Cargo Shipment of Fuel Cell Vehicles
Robert Wichert, US Fuel Cell Council

Progress over the past three years
Over the past three years the fuel cell and hydrogen industries and allied fuel providers 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 for commercial transport, distribution and for personal use, even on board commercial aircraft. Prior to 2005, some fuel cell fuels could not be properly shipped or transported in normal commerce at all. Starting next year, all types of 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 those model regulations are adopted by the various authorities regulating shipment worldwide. This progress has been good for fuel cells, including fuel cells using hydrogen as fuel, but challenges remain. The USFCC is working with a wide range of stakeholders on shipment regulations for hydrogen fuel cell vehicles to meet some of these challenges. 

Cargo Shipment of Vehicles
The shipment of automobiles, buses and other vehicles is done routinely, safely and in accordance with local regulations to prevent any safety problems. Although the vehicles themselves are not inherently dangerous during shipment, some aspects of the shipment of vehicles require special consideration to assure safety. For example, many vehicles include airbag inflators and seat belt tensioners that consist of small amounts of what might otherwise be considered explosives. These small solid propellant devices are safe in the manner in which they are used, but the materials themselves might be considered hazardous materials -- or "dangerous goods" in the language of international trade. In order to regulate these materials while they are shipped as part of a vehicle, the vehicle itself might be regulated as dangerous goods. 

Batteries are also considered dangerous goods by international shipping regulations due to their energy content, short circuit potential and chemical constituents. These might be routinely shipped with vehicles and regulation of the vehicle with the batteries serves to ensure that batteries are not shipped in an unregulated manner. 

Fuel, of course, is often either flammable gas or flammable liquid and such substances are always considered dangerous goods by international shipping regulations. The shipment of vehicles, with fuel on board, must be done carefully in accordance with applicable regulations to assure safety and compliance with the law. 

International Shipment of Dangerous Goods – Regulatory Background
The UN Recommendations on the Transport of Dangerous Goods, Model Regulations are intended to form the basis for international shipping regulations for hazardous materials worldwide. These model regulations are published every two years by the United Nations after being debated and approved by their Sub-Committee of Experts on the Transport of Dangerous Goods (UN-SCETDG). More information on this deliberative body can be found at . The UN Model Regulations are then passed on to the regulatory bodies for the various modes of transportation:

All of these international and regional regulations are codified and enforced by the countries that have agreed to comply with them by contract or by treaty. Most countries choose to do so. In the United States, Title 49 of the US Code of Federal Regulations (49CFR) implements regulations for the transport of dangerous goods that follow the UN Model Regulations and follow the ICAO Technical Instructions. Other countries do likewise, with some exceptions. It is important to note that even though international regulations exist, the local laws always take precedence over the international agreements.

Vehicle shipment by air, land and sea
The UN Model Regulations only apply to vehicle shipment by air. For this reason the ICAO Technical Instructions for air cargo shipment include regulations for the international shipment of vehicles by air, but the international regulations cited above for road, rail and ocean shipment do not. Seagoing shipping companies, and in some cases the various countries, have their own guidance for the shipment of vehicles by ocean vessel. Although the UN Model Regulations do not apply to shipment by ocean vessel, the US regulations in 49CFR include regulations for marine shipment of road vehicles which are independent of the UN recommendations. These inconsistencies, and the lack of international model regulations for the shipment of vehicles by sea, have led to some confusion regarding ocean shipment of vehicles of all kinds. Hydrogen fuel cell vehicles may suffer the same fate. 

Cargo shipment of fuel cell vehicles
At this point in time, the UN model regulations do not properly address fuel cell vehicles. The only current UN model regulation entries for vehicles are UN 3166 and UN 3171 which specifically address internal combustion engine vehicles and battery-only electric vehicles, respectively. UN 3166 includes both flammable gas powered vehicles and flammable liquid powered vehicles, with appropriate guidance for each type included in the ICAO Technical Instructions for shipment by air. Without guidance on international shipment of fuel cell vehicles manufactures have been required to ship their fuel cell vehicles under special permits or by removing all dangerous goods and fuel in order to comply with the regulations in place. Proper coverage of fuel cell vehicles by the UN model regulations might help to eliminate some confusion regarding their shipment. 

