The German hydrogen regulation, codes and standards roadmap
2020; Wiley; Volume: 45; Issue: 4 Linguagem: Inglês
10.1002/er.6249
ISSN1099-114X
Autores Tópico(s)Nuclear and radioactivity studies
ResumoInternational Journal of Energy ResearchVolume 45, Issue 4 p. 4835-4840 PERSPECTIVEFree Access The German hydrogen regulation, codes and standards roadmap Reinhold Wurster, Corresponding Author reinhold.wurster@lbst.de orcid.org/0000-0001-8215-9645 Ludwig-Bölkow-Systemtechnik GmbH, Ottobrunn, Germany Correspondence Reinhold Wurster, Ludwig-Bölkow-Systemtechnik GmbH, Daimlerstr. 15, 85521 Ottobrunn, Germany. Email: reinhold.wurster@lbst.deSearch for more papers by this authorElena Hof, NOW GmbH, Berlin, GermanySearch for more papers by this author Reinhold Wurster, Corresponding Author reinhold.wurster@lbst.de orcid.org/0000-0001-8215-9645 Ludwig-Bölkow-Systemtechnik GmbH, Ottobrunn, Germany Correspondence Reinhold Wurster, Ludwig-Bölkow-Systemtechnik GmbH, Daimlerstr. 15, 85521 Ottobrunn, Germany. Email: reinhold.wurster@lbst.deSearch for more papers by this authorElena Hof, NOW GmbH, Berlin, GermanySearch for more papers by this author First published: 01 December 2020 https://doi.org/10.1002/er.6249 Funding information: Nationale Organisation Wasserstoff- und Brennstoffzellen-Technologie NOW AboutSectionsPDF ToolsRequest permissionExport citationAdd to favoritesTrack citation ShareShare Give accessShare full text accessShare full-text accessPlease review our Terms and Conditions of Use and check box below to share full-text version of article.I have read and accept the Wiley Online Library Terms and Conditions of UseShareable LinkUse the link below to share a full-text version of this article with your friends and colleagues. Learn more.Copy URL Share a linkShare onEmailFacebookTwitterLinked InRedditWechat Abbreviations ADR Accord européen relatif au transport international des marchandises Dangereuses par Route (European Agreement concerning the International Carriage of Dangerous Goods by Road) AFID Alternative Fuels Infrastructure Directive (2014/94/EU) BetrSichV Betriebssicherheits-Verordnung (Ordinance on Industrial Safety) CEN Comité Européen de Normalisation (European Committee for Standardization) CENELEC Comité Européen de Normalisation Électrotechnique (European Committee for Electrotechnical Strandardization) EC European Commission EIGA European Industrial Gases Association EU European Union FC Fuel Cell FCEV Fuel Cell Electric Vehicle FCH JU Fuel Cell and Hydrogen Joint Undertaking (a public-private Partnership under participation of the European Commission) GB GB standard—GB stands for Guobiao, also 國家標準 / 国家标准, Guójiā Biāozhǔn—"National Standard" GTR Global Technical Regulation H2 Hydrogen IEC International Electrotechnical Committee ISO International Standardization Organization NLF New Legislative Framework OIML Organisation Internationale de Métrologie Légale (International Organization of Legal Metrology) RCS Regulations, Codes and Standards SDO Standard developing organizations TC Technical Committee TRBS Technische Regeln für Betriebssicherheit (technical rules for operational safety) UN United Nations UN ECE United Nations Economic Commission for Europe WG Working Group 1 INTRODUCTION The efficient and cost-effective realization and implementation of hydrogen and fuel cell technologies in the existing energy and transport systems require appropriate laws (regulations), standards and processes ("Regulations, Codes and Standards"—RCS). Almost all relevant regulations that are applicable to hydrogen and fuel cells in Germany today are based on, or must be adapted in, European legislation (directives or regulations). Likewise, the essential part of the standards used today is, or will be, harmonized with international (ISO, IEC) or European (EN) standards. New standards are essentially developed only within the framework of ISO, IEC or CEN, CENELEC. For example, in 2017, approximately 75% of the new standards relevant for Europe were international and only 20% European standards. Hydrogen (H₂) and Fuel Cell (FC) technologies are developed worldwide, especially in Asia, Europe and North America. This influence is also reflected in important regulations and standards for hydrogen (H₂ RCS). Due to the path of regulatory development via the New Legislative Framework adopted by the European Commission, the relevant actors have to anticipate, synchronize and harmonize the development of standards and regulations. Hence, an increased representation of German experts is required in all relevant international standardization committees. Consequently—in order to ensure