Data
The need for standards in any field has obvious benefits. By following the standards, all developers can adopt the best practice that has emerged from all the R & D up to that point, and all facilities will function in a similar way, and will have the same level of reliability and safety.
The same is true of projects large and small involving hydrogen. Hydrogen projects in the UK are not currently under the control of any one body, but developers must instead consult deal with a number of bodies depending on the type of project. This includes the Local Authority / Town and Country Planning Authority which regulates the use of land, undertakes the Environmental Impact Assessment and is the hazardous substance authority in relation to storage. The Health and Safety Executive assesses local authority decisions and signs off driver training. The UK Vehicle Certification Agency approves hydrogen transport vehicles. The Oil and Gas Authority regulates new pipelines and decommissioning. Ofgem regulates the gas network.
With a mixed bag of regulations, codes of practice and guidance, it can be administratively difficult to get projects off the ground, but we can show here the activity taking place by standards organisations to get uniform regulations in place worldwide. There is naturally a significant level of caution embodied in these standards as a major incident could seriously damage the fledgling hydrogen sector.
We provide a summary below and a comprehensive list in the diagram above. The latter gives the title of publications relevant to different aspects of hydrogen projects which you may wish to refer to (data taken from the fuel cell standards website). It is evident there are many regulations, and that they are similar in different countries, but there are big gaps as well. Though there is an attempt to separate the scope, there are huge overlaps in content. There is a need for harmonisation. Note that these regulations tend to be very expensive to purchase!
OVERVIEW
If storing or transporting hydrogen the correct labelling is required. The following should be indicated:
H220: Extremely flammable gas.
H280: Contains gas under pressure; may explode if heated.
Label should include the word ‘Danger’
Text should include:
P210: Keep away from heat, hot surfaces, sparks, open flames and other;
P377: Leaking gas fire: Do not extinguish, unless leak can be stopped safely;
P381: Eliminate all ignition sources if safe to do so;
P403: Store in a well-ventilated place.
Use appropriate warning symbols
First Aid advice may include:
‘In high concentrations may cause asphyxiation.
Symptoms may include loss of mobility/consciousness. Victim may not be aware of asphyxiation. Remove victim to uncontaminated area wearing self-contained breathing apparatus. Keep victim warm and rested. Call a doctor. Apply artificial respiration if breathing stopped.’
Firefighting advice may include:
‘In case of fire: Stop leak if safe to do so. Do not extinguish flames at leak because possibility of uncontrolled explosive re-ignition exists. Continue water spray from protected position until container stays cool. Use extinguishants to contain the fire. Isolate the source of the fire or let it burn out.
Firefighters must use standard protective equipment including flame retardant coat, helmet with face shield, gloves, rubber boots, and in enclosed spaces, SCBA. Guideline: EN 469 Protective clothing for firefighters. Performance requirements for protective clothing for firefighting. EN 15090 Footwear for firefighters. EN 659 Protective gloves for firefighters. EN 443 Helmets for fire fighting in buildings and other structures. EN 137 Respiratory protective devices - Self-contained open-circuit compressed air breathing apparatus with full face mask - Requirements, testing, marking.’
Refer to this complete example to understand how to complete a full assessment.
SPECIFIC UK STANDARDS
The EU Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR) place duties on employers to eliminate or control the risks from explosive atmospheres in the workplace. Directive 99/92/EC (ATEX 137) states the minimum requirements for improving the health and safety protection of workers potentially at risk from explosive atmospheres. Directive 94/9/EC (ATEX 95) describes the equipment and protective systems required.
If stored under pressure, the Pressure Equipment Directive 1999 (EU directive 97/23/EC) applies and is implemented in the UK through Pressure Equipment (Safety) Regulations 2016 (PESR). In addition, the BCGA (British Compressed Gas Association) Codes of Practice are useful, in particular CP4, CP16, CP18, CP29, CP31, CP33, CP34, CP36, CP39, CP41, CP43, CP46.
The Health and Safety Executive (HSE) Manual Handling Regulations 1992 provide direction and guidance on assessing the risk of personal injury during gas cylinder manual handling operations; transporting or supporting loads by hand or by 'bodily force'. Key points of focus include ensuring good training and communication, clear work environment, manageable load handling and a reasonable work routine. The COSHH (Control of Substances Hazardous to Health) is the law in the UK that requires employers to control substances that are hazardous to health. Risk should be assessed, exposure limits controlled, chemical data should be readily available, control measures should be in place, PPE provided, monitoring conducted and health surveillance arrangements in place. A number of documents relate specifically to hydrogen, for example RR715 gives guidance on the installation of stationary fuel cells. RR769 is a position paper on the hazards of liquid hydrogen. If more than 2 tonnes of hydrogen is stored on site, the COMAH (Control of Major Accident Hazards) regulations apply, or the Planning (Hazardous Substances) Regulations 2015 if the quantity is small, and RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations) becomes relevant. The operator must have in place various strategies, including safety plans, emergency plans and a Major Accident Prevention Policy.
The British Standards Institution (BSI) has provided a guide for the selection, installation, use and maintenance of apparatus for the detection and measurement of combustible gases or oxygen (BSI - BS EN 50073) though this is current marked as ‘inactive’.
The 1986 Gas Act is also relevant (thought it deals mainly with natural gas). Specifically, it states in the Gas Safety (Management) Regulations that the concentration of hydrogen that can be injected onto the UK gas network is 0.1%. There is a desire to increase the hydrogen blend to up to 20% or more, but the regulations will need to be amended to allow for this. If moving hydrogen by road or pipeline, the HSE Gas Safety (Management) Regulations 1996 and Pipeline Safety Regulations (1996) should be consulted. The European Agreement concerning the International Carriage of Dangerous Goods by Road (“ADR”) regulates the transport of hydrogen, which is classified as a dangerous good under Annex 5 of the ADR. Drivers transporting hydrogen must be appropriately trained, and vehicles must meet specifications required for hazardous cargoes.
If planning a new stationary facility, an Environmental Impact Assessment may be needed to adhere to the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (there are separate versions for Northern Ireland, Scotland and Wales).
Investigations