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
Is it a barrier?
Yes
Type of Barrier
Regulatory gap
Assessment Severity
1
Assessment
Since there are no hydrogen–driven vessels there is no legislation on operation and maintenance. The only exception is the pilot project HEPIC (Hydrogen Electric Passenger venICe boat), the first Hydrogen/FC Italian passenger boat, promoted in 2014 by Hydrogen Park and co–financed by Veneto Region, with the aim to realize the first Italian “zero emission” passenger boat, powered with electric motor and a hybrid system of hydrogen fuel cells and batteries

When hydrogen–driven vessels will be diffused the regulation will be modified consequently. At the moment, the Paris Memorandum of Understanding on State Port Control (Paris MoU on PSC) is applied

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 specific 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 - There is not a specification / regulation
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 - There is not a specification / regulation n/a
Question 2 Which are the responsible authorities/independent bodies to carry out technical inspections?
Procedures of refuelling have to be considered by the responsible authority that give the permission form navigation (The Italian Coast Guard at the peripheral offices). There is an assessment and control work between the technical classification company like RINA, the ship owner and the ship manufacturer. Then the request for identification to the Italian Coast Guard at the peripheral offices is made by the owner of the boat. There is not a defined roadmap. Port State Control (PSC) is the power of a State, deriving from international agreements, to carry out checks on foreign ships docking in its ports, with the aim of verifying their compliance with international regulations relating to shipping safety, anti–pollution and on–board living conditions, for the purposes of eventual application of relevant corrective measures. In this context, as regards Italy the Paris Memorandum of Understanding on State Port Control (Paris MoU on PSC) is applied. In Italy PSC inspections are implemented by qualified Coast Guard officers, in accordance with Legislative Decree 24 March 2011 n. 53, transposition of Directive 2009/16/CE)
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:

  • Legislative Decree n.53 of 24 March 2011
    Legislative Decree March 24, 2001 n.53 introduced several provisions to comply with European Commission Directive 2009 /16 , for the purpose of implementing effective procedures to monitor vessels of no Italian flag which call at Italian ports, and in compliance with international and EU provisions relating to safe navigation, marine transport, seamen, vessels, port facilities, marine and coastal environment and marine biological resources.

EU Legislation: