Service and maintenance
This LAP deals with:
• The differences in the roadworthiness inspection, service and maintenance (process and requirements) for hydrogen vehicles compared to conventional vehicles,
• The responsible authorities/independent bodies to carry out technical inspections,
• The requirements to operate a testing centre/service and maintenance company for hydrogen vehicles.
• The differences in the roadworthiness inspection, service and maintenance (process and requirements) for hydrogen vehicles compared to conventional vehicles,
• The responsible authorities/independent bodies to carry out technical inspections,
• The requirements to operate a testing centre/service and maintenance company for hydrogen vehicles.
Glossary:
A motor vehicle service is a series of maintenance procedures carried out at a set time interval or after the vehicle has travelled a certain distance. The service intervals are specified by the vehicle manufacturer in a service schedule and some modern cars display the due date for the next service electronically on the instrument panel. Technical inspection (roadworthiness test) means an inspection designed to ensure that a vehicle is safe to be used on public roads and that it complies with required and mandatory safety and environmental characteristics.
Pan-European Assessment:
The hydrogen powered vehicles as the conventional vehicles are subject to periodic roadworthiness tests. Roadworthiness testing is a part of a wider regime ensuring that vehicles are kept in a safe and environmentally acceptable condition during their use. This regime should provide for periodic roadworthiness tests of vehicles and technical roadside inspection of commercial vehicles as well as a vehicle registration procedure allowing for the suspension of a vehicle’s authorisation to be used in road traffic where the vehicle constitutes an immediate risk to road safety.
The specific service and maintenance requirements and procedures for hydrogen powered vehicles are defined in guidelines, published by the manufacturers. In addition, at national level are issued a limited number of instructions concerning this matter.
The maintenance know-how and expertise will be developed and deployed with the growing number of vehicles and therefore no serious hurdles for service, maintenance and inspections of hydrogen powered vehicles could be identified. However, the lack of clear rules for service and inspection at present is seen as an operational barrier and regulatory gap, which might result in damages to vehicles or work accidents due to the use of inappropriate techniques.
The development of unified rules and procedures for service and inspection of the specific components of hydrogen powered vehicles such as high pressure hydrogen storage, fuel cell stacks and high voltage components by FCEV, hydrogen gas leak detection system are fundamental for the safety performance of hydrogen powered vehicles and could help to achieve a large degree of harmonisation of practice. Skilled service and testing staff and appropriate equipped inspection and maintenance facilities could increase the safety at the workplace and avoid workers' exposure to higher risks.
The specific service and maintenance requirements and procedures for hydrogen powered vehicles are defined in guidelines, published by the manufacturers. In addition, at national level are issued a limited number of instructions concerning this matter.
The maintenance know-how and expertise will be developed and deployed with the growing number of vehicles and therefore no serious hurdles for service, maintenance and inspections of hydrogen powered vehicles could be identified. However, the lack of clear rules for service and inspection at present is seen as an operational barrier and regulatory gap, which might result in damages to vehicles or work accidents due to the use of inappropriate techniques.
The development of unified rules and procedures for service and inspection of the specific components of hydrogen powered vehicles such as high pressure hydrogen storage, fuel cell stacks and high voltage components by FCEV, hydrogen gas leak detection system are fundamental for the safety performance of hydrogen powered vehicles and could help to achieve a large degree of harmonisation of practice. Skilled service and testing staff and appropriate equipped inspection and maintenance facilities could increase the safety at the workplace and avoid workers' exposure to higher risks.
Is it a barrier?
Not a substantive issues for FCEVs in the UK at this time. There is currently a very limited network for FCEV service and maintenance (exclusively via OEM dealers) and a limited knowledge of technical / service requirements outside – with operational and
Type of Barrier
Operational barriers, Economic barriers
Assessment Severity
NA
Assessment
Not a substantive issues for FCEVs in the UK at this time. There is currently a very limited network for FCEV service and maintenance (exclusively via OEM dealers) and a limited knowledge of technical / service requirements outside – with operational and higher cost implications for deployment and future use
Questions:
Question 1
Is there a difference in the service and maintenance inspection (process and requirement) for a hydrogen vehicle compared to a conventional vehicle?
a - cars (incl. taxis)
a - There are no specific service / maintenance requirements for FCEVs in the UK and only the standard vehicle MOT testing applies (the first such test being 3 years after registration of the vehicle and annually thereafter). It is therefore essentially for the FCEV vehicle manufacturer to specify the service and maintenance regime.
The UK Department of Transport has recently initiated a public consultation on Directive 2014/45/EU (on periodic roadworthiness tests for motor vehicles) which indicates that amendments can be expected to the Uks existing MOT legislation to accommodate the requirements of Directive 2014/45/EU, also Directives 2014/46/EU on the registration documents of vehicles and 2014/47/EU on the roadside inspections of vehicles – and affecting FCEVs within thany such changes.
