Transportation and Shipment of Small Fuel Cells and Their Fuels – An Update
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. The International Civil Aviation Organization (ICAO) has approved changes to their Technical Instructions For The Safe Transport of Dangerous Goods by Air that 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 following fuel cell cartridge types are currently covered by the 15th Revised Edition of the United Nations Recommendations on the Transport of Dangerous Goods, Model Regulations


The US Fuel Cell Council, on behalf of the fuel cell industry, again petitioned ICAO to allow carry-on and use of all fuels by airline passengers in 2007. This was approved in November of 2007, taking effect in January of 2009.  In the United States, the US Department of Transportation published a Notice of Proposed Rulemaking for the purpose of harmonizing the US regulations with the ICAO Technical Instructions in July of 2008.  This Notice of Proposed Rulemaking can be found here:

Hydrogen stored in metal hydride storage systems
Currently the regulations for the transport of hydrogen stored in metal hydride storage systems are not well harmonized.  The United Nations Recommendations on the Transport of Dangerous Goods, Model Regulations requires special approval by the country of origin for any shipments, but the ICAO Technical Instructions For The Safe Transport of Dangerous Goods by Air allow shipments provided that the hydrogen in metal hydride storage systems comply with IEC PAS 62282-6-1 and the International Standards Organization (ISO) document ISO TS 16111, Transportable gas storage devices -- Hydrogen absorbed in reversible metal hydride.  These two documents are well harmonized and compatible, so compliance with the air transport regulations is not onerous provided that the proper guidance is followed.  It should be pointed out that the shells of the metal hydride storage systems are expected to be cylinders in compliance with ISO cylinder standards and if they are not, specific approval by the country of origin is required.

In order to better harmonize the transport regulations for hydrogen stored in metal hydride storage systems, the US Fuel Cell Council, on behalf of the fuel cell industry, has proposed changes to the United Nations Recommendations on the Transport of Dangerous Goods, Model Regulations to allow hydrogen in metal hydride storage systems to be shipped without special approvals by the country of origin provided that they comply with ISO 16111.  This proposal will be considered by the United Nations Recommendations on the Transport of Dangerous Goods, Model Regulations in December and can be found here:

If these proposals are accepted, further revisions by ICAO and the other model bodies should follow.

In response to recommendations by the US Department of Transportation Federal Aviation Administration, the US Fuel Cell Council, on behalf of the fuel cell industry, has proposed new definitions for fuel cells and fuel cell cartridges to be included in the ICAO Technical Instructions for The Safe Transport of Dangerous Goods by Air.  These definitions are drawn from both the United Nations Recommendations on the Transport of Dangerous Goods, Model Regulations and the IEC Technical Committee on Fuel Cells nomenclature document IEC TS 62282-1, Fuel cell technologies - Part 1: Terminology.  This proposal can be found here:

The two proposed definitions are as follows:

FUEL CELL. A fuel cell is an electrochemical device that converts the chemical energy of a fuel to electrical energy, heat and reaction products.

FUEL CELL CARTRIDGE. An article that stores fuel for discharge into the fuel cell through a valve(s) that control the discharge of fuel into the fuel cell.

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 the14th 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 – ICAO approves passenger carry-on and air shipment of all current fuel cell fuels – Takes effect January 1, 2009.
  • July 2008 – US Department of Transportation issues Notice of Proposed Rulemaking to allow all fuel cell types to be shipped and carried on board passenger airliners.
  • October 2008 - ISO 16111 is approved as an International Standard
  • PROPOSED – November 2008 – ICAO Dangerous Goods Panel approves definitions of FUEL CELL and FUEL CELL CARTRIDGE to support further regulatory work.
  • PROPOSED – December 2008 – United Nations Sub-Committee of Experts on the Transport of Dangerous Goods approves hydrogen in metal hydride storage systems in compliance with ISO 16111.
  • January 2009 -- ICAO passenger carry-on and air shipment of all fuel cell fuels takes effect worldwide.

Cargo Shipment of Fuel Cell Vehicles
Robert Wichert, U.S. Fuel Cell Council

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 here. 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. 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. 

Cargo shipment of fuel cell vehicles
As was described in an earlier article, 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, manufacturers 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. 

The fuel cell industry has recently made revised proposals 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 US Fuel Cell Council proposals can be found here:

These revised proposals include new language to properly allow fuel cell powered equipment to be shipped as equipment powered by a “FUEL CELL ENGINE.” This revision is in response to suggestions made by industry members who make fuel cell powered implements such as fork lifts and other mobility equipment.

