Safety requirements (compliance with safety regulation / risk control expectations)

This LAP is concerned with risk management and safety requirements for hydrogen injection and transport in the low pressure local DSO gas grid and the regulatory oversight to ensure safe operations


Safety regarding the handling and precautions to be taken when dealing with pure hydrogen and blend of H2 and NG when injected in the grid.
Is it a barrier?
Type of Barrier
Regulatory gap, Structural barriers
Assessment Severity


Question 1 Which safety precautions are needed at your facilities when dealing with hydrogen and how is this related to legal and administrative procedures (e.g. ATEX, leakage detection, etc.)?
In general, by the construction and operation of hydrogen injection systems must be respected the safety requirements of: 1. DVGW Worksheets: G 265–1/3 Systems for the upgrading and injection of biogas into gas supply networks/ Systems for injection of hydrogen into gas supply networks G 491 Gas pressure control systems and 2.Technical regulations in accordance with the Ordinance on Industrial Safety and Health. a) All equipment components (feeding pipe, valves (e.g., pressure control device), compressor, gas meters, etc.) have to be certified by notified body ( TÜV, DEKRA etc. in Germany) for material compatibility and have respective documents for pressure equipment and for explosive equipment (CE– conformity declarations, CE–marking); The process gas chromatograph has to be calibrated for detection and measuring of hydrogen; b) The injection facilities have to be equipped with an emergency shut down, which comes into action when the properties of the injected gas leave the acceptable range. c) Implementation of risk assessment of the plants (creation of safety data sheets) and classification of EX–zones.
Question 2 Which additional safety requirements are needed for the injection of hydrogen compared to the injection of natural gas?
For hydrogen concentrations up to 10 Vol.–%, no increased safety risk against natural gas can be assumed, if maintenance and service plans, ex zones and operational plans are adapted, hydrogen operators sensitized, fire brigades are specially trained and prepared. It is possible that additional monitoring measures are necessary for the injection systems e.g. leakage monitoring system At higher hydrogen concentrations > 10 Vol.– % a step–by–step safety adjustment adapted to the hydrogen concentration must be made, which also involves the exchange of hardware.
Question 3 For which aspects is it needed to have good agreements about safety between the supplier and DSO?
The assessment of grid compatibility (calculation of the maximum permissible hydrogen content) in the particular gas network and the permissible feed–in volume or capacity) is essential for the connection agreement in order to ensure the grid to be operated and the gas to be used safely.
Question 4 Which is the competent authority or entity with regard to safety requirements?
The competent authority is the permitting authority, issuing a construction and operation permit for the injection installation. The responsible authorities vary among the states, normally this is the state Trade Supervisory Inspectorate (Gewerbeaufsichtsamt).The responsible authority may involve in the permitting process various institutions such as fire brigade. The network operator can also have some safety requirements.
Describe the comparable technology and its relevance with regard to hydrogen

National legislation:

EU Legislation:

  • ATEX Directive 2014/34/EU - covering equipment and protective systems intended for use in potentially explosive atmospheres
    The Directive defines the essential health and safety requirements and conformity assessment procedures (Article 4) to be applied before products are placed on the EU market and is significant for the engineering of hydrogen production plants. It covers inter alia equipment and protective systems intended for use in potentially explosive atmospheres.

    The Directive requires employers to classify areas where hazardous explosive atmospheres may occur into zones. The classification given to a particular zone, and its size and location, depends on the likelihood of an explosive atmosphere occurring and its persistence if it does.

    The Directive requires the manufacturers to design their equipment to be suitable for use within their customer’s explosive atmosphere. Therefore, manufacturers of equipment rely upon their customer to give them information about the classification of the zone and the flammable substance(s) within that zone.

    The Directive describes the rules and regulations for all actors in the value chain, with respect to ensuring that only safe equipment for use in potentially explosive atmospheres are sold and applied. It provides regulation of how the equipment shall be constructed, produced and documented, as well as the rules for CE-labelling.

    It also contains, inter alia conformity assessment procedures (Art 13) EU declaration of conformity (Art 14) and General principles of the CE marking (Art 16)

    The Directive is relevant for the approval of landing / bunkering installations
  • Directive 2010/75/EU on industrial emissions (integrated pollution prevention and control (IED)
    The Directive, which applies to the production of hydrogen (production on an industrial scale by chemical or biological processing) (Annex I, point 4.2) contains inter alia:
    • Basic obligations of the operator (Article 11)
    • The content of permitting applications (Article 12)
    • Permitting Conditions (Article 14)
    • Emission limit values, (Article 15)
    • Monitoring requirements (Article 16)
    • Access to information and public participation (Article 24)

    The meaning of "production on an industrial scale by chemical or biological processing in Annex I section 4" has been clarified by the EU Commission, in support of transposition and implementation measures. :

    Annex I Section 4 (“chemical industry”) refers to “production on an industrial scale” and contains no quantitative capacity thresholds. The scale of chemical manufacture can vary from a few grams (of a highly specialised product), to many tonnes (of a bulk chemical product); yet both may correspond to “industrial scale” for that particular activity.

    Various criteria should be taken into account to decide whether production is “on an industrial scale”, including such factors as the nature of the product, the industrial character of the plant and machinery used, production volume, commercial purpose, production solely for own use, environmental impact. Such considerations should take account of the primary objective of the IED as expressed in Article 1 as to "prevent or, where that is not practicable, to reduce emissions into air, water and land and to prevent the generation of waste, in order to achieve a high level of protection of the environment taken as a whole", complemented by the general principle set in Article 11 (c) that "no significant pollution is caused".

    The fact that the activity is carried out for "commercial purposes" may be a strong indicator of "industrial scale", […] However, it may not be sufficient to use the “commercial purpose” of an activity as the sole determinant of "industrial scale". It may also be important to take into account the potential environmental impact of a production sequence.

    Directive 2010/75/EU established an integrated approach towards prevention and control. This integrated approach means that the permits must take into account the whole environmental performance of the plant, covering e.g. emissions to air, water and land, generation of waste, use of raw materials, energy efficiency, noise, prevention of accidents, and restoration of the site upon closure. The permit conditions including emission limit values must be based on the Best Available Techniques (BAT).
  • Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment (SEA Directive)
    The Directives (and their subsequent amendments) define a strategic environmental impact assessment procedure. The procedure is summarized as follows: the developer may request the competent authority define what should be covered by the EIA information to be provided by the developer (scoping stage); the developer must provide information on the environmental impact (EIA report – Annex IV); the environmental authorities and the public (and affected Member States) must be informed and consulted; the competent authority decides, taken into consideration the results of consultations. The public is informed of the decision afterwards and can challenge the decision before the courts.

    In line with the EIA Directive, Production and Storage of Hydrogen falls within the projects listed in Annex II (6a and 6c -production of chemicals; and storage facilities for chemical product), for which Member States shall determine whether the project shall be made subject to an assessment or not. In some EU countries, storage of 5 tons of hydrogen or more falls within the scope of the Directives.

    The latest amendment, (Directive 2014/52/EU) introduces minimum requirements with regards to the type of projects subject to assessment, the main obligations of developers, the content of the assessment and the participation of the competent authorities and the public.