator.
Question 2 Which authorities are competent to allocate the routes? (and at what level: national, local?)
Finnish Transport and Communications Agency (Traficom) and Finnish Transport Infrastructure Agency are the national authorities. The prohibition can be proposed by municipality and set by Traficom. The prohibited area can be a road or part of a road like densely populated area.
Question 3 Are the regulations differing from the transport of other types of gas?
No specific treatment for hydrogen. The transportation prohibition of dangerous goods has a classification A and B based on the amount of the goods. Zone A means full prohibition of transport, a “no–go–zone”. Zone B means drive–through prohibition: in a B zone driving to the target via the shortest route, loading and unloading of cargo is allowed.
Describe the comparable technology and its relevance with regard to hydrogen
Road transport of industrial gasses in general.
Vaarallisten aineiden kuljetusta koskevia säädöksiä ja määräyksiä / Master list of ADR regulation information by Finnish Transport Safety Agency (Trafi)
Up–to date collection of national and EU legal and administrative processes including links to the sources. The other references below are found from this site.
- Laki vaarallisten aineiden kuljetuksesta (719/1994 ajantasainen säädös) / Law about transportation of dangerous goods
Valtioneuvoston asetus vaarallisten aineiden kuljetuksesta tiellä (194/2002 ajantasainen säädös) / Governmental regulation on transportation of dangerous goods
Chapter 3: Packages; Chapter 4: Containers; Chapter 5: Transportation
Trafin määräys (VAK–tie 2017): Vaarallisten aineiden kuljetus tiellä (TRAFI/248800/03.04.03.00/2016) / Regulation by Finnish Transport Safety Agency (Trafi) about ADR transportation on road (on–road ADR 2017)
The pdf files are available behind the link. The technical attachment is very detailed (1116 pages).
Vaarallisten aineiden kuljetusten reittirajoitukset / ADR route limitations
List of places that have locally ADR transport prohibition
European Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances [CLP regulation]
The CLP Regulation (Classification, Labelling and Packaging of substances and mixtures) entered into force on the 20th of January 2009 and replaced the two previously existing laws or legal instruments, the Dangerous Substance Directive (DSD) and the Dangerous Preparation Directive (DPD). CLP is based on the Globally Harmonized System (GHS), a set of recommendations drafted by the United Nations. The CLP Regulation is applied to substances since 2010 and to mixtures since June 2015.
The Regulation includes hydrogen in its list of substances of hazardous substances (Part 3, Table 3.1) establishes rules for the harmonised classification and labelling of hydrogen.
Directive 2014/68/EU of the European Parliament and of the Council of 15 May 2014 on the harmonisation of the laws of the Member States relating to the making available on the market of pressure equipment.
The Pressure Equipment Directive, applies to the design, manufacture and conformity assessment of pressure equipment and assemblies with a maximum allowable pressure greater than 0.5 bar.
Technical requirements and classification according to an ascending level of hazard, depending on pressure, volume or nominal size, the fluid group and state of aggregation, as well as conformity assessment procedures are laid down and required by the Directive
Hydrogen is a fluid which falls under Group 1. Group 1 consists of dangerous fluids (flammable, toxic and/or oxidizing). As a result, a large part of the equipment for H2 production, storage and distribution must meet the technical requirements set out in the Pressure Equipment Directive (PED).
The Directive is relevant for the approval of landing / bunkering installations
Directive 2008/68/EC of the European Parliament and of the Council of 24 September 2008 on the inland transport of dangerous goods.
Extends the uniform rules of ADR to national transport.
Restrictions on grounds of transport safety
1. Member States may on grounds of transport safety apply more stringent provisions, with the exception of construction requirements, concerning the national transport of dangerous goods by vehicles, wagons and inland waterway vessels registered or put into circulation within their territory.
Commission Regulation (EU) No 453/2010 of 20 May 2010 amending Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)
The Regulation defines the requirement for safety data sheets. It provides, as part of Annex 1 and 2 detailed requirements for the compilation of safety data sheets, which should include, inter alia: (i) Identification of the substance/mixture and of the company/undertaking, (ii) Hazards identification, (iii) Composition/information on ingredients, (iii) First aid measures, (iv) Accidental release measures, (v) Handling and storage, (vi) Exposure controls/personal protection, (vii) Physical and chemical properties, (viii) Toxicological information, (ix) Ecological information, (x) Transport information, (xi) Regulatory information
ADR European Agreement concerning the international carriage of dangerous goods by roads.
hazardous materials may in general be transported internationally in wheeled vehicles, provided that conditions be met for the product packaging and labelling; and that the construction, equipment, and use of vehicles for the transport is compliant:
Safety data Sheet SDS Eiga067A
Point 14 Transport informations