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 held 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. 

Vehicle shipment by sea
At the present time the UN Model Regulations only apply to vehicle shipment by air, but a recent proposal by the US Department of Transportation would change that. This proposal would essentially align the worldwide requirements for shipment by seagoing vessel with those of the United States. The main points of this proposal are:

  1. Shipment by vessels specifically designed and approved by the country of registry for vehicle shipment are not subject to further regulation provided that there are no signs of leakage from the vehicles being shipped. This would allow shipment of non-leaking vehicles by vessels meeting the requirements of the country of registry for safe vehicle shipment, without further regulation by other states on the route or at the destination state.
  2. If the fuel tank of the flammable gas powered vehicle being shipped is empty, or at a pressure of less than 2 BAR with closed isolation valves, and all batteries are protected from short circuit, the vehicle may be shipped without further regulation regardless of the ship being used.
  3. Battery powered vehicles, without flammable fuels, may be shipped on any vessel if the batteries are protected from short circuit without further regulation regardless of the ship being used.
  4. Vehicles not meeting any one of the above qualifications must meet the following requirements:
    1. No leakage
    2. Flammable liquid powered vehicles must have their tanks no more than 25% full.  [There is a separate proposal to ICAO to allow a maximum of 4 litres of fuel for air transport ].
    3. Flammable gas powered vehicles must have their fuel isolation valves closed.
    4. Batteries must be protected from short circuit and lithium ion or lithium metal batteries must meet the requirements of the United Nations Manual of Tests and Criteria, Part III, subsection 38.3, unless otherwise approved by the competent authority.  [There are several revisions being contemplated for these tests and criteria:

Contacts for more information
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


ISO/TC 197 Update
Randy Dey, Convenor of ISO/TC 197 WGs 8 and 11

Two ISO/TC 197 working groups, and one task group met in early November in The Hague to advance work items pertaining to electrolyzers for domestic applications and hydrogen refueling stations.

Working Group 8 met on November 6 to advance document ISO/DIS 22734-2.2: Hydrogen generators using water electrolysis process – Part 2: Residential applications. The working group reviewed comments received from circulation of the draft earlier this year and a report from the task group working mainly on improving the test requirement section. The working group is planning to continue efforts to resolve outstanding items in order to finalize a Draft International Standard for circulation. Items under discussion include oxygen venting, hydrogen venting indoors, access panels, leak detection methods and threshold levels.

Working Group 11 met on November 7 to work toward an International Standard for hydrogen refueling stations. The Technical Specification (TS) was approved for publication earlier this year. The WG is continuing its work towards the publication of the international standard. A special effort has been made to get a broader group of stakeholders involved in the development of this international standard. 

The WG formed two task groups in June. Task Group 1 is addressing safety distances and hazardous areas. This task group met on November 5 to exchange information on methodolgies developed for determining separation distances. Members of TG1 agreed to define an approach that would allow system designers to account for mitigations such as safety protection systems and interlocks as part of defining necessary separation distances. TG 1 agreed to work by teleconference to develop a new work plan and further develop the approach.

Task Group 2 is addressing dispensing systems. Recent efforts have been on resolving comments raised during the last ballot. Future efforts will include a risk analysis of the dispenser to ensure that necessary safety protections and interlocks are defined. TG 2 will also continue its work by teleconference.

During the meeting on November 7, an additional task force was created by WG 11 to provide input on the comments that have not yet been resolved.

An additional 4 months was provided to complete this work. 

NFPA 2 Slips Cycle
Martin T Gresho, NFPA 2 - Hydrogen Technologies

The NFPA Hydrogen Technologies Technical Committee voted to slip a code development cycle by 6 months with the much anticipated NFPA 2 document. NFPA 2 is primarily an extract document to consolidate the hydrogen provisions throughout the NFPA codes into a single document for ease of use. The Technical Committee (TC) reached the decision to slip cycle after it was determined that releasing the current draft would be inefficient because the TC has not sufficiently completed its work in consolidating the extracted text into one easy to use, enforceable document. The TC expects the needed integration work to take several months. This will also allow the excerpts to accurately reflect the final language from the ROC meetings for NFPA 52, 55, and 853.

