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
At the moment there are no special requirements for ships using hydrogen as propulsion, except those of the IGF Code.

Additional documentation requirements for alternative designs may be followed by specific operation and maintenance requirements in future.

The impact of thisLAP 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 - Resolution MSC.392(95) (containing amendments to SOLAS e.g. IGF Code, alternative design) is implemented by the Government Decree 1010/2016. The ISM Code has been made mandatory by the Regulation No 336/2006 of the European Parliament and of the Council on the implementation of the International Safety Management Code within the Community .
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 - N/A
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 - For low flash–point ships using fuel cells and hydrogen, there will be a list of minimum documentation requirements, to ensure compliance with the requirements of the IGF Code (resolution MSC.391(95), specifying the requirements for additional documentation for different alternative designs.
Question 2 Which are the responsible authorities/independent bodies to carry out technical inspections?
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.
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:

EU Legislation: