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
Regulatory gap
Assessment Severity
3
Assessment
The absence of specific rules for the type/design approval of hydrogen fuel cells vessels is a major obstacle for the commercial deployment of hydrogen fueled vessels in the maritime sector.
The “alternative design process” is currently the only means for approval of hydrogen vessels.
This process implies much higher cost, regulatory uncertainty and delays (estimation of more than one extra year for approval, as compared with other, more established technologies).

Questions:

Question 1 Permit / approval a - Which is the responsible authority delivering the permit/approval required?
The maritime sector is a federal competence, whereas inland shipping is a regional competence since Jan 1, 2015 (due to the 6th state reformation). For the sea-faring vessels , the Federal Public Service for mobility (> DG Maritiem Vervoer/Transport Maritime > Belgian Maritime Inspectorate) is responsible for checking the compliance with applicable legislation. For inland shipping, the regional departments of mobility are responsible.
Question 1 Permit / approval b - What are the procedures to be followed?
For maritime shipping: The alternative design procedure applies, with a risk-based approach. The Belgian Maritime Inspectorate defines the specific newbuilding procedure for a non-conventional vessel; the requirements defined by the BMI are dependent on the specific function and use area (In/outside Belgian territorial waters). In the case of national passenger ships, the Royal Decree of November 1981 gives BMI the authority to allow alternative fuels including hydrogen for vessel that operate 100% within national waters, such that international rules are not applicable and it can be categorized as a “national passenger ship” for which a specific set of requirements and norms defined . For the machinery-related components, a classification company has to be involved for the risk assessment and the approval of the implementation of the required measures. For inland shipping: For each individual ship recommendations from the CCNR and the ADN safety commission are required. First a risk analysis and design optimization has to be done, with the help of a classification company. Then the responsible representatives from the regional inland shipping commissions have to request for approval in the CCNR and subsequently at the ADN safety commission. Since these commissions only meet a few times a year, the whole procedure costs a lot of time
Question 2 What are the requirements for the use of fuel cells? a - All cases
There is no general procedure for fuel cells in shipping. For maritime applications, at international level, the International code for safety of ships using gases or other low flash-point fuels (IGF Code) contains mandatory provisions for arrangement, installation, control and monitoring, equipment and systems using low flashpoint fuels. The Code is mandatory under the International Convention for the Safety of Life at Sea (SOLAS). As Hydrogen has a flashpoint below 60°C, the IGF code generally applies. Nevertheless, Hydrogen as a fuel and Fuel Cells are not specifically addressed in the IGF code; the code is initially focusing on LNG. As such, the use of hydrogen as a fuel and hydrogen fuel cells is not explicitly covered by IMO rules. The regulatory gap applies to both propulsion (main or auxiliary) as well as the use of HFC for heating, cooling and other power generation purposes. Continued work has been agreed under the IGF Code working group, on E.g. fuel cells and methanol. In the absence of specific provisions, according to the IGF code, the use of other low flashpoint fuels including hydrogen can be approved based on alternative design . The Alternative Design Assessment is regulated by the convention of life at Sea (SOLAS II-1/55). The alternative design is the process by which the safety, reliability and dependability of the systems must be demonstrated to be equivalent to that achieved with new and comparable conventional oil-fueled main and auxiliary machinery. The equivalence of the alternative design shall be demonstrated by a risk-based approach as specified in SOLAS regulation II-1/55 and approved by National Maritime Authorities. The alternative design procedure applies and the use of fuel cells is part of the risk assessment. There is no experience yet in Belgium with fuel cells in ships.
Question 2 What are the requirements for the use of fuel cells? b - Additional requirements in case of liquid hydrogen
There is no general procedure for liquid hydrogen in shipping. The alternative design procedure applies and the use of liquid hydrogen is part of the risk assessment. There is no experience yet in Belgium with liquid hydrogen in ships.
Question 2 What are the requirements for the use of fuel cells? c - Additional requirements in case of compressed hydrogen
There is no general procedure for liquid hydrogen in shipping. The alternative design procedure applies and the use of compressed hydrogen is part of the risk assessment. There is no experience yet in Belgium with compressed hydrogen in ships.
Question 3 Who can do the technical implementation work (professional skills requirement)?
The IGF Code contains mandatory provisions for the arrangement, installation, control and monitoring of machinery, equipment and systems using low–flashpoint fuels, focusing initially on LNG. According to the Guideline of Maritime Safety Committee MCS.1/Circ.1455/2013 Design team is a team established by the owner, builder or designer, which may include, as the alternative design and arrangements demand, a representative of the owner, builder or designer and expert(s) having the necessary knowledge and experience for the specific evaluation at hand. Other members may include marine surveyors, ship operators, safety engineers, equipment manufacturers, human factor experts, naval architects and marine engineers
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?
There is no general procedure for hydrogen ships. The alternative design procedure applies but its duration and costs depend very much on the specific requirements set by the BMI, the outcome of the risk analysis, the people involved....
Describe the comparable technology and its relevance with regard to hydrogen
LNG

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"