On-board hydrogen transport

This LAP analyses the specific requirements for hydrogen when transported on-board vessels, together with the authorities competent to apply the rules and standards.


Transportation of compressed or refrigerated hydrogen in bulk or as packed cargo, excluded from the ship's own cargo tanks.

Pan-European Assessment:

The maritime transport of Liquified hydrogen as cargo is partially covered by interim recommendations contained in resolution MSC. 420(97) while compressed hydrogen needs to follow the same rules as gases with low flash points such as compressed natural gas, given their similar properties. Nevertheless, on-board hydrogen transport is characterized by an operational barrier, stemming from limited administrative and practical experience
However, the HyLAW study was not able to find documentation on the experiences of operators and authorities so far and do not have enough information to assess the severity of this barrier.


EU Legislation:

  • Directive 2012/18/EU of the European Parliament and of the Council of 4 July 2012 on the control of major-accident hazards involving dangerous substances (so-called SEVESO Directive)
    The Directive covers situations where dangerous substances may be present (e.g. during processing or storage) in quantities exceeding certain thresholds.

    It establishes:
    • General obligations on the operator (Article 5)
    • Notification (information on the form and amount of substances, the activity, and the surrounding environment) of all concerned establishments (Article 7),
    • The obligation to deploy a major accident prevention policy (Article 8),
    • The obligation to produce a safety report for upper-tier establishments (Article 10);
    • The obligation to produce internal emergency plans for upper tier establishments (Article 12);
    • Authorities to exert control of the siting of new establishments, modifications to new establishments, and new developments including transport routes, locations of public use and residential areas in the vicinity of establishments, (Article 13)
    • The obligation to conduct public consultations on specific individual projects that may involve risk of major accidents (Article 15)

    Annex I, Part 1, establishes Hydrogen as a dangerous substance (therefore within scope) and lists the quantity of hydrogen for the application of lower-tier requirements (≥ 5t) and upper-tier requirements (≥ 50t).

    For quantities of less than 5 tonnes of hydrogen, none of the obligations above would apply.

    The Directive is relevant for both the approval of bunkering / landing installations as well as on board transport of hydrogen
  • Resolution MSC.420(97) (adopted on 25 November 2016) Interim recommendations for carriage of liquefied hydrogen in bulk
    Annex 18: Interim recommendations for carriage of liquefied hydrogen in bulk.
  • Resolution MSC.370(93) (adopted on 22 May 2014); Amendments to the international code for the construction and equipment of ships carrying liquefied gases in bulk (IGC Code)
    The 2016 edition of the IGC Code incorporates amendments adopted by the MSC at its ninety–third session (May 2014) by resolution MSC.370(93), consisting of a complete replacement text of the IGC Code. The new requirements apply to ships whose keels are laid, or which are at a similar stage of construction, on or after 1 July 2016. They introduce new requirements for advanced analysis, including dynamic loads, buckling considerations, crack propagations analysis, detail fatigue analysis, etc.
  • 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.
  • International Maritime Dangerous Goods Code (IMDG Code)
    Part 1, General provisions, definitions and training, Part 2, Classification, Part 4, Packing and tank provisions, Part 5, Consignment procedures, Part 6, Provisions for the construction and testing of pressure receptacles, aerosol dispensers, small receptacles containing gas (gas cartridges) and fuel cell cartridges containing liquefied flammable gas, Part 7, Requirements concerning transport operations.
  • International Code for the Construction and Equipment of Ships carrying Dangerous Chemicals in Bulk (IBC Code)
    Chapter 2. ship survival capability and location of cargo tanks, chapter 3, Ship arrangements, chapter 4, cargo containment, chapter 5, cargo transfer, chapter 6, materials of construction, chapter 7, cargo temperature control, chapter 8, tank venting systems, chapter 11, fire protection and fire extinction, chapter 12, mechanical ventilation in the cargo area, chapter 14, personnel protection, chapter 15, special requirements, chapter 16, operational requirements.