Safety requirements related to the end-user equipment
This LAP is concerned with the safety requirements (and design and operation aspects) for commercial and domestic end user equipment operating with hydrogen gas blends resulting from hydrogen injected and distributed in the local gas grid at the DSO level
Glossary:
The requirements needed to guarantee the safety of the end user application.
Is it a barrier?
Yes
Type of Barrier
Structural barriers, Regulatory gap
Assessment Severity
3
Questions:
Question 1
Is there any legislation with regard to safety requirements related to end-user equipment (e.g.: limits in terms of H2 for use in gas appliances)?
If yes, please answer the following question.
H2 is not allowed to be injected in the network purely. Under the Article 54 from Law 34/1998, hydrogen is allowed to be injected only with SNG.
National legislation:
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Law 34/1998, of 7 October, of the hydrocarbons sector.
In title IV "Management of the supply of combustible gases by pipeline" is explained the gas grid system and its regulation processes.”
- Resolution of 22 of September of 2011, of the Directorate General of Energy Policy and mines, by which modifies the protocol of detail PD–01 «Measurement» of the norms of technical management of the gas system.
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Admissible hydrogen concentrations in natural gas systems
Scientific study regarding the injections of hydrogen into the natural gas grid, and how it affects to the different equipments
EU Legislation:
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Regulation (EU) 2016/426 of the European Parliament and of the Council of 9 March 2016 on appliances burning gaseous fuels and repealing Directive
This Regulation applies to appliances burning gaseous fuels used for cooking, refrigeration, air-conditioning, space heating, hot water production, lighting or washing, and also forced draught burners and heating bodies to be equipped with such burners and to safety devices, controlling devices or regulating devices and sub-assemblies thereof, designed to be incorporated into an appliance or to be assembled to constitute an appliance (fittings).
Article 7 sets the obligations of manufacturers which should inter alia:
• ensure that appliances and fittings meet the essential requirements set out in Annex I.
• draw up the technical documentation referred to in Annex III (‘technical documentation’)
• carry out the relevant conformity assessment procedure
• keep the technical documentation and the EU declaration of conformity for 10 years
• ensure that procedures are in place for series production to remain in conformity
• carry out sample testing of appliances made available on the market,
• investigate, and, if necessary, keep a register of complaints, of non-conforming appliances and fittings and recalls of such appliances and fittings, and shall keep distributors informed of any such monitoring.
• ensure that their appliances and fittings bear a type, batch or serial number or other element allowing their identification, and the inscriptions provided for in Annex IV.
• indicate on the appliance their name, registered trade name or registered trade mark, and the postal address at which they can be contacted
• ensure that the appliance or fitting is accompanied by instructions and safety information
• ensure that the fitting is accompanied by a copy of the EU declaration of conformity containing, inter alia, instructions for incorporation or assembly, adjustment, operation and maintenance
• take corrective measures necessary to bring that appliance or fitting into conformity, to withdraw it or recall it, if appropriate.
• where the appliance or the fitting presents a risk, immediately inform the competent national authorities giving details, in particular, of the non-compliance and of any corrective measures taken
• provide competent national authority with all the information and documentation necessary to demonstrate the conformity of the appliance.
Article 9 sets obligations for importers which should inter alia:
• ensure that the appropriate conformity assessment procedure has been carried out
• ensure that the manufacturer has drawn up the technical documentation, that the appliance bears the CE marking and is accompanied by instructions and safety information and that the manufacturer has complied with the requirements set out in Article 7(5) and (6).
• indicate on the appliance their name, registered trade name or registered trade mark, and the postal address at which they can be contacted
• ensure that the appliance is accompanied by instructions and safety information in accordance with point 1.5 of Annex I, in a language which can be easily understood by consumers and other end-users, as determined by the Member State concerned.
• ensure that the fitting is accompanied by a copy of the EU declaration of conformity containing, inter alia, instructions for incorporation or assembly, adjustment, operation and maintenance in accordance, in a language which can be easily understood by appliance manufacturers, as determined by the Member State concerned.
• ensure that, while an appliance or a fitting is under their responsibility, storage or transport conditions do not jeopardise its compliance with the essential requirements
• carry out sample testing of appliances made available on the market, investigate, and, if necessary, keep a register of complaints, of non-conforming appliances and fittings and recalls of such appliances and fittings, and shall keep distributors informed of any such monitoring.
• for 10 years after the appliance or the fitting has been placed on the market, keep a copy of the EU declaration of conformity at the disposal of the market surveillance authorities and ensure that the technical documentation can be made available to those authorities, upon request
• further to a reasoned request from a competent national authority, provide it with all the information and documentation necessary to demonstrate the conformity of an appliance or a fitting in a language which can be easily understood by that authority
Article 10 sets the obligations of distributors which should inter alia:
• verify that the appliance bears the CE marking and that it is accompanied by instructions and safety information and that the manufacturer and the importer have complied with the requirements set out in Article 7(5) and (6) and Article 9(3) respectively
• not make the appliance or the fitting available on the market until it has been brought into conformity.
• ensure that, while an appliance or a fitting is under their responsibility, storage or transport conditions do not jeopardise its compliance with the essential requirements
• make sure that the corrective measures necessary to bring that appliance or fitting into conformity, to withdraw it or recall it, if appropriate, are taken. Furthermore, where the appliance or the fitting presents a risk, distributors shall immediately inform the competent national authorities of the Member States in which they made the appliance or the fitting available on the market to that effect, giving details, in particular, of the non-compliance and of any corrective measures take