NFPA Upholds Appeal to Harmonize Separation Distance Tables

At its meeting of 4-6 August 2009, the NFPA Standard Council considered an appeal from Larry Fluer of Fluer, Inc., requesting that the Council accept Comment 52-34 to the 2010 edition of NFPA 52,VehicularGaseous Fuel Systems Code (formerly NFPA 52, Vehicular Fuel Systems Code). Specifically, the appeal requests the replacement of existing Table 9.3.1.3, Separation Distances for Outdoor Gaseous Hydrogen Systems with the corresponding extracted table (55:10.3.2.2.1) from NFPA 55, Compressed Gases and
Cryogenic Liquids Code (formerly NFPA 55, Storage, Use, and Handling of Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and Tanks) and accompanying material as shown in the Comment to support the Table.

After reviewing and considering all the information available to it, the Council has voted to uphold the appeal. The effect of this action is the replacement of existing Table 9.3.1.3, Separation Distances for Outdoor Gaseous Hydrogen Systems with the extracted table from NFPA 55 (Table 10.3.2.2.1) and accompanying material to support the Table as shown in Comment 52-34.

Access to Market: FC Regulation Standardization in USA
Robert Wichert, U.S. Fuel Cell Council

FUEL CELL CONSUMER PRODUCTS
There are no overall federal US requirements specific to the certification of fuel cells, but an unsafe product will almost certainly be pulled off the market and the whole marketing chain will face legal and monetary penalties.

The US Consumer Products Safety Commission will take action to restrict sale and can prosecute manufacturers, distributors, importers, wholesalers and retailers if a product is found to be unsafe or harmful.  Prosecution can result in recalls, or voluntary recalls may preclude prosecution.  Prosecution can also result in legal injunctions or monetary fines.  Action is normally based on consumer or community complaints and is usually the result of death or injury due to bad design, harmful chemicals or ignoring good practice. 

In addition to Consumer Product Safety Commission oversight, the US Environmental Protection Agency as well as the US National Highway Traffic Safety Administration agency have oversight responsibilities.  The US National Highway Traffic Safety Administration agency will prosecute or take other action if vehicles are not properly designed to meet the Federal Motor Vehicle Safety Standards.  The US Environmental Protection Agency will prosecute or take other regulatory action or impose monetary penalties if a product releases or contains restricted chemicals or compounds in hazardous amounts.

There are special restrictions on products intended for use by children.  According to the US Consumer Product Safety Commission, the term “children's product” means a consumer product designed or intended primarily for children 12 years of age or younger.  This special set of products must not contain lead or be potentially hazardous to children.  Fuel cells for this market will be subject to special scrutiny.

The US legal system is another way for the individual consumer to restrict the sale of a hazardous product, or even collect monetary damages from those who make or sell a hazardous product.  All aspects of the product are taken into account during such legal action. 

There are no overall US Federal requirements for the certification of fuel cells, but a prudent manufacturer will take measures to preclude producing a hazardous product, or even the public perception of producing a hazardous product.  Even public perception can lead to lawsuits.  In addition, in order to protect themselves from spurious or unjust litigation, a prudent manufacturer might choose to follow industry guidelines for the fuel cell product to show that due diligence and proper design practices are followed. 

Not only is the manufacturer subject to litigation, but the wholesaler and the retailer, like WalMart or Sears or Macys or Radio Shack, might also be sued by a consumer who feels that they have been sold an unsafe product.  In order to protect themselves from spurious or unjust litigation, a retailer may require compliance with industry standards and may require third party certification (not by the manufacturer and not by the retailer) that those industry standards have been met.

On top of the requirements to produce and sell a safe product to avoid litigation and recalls, US Federal Communications Commission standards must be met in compliance with Title 47 of the US Code of Federal Regulations to ensure that the device does not interfere with radio communications in an improper manner.

For fuel cell cartridges and systems to be allowed on board passenger aircraft as carry-on baggage they must meet IEC PAS 62282-6-1.  This is a regulation promulgated by the international civil aviation organization in their document “technical instructions for the safe transport of dangerous goods by air” and adopted by essentially every country as their laws for aircraft transport.

