Permitting process / requirements

This LAP refers to the permitting process and requirements for on one hand the drivers/transporting company and on the other hand the equipment (trailer). It defines what certification is needed for a driver/transporting company to transport hydrogen on public roads and which authority is competent to deliver the certification. It also gives information about the requirements needed for an equipment to be allowed to transport hydrogen on public roads, and if there is any specific approval required for the equipment.

Glossary:

The Permitting process is a process in which an applicant files forms to a (regulatory) agency/competent authority with required narratives, maps, etc., to ensure in advance that the proposed operation will be in compliance with the applicable standards. Permitting requirements are the legal (regulations and standards) requirements.
An internal safety distance is the minimal separation distance between a potential hazard source (e.g. equipment involving dangerous substances) and an object (human, equipment or environment), which will mitigate the effect of a likely foreseeable incident and prevent a minor incident escalating into a larger incident (also known as domino effect).

Pan-European Assessment:

The permitting process and requirements for the drivers/transporting company and the equipment (trailer) are well harmonized in Europe, because all countries follow the ADR regulation. As restrictions applied to hydrogen are the same as for any other flammable gas, most of the countries don’t see this LAP as a barrier
Is it a barrier?
No
Assessment Severity
0
Assessment
National transposition of the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) provides rules for transport of hydrogen by road, like respective safety obligations of participants in hydrogen transportation chain and regarding Safety Advisers who are responsible to monitor, control and identify ways in which the work associated with the transport of dangerous goods is carried out as safely as possible.

Questions:

Question 1 Drivers/transporting company: a - What certification is needed for a driver/transporting company to transport hydrogen on public roads?
a - The regulation ADR 2017, as transposed by Decree of Ministry of Infrastructure and Transport, 12 May 2017, in Part 1 ‘General provisions’ of the Annex A contains provisions concerning the respective safety obligations and certification of the various participants in dangerous goods transportation chain and regarding Safety Advisers who are responsible to monitor, control and identify ways in which the work associated with the transport of dangerous goods is carried out as safely as possible. The vehicle driver must have an ADR certificate.
Question 1 Drivers/transporting company: b - Which authority is competent to deliver the certification?
b - National requirements for appointment, tasks, training, examination and certification of dangerous goods Safety Advisers (DGSA) are set out by Ministry of Infrastructure and Transport (art.11, Legislative decree n.35, 27 January 2010).
Question 2 Equipment (e.g. trailer): a - What are the requirements needed for equipment to be allowed to transport hydrogen on public roads?
a - The Annex B of the ADR 2017 makes provisions concerning transport equipment and transport operations. In particular is divided in Part 8 Requirements for vehicle crews, equipment, operation and documentation and Part 9 Requirements concerning the construction and approval of vehicles.
Question 2 Equipment (e.g. trailer): b - Is any specific approval required for the equipment to be allowed to transport hydrogen (gas/liquid)?
b - The equipment shall comply with the requirements of ADR European Agreement for tanks and vehicles and also with the requirements of Transportable Pressure Equipment Directive.(ADR tank approval, ADR vehicle approval)

National legislation:

EU Legislation:

  • Directive 2008/68/EC of the European Parliament and of the Council of 24 September 2008 on the inland transport of dangerous goods.
    Extends the uniform rules of ADR to national transport.

    Article 5

    Restrictions on grounds of transport safety

    1. Member States may on grounds of transport safety apply more stringent provisions, with the exception of construction requirements, concerning the national transport of dangerous goods by vehicles, wagons and inland waterway vessels registered or put into circulation within their territory.
  • Directive 2004/54/EC of 29. April 2004 Minimal safety requirements for tunnels in the trans-European roads.
    The Directive applies to tunnels of more than 500 meters, in the Trans-European Road Network- TERN), included in the EEC agreement from 1999. It specifies both technical and operational requirements, and has been implemented in Norway (with some adjustments) through the Regulation on minimum safety requirements for certain tunnels [Forskrift om minimum sikkerhetskrav til visse vegtunneler (tunnelsikkerhetsforskriften)] of 15.05.07. Annex 1 is on safety measures, and chapter 3.7 of this annex, specifies such measures with respect to the transport of dangerous goods.
  • Directive 2010/35/EU, the Transportable Pressure Equipment Directive (TPED)
    The Directive applies to the design, manufacture, conformity assessment and periodic reassessment of transportable cylinders, tubes, cryogenic vessels and tanks for transporting gases as well as hydrogen cyanide, hydrogen fluoride and hydrofluoric acid. It also covers their associated valves and other pressure equipment. The Directive defines 3 categories for pressure equipment, based on its pressure volume product (P.V) in bar litres and hence its stored energy
  • ADR European Agreement concerning the international carriage of dangerous goods by roads.
    hazardous materials may in general be transported internationally in wheeled vehicles, provided that conditions be met for the product packaging and labelling; and that the construction, equipment, and use of vehicles for the transport is compliant: