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 ICAO Technical 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:
- 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.
- 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.
- 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.
- Vehicles not meeting any one of the above qualifications must meet the following requirements:
- No leakage
- 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 ].
- Flammable gas powered vehicles must have their fuel isolation valves closed.
- 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:
- http://www.unece.org/trans/doc/2008/ac10c3/
ST-SG-AC10-C3-2008-86e.pdf
- http://www.unece.org/trans/doc/2008/ac10c3/
ST-SG-AC10-C3-2008-58e.pdf].
Contacts for more information
Industry stakeholders who are interested in affecting this issue are encouraged to contact the US Fuel Cell Council at www.usfcc.com or their Technical Director, Robert Wichert, at wichert@usfcc.com
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