Question 1
Is there a difference in the service and maintenance inspection (process and requirement) for a hydrogen vehicle compared to a conventional vehicle?
b - buses
b - there is no difference - the same MOT framework process applies for service and maintenance
Question 1
Is there a difference in the service and maintenance inspection (process and requirement) for a hydrogen vehicle compared to a conventional vehicle?
c - trolleybuses
c - there is no difference - the same MOT framework process applies for service and maintenance
Question 1
Is there a difference in the service and maintenance inspection (process and requirement) for a hydrogen vehicle compared to a conventional vehicle?
d - trucks
If yes, please specify, e.g. what are the specific maintenance needs and service requirements for hydrogen vehicles?
d - there is no difference - the same MOT framework process applies for service and maintenance
Question 2
Which are the responsible authorities/independent bodies to carry out technical inspections?
a - cars (incl. taxis)
a - MOT test certificates are currently issued in Great Britain under the auspices of the Driver and Vehicle Standards Agency (DVSA) and covering all vehicle types
Question 2
Which are the responsible authorities/independent bodies to carry out technical inspections?
b - buses
b - same MOT test requirements under the DVSA framework
Question 2
Which are the responsible authorities/independent bodies to carry out technical inspections?
c - trolleybuses
c - same MOT test requirements for the Bus & Coach category under the DVSA framework
Question 2
Which are the responsible authorities/independent bodies to carry out technical inspections?
d - trucks
d - same MOT test requirements for light, medium and heavy duty trucks under the DVSA framework
Question 3
Is there a framework and if yes, what are the requirements to operate a testing, inspection and certification (service and maintenance) company for hydrogen vehicles? Are they different from a conventional vehicle?
a) technical
i. cars (incl. taxis)
ii. buses
iii. trolleybuses
iv. trucks
b) legislative / certification
i. cars (incl. taxis)
ii. buses
iii. trolleybuses
iv. trucks
There is no specific and separate framework for operating a test / inspection and certification company for hydrogen vehicles. In principle, the DVSA network, which comprises ~20,000 MOT Test Centres and 53,000 Testers (where both Testers and Test Centre premises have to meet DVSA criteria o operate a Test Centre and undertake testing & issue MOT test certificate) can perform the services for hydrogen and conventional vehicles. In practice hydrogen vehicles can be tested at any MOT test station – but test personnel will need training for hydrogen and fuel cell systems and there may need to be provision of H2 sensors at indoor test areas and/or test sites to provide high ventilation flow rates to cover potential H2 discharge within LEL limits. Currently, OEMs with FCEVs are selectively using their dealer network to cover technical work and using MOT test centres only for MOT certification needs
Describe the comparable technology and its relevance with regard to hydrogen
As for BEVs and alternatively fuelled vehicles (CNG, LPG, etc)
National legislation:
-
The Motor Vehicles (Tests) Regulations 1981
relevant MOT Inspection procedures and detailed guide to the inspection for statutory MOTtesting;
- DfT: Merger of Driving Standards Agency, Vehicle and Operator Services Agency, and Driver and Vehicle Standards Agency
EU Legislation:
-
Commission Regulation (EU) No 630/2012 of 12 July 2012 amending Regulation (EC) No 692/2008, as regards type–approval requirements for motor vehicles fuelled by hydrogen and mixtures of hydrogen and natural gas with respect to emissions, and the inclusion of specific information regarding vehicles fitted with an electric power train in the information document for the purpose of EC type–approval.
Regulation 692 / 2008 contains inter alia general requirements for type-approval and other provisions related to the application for EC type-approval of a vehicle with regard to emissions and access to vehicle repair and maintenance information
Regulation 630/2012 extends the scope of Regulation (EC) No 692/2008 to hydrogen fuel cell vehicle -
Commission Regulation (EC) No 692/2008 of 18 July 2008 implementing and amending Regulation (EC) No 715/2007 of the European Parliament and of the Council on type–approval of motor vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle repair and maintenance information.
Regulation 692 / 2008 contains inter alia general requirements for type-approval and other provisions related to the application for EC type-approval of a vehicle with regard to emissions and access to vehicle repair and maintenance information
Regulation 630/2012 extends the scope of Regulation (EC) No 692/2008 to hydrogen fuel cell vehicle -
Directive 2014/45/EU of the European Parliament and of the Council of 3 April 2014 on periodic roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC Text with EEA relevance (with effect from 20 May 2018)
This Directive establishes minimum requirements for a regime of periodic roadworthiness tests of vehicles used on public roads. This applies to vehicles with a design speed exceeding 25 km/h of the following categories: M1, M2 and M3 (passenger motor vehicles, N1, N2 and N3 (motor vehicles for the carriage of goods, O3 and O4 (trailers over 3,5 tonnes) L (two or three wheels over 125cm3).