Permitting process / requirements
This LAP refers to the permitting process and requirements for on one hand the drivers/transporting company and on the other hand the equipment (trailer). It defines what certification is needed for a driver/transporting company to transport hydrogen on public roads and which authority is competent to deliver the certification. It also gives information about the requirements needed for an equipment to be allowed to transport hydrogen on public roads, and if there is any specific approval required for the equipment.
Glossary:
The Permitting process is a process in which an applicant files forms to a (regulatory) agency/competent authority with required narratives, maps, etc., to ensure in advance that the proposed operation will be in compliance with the applicable standards. Permitting requirements are the legal (regulations and standards) requirements.
An internal safety distance is the minimal separation distance between a potential hazard source (e.g. equipment involving dangerous substances) and an object (human, equipment or environment), which will mitigate the effect of a likely foreseeable incident and prevent a minor incident escalating into a larger incident (also known as domino effect).
An internal safety distance is the minimal separation distance between a potential hazard source (e.g. equipment involving dangerous substances) and an object (human, equipment or environment), which will mitigate the effect of a likely foreseeable incident and prevent a minor incident escalating into a larger incident (also known as domino effect).
Pan-European Assessment:
The permitting process and requirements for the drivers/transporting company and the equipment (trailer) are well harmonized in Europe, because all countries follow the ADR regulation. As restrictions applied to hydrogen are the same as for any other flammable gas, most of the countries don’t see this LAP as a barrier
Is it a barrier?
No
Assessment Severity
0
Assessment
Basically it is not a real barrier but because the national authorities often require certificates and other approvals – in addition to the certificates and approvals issued in the country where the equipment was manufactured – it might be a relatively lengthy hence costly process. It might have a negative implication because of the thereby generated costs.
Questions:
Question 1
Drivers/transporting company:
a - What certification is needed for a driver/transporting company to transport hydrogen on public roads?
a - The driver needs a certificate allowing the transport of dangerous goods. For H2-transports an additional special education/training is required.
Question 1
Drivers/transporting company:
b - Which authority is competent to deliver the certification?
b - The additional education is offered by driving schools specialised on such transports or by institutes for occupational training.
Question 2
Equipment (e.g. trailer):
a - What are the requirements needed for equipment to be allowed to transport hydrogen on public roads?
a - All trucks which transport hazardous goods, have to be equipped according to the relevant technical provisions. The equipment shall be in compliance with the requirements of the Law on pressure equipment (Druckgerätegesetz) – which itself is based on Directive 2014/68 EU. Other requirements are CE certification, compliance with the requirements for explosion avoidance/protection and the used practice in industry.
Question 2
Equipment (e.g. trailer):
b - Is any specific approval required for the equipment to be allowed to transport hydrogen (gas/liquid)?
b - Approvals have to be in line with the law on pressure equipment Druckgerätegesetz , transposing the Transportable Pressure Equipment Directive.
Describe the comparable technology and its relevance with regard to hydrogen
Natural gas (CNG) and other flammable gases/liquids
National legislation:
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Law on pressure equipment = Druckgerätegesetz
Article 1 respectively Article 2 “guide” to the other specific provisions (articles)
- Regulation on explosion protection = Explosionsschutzverordnung
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Law on transportation of dangerous goods= Bundesgesetz über die Beförderung gefährlicher Güter
Article 2 specifies the relevant regulations – namely ADR – to be applied. Article 8 deals with permissions regarding transport of dangerous goods
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CE Marking
Depending on the part of the equipment/machinery used
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ADR, transposed into Austrian law via BGBl. 522/1973
Several relevant articles – depending of the framework
EU Legislation:
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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.
Article 5
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. -
Directive 2004/54/EC of 29. April 2004 Minimal safety requirements for tunnels in the trans-European roads.
The Directive applies to tunnels of more than 500 meters, in the Trans-European Road Network- TERN), included in the EEC agreement from 1999. It specifies both technical and operational requirements, and has been implemented in Norway (with some adjustments) through the Regulation on minimum safety requirements for certain tunnels [Forskrift om minimum sikkerhetskrav til visse vegtunneler (tunnelsikkerhetsforskriften)] of 15.05.07. Annex 1 is on safety measures, and chapter 3.7 of this annex, specifies such measures with respect to the transport of dangerous goods.
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Directive 2010/35/EU, the Transportable Pressure Equipment Directive (TPED)
The Directive applies to the design, manufacture, conformity assessment and periodic reassessment of transportable cylinders, tubes, cryogenic vessels and tanks for transporting gases as well as hydrogen cyanide, hydrogen fluoride and hydrofluoric acid. It also covers their associated valves and other pressure equipment. The Directive defines 3 categories for pressure equipment, based on its pressure volume product (P.V) in bar litres and hence its stored energy
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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: