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
Legal gap for the use of fuel cells and associated fuels. No exact requirements for fuel cell ships, which makes approval more complicated. Alternative design process and its approval can take considerably more time.

Questions:

Question 1 Permit / approval a - Which is the responsible authority delivering the permit/approval required?
a - The Finnish Transport and Communications Agency (Traficom) is the responsible authority. Traficom has made an agreement by which it has authorized certain recognised organisations (classification societies) to carry out certain surveys. The division of labour between Traficom and the classification societies is set out in the agreement (Agreement governing the delegation of statutory certification services for ships registered in Finland) and its appendices.
Question 1 Permit / approval b - What are the procedures to be followed?
b - The procedure is defined in MSC.1/Circ.1455 – guidelines for the approval of alternatives and equivalents. It contains 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 include 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 - Presently there are no spesific regulations for the use of fuel cells on board, because fuel cells are not included as fuel consumers in the current version of the IGF Code. The IGF Code Correspondence Group (IGF CG) is developing draft amendments to the IGF Code regarding fuel cells. This includes agreeing on the definition of the fuel cell system, the elements to be included within the system boundaries, and requirements for fuel cell installations. Fuel cells are intended to be included in the scope of the IGF Code in its first revision.
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)?
Requirements according to the IGF Code. For alternative design (according to MSC.1/Circ.1212 and MSC.1/Circ.1455) a design team acceptable to the Administration should be established by the owner, builder, or designer, and expert(s) having the necessary knowledge and experience in safety, design and/or operation as necessary for the specific evaluation at hand. Other members may include marine surveyors, ship operators, safety engineers, equipment manufacturers, human factors experts, naval architects and marine engineers. The level of expertise that individuals should have to participate in the team may vary depending on the complexity of the alternative design and arrangements for which approval is sought.
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. Although the IGF is mandatory for all low–flashpoint fuels, it only contains detailed requirements for natural gas (either liquid or gas) on 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. Estimate about one year extra for alternative design.
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"