In the US, the US Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA) agency has issued a letter of interpretation that makes it clear that in the US, fuel cell vehicles are to be treated the same as internal combustion engine vehicles under UN 3166 for the purposes of cargo shipment. The lack of UN model regulations for fuel cell vehicles has resulted in some confusion, however, regarding how fuel cell vehicles should be shipped internationally to and from the United States and has resulted in potential inconsistencies between US regulations and regulations in other nations, such as Japan. The lack of international model regulations for marine shipment of fuel cell vehicles has also resulted in some reports of confusion and reluctance on the part of maritime shippers to take shipments of hydrogen fuel cell vehicles by maritime cargo vessel, especially those where the vehicle is driven on and off the ship. 

Revisions to regulations in progress now
The fuel cell industry has started on the first steps to rectify this situation. The US Fuel Cell Council has filed a proposal to the UN Sub-Committee of Experts on the Transport of Dangerous Goods to include specific language regarding fuel cell engines and fuel cell vehicles. The Fuel Cell Council proposal can be found here:

The proposal by the US Fuel Cell Council essentially would make the classification advice by the US Department of Transportation a worldwide recommendation, classifying fuel cell vehicles under UN 3166, along with other flammable gas or flammable liquid vehicles since the risks are the same. Although this can help to clarify some confusion regarding the shipment of hydrogen fuel cell vehicles, additional work remains to be done. 

Since the UN Model Regulations for the cargo shipment of vehicles apply specifically only to shipment by air, and some reluctance to ship fuel cell vehicles by sea has been predicted, it may be prudent to consider the application of the UN Model Regulations to shipments by sea or even by road or rail. This will almost certainly by discussed at the upcoming meeting of the UN Sub-Committee of Experts on the Transport of Dangerous Goods in July of 2008. 

If a decision is reached on this issue, consequential changes to the regulations will certainly need to follow. The ICAO Technical Instructions For The Safe Transport of Dangerous Goods by Air will need to be revised to reflect the UN Model Regulations. The ICAOTechnical Instructions now provide specific instructions and special provisions that must be followed for the shipment of vehicles by air. For vehicles using flammable gas as fuel, the fuel must be removed or the fuel tank must be equipped with valves in the closed position and the amount of fuel is limited to 2000 kPa pressure in the fuel tank, or less than 5% of the maximum allowable working pressure of the fuel tank, whichever is lower. This restriction may not be sufficient for fuel cell vehicles and may need to be revised. 

If the UN-SCETDG decides that the UN Model Regulations, should apply to ocean shipment of vehicles, changes to the International Maritime Organization International Maritime Dangerous Goods Code (IMDG Code) as well as regional agreements such as the European Agreement Concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN) will need to be changed to harmonize them with the UN Model Regulations. 

Other decisions by the UN-SCETDG might affect The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) or the International Regulations Concerning the Carriage of Dangerous Goods by Rail (RID). Finally, the country by country regulations will have to be harmonized with the final decisions made. All of these steps will happen over the next two years as the UN and the other various regulatory bodies make their decisions. 

Industry stakeholders who are interested in affecting this issue are encouraged to contact the US Fuel Cell Council at or their Technical Director, Robert Wichert, at

Changes to Consider in the Federal Motor Carrier Safety Regulations and North American Standard Inspection Procedures to Accommodate Hydrogen as an Alternative
Karen Hall, National Hydrogen Association

The U.S. Federal Motor Carrier Safety Administration has released a report that explores what changes might be necessary to safety regulations and inspection procedures in order to accommodate commercial vehicles that use hydrogen as an alternative fuel.

You can download the report here (1,632Kb PDF) or through the Transportation Research Board website online at

Michigan's Rules for Hydrogen Storage Go into Effect
Robert McCann, Michigan Department of Environmental Quality

New rules regarding storage and handling of gaseous and liquefied hydrogen systems went into effect today. The rules, promulgated pursuant to the Fire Prevention Code, are the result of the cumulative efforts of the Department of Environmental Quality, local fire chiefs, industry experts, and other stakeholders and are the first of their kind in the nation.