the representation of Germany's interests in the future—a more active participation in committee work is required, particularly within the EU, UNECE, ISO, IEC, CEN and CENELEC. The development of standards and regulations and, in particular, the coordination between the two is complex and requires a concerted approach and substantial efforts. For this reason, the development of a roadmap strategy paper [1] was commissioned by NOW GmbH and hence prepared by LBST GmbH, in order to identify potentials and obstacles in a hydrogen RCS context. Furthermore, expedient measures and instruments have been identified, which could be implemented within a certain timeline to foster the involvement of German players in the establishment of a beneficial regulatory framework for hydrogen and FC technologies. The progress of this implementation must be regularly reviewed and, where appropriate, be adapted to changing requirements. As the topics with the biggest needs for action have been identified in the following ones: The revision and further development of the Alternative Fuels Infrastructure Directive (AFID) (2014/94/EU), the Global Technical Regulation on Hydrogen and Fuel Cell Vehicles (GTR 13) and the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR). The development of hydrogen and fuel cell standards within the framework of the relevant international bodies of ISO (eg, technical committees [TC] 197, 158, 58, 22), IEC (eg, TC 105 and 31) and the European technical committees of CEN / CENELEC (eg, TC 268 and Joint TC 6). An enhanced involvement of German and European players from industry, research and governmental institutions in these regulatory and standardization activities 2 MATERIALS AND METHODS In order to understand the complexity of RCS and the variety and multitude of aspects to be considered, some observations and clarifications have to be given at first hand. In almost all countries, standards are voluntary definitions of minimum requirements (see Figure 1) for interfaces between technological components or of such components with other systems or of technologies that use common elements shared by different platforms, sub-systems or systems. Standards intend to provide precise descriptions guaranteeing the compatibility of the related items through a written text agreed in scope and content among those developing such standards documents, typically standard developing organizations (SDOs). Standards can constitute barriers and protect commercial interests and at worst even impair innovations. On the other hand, standards can facilitate a harmonized market access, manufacturing and wide-spread use. In general, standards shall not be design but performance-oriented [3]. The only country where standards exist, which immediately have legal relevance and are mandatory to be applied, is China with its GB standards [4]. In most other countries or regions, standard may acquire legal relevance when referenced from legislation, like in the EU when referenced from a regulation or a directive. FIGURE 1Open in figure viewerPowerPoint Topics have to be considered in H2 RCS [4] [Colour figure can be viewed at wileyonlinelibrary.com] In order to simplify and harmonize the regulatory process, some governments have adopted the practice to write legal documents based on existing widely harmonized standards, see Figure 2. The European Union uses this approach in its so-called New Legislative Framework (NLF) [5] in order to harmonize legal requirements EU-wide with as limited efforts as possible by referring to existing international standards (ISO, IEC, EN). Which standards may be referenced is regulated in the EU Regulation on Standardization EU/1025/2012. FIGURE 2Open in figure viewerPowerPoint Possible interaction between regulatory documents and standards in the EU [4] [Colour figure can be viewed at wileyonlinelibrary.com] One of the most prominent results of this legislative process in the hydrogen sector in Europe is the Alternative Fuels Infrastructure Directive (AFID) 2014/94/EU. When referencing three existing standards for hydrogen in ANNEX II of this Directive in 2014, rapidly it turned out that these standards still needed improvement, were premature or did not sufficiently ensure EU-wide interoperability of the addressed hydrogen infrastructure. Consequently, in March 2015, the EC had to issue mandate M 533 and to order CEN to revise these standards (ISO/TS 20100, ISO 14687-2, ISO 17268). In German approval processes, using standards for specific technologies and applying these analogically to other comparable technologies, which are lacking availability of explicit rules, is