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))
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
Is it a barrier?
Yes
Type of Barrier
Regulatory gap
Assessment Severity
1
Assessment
In case of usage of hydrogen as fuel for fuel cell driven ships/vessels this LAP could hinder the market penetration of hydrogen but in Austria this sector hasn’t got a very high importance regarding hydrogen application yet
The impact of this lap, as a barrier and regulatory gap is difficult to estimate, due to lack of experience among the relevant stakeholders..
The impact of this lap, as a barrier and regulatory gap is difficult to estimate, due to lack of experience among the relevant stakeholders..
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
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?
b - additional requirements in case of liquid hydrogen
b - no experience existent currently
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 - no experience existent currently
n/a
Question 2
Which are the responsible authorities/independent bodies to carry out technical inspections?
no experience existent currently
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:
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IMO resolution MSC 391(95): Adoption of the international code of safety for ships using gases or other low–flashpoint fuels (IGF Code)
Although Austria entered the IMO one can’t get an approval for sea–vessels in Austria since the administrative burdens and thereto related costs are simply too high
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Law on shipping/navigation = Schifffahrtsgesetz
Not mentioned in the act, hence the scope which is relevant is not given
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Trade, Commercial and Industry Regulation Act = Gewerbeordnung
Article 32 defines the possible services which can provided by by industrial/craftman
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Law on industry safety
Article 6 area of operation of employees
EU Legislation:
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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.
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MSC.1/Circ.1455 – Guidelines for the approval of alternatives and equivalents
Requires development of maintenance and inspections procedures.
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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.
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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.