These rules will apply to all gaseous and liquefied hydrogen storage systems and will regulate the storage and handling of hydrogen for industry and commercial operations. The DEQ hopes the rules form the basis for regulating and promoting the infrastructure necessary to support the expansion of fueling stations to accommodate hydrogen as an alternative fuel for the automotive industry.

Questions regarding these rules may be directed to the Storage Tank Unit, Storage Tank and Solid Waste Section, Waste and Hazardous Materials Division, DEQ, P.O. Box 30241, Lansing, Michigan 48909-7741, at 517 335 2690; or contact Andrea Zajac at 517 335 7294 or by e mail at

A copy of these rules may be downloaded from the DEQ Web site by clicking on
 or by going to (and click on "Land," "Storage Tanks," "Aboveground Storage Tanks," and under "Laws & Rules," click on "Gaseous & Liquefied Hydrogen Rules").

Editor's note: DEQ news releases are available on the department's Internet home page at

ISO/TC 197 (Hydrogen Technologies) Update for May 2008
Karen Hall, National Hydrogen Association

The U.S. TAG for ISO/TC 197 will meet on Friday, May 30 at CGA in Chantilly, Virginia beginning at 9 AM. A primary purpose for the TAG meeting is to prepare for the ISO/TC 197 meeting in Brisbane, Australia June 13. 

Currently out for vote

  • ISO/DIS 15869.3, Gaseous hydrogen and hydrogen blends—Land vehicle fuel tank
    Vote concludes August 26, 2008. U.S. TAG votes and comments by July 2. NHA members are encouraged to contact Karen Hall to provide comments and input on behalf of the NHA. Other countries are encouraged to contact their national mirror committees for additional information and an opportunity to review the document.

  • ISO/FDIS 22734-1, Hydrogen generators using water electrolysis process—Part 1: Industrial and commercial applications
    Vote concludes May 28, 2008. NHA members are encouraged to contact Karen Hall to provide comments and input on behalf of the NHA. Other countries are encouraged to contact their national mirror committees for additional information and an opportunity to review the document.

  • ISO/DIS 16110-2, Hydrogen generators using fuel processing technologies—Part 2: Procedures to determine efficiency
    U.S. votes are due by July 14, 2008 to allow time for obtaining a consensus U.S. position before the close of voting. NHA members are encouraged to contact Karen Hall to provide comments and input on behalf of the NHA. Other countries are encouraged to contact their national mirror committees for additional information and an opportunity to review the document.

New U.S. TAG Administrator
As of June 1, 2008, Jill Thompson will be the CGA U.S. TAG Administrator for ISO/TC 197. 

The NHA thanks Debbie Angerman of CGA for providing regular updates for the Hydrogen & Fuel Cell Safety Report and for serving the U.S. TAG so well over the years. 

SAE Publishes Hydrogen Quality Guidelines
Karen Hall, National Hydrogen Association

The Society for Automotive Engineers (SAE) has recently announced that the second version of document: J2719_200804 - Information Report on the Development of a Hydrogen Quality Guideline for Fuel Cell Vehicles has been published. 

The Hydrogen Quality Work Group of the SAE Fuel Cell Standards Committee has continued to develop this document, validating information contained in the first published version and working with ASME to develop test methods. This work, along with an international validation activity, continues, and will be used to update both the SAE Information Report and a similar ISO Technical Report. 

It is envisioned that the Information Report will be used to:

  • Simplify the testing and documentation requirements for fueling stations used in the fleet demonstration programs

  • Prioritize the testing of the effects of non-hydrogen constituents on fuel cell and storage media performance

  • Prioritize the durability effort on fuel cells

  • Prioritize the development of analytical measurement techniques and instruments

  • Assist in the compatibility testing of materials to be used with hydrogen fuel

  • Assist in setting the minimum functional requirements for components to be in contact with hydrogen fuel

  • Continue the dialogue in generating a fuel specification

The activity has utilized experts from around the world, including automobile manufactures, fuel cell developers, and hydrogen suppliers. The work has been coordinated with a similar activity in ISO/TC 197.

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