SAFETY STANDARDS WHICH MIGHT BE FOLLOWED, ALTHOUGH REGULATIONS DO NOT REQUIRE THIS:
 

ANSI/CSA America FC1-2004 (formerly ANSI Z21.83) American National Standard For [Stationary] Fuel Cell Power Systems

ANSI/CSA America FC3-2004 American National Standard For Portable Fuel Cell Power Systems

IEC 62282-5-1 International Electrotechnical Commission Portable Fuel Cell Appliance – Safety

IEC/PAS 62282-6-1 (2006-02) International Electrotechnical Commission Micro Fuel Cells - Safety

IEC 62282-2 Edition 1.1: 2007-03; Fuel cell technologies – Part 2: Fuel cell modules

Underwriters Laboratories Outlines of Investigation for portable fuel cells:
a) OI 2265A Methanol Fueled Micro Fuel Cells
b) OI 2265C Borohydride Fueled Micro Fuel Cells
c) OI 2262A Borohydride Fuel Cartridges

CE Marking is not required to sell a product in the US.

Manufacturers may choose to have independent, third-party (not by the manufacturer and not by the user) certification by a Nationally Recognized Testing Laboratory, such as Underwriters Laboratories (UL), CSA America (CSA), Factory Mutual (FM) or another testing laboratory.  These laboratories can mark the product with their logo to show evidence of such certification.  These marks have come to reflect a certain level of quality assurance and oversight by these testing laboratories and have come to be expected on electrical and gas equipment, although strictly speaking it is not necessarily required for consumer products.

POWER GENERATING PLANTS
In the United States, there is no nationwide requirement or regulation that applies to power plants.  Neither large generating plants nor small generating plants have nationwide regulations.  There are US federal requirements regarding the inter-state sales of electrical power and energy, but the construction of the power plant is a local issue, not a national issue.  
Local laws do apply to power generating plants since almost every US location has a local building code that requires buildings, equipment and other structures to be designed and built safely, for the good of everyone.  This might be under the jurisdiction of a city or a county or a parish or a special district.  For instance, New York City has its own unique requirements, different from Seattle, Washington.  Even areas which are not in a city are covered by laws that apply to other larger jurisdictions such as counties or parishes.  Some states, such as California, also have statewide standards.  This situation is well known to construction professionals and is enforced by the typical requirement to obtain a building permit, have periodic inspections by the local Building Department or other authority having jurisdiction over the project, and obtain a final permit to occupy or use the facility.  Local jurisdictions have local deviations and sometimes deviations are applied on a use-by-use basis.  Hospitals may have more stringent requirements than office buildings, for instance.  A typical set of building and construction regulations might include the following:

  1. Building Code – including seismic and structural standards
  2. Mechanical Code – including ventilation requirements
  3. Plumbing Code – including fuel piping, water and waste piping and process piping
  4. Energy Code – including energy efficiency and insulation
  5. Fire Code – including ventilation and fire protection requirements
  6. Electrical Code – including wiring, hazardous locations and fire protection requirements
  7. Administrative Requirements – including the requirements to obtain permits, mitigate environmental impacts, fees and inspection requirements
  8. Air Quality Regulations – including gaseous and particulate emissions

THESE REGULATIONS NORMALLY REQUIRE COMPLIANCE WITH STANDARDS
Some local regulations require that fuel cells be certified to comply with ANSI/CSA America FC1-2004 (formerly ANSI Z21.83); American National Standard For Fuel Cell Power Systems.  This standard is similar to 62282-3-1: Fuel Cell Power Systems – Safety, but it is different enough that in order to meet the local regulations, the fuel cell must be certified to comply with ANSI/CSA America FC1-2004.  In addition to compliance, it is normally required that the fuel cell be certified to comply by a “third-party” Nationally Recognized Testing Laboratory such as Underwriters Laboratories (UL), CSA America (CSA), Factory Mutual (FM) or another testing laboratory to comply.  This “third party testing” (not done by the manufacturer or by the user) is normally required by the building code regulations to ensure that a high level of quality assurance is provided.

Other regulatory requirements might include compliance with the following standards:

  • NFPA 54: National Fuel Gas Code
  • NFPA 55: Standard for the Storage, Use, and Handling of Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and Tanks, 2005 Edition
  • US Department of Labor Occupational Safety & Health Administration (OSHA) 29 CFR 1910 Subpart H – Hazardous Materials 1910.103 – Hydrogen
  • NFPA 853: Standard for the Installation of Stationary Fuel Cell Power Plants 2003 Edition 
  • NFPA 70: National Electrical Code Article 692 Fuel Cell Systems
  • ANSI / IEEE 1547-2003: IEEE Standard for Interconnecting Distributed Resources with Electric Power Systems
  • ANSI/CSA America FC1-2004 (formerly ANSI Z21.83) American National Standard For Fuel Cell Power Systems
  • IEC 62282-3-1: Fuel Cell Power Systems – Safety 
  • American Society of Mechanical Engineers PTC 50: Performance Test Code, For Fuel Cell Power System Performance
  • IEC 62282-3-2 (2006-03): Fuel Cell Power System – Performance

