U.S. Fuel Cell Council Leads Efforts for Transportation and Shipment of Small Fuel Cells and Their Fuels
Robert Wichert, U.S. Fuel Cell Council
Over the past three years the fuel cell and hydrogen industries have made great progress on standards and regulations for the transportation of small fuel cells and their fuels. Standards and regulations for fuel cells and their fuels, including hydrogen, have progressed by defining the requirements for shipping, transporting and carrying fuel cells and their fuels both for commercial distribution and for personal use. Prior to 2005, some fuel cell fuels could not be properly shipped or transported in normal commerce at all. Starting next year fuel cells and fuel cell fuels can be shipped in accordance with the 15th Revised Edition of the United Nations Recommendations on the Transport of Dangerous Goods Model Regulations, when adopted by the various authorities regulating shipment worldwide. This November the International Civil Aviation Organization (ICAO) will consider changes to their Technical Instructions For The Safe Transport of Dangerous Goods by Air that would incorporate the previous changes to the 15th Revised Edition of the UN Model Regulations and also allow all manner of fuel cells and their fuels to be transported by air, and carried on board passenger aircraft for passenger use. Robert Wichert of the US Fuel Cell Council serves as the industry representative to ICAO and to the United Nations and can be contacted for more information on these topics.
The first fuel cell fuel type to be addressed by the United Nations Sub-Committee of Experts on the Transportation of Dangerous Goods was methanol. Approved in December of 2004, the proper shipping name - UN 3473 - FUEL CELL CARTRIDGES Containing Flammable Liquids was included in the 14th Revised Edition of the UN Recommendations on the Transport of Dangerous Goods. Subsequent to that approval, the fuel cell industry petitioned the International Civil Aviation Organization (ICAO) to allow passengers to carry fuel cells and their fuels on board passenger aircraft for passenger use in flight. In November of 2005, ICAO approved not only methanol but also formic acid and butane for passenger carry-on and passenger use in flight, providing that an international specification for the safety of such systems was followed. This international specification, IEC PAS 62282-6-1, Fuel cell technologies - Part 6-1: Micro fuel cell power systems - Safety was published early in 2006 under the leadership of Harry Jones of Underwriters Laboratories. ICAO allowed this use by including these fuel cells and fuel cell fuels in their publication of the ICAO Technical Instructions For The Safe Transport of Dangerous Goods by Air, which became effective January 1, 2007. This was somewhat remarkable, actually, since formic acid and butane fuel cells were not listed in the UN Recommendations on the Transport of Dangerous Goods and UN listing is normally a prerequisite for coverage by the ICAO Technical Instructions.
Although adoption of the ICAO Technical Instructions For The Safe Transport of Dangerous Goods by Air is automatic in many countries, in the United States the US Department of Transportation must modify Title 49 of the Federal Code of Regulations (49CFR) to accommodate the change. The Pipeline and Hazardous Material Safety Administration agency (PHMSA) of the US Department of Transportation issued a Notice of Proposed Rulemaking on September 20, 2007 to do just that. The final outcome of this rule change will be decided later this year.
Also in December of 2004, the proper shipping name – UN 3468 HYDROGEN IN A METAL
HYDRIDE STORAGE SYSTEM was added to the 14th Revised Edition of the UN Recommendations on the Transport of Dangerous Goods. This made it possible to ship hydrogen in a metal hydride. Before this time it could not be shipped properly at all because it had attributes not covered by the current regulations. After the 14th Revised Edition of the UN Recommendations on the Transport of Dangerous Goods was published in January of 2006 and adopted by the various modal authorities having jurisdiction worldwide, hydrogen stored in a metal hydride could be shipped, but only with the explicit permission of the country where it was being shipped. This tended to discourage the use of hydrogen in metal hydrides since obtaining the explicit permission of each country where the system might be shipped was a difficult process. In November of 2005 the International Civil Aviation Organization approved modifications to UN 3468 that allowed shipment by air without explicit permission of the country where the system was shipped, providing that an international specification for the safety of such systems was followed. This international specification, IEC PAS 62282-6-1, Fuel cell technologies - Part 6-1: Micro fuel cell power systems - Safety also required compliance with another international specification, ISO TS 16111, Transportable gas storage devices -- Hydrogen absorbed in reversible metal hydride. ISO TS 16111 was developed under the leadership of Ned Stetson who now works in the hydrogen storage program at the US Department of Energy. Both of these specifications were developed by the fuel cell and hydrogen industries during the same time frame for this purpose, among others.
