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September 2008
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
  • 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)
  • 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 3478 FUEL CELL CARTRIDGE OR FUEL CELL CARTRIDGE CONTAINED IN EQUIPMENT OR FUEL CELL CARTRIDGE PACKED WITH EQUIPMENT, containing liquefied flammable gas (e.g. butane)
  • UN 3468 HYDROGEN IN A METAL HYDRIDE STORAGE SYSTEM

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:http://edocket.access.gpo.gov/2008/pdf/E8-16579.pdf

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.

Definitions
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:
http://www.icao.int/anb/FLS/DangerousGoods/DGP/
WorkingGroups/WG08/WPs/DGPWG.08.WP.003.1.Rev.en.pdf

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.

Timeline
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 – 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.