Approval for landing/bunkering installations

This LAP contains information about the procedures for landing and bunkering installations associated with hydrogen transport on vessels. It provides information on the responsible approving authority and the particularities of the procedure when considering hydrogen in it’s liquid or compressed form.

Glossary:

Protection of employees from explosion risk in areas with potentially explosive atmospheres, relating to a set of zone definitions, minimum safety and health requirements, and criteria for the selection of equipment and protective systems in the different zones

Pan-European Assessment:

In most countries, requirements for bunkering (loading) of hydrogen as a fuel on–board the vessel are not yet developed. It is likely that, for now, general rules stemming from storage of hydrogen (see category 2) and rules covering HRS’s (see category 4.4) would apply. It is worth noting that, given the high energy demand of medium to large vessels, the quantities involved will be in the order of several tonnes, hence hydrogen storage facilities would likely be subject to significant obligations and requirements (e.g. SEVESO)

Existing rules for safe handling of inflammable, reactive and pressurized substances (e.g. which cover inter alia LNG) currently apply, however, it is not certain how these would be adapted to hydrogen. From this point of view, this process is characterized by a clear regulatory gap.

Early indication would show that further risk studies and technology qualification is required for the establishment of specific regulatory guidance covering liquid and compressed gaseous hydrogen for landing and bunkering installations. This is further indication that specific regulatory solutions to this regulatory gap are years away. Although there is limited practical experience, the lack of clarity as to the applicable rules s further reinforces the severity of the administrative barriers faced by the introduction of hydrogen as a fuel in the maritime sector.
Is it a barrier?
Yes
Type of Barrier
Regulatory gap
Assessment Severity
2
Assessment
The Regulation for safe handling of inflammable, reactive and pressurized substances, including relevant installations and equipment, applies to all. The requirement of consent comes in for installations harbouring above 5 tons of hydrogen and must be foreseen for all bunkering of hydrogen for passenger ships.


The IGF Code does not include requirements for storage and use of hydrogen as a fuel in ships. Use of fuel cells in ships is also not regulated.

Questions:

Question 1 Which is the responsible approval authority?
Maritime Offices under Ministry of Maritime Economy and Inland Navigation Polski Rejestr Statków (Polish Register of Shipping) UDT – Technical Supervision Ministry of the Environment
Question 2 Is the procedure different than for conventional vessels? a - If yes, what is the procedure to follow? E.g.: Requirement for additional certificates and documents: all cases additional requirements in case of liquid hydrogen additional requirements in case of compressed hydrogen
a - i. n/a ii. n/a iii. n/a
Question 2 Is the procedure different than for conventional vessels? b - How much time does it take and what are the additional costs incurred?
b - n/a
Describe the comparable technology and its relevance with regard to hydrogen
Conventional fossil fuel, LNG and biomethanol as fuel for fuel cells are the relevant technologies to compare with. The Regulation for safe handling of inflammable, reactive and pressurized substances, including relevant installations and equipment, applies to all. The requirement of consent comes in for installations harbouring above 5 tons of hydrogen and must be foreseen for all bunkering of hydrogen for passenger ships.

National legislation:

EU Legislation:

  • Directive 2012/18/EU of the European Parliament and of the Council of 4 July 2012 on the control of major-accident hazards involving dangerous substances (so-called SEVESO Directive)
    The Directive covers situations where dangerous substances may be present (e.g. during processing or storage) in quantities exceeding certain thresholds.

    It establishes:
    • General obligations on the operator (Article 5)
    • Notification (information on the form and amount of substances, the activity, and the surrounding environment) of all concerned establishments (Article 7),
    • The obligation to deploy a major accident prevention policy (Article 8),
    • The obligation to produce a safety report for upper-tier establishments (Article 10);
    • The obligation to produce internal emergency plans for upper tier establishments (Article 12);
    • Authorities to exert control of the siting of new establishments, modifications to new establishments, and new developments including transport routes, locations of public use and residential areas in the vicinity of establishments, (Article 13)
    • The obligation to conduct public consultations on specific individual projects that may involve risk of major accidents (Article 15)

    Annex I, Part 1, establishes Hydrogen as a dangerous substance (therefore within scope) and lists the quantity of hydrogen for the application of lower-tier requirements (≥ 5t) and upper-tier requirements (≥ 50t).

