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
• 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.
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?
Assessment Severity
NA
Questions:
EU Legislation:
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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"
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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.
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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.
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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.
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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"