The specific standards that must be followed may be called out in the local regulations specifically.  But the local regulations may not discuss fuel cells at all.  If this is the case, WHEN NO STANDARDS EXIST, THE REGULATORY OFFICIALS CAN USE THEIR BEST JUDGEMENT, OR JUST SAY “NO” TO THE PROJECT.  If a fuel cell is certified to the above standards, however, it might have a better chance to be approved by the local officials.

 

Developments and Initiatives: Creating Modern Regulations for the Transport of Dangerous Goods
Courtesy ISO Focus

The world of international transport has seen the need to guarantee safety when carrying dangerous goods, such as gases in cylinders. Each mode of transport has developed its own rules such as the International Maritime Dangerous Goods Code developed by the International Maritime Organization (IMO) and the Technical Instructions published by the International Civil Aviation Organization (ICAO).

DISCLAIMER
This article was first published in June 2009 issue of ISO Focus magazine www.iso.org/isofocus and is reproduced here with the kind permission of ISO Central Secretariat.

International Short Course on "Hydrogen Production and Storage" Offered

5th International Short Course and Advanced Research Workshop: Hydrogen Production and Storage
19th – 23rd October 2009 , Belfast, UK
Early bird discount – book before 4th September for a 10% discount

Dear Colleagues, 

It is our pleasure to invite you to the 5th International short course and advanced research workshop in the series ‘Progress in Hydrogen Safety’. The subject of the 5th course is ‘Hydrogen production and storage’ . The brochure and registration form can be found at:http://hysafer.ulster.ac.uk/phs/. This promises to be an exciting event for industrialists, professionals, and researchers. International and domestic keynote speakers will present their expertise and experience in the emerging field of hydrogen economy, examples of the expertise you will hear include:

  • Jason Stoyel, TNEI, UK
    1. Hydrogen production from wind: Technical challenges
    2. Hydrogen safety at Yorkshire’s Forwards hydrogen mini grid 
  • Karl Verfondern, Research Centre Juelich, Germany
    1. Hydrogen production methods using nuclear energy
    2. Safety concepts for nuclear hydrogen production systems

Details on further speakers and the full programme will be available in August.

Who Should Attend? 
The International short course and advanced research workshop is an innovative event for researchers, professionals and industrialists alike and is ideally suited to those who wish to meet the growing demand for specialised professionals in academia and industry in hydrogen safety engineering, to help meet the needs of the economy and promote wealth creation. The course is an ideal educational and networking event for those working in industries and services, such as: aerospace, process industries, energy industry, civil works, transport and distribution, fire and rescue services, regulatory authorities, teaching and research institutes, various industrialist co operations, enterprise agencies, councils consultancies and those who have an interest in working with hydrogen in this new and rapidly advancing field.

The course is flexible and can be attended on individual days to suit your working pattern.

Wish to continue your education in hydrogen safety engineering after the International Short Course and Advanced Research workshop?
The teaching materials from the International short course series ‘Progress in Hydrogen Safety’ are used in the World's First Higher Educational Programme in Hydrogen Safety the PgCert/PgDip/MSc in Hydrogen Safety engineering offered by the University of Ulster. Those attending the International Short Course and Advanced Research Workshop, and who are also registered with the PgCert/PgDip/MSc in Hydrogen Safety Engineering, can obtain 20 CATS Points for the module “Progress in hydrogen safety” leading to the degree PgDip/MSc in Hydrogen Safety Engineering. 

I look forward to hearing from you,

Joan Casey, Business Manager
University of Ulster Hydrogen Safety Engineering (HySAFER Centre) 
w: http://hysafer.ulster.ac.uk/ 
e: j.casey@ulster.ac.uk

Agenda Now Available for NextEnergy's 2009 Hydrogen Codes and Standards Conference

Please note that the date for this event is now September 30th, 2009.

The Conference will highlight the latest developments in the hydrogen safety and permitting industry, as well as other technological developments in the realm of hydrogen.  This all-day event will be held at NextEnergy Center in downtown Detroit, MI.  All hydrogen industry members, permitting authorities, and individuals interested in hydrogen safety are encouraged to attend!

For more information, please contact Ryan Smith atryans@nextenergy.org