accepted practice. In other countries this is not the case. This pragmatic and well-structured German approval process has so far allowed Germany to act with relatively low international reconcilement efforts. Nowadays, however, the NLF approach requires a significantly increased commitment in standardization as well as regulatory bodies, especially with regard to the national implementation of applicable/mandatory rules. Generally speaking, players need simple regulations and standards that are practical and easy to implement. In order to achieve this in a staged approach, the following implications have to be observed and addressed: RCS is a broad, complex topic and subject to constant change Duplication potentially is created through the lack of information Comprehensive examination of the subject Regulations, Codes and Standards (RCS) before an RCS strategy can be developed is mandatory Prerequisite to develop an understanding of how best to deal with the different aspects of RCS: Continuous attention to important developments Regular active participation in the corresponding RCS committees Setting a national position in RCS and alignment with EU Member States (eg, in and through the GSG) Introduction of this position into EU Member State bodies, for example, European Commission The benefit of harmonized RCS for stakeholders from the hydrogen and fuel cell industry consists of: Ensuring that interests of EU companies and member state policies are safeguarded in the European and international context [Lobby] Creating a European and internationally reliable framework, under which the stakeholders can act, consolidate and expand their position [Trend-setter] Fast transfer of technology developments into products for both the European as well as export markets [Technology leadership] Enhancing a broad acceptance for hydrogen technologies in society Investment security regarding clean future technologies like hydrogen fuel cells As the relevant international RCS bodies for participation and coordination, the following are suggested: with respect to regulations: Within the United Nations Economic Commission for Europe (UN ECE) Global technical regulations on hydrogen fuel cell electric vehicles (FCEV) revision of the GTR No.13 for hydrogen and fuel cell vehicles, according to the 1998 agreement revision of the UN ECE R134—type approval of hydrogen fuel cell vehicles in Europe, according to the 1958 agreement European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) relevant EC Working Groups of relevant Directorates General International Organization of Legal Metrology (OIML) TC 8/SC 7 recommendation on measuring systems for gaseous fuel with respect to standards: ISO: TC 197—Hydrogen Technologies, TC22/SC25—Vehicles using Gaseous Fuels, TC58—Gas Cylinders or TC58/SC3—Cylinder Design, TC158—Analysis of Gases, IEC: TC 105—Fuel Cell Technologies, CEN: TC 268 Cryogenic Vessels—WG5 Specific Hydrogen Technologies Applications CEN/CLC/JTC 6 on Hydrogen, EIGA WG 11 Hydrogen Energy, Figure 3 visualizes the hierarchy and legal function of German national as well as international RCS, structured according to their level of detail. FIGURE 3Open in figure viewerPowerPoint Regulatory topology as displayed by the German H2-Roadmap 2025 [1] [Colour figure can be viewed at wileyonlinelibrary.com] In the following Figure 4, the most important needs for action as displayed in the German H2-Roadmap 2025 and their anticipated timelines are illustrated: FIGURE 4Open in figure viewerPowerPoint Identified need for action in the German H2-roadmap 2025 [1] [Colour figure can be viewed at wileyonlinelibrary.com] The topological integration of the German legislation into the European and international regulatory framework is shown in Figure 5: FIGURE 5Open in figure viewerPowerPoint Topological integration of the German legislation into European and international RCS [2] [Colour figure can be viewed at wileyonlinelibrary.com] The latter indicates that—according to German legislation—technical rules for operational safety (TRBS), which reflect the state of the art and ensure the implementation of the Ordinance on Industrial Safety (BetrSichV) as issued by the German Federal Ministry of Labor and Social Affairs, have to be complied with in addition to the international and European framework legislation. 