Safety requirements and process (safety distances internal / external)
This LAP analyses, in general, the safety requirements (regulations and standards) associated with the approval of HRS. In particular, this LAP looks at the general rules applicable to an HRS (e.g. permitting regime, agreement) apart from the land use planning, including but not limited to:
a) environmental assessment (e.g.: emissions (IED), noise, etc.)
b) risk assessment
c) technical, including internal/external safety distances safety requirements
d) Personnel safety requirements
The LAP also explores whether it is allowed to install an HRS indoors (for example for forklifts) as well as the additional requirements applicable when an HRS is installed indoors.
Safety requirements, risk assessments, safety distances and other requirements covered in this section are essential elements which ensure the long-term sustainability of any future HRS network, therefore, although they impose high costs (both economically, as well as in time required for planning, building and permitting), overall, they are seen as necessary investments for a safe, sustainable operation of the HRSs.
Currently, there is no clear set of safety requirements, (including distances, permits, assessments) defined specifically for Hydrogen Refueling stations in most European countries. In practice, the requirements imposed on HRS projects will be based case-by-case risk assessments or represent precautious estimations by local authorities. In this sense, a regulatory gap and, to a certain extent, a structural barrier can be observed.
The regulatory gap for safety requirements specific to HRS has several major consequences:
• HRS operators face uncertainty during permitting: there is no standardized approach by the administration for the interpretation of the applicable regulation, which can lead to non–uniform interpretation by different authorities,
• Unreasonably high requirements: Authorities which wish to exercise a high degree of precaution in the face of limited experience with hydrogen technologies interpret general (industrial) regulations by imposing the “maximum” level prescribed
• Duplication of efforts, without added safety benefits: every new HRS project is treated on a case by case basis which increases the necessity of individual (case–by–case) modelling, calculation, planning, etc. Designs which have been deemed safe already could be replicated at lower administrative and economic cost, however this does not appear to be the case in most countries.
• Disincentive HRS with on-site production: the authorization procedure for HRS with on–site production is cumbersome and, in some cases, prohibitive
The administrative practice and existing rules in some countries impose excessive safety distances for Hydrogen Storage, this is seen as a structural barrier, as imposing unreasonable safety distances prevents the adaptation of conventional refueling stations to include hydrogen re-fueling within existing locations, therefore resulting in a major barrier for the accelerated uptake of hydrogen mobility.
This map depicts the severity of this barrier across the HyLaw Partner countries.
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The HyLAW project has received funding from the Fuel Cells and Hydrogen 2 Joint Undertaking under grant agreement No 737977.
This Joint Undertaking receives support from the European Union’s Horizon 2020 research and innovation programme, Hydrogen Europe and Hydrogen Europe Research.