The result of the decision is that NFPA 2 is now on the Fall 2010 cycle. For additional information on the NFPA code development process, please see

Permitting Guideline to Facilitate European Installations
Karen Hall, National Hydrogen Association

The Hydrogen Permitting (HYPER) project started at 1 November 2006, and is scheduled to end in February 2009. The work programme of the HYPER project was structured around the development of an Installation Permitting Guide (IPG) and includes:

  • An assessment of current knowledge on installation requirements of small stationary hydrogen and fuel cell systems
  • Detailed case studies of representative installations
  • Modelling and experimental risk evaluation studies to investigate fire and explosion phenomena

The IPG was created in response to the growing need for guidance to facilitate permitting of small hydrogen and fuel cell stationary installations in Europe. This document is not a standard, but is a compendium of useful information for a variety of users with a role in installing these systems, including:

  • Design Engineers
  • Manufacturers
  • Installers
  • Operators/Maintenance
  • Regulators

The draft document is presently organised as follows:

  • Introduction and Scope (Chapter 1)
  • Background (Chapter 2)
  • General and Higher Level Requirements (Chapter 3)
  • System Specific and Siting Considerations (Chapter 4)
  • Appendices

The Installation Permitting Guide (IPG) provides a structured analysis of known documents relevant for the permitting of hydrogen and fuel cell systems in Europe, records best practices for the installation of different generic types of hydrogen and fuel cell systems, provides guidance on issues not properly dealt with in existing documents, and hence, provides the basis for harmonized permitting guidance. The IPG takes account of issues such as the installation environment, country and jurisdiction as well as taking full account of the already established permitting requirements for natural gas appliances.

The project is mainly aimed at installations incorporating fuel cells with net electrical outputs up to 10kWel (small according to IEC 62282-3-3 Ed. 1, Chapter 11). Systems providing combined heat and power (CHP) on the order of 50 kW combined heat and electrical power, suitable for small back up power supplies, residential CHPs and small renewable storage systems may therefore be included. In addition, much of the guidance provided may also be applicable to larger systems which may serve small communities or groups of households.

The draft has evolved in recent months following targeted stakeholder meetings and reviews. The UK is planning a review on November 26th to introduce the IPG to UK regulators, and to get feedback from a regulatory perspective. This information will be incorporated into the draft, which will then be made available for public review.

The NHA will seek permission to publish the draft, or to provide a link to the draft, in the Hydrogen and Fuel Cell Safety Report once it is available for public review.

Voting Responsibilities in ISO
Karen Hall, National Hydrogen Association

ISO/TC 197 is the International Technical Committee responsible for developing standards in hydrogen technologies.  As there is a growing interest in the development of international standards and technical specifications for hydrogen energy technologies, organizations are becoming more involved in the development of these standards within ISO/TC 197.

Voting Within the National Mirror Committee
When new experts become involved, they are provided a document describing their role in their National Mirror Committee, and the ISO Technical Committee. Even so, experts often are not clear about what is expected of them, particularly when the expert is only involved for their interest or expertise in one or more specific technologies. ISO/TC 197 has active work items in many technologies, so there are inevitably some items for which an expert may have no interest or expertise. In this case, the expert can still make an important contribution by replying with an abstention on the national vote.

This is important because the National Mirror Committee administrator strives to keep the committee roster current, by ensuring members are actively participating in the work and that interested parties have the opportunity to participate. By responding to ballots, the administrator knows the member is still an active participant.

Active participation on a National Mirror Committee requires responses to ballots. Participation includes reviewing and providing input to the national position on draft documents relating to the member’s area(s) of interest and expertise. Being involved doesnot necessarily require travel, however the expert is welcome to attend meetings if they wish.

Participants may also join active Working Groups of ISO/TC 197. This may be beneficial when a document under development relates directly to the interests of the expert’s organization. For example, a company that manufactures, plans to distribute or use electrolyzers for domestic applications may wish to be an active expert of WG 8, which is currently developing an international standard on this topic.

In addition, experts on key aspects of a document are encouraged to participate to ensure the standard development process has the benefit of this specialized expertise. For example, experts on processes to determine safety distances may wish to provide input to Task Group 1 of WG 11, even if their organization is not planning to build, operate or use hydrogen refuelling stations, as this specialised expertise may otherwise be lacking.

Voting by Countries
Depending on the status of the document, members of a National Mirror Committee are asked to respond in accordance with the ISO procedures. They may be asked to indicate their position as voting for approval of the document to move to its next stage of development, including publication, or vote against moving the document forward, in which case the member must provide technical reasons (comments). Alternatively, the member may indicate that the National Mirror Committee should abstain from voting on this document.

