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
It is an inherent transport issue for the transport of hazardous flammable / explosive gasses and the industrial gas firms (BOC Linde, Air Products, etc.) indicate that this is just part of their operational planning. New entrants and those with new transportable H2 refuelling systems have reported that the complexity and requirements for vehicle and H2 storage equipment adherence is a barrier. It has also been noted by industry that the Pressure Equipment Regulations which cover the cylinders and other storage tanks used for hydrogen transport are onerous and that there may be country specific requirements for tank testing rather than a uniform testing regime across the EC

Questions:

Question 1 Drivers/transporting company: a - What certification is needed for a driver/transporting company to transport hydrogen on public roads?
a - The driver must have had specific safety training aligned with the specific hazardous cargo (or mixed loads) being transported both at the operational level and in case of emergency the specific procedures that need to be followed and which emergency numbers to be used / which agency must be informed. The transport company is responsible for ensuring the driver is fully trained and that there are regular updates to training. It must also ensure that the vehicle meets ‘design, construction and use’ standards for the specific hazardous cargo (or mixed loads) to be carried and that the correct markings and signs are displayed in the correct locations. It must also ensure that drivers carry the correct ADR paperwork on each and every journey and follow the correct ADR procedures; and that all required safety equipment is installed, regularly inspected and fit for emergency use. Driver training must be carried out by an approved agency (or in–house agency) approved by the UK Health & Safety Executive in order to be an approved driver.
Question 1 Drivers/transporting company: b - Which authority is competent to deliver the certification?
UK Health & Safety Executive
Question 2 Equipment (e.g. trailer): a - What are the requirements needed for equipment to be allowed to transport hydrogen on public roads?
2 a - The truck / trailer, as the 'vehicle' must meet ‘design, construction and use’ standards for the specific hazardous cargo (or mixed loads) to be carried and the UK VCA (vehicle certification agency) is the authority to check and certify this when the vehicle is new and entering service, and then on an annual basis to ensure continuing compliance. Pressure vessels fitted to the vehicle as cylinders or tubes for H2 transport above 0.5barg must also comply with Pressure System Safety Regulations. If they are removable not fixed cylinders then they need to conform to the regulations on a stand alone basis and the vehicle will need to be shown (to the VCA) to be designed for their safe carriage The Pressure Equipment Regulations apply in the UK to the design, manufacture, conformity assessment and periodic reassessment of transportable cylinders, tubes, cryogenic vessels and tanks for transporting gases; also covers associated valves and includes both refillable and non–refillable cylinders. It applies to existing equipment as well as new equipment introduced since the PED implementation date, 1st July 2001. Existing equipment is checked for compliance during annual periodic assessments. Aspects of the design, production and testing of the equipment are the subject of a large number of harmonized standards. In addition to ensuring that the equipment is capable of meeting the performance requirements of the directive, manufacturers must also complete a specified declaration of conformity and they must compile and maintain a technical file of information about how the equipment was designed and manufactured and supply it to the Notified body. The ADR specifies what needs to be marked on the equipment and included in the instructions .
Question 2 Equipment (e.g. trailer): b - Is any specific approval required for the equipment to be allowed to transport hydrogen (gas/liquid)?
Approvals are required by the VCA (Vehicle Certification Agency, part of UK Department for Transport). The VCA accepts the ADR certification issued in any other EU country for a EU built / certified truck / trailer and the chassis of the trailer that is transporting H2 also needs to be ADR-certified and considered valid for transporting dangerous goods in the form of hydrogen. Approval / certification of the chassis in the UK is with the Driver & Vehicle Standard Agency (DVSA)
Describe the comparable technology and its relevance with regard to hydrogen
Other flammable hazardous gasses

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: