Design/Type approval

This LAP analyses the rules surrounding the Design/Type approval of Hydrogen Fuell Cell Powered vessels. It looks, specifically into:
• the responsible authority delivering the permit/approval
• the procedures to be followed
• the requirements for the use of fuel cells (incl. additional requirements in case of liquid or compressed hydrogen
• the specific type approval process for a hydrogen boat/ship

Glossary:

Type approval means the procedure whereby it is certified that a type of vessel, system, component or separate technical unit satisfies the relevant administrative provisions and technical requirements

Pan-European Assessment:

In the context of design / type approval of hydrogen / hydrogen fuel cell vessels, there is a very clear and highly damaging regulatory gap

The current procedure for design and type approval of hydrogen and hydrogen fuel cell vessels (i.e. the alternative design) is not the solution to mass deployment. The procedure for approval of alternative design is lengthy, costly, unpredictable and subject to individual (subjective) interpretation.
Is it a barrier?
Yes
Type of Barrier
Operational barrier, Economic barrier, Regulatory gap
Assessment Severity
3
Assessment
As there is no experience in this field, there is a huge lack of regulation. The first step should be the use of some demostration prototypes in Europe, and after this prototypes demostrate the correct performance of the hydrogen as a fuel, then the EU should work in this legislation and its promotion as fuel. Also fuel cells and hydrogen used in back up applications and power applications should be considered in this field, because this equipment should follow specific rules in order to be allowed to be shipped in a boat.

Questions:

Question 1 Permit / approval a - Which is the responsible authority delivering the permit/approval required?
a - The Merchant Marine, which is part of the “Ministerio de Fomento”, is the organism that rules the type–approval and the inspections of the ships.
Question 1 Permit / approval b - What are the procedures to be followed?
b - For Spanish boats Chapter III from RD 1837/2000. For other countries’ boats Chapter IV from RD 1837/2000 In order to obtain the type approval, a project has to be presented before building the ship. This project has to consider all the international agreements (SOLAS, MARPOL) and respect them. The procedure is mainly defined in MSC.1/Circ.1455 – guidelines for the approval of alternatives and equivalents. The process has five stages: 1) Development of a preliminary design, 2) Approval of a preliminary design, 3) Development of final design, 4) Final design testing and analyses, and 5) Final approval. The guidelines describe the process in detail and includes comprehensive technical, risk and environmental assessment, with broad stakeholder involvement.
Question 2 What are the requirements for the use of fuel cells? a - All cases
a - a - There are no specific regulations yet for use of fuel cells on board. The IGF Code Correspondence Group (IGF CG) is developing draft amendments to the IGF Code regarding fuel cells. The amendments to SOLAS(International Convention for the Safety of Life at Sea) chapter II–1 (Construction – Structure, subdivision and stability, machinery and electrical installations), include amendments to Part F Alternative design and arrangements, to provide a methodology for alternative design and arrangements for machinery, electrical installations and low–flashpoint fuel storage and distribution systems; and a new Part G Ships using low–flashpoint fuels, to add new regulations to require ships constructed after the expected date of entry into force of 1 January 2017 to comply with the requirements of the IGF Code, together with related amendments to chapter II–2 and Appendix (Certificates). Some notified bodies have developed guidelines for fuel cell systems installations in ships using gas. These Guidelines should be applied in addition to the relevant provisions of the SOLAS. Moreover, in order to use a fuel cell in a ship, this equipment has to be approved before, following the instructions and the type–approval tests explained in the RD 701/2016 for the boats in Spanish waters, or an ammend that appaers for this rule.
Question 2 What are the requirements for the use of fuel cells? b - Additional requirements in case of liquid hydrogen
b - The IGF Code (International Code of Safety for Ships Using Gases or Other Low–Flashpoint Fuels) contains detailed requirements for natural gas. Other low–flashpoint fuels are allowed but, given that no detailed requirements have been adopted yet for fuels other than natural gas, approval is based on the alternative design approach
Question 2 What are the requirements for the use of fuel cells? c - Additional requirements in case of compressed hydrogen
c - The IGF Code contains detailed requirements for natural gas. Other low–flashpoint fuels are allowed but, given that no detailed requirements have been adopted yet for fuels other than natural gas, approval is based on the alternative design approach. The possible allowed locations for pressure tanks are still an open issue. There is need to qualify the pressure tanks for maritime use, referring to Pressure Equipment Directive, Agreement Concerning the international carriage of dangerous Goods by Road (ARD), IEC and ISO rules and standards for fuel cells in rod vehicles and small stationary power systems.
Question 3 Who can do the technical implementation work (professional skills requirement)?
The implementation work is done by the shipyard operators, because once the project has been approved, they are the responsible of built the ship. All the technical work needs to be supervised by a technician with the competences of a Naval Engineer.
Question 4 Is there a specific type approval process for a hydrogen boat/ship? If yes, please specify, e.g. how long does the procedure take and what are the costs to obtain a type approval?
Yes. The International Code of Safety for Ships using Gases or Low–Flash–Point Fuels (IGF Code) provides specific requirements for ships using natural gas, ethyl–methyl alcohols, hydrogen, low flashpoint diesel and bio diesel. However, the code only contains detail requirements for natural gas (LNG or CNG) and only for use in internal combustion engines, boilers and gas turbines. Until IMO has approved a phase 2 development of the IGF Code, applications falling within the frame of the IGF Code Part A, including use of fuel cells, are required to follow the alternative design method in accordance with SOLAS Regulation II–1/55 for demonstration of an equivalent level of safety.
Describe the comparable technology and its relevance with regard to hydrogen
Comparable technologies are conventional fossil fuel, LNG and biomethanol as fuel for fuel cells. They are subject to the same procedures as per the IGF Code (IGF A, 3.2.1, IGF A 4.2, IGF A, 4.3), but as the Code does not provide specific requirements for fuel cells, MSC.1/Circ.1455 will apply.

