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.

Glossary:

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.
Is it a barrier?
Yes
Type of Barrier
Operational barrier
Assessment Severity
Assessment
At a glance, one might be inclined to conclude that a regulatory gap, exists, in that the IGC Code lacks specific requirements for hydrogen. However liquified hydrogen 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. Given this an operational barrier, stemming from lack of administrative and practical experience is more appropriate

Nevertheless, the 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.

Questions:

Question 1 Does hydrogen have to follow specific requirements when transported?
To ensure safety of life at sea, on–board transport of hydrogen in bulk or as packed cargo is subject to legal–administrative requirements related to the International Code for Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code) and the International Maritime Dangerous Goods Code (IMDG Code). Currently, the IGC Code lacks specific requirements for hydrogen. However, the IMDG Code imposes requirements for compressed and refrigerated liquid hydrogen which are comparable to those for compressed and liquid natural gas. A first draft of specific requirements for liquefied hydrogen as cargo under the IGC Code was proposed at the CCC (Carriage of Cargoes and Containers) sub–committee meeting. IMO adopted a set of interim recommendations for carriage of liquefied hydrogen in bulk (resolution MSC.420(97), on 25 November 2016). These recommendations state inter alia that • Materials of construction and ancillary equipment such as insulation should be resistant to the effects of high oxygen concentrations • For cargo pipes containing liquid hydrogen and cold hydrogen vapour, measures should be taken to prevent the exposed surfaces from reaching -183°C. • Double tube structures ensuring no leakage, or fixed hydrogen detectors being capable of detecting a hydrogen leak, should be provided for places where leakage of hydrogen may occur, such as cargo valves, flanges, and seals • The amount of carbon dioxide carried for a carbon dioxide fire-extinguishing system should be sufficient to provide a quantity of free gas equal to 75% or more of the gross volume of the cargo compressor and pump rooms in all cases. • An appropriate procedure should be established for warm-up, inert gas purge, gas-free, hydrogen purge and pre-cooling. • Only almost pure para-hydrogen (i.e. more than 95%) should be loaded. • In the case that fusible elements are used as a means of fire bdetection required by paragraph 18.10.3.2 of the Code, flame detectors suitable for hydrogen flames should be provided in addition at the same locations. • Liquid and gas hydrogen pipes should not pass through enclosed spaces other than those referred to in paragraph 5.2.2.1.2 of the Code, (i.e. resolution MSC.370(93)) • A risk assessment should be conducted
Question 2 a - Are there special requirements for on-board transportation of liquefied hydrogen?
a - IMO adopted a set of interim recommendations for carriage of liquefied hydrogen in bulk (resolution MSC.420(97), on 25 November 2016). Under the IMDG Code, the same restrictions apply to compressed and refrigerated liquid hydrogen limitations as packed cargo. In any case, liquid hydrogen cannot be stowed under deck
Question 2 b - Are there special requirements for on-board transportation of hydrogen as compressed natural gas?
b - Whereas the international code of safety for ships using gases or other low-flashpoint fuels (IGF Code) allows storage of fuel natural gas on–board passenger ships carrying more than 25 passengers, it is anticipated that initial restrictions regarding storage quantities and locations will be put in place for hydrogen (e.g. storage on top deck).
Question 3 Which authorities are competent to apply the regulations and standards?
If the standard has been made mandatory and mentioned in law, then any authority or entity, responsible and involved in maritime transportation of hydrogen must apply it.
Describe the comparable technology and its relevance with regard to hydrogen
Vessels carrying low–flashpoint fuels, such as liquefied natural gas (LNG) or compressed natural gas (LNG), The IMDG Code gives requirements for compressed and refrigerated liquid hydrogen which are comparable to those for compressed and liquid natural gas, and they have the same limitations as packed cargo.

National legislation:

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.