There are a number of reasons why a country might abstain. For example, a document may not be of interest to the country or there may be no experts on the relevant technologies on the National Mirror Committee. An Abstention means that the request has been considered, and the country has no opinion or that consensus can not be reached at the present time.

Since abstentions are excluded when the votes are counted (along with negative votes not accompanied by technical reasons), they are an important part of the voting process. When a country abstains, the fate of the document is decided by the countries that have voted for approval or who have provided technical reasons for not doing so. Due to the mathematical procedure used to determine the results of a vote, casting a vote in favor of a document without due consideration from experts can lead to a document moving forward prematurely.

The voting requirements vary for different processes and the type of document under consideration. In the case of balloting a Draft International Standard in ISO/TC 197, the following example represents the impact of abstaining:

Let’s say tere are 21 countries submitting a vote on an  ISO/TC 197 ballot. For a given item out for vote, 11 of these 21 countries either are unable to achieve national consensus, or are not involved in the technology being addressed and have no national interest in the document. Of the remaining 10 active countries, 5 of these want to vote against the document with technical reasons, and 5 want to vote to approve the document moving to Final Draft International Standard, with or without comments. If the 11 disinterested countries vote to approve even though they are not familiar with the work but want to register a vote, the results of the vote would be as follows:


In favor: 11 + 5 = 16
Against:  5
Abstentions: 0

16/21 = 76% in favor (requirement is greater than 66.66%)
5/21 = 23.8% against (25% is required for the vote to fail)
The document would pass, despite the fact that half of active countries with a national interest have serious technical concerns. If you are in one of those 5 countries, you would not be very happy about this result.

If, however, countries with no national consensus, no interest or no expertise vote to Abstain, the results are as follows:


In favor: 5
Against: 5
Abstentions: 11

5/10 = 50% in favor (requirement is greater than 66.66%)
5/10 = 50% against (25% is required for the vote to fail)
This time the document fails. This result is more consistent with the desires of the countries with an interest in the document, and who are likely to use it.

Even if only 5 of the 11 countries with no interest were to abstain, the result is different than if they all were to submit an approval without an expert review. In this case the result would be:


In favor: 6 + 5 = 11
Against:  5
Abstentions: 5

11/16 = 68.75% in favor (requirement is greater than 66.66%)
5/16 = 31.25% against (25% is required for the vote to fail)
Therefore the vote fails as it received negative votes by more than 25% of those voting.

Everyone with a vote in a National Mirror Committee is encouraged to respond to ballots. Individual members with no interest or expertise in an item may indicate they would like to personally abstain. If a member feels their country has no interest or expertise, they can indicate that the national position should be to abstain. By doing so, a member can fulfill their obligations, and allow appropriate weight to be given to those experts for whom the activity is important.

NoE HySafe Announces Third International Conference on Hydrogen Safety (ICHS3)

The NoE HySafe on behalf of the European Commission and with the endorsement of the U.S. DOE and IPHE, are organizing the Third International Conference on Hydrogen Safety (ICHS3).

The conference will be held in Ajaccio on September 16 - 18, 2009.

The network wish to organize such event in collaboration with the principal EU and International projects.

The ICHS conference will focus on issues pertaining to the improvement, knowledge and understanding of hydrogen safety. It aims at providing a basis that will foster removal of safety related barriers to implementation of hydrogen as an energy carrier. The conference is expected to contribute to building public awareness and trust in hydrogen technologies by providing a basis for communicating both the risks associated with hydrogen and their management. Since the ICHS will focus on safety issues and measures to encourage an extensive use of hydrogen based technologies, its contents will be different from other "Hydrogen Conferences." All contributions to be included in the Conference will be evaluated exclusively in the light of their scientific content.


Please, forward this information to whom it may concern. We remind you that the deadline for sending abstracts is December 31st, 2008.

HySAFE to Host International Short Course: "Hydrogen Regulations, Codes and Standards"

It is our pleasure to invite you to attend an international short course "Hydrogen regulations, codes and standards," which will be held during 26 30 January 2009 in Belfast. The technical programme of the course and more details about the international short course series "Progress in Hydrogen Safety" can be found below.


This is the 2nd short course in the exciting new series of industrially oriented short courses organised by the HySAFER centre at the University of Ulster in collaboration with international partners. The second short course will be delivered by experts from Canada, France, Sweden, USA, and the UK. The series of International Short Courses is aimed at those with an interest in safe use of hydrogen and fuel cell technologies and infrastructures. It will also be of interest to those people who are keen to source alternative energy to help their business.

Don't hesitate to contact us if you have any questions