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
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.
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:
-
Government Decree on implementation of Resolution MSC.392(95) 1010/2016,
Alternative design procedure and IGF Code
-
Act on Ships’ Crews and the Safety Management of Ships (Laki laivaväestä ja aluksen turvallisuusjohtamisesta) 1687/2009 as amended
Safety management on board
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.