3 CURRENT CHALLENGES It has become clear in these RCS activities over the last years that sometimes not all international standards and regulations can be implemented nationally or regionally without certain adaptations required by national legislation. Simultaneously, not all specific national legislative requirements can be agreed upon in the international committees at UN or ISO. Furthermore, many national laws cannot be adapted to such a degree that international standards or regulations could be transplanted 1:1. As two prominent examples may serve the following: the UN GTR13 on type approval of FCEVs and ISO 19880-1 on layout, operation and maintenance of HRSs. Certain Chinese requirements might not be accepted in the present modification process of GTR 13 and thus—even if China adopts the final GTR 13-II in its GB—some additional requirements may have to be included. Regarding ISO 19880-1, an international standard cannot include all local specificities as standards try to cover minimum requirements only. Consequently, the European AFID required certain interoperability needs that were not covered by this ISO standard. Hence, the development of a European standard—EN 17127—was initiated to address these while still being harmonized with the respective ISO document as much as possible. Analogous to the standards EN 17124 on hydrogen quality and quality control (harmonized with ISO 14687 and ISO 19880-8) and EN ISO 17268 on refuelling connection devices, EN 17127 is now referenced from the AFID and legally binding. 4 OPPORTUNITIES The development of a harmonized position on hydrogen and fuel cell relevant RCS, per country, per region and globally has been identified as very desirable, efficient and effective. Harmonization efforts at all levels of legislation and standards development—including the alignment between both—where required, necessary or advisable have started, are on-going or still have to be initiated in some cases. These international efforts typically occur on the level of UN, EU, ISO and IEC bodies. Although the three large economic areas of China, the EU and North America could agree on regulations and standards for their regions separately, harmonizing specifications and interfaces of components and sub-systems on a global level makes a lot of sense due to the international exchange between these regions—especially with regard to the fast economic growth of both Asian and African countries. In this context, harmonization could contribute significantly to economic efficiency by limiting the number of solutions required (eg, with respect to materials and quality control), hence fostering the implementation of hydrogen and fuel cell applications in national, regional and global markets. 5 FUTURE DIRECTIONS The establishment of a national H2 RCS coordination platform has been identified as a useful instrument to achieve a successful implementation of regulatory and normative requirements while involving all relevant actors and stakeholders. Major tasks of this platform could include, but are not limited to: Observation of priority developments and trends Development of a unified position/vote in RCS matters on a national level Regular consultation/harmonization with the relevant actors on national level (representatives of industry, relevant networks and other experts) Development of a unified position/vote in RCS matters within Europe Coordination of RCS activities with the FCH JU in Europe Cooperation with the European Government Support Group (GSG) to achieve an agreement on common positions among the EU member states Influence of/participation in European (CEN/CENELEC) and international (ISO/IEC) standards development ACKNOWLEDGEMENTS The research was funded by the German BMVI (Federal Ministry of Transport and Digital Infrastructure). REFERENCES 1Wurster, R. Dey, R Elliger, T and Jungsbluth J. 2018. Die Deutsche H2-RCS-Roadmap 2025,commissioned and edited by NOW GmbH, Berlin. https://www.now-gmbh.de/de/aktuelles/presse/now-broschuere-die-deutsche-h-rcs-roadmap-2025. Google Scholar 2Zerta, M, Die Deutsche H2-RCS Roadmap 2025, Presentation by Ludwig-Bölkow-Systemtechnik GmbH, Vollversammlung zum Nationalen Innovationsprogramm Wasserstoff- und Brennstoffzellentechnologie (NIP), Berlin, 6 December 2018. Google Scholar 3 Deliverable D10, Measures for codes, standards and regulations for safe (and efficient) deployment of hydrogen in European Union, VTT, 20 December 2004. Google Scholar 4R. Wurster, Regulations, Codes and Standards (RCS) for Hydrogen and the Role of European Member States, Presentation to the Government Support Group, Austrian Ministry for Transport, Innovation and Technology, Vienna, October 6th, 2016. Google Scholar 5 New Legislative Framework. https://ec.europa.eu/growth/single-market/goods/new-legislative-framework_en. Google Scholar Volume45, Issue425 March 2021Pages 4835-4840 FiguresReferencesRelatedInformation
Referência(s)