National legislation:

EU Legislation:

  • Directive 2014/90/EU of the European Parliament and of the Council of 23 July 2014 on marine equipment
    Directive 2014/90/EU makes the minimum SOLAS requirements mandatory in the EU. Several countries outside the EU area also automatically approve and accept products with M.E.D. 96/98/EC authorization.
    This Directive applies to equipment placed or to be placed on board an EU ship and for which the approval of the flag State administration is required by the international instruments, regardless of whether the ship is situated in the Union at the time when it is fitted with the equipment.
    The directive covers types of marine equipment that fall under following International Conventions developed by the International Maritime Organization (IMO):
    •SOLAS 1974: Life–saving appliances/navigation equipment/radio equipment
    •MARPOL 1973: Marine
  • Directive 2009/45 on safety rules and standards for passenger ships.
    Directive 2009/45/EC introduces uniform rules on new and existing passenger ships and high-speed passenger craft, when both categories of ships
    and craft are engaged on domestic (intra- EU) voyages.

    Article 6 defines the general safety requirements for passenger ships. Article 9, introduces Additional safety requirements, equivalents, exemptions.
    The Directive also states that member states may adopt additional measures and adopt measures allowing equivalents for the detail requirements laid down in Annex 1 to the Directive, according to a stated procedure. Chapter II–2 of Annex 1, is specifically on requirements with respect to fire protection, detection and extinction.
  • IGF Code: International Code of Safety for Ships Using Gases or Other Low–Flashpoint Fuels, 2016 Edition (I109E)
    The main part (A–1) contains specific requirements for use of natural gas and is limited to this. The initial part (A) opens up for use of other gases and LFLs through "Alternative Design"
  • International Convention for the Safety of Life at Sea (SOLAS) EU directive
    Chapter I, on surveying the various types of ships and certifying that they meet the requirements of the convention. Chapter II–1 – Construction – Subdivision and stability, machinery and electrical installations. Chapter II–2 – Fire protection, fire detection and fire extinction: Fire safety provisions for all ships with detailed measures for passenger ships, cargo ships and tankers..Chapter III – Life–saving arrangements. Chapter V – Safety of navigation, requires that all vessels are sufficiently and efficiently manned from a safety point of view, including requirements concerning all potential dangers to navigation, the competence of the crew, and all other relevant factors. Chapter VII – Carriage of dangerous goods, requires compliance with the International Bulk Chemical Code (IBC Code), and the International Maritime Dangerous Goods Code (IMDG Code. Chapter IX – Management for the Safe Operation of Ships requires every shipowner and any person or company that has assumed responsibility for a ship to comply with the International Safety Management Code (ISM). Chapter XI–1 – Special measures to enhance maritime safety, including operational requirements.
  • MSC.1/Circ.1455, 24 June 2013: Guidelines for the approval of alternatives and equivalents as provided in various IMO instruments
    As noted above, the whole document is relevant and defines the alternative design process and approval requirements in detail.
  • International Convention for the Safety of Life at Sea (SOLAS)
    Chapter I, on surveying the various types of ships and certifying that they meet the requirements of the convention. Chapter II–1 – Construction – Subdivision and stability, machinery and electrical installations. Chapter II–2 – Fire protection, fire detection and fire extinction: Fire safety provisions for all ships with detailed measures for passenger ships, cargo ships and tankers..Chapter III – Life–saving arrangements. Chapter V – Safety of navigation, requires that all vessels are sufficiently and efficiently manned from a safety point of view, including requirements concerning all potential dangers to navigation, the competence of the crew, and all other relevant factors. Chapter VII – Carriage of dangerous goods, requires compliance with the International Bulk Chemical Code (IBC Code), and the International Maritime Dangerous Goods Code (IMDG Code. Chapter IX – Management for the Safe Operation of Ships requires every shipowner and any person or company that has assumed responsibility for a ship to comply with the International Safety Management Code (ISM). Chapter XI–1 – Special measures to enhance maritime safety, including operational requirements.
  • IGF Code: International Code of Safety for Ships Using Gases or Other Low–Flashpoint Fuels, 2016 Edition (I109E)
    The main part (A–1) contains specific requirements for use of natural gas and is limited to this. The initial part (A) opens up for use of other gases and LFLs through "Alternative Design"