    For quantities of less than 5 tonnes of hydrogen, none of the obligations above would apply.

    The Directive is relevant for both the approval of bunkering / landing installations as well as on board transport of hydrogen
  • ATEX Directive 2014/34/EU - covering equipment and protective systems intended for use in potentially explosive atmospheres
    The Directive defines the essential health and safety requirements and conformity assessment procedures (Article 4) to be applied before products are placed on the EU market and is significant for the engineering of hydrogen production plants. It covers inter alia equipment and protective systems intended for use in potentially explosive atmospheres.

    The Directive requires employers to classify areas where hazardous explosive atmospheres may occur into zones. The classification given to a particular zone, and its size and location, depends on the likelihood of an explosive atmosphere occurring and its persistence if it does.

    The Directive requires the manufacturers to design their equipment to be suitable for use within their customer’s explosive atmosphere. Therefore, manufacturers of equipment rely upon their customer to give them information about the classification of the zone and the flammable substance(s) within that zone.

    The Directive describes the rules and regulations for all actors in the value chain, with respect to ensuring that only safe equipment for use in potentially explosive atmospheres are sold and applied. It provides regulation of how the equipment shall be constructed, produced and documented, as well as the rules for CE-labelling.

    It also contains, inter alia conformity assessment procedures (Art 13) EU declaration of conformity (Art 14) and General principles of the CE marking (Art 16)

    The Directive is relevant for the approval of landing / bunkering installations
  • Directive 1999/92/EC of the European Parliament and of the Council of 16 December 1999 on minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres
    Directive 1999/92/EC lays down minimum requirements for the safety and health protection of workers potentially at risk from explosive atmospheres which will apply to facilities involved in the production, storage and distribution of hydrogen. It sets out a number of specific obligations on the employer, including inter alia:

    • Prevention of and protection against explosions
    • Assessment of explosion risks
    • Special requirements for work equipment and workplaces
  • Directive 2014/68/EU of the European Parliament and of the Council of 15 May 2014 on the harmonisation of the laws of the Member States relating to the making available on the market of pressure equipment.
    The Pressure Equipment Directive, applies to the design, manufacture and conformity assessment of pressure equipment and assemblies with a maximum allowable pressure greater than 0.5 bar.

    Technical requirements and classification according to an ascending level of hazard, depending on pressure, volume or nominal size, the fluid group and state of aggregation, as well as conformity assessment procedures are laid down and required by the Directive

    Hydrogen is a fluid which falls under Group 1. Group 1 consists of dangerous fluids (flammable, toxic and/or oxidizing). As a result, a large part of the equipment for H2 production, storage and distribution must meet the technical requirements set out in the Pressure Equipment Directive (PED).

    The Directive is relevant for the approval of landing / bunkering installations
  • Directive 2009/16/EC on port State control
    Directive 2009/16 introduces within the EU a port State control
    system based on the inspections performed within the Community and the Paris MOU. It’s purpose is to increase compliance with international and relevant Community legislation on maritime safety, maritime
    security, protection of the marine environment and onboard
    living and working conditions of ships of all flags;

    It does so by establishing common criteria for control of ships by the
    port State and by harmonising procedures on inspection and
    detention
  • Directive 2013/38/EU of the European Parliament and of the Council of 12 August 2013 amending Directive 2009/16/EC on port State control
    Directive 2009/16 introduces within the EU a port State control
    system based on the inspections performed within the Community and the Paris MOU. It’s purpose is to increase compliance with international and relevant Community legislation on maritime safety, maritime
    security, protection of the marine environment and onboard
    living and working conditions of ships of all flags;

    It does so by establishing common criteria for control of ships by the
    port State and by harmonising procedures on inspection and
    detention