Operation and maintenance

This LAP looks at the difference in the service and maintenance inspection (process and requirement) for a hydrogen vessel compared to vessels using other low flash-point fuels. It also lists the responsible authorities or independent bodies assigned to carry out technical inspections

Glossary:

The owner of a boat or ship using fuel cells and hydrogen as (primary or auxiliary) propulsion is required to
to ensure and document that operational procedures for the loading, storage, operation, maintenance, and inspection of systems for gas or low-flashpoint fuels minimize the risk to personnel, the ship and the environment and that are consistent with practices for a
conventional oil fuelled ship whilst taking into account the nature of the liquid or gaseous fuel. (By IMO resolution (MSC.391(95))

Pan-European Assessment:

There are no special requirements for ships using hydrogen as propulsion, except those of the IGF Code, so as per now there is no barrier specifically for hydrogen. However, the additional documentation requirements for alternative designs could perhaps be followed by specific operation and maintenance requirements in future

select country:

Is it a barrier?

Yes

Type of Barrier

Regulatory gap

Assessment Severity

Assessment

There is no specific regulation. Moreover, and as in the FCEV, it will become neccessary in the future that the manufacturers provide with useful information and maintenance trainnings to the technician that will be incharged of the maintenance work, in order to obtain long life and profitable products.

Questions:

Question 1 Is there a difference in the service and maintenance inspection (process and requirement) for a hydrogen vessel compared to vessels using other low flash-point fuels? a - all cases

a - There is no specification / regulation particular to hydrogen fuel cell vessels

b - NA

Question 1 Is there a difference in the service and maintenance inspection (process and requirement) for a hydrogen vessel compared to vessels using other low flash-point fuels? c - additional requirements in case of compressed gaseous hydrogen If yes, please specify, e.g. what are the specific maintenance needs and service requirements for hydrogen vehicles?

c - NA There is no regulation about this specific differentiation. Due to it, the more similar regulation is the one related with low flash–point fuels information MSC 391(35).

Question 2 Which are the responsible authorities/independent bodies to carry out technical inspections?

The Merchant Marine is the responsible authority. The inspections are made by government workers, who should have been instructed as it is explained in the Art 9 of the RD 1837/2000, as function of the requirements of their work.

Describe the comparable technology and its relevance with regard to hydrogen

LNG and biomethanol as fuel for fuel cells. Same treatment 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:

Royal Decree 1837 / 2000 of 10 November, which approves the regulation of inspection and certification of civilian ships.
Annex I. Chapter III Related with the Technical Inspections. It says that the test will be defined as function of the machinery that is implicit in the vehicle.

EU Legislation:

IMO resolution MSC 391(95): Adoption of the international code of safety for ships using gases or other low–flashpoint fuels (IGF Code)
Includes regulations to meet the functional requirements for for ships using gases or other low–flashpoint fuels. Chapter 5, ship design and arrangement; chapter 6, fuel containment system, chapter 7, general material design, chapter 8, bunkering, chapter 10, power generation, chapter 11, fire safety, chapter 12, explosion prevention, chapter 15, control, monitoring and safety systems, chapter 17, drills and emergency exercises, chapter 18, operations.
MSC.1/Circ.1455 – Guidelines for the approval of alternatives and equivalents
Requires development of maintenance and inspections procedures.
International Management Code for the Safe Operation of Ships and for Pollution Prevention (ISM Code)
Lays down the requirement for a working Safety Management System (SMS) for ships. Chapter 3, Company responsibilities and authorities, chapter 5, Masters responsibilities and authority, chapter 6, personnel qualifications, chapter 7, Key shipboard operations, chapter 8, Emergencies, chapter 9, Non–conformities and accidents, chapter 10, Maintenance., chapter 12, Company verification, review, and evaluation.
International Management Code for the Safe Operation of Ships and for Pollution Prevention (ISM Code)
Chapter 3, Company responsibilities and authorities, chapter 5, Masters responsibilities and authority, chapter 6, personnel qualifications, chapter 7, Key shipboard operations, chapter 8, Emergencies, chapter 9, Non–conformities and accidents, chapter 10, Maintenance., chapter 12, Company verification, review, and evaluation.