In 2006 the fuel cell industry, through the kind assistance of the US Department of Transportation and Transport Canada, petitioned the United Nations Sub-Committee of Experts on the Transportation of Dangerous Goods for proper shipping names for the following additional fuel cell fuels:
- UN 3476 Fuel cell cartridge or fuel cell cartridge contained in equipment or fuel cell cartridge packed with equipment, containing water-reactive substances (e.g. borohydrides)
- UN 3477 Fuel cell cartridge or fuel cell cartridge contained in equipment or fuel cell cartridge packed with equipment, containing corrosive substances (e.g. borohydrides or formic acid)
- UN 3478 Fuel cell cartridge or fuel cell cartridge contained in equipment or fuel cell cartridge packed with equipment, containing hydrogen in metal hydride
- UN 3479 Fuel cell cartridge or fuel cell cartridge contained in equipment or fuel cell cartridge packed with equipment, Containing liquefied flammable gas (e.g. butane)
And to amend UN 3473 as indicated below:
- UN 3473 Fuel cell cartridge or fuel cell cartridge contained in equipment or fuel cell cartridge packed with equipment, containing flammable liquids (e.g. methanol)
This request was granted, and these new proper shipping names will take effect upon publication of the 15th Revised Edition of the UN Recommendations on the Transport of Dangerous Goods in January of 2008, with adoption by the various modal authorities having jurisdiction worldwide to follow.
Now that proper shipping names for hydrogen stored in metal hydride, flammable gases (butane) and corrosive substances (borohydrides and formic acid) are listed in the UN recommendations, the US Fuel Cell Council, on behalf of the fuel cell industry, has again petitioned ICAO to allow carry-on and use of all fuels by airline passengers. This will be considered in November, 2007, at the 21st meeting of the ICAO Dangerous Goods Panel.
Subsequent to granting the permission to carry-on methanol, formic acid and butane fueled fuel cells, terrorist plots to use liquids as a weapon have limited liquids that may be brought on board aircraft from outside the secure area at airports worldwide. The US Fuel Cell Council, on behalf of the fuel cell industry, is working with the US Transportation Security Administration agency (TSA), as well as the International Civil Aviation Authority (ICAO) to cope with this situation. As part of this strategy the US Fuel Cell Council will ask ICAO to consider allowing fuel cells and their fuels to be put into checked baggage at the 21st meeting of the ICAO Dangerous Goods Panel in November, 2007.
A simplified timeline for small fuel cell shipment regulations is given below:
- December 2004 – UN Approves UN 3473 - FUEL CELL CARTRIDGES Containing Flammable Liquids and UN 3468 HYDROGEN IN A METAL HYDRIDE STORAGE SYSTEM in the 14th Edition of the UN Recommendations on the Transport of Dangerous Goods – Takes effect January 1, 2006.
- November 2005 – ICAO approves transport of UN 3473 and UN 3468 by air and passenger aircraft carry-on and use of formic acid, butane and methanol fuel cells – Takes effect January 1, 2007.
- February 2006 – IEC PAS 62282-6-1, Fuel cell technologies - Part 6-1: Micro fuel cell power systems - Safety is published.
- October 2006 -- ISO TS 16111, Transportable gas storage devices -- Hydrogen absorbed in reversible metal hydride is published.
- December 2006 – UN Approves UN 3476, UN 3477, UN 3478, UN 3479 and amends UN 3473 – Takes effect January 1, 2008.
- September 2007 – US Department of Transportation PHMSA issues notice of proposed rulemaking to allow fuel cells and fuel cell fuels to be carried on board and used by airline passengers. Other countries have already done this, worldwide.
- November 2007 (Future) – ICAO considers passenger carry-on, checked baggage and air shipment of all fuel cell fuels – Takes effect January 1, 2009.
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