Hydrogen Fuel Cells: Standards

The following standards (which may not include all applicable OSHA standards) may be applicable to employers storing, using, or producing hydrogen, or can be considered as a useful source for information pertaining to hazards of hydrogen.

29 CFR 1910.38, Emergency action plans, specifies the required content of an emergency action plan when an emergency action plan is required by another standard.

29 CFR 1910.101, Compressed gases (general requirements), contains requirements for compressed gases in containers including cylinders, portable tanks, rail tankcars, or motor vehicle cargo tanks. The inspection requirements of compressed gas cylinders are contained under 1910.101(a); the in-plant handling, storage, and utilization of all compressed gases in cylinders, portable tanks, rail tankcars, or motor vehicle cargo tanks under paragraph (b); and the safety relief device requirements for compressed gas containers in paragraph 1910.101(c).

29 CFR 1910.103, Hydrogen, contains requirements for hydrogen systems. Paragraph (b) of this section applies to gaseous hydrogen systems on consumer premises where the hydrogen supply originates outside the consumer premises and is delivered by mobile equipment. It does not apply to gaseous hydrogen systems having a total hydrogen content of less than 400 cubic feet, nor to hydrogen manufacturing plants or other establishments operated by the hydrogen supplier or his agent for the purpose of storing hydrogen and refilling portable containers, trailers, mobile supply trucks, or tank cars. Paragraph (c) under § 1910.103 applies to liquefied hydrogen systems on consumer premises. The standard excludes liquefied hydrogen portable containers of less than 150 liters (39.63 gallons) capacity and liquefied hydrogen manufacturing plants or other establishments operated by the hydrogen supplier or his agent for the sole purpose of storing liquefied hydrogen and refilling portable containers, trailers, mobile supply trucks, or tank cars.

29 CFR 1910.119, Process safety management of highly hazardous chemicals, covers processes containing a threshold quantity of a highly hazardous chemical. A process is defined as ‘‘* * * any activity involving a highly hazardous chemical including any use, storage, manufacturing, handling or on-site movement of such chemicals, or combination of these activities.’’ The standard applies to flammable liquids and gases at a threshold quantity of 10,000 pounds or more, specified quantities of chemicals listed in Appendix A of the standard, and to the manufacture of explosives. Because hydrogen would be covered as a flammable gas, the PSM standard would apply to processes containing hydrogen in quantities of 10,000 pounds or more, with some exceptions.

29 CFR 1910.120, Hazardous waste operations and emergency response, contains requirements for emergency response operations. When there is more than an incidental release of hydrogen, or a substantial threat of a release, then emergency response operations must comply with § 1910.120(q), ‘‘Emergency response to hazardous substance releases.’’

29 CFR 1910.132(a), Personal protective equipment, requires that protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever necessary.

29 CFR 1910.156, Fire brigades, contains requirements for the organization, training, and personal protective equipment of fire brigades whenever they are established by an employer. The requirements under 1910.156 apply to fire brigades, industrial fire departments and private or contractual type fire departments. Personal protective equipment requirements contained in this section apply only to members of fire brigades performing interior structural fire fighting.

29 CFR 1910.307, Hazardous (Classified) locations, contains requirements for electrical installations in hazardous locations. Locations where flammable concentrations of hydrogen may exist under normal or abnormal conditions may be classified as Class I, Division 1 or 2 locations. Electric equipment in these locations must be: (1) Approved as intrinsically safe for locations, (2) approved for installation in locations classified due to the presence of hydrogen, or (3) of a type and design which the employer demonstrates will provide protection from the hazards arising from the combustibility and flammability of hydrogen.

29 CFR 1910.1200, Hazard communication, requires that hazards associated with hydrogen must be conveyed to employees. In addition, the standard requires that the information be transmitted through a comprehensive hazard communication program, including, but not limited to, container labeling, material safety data sheets, and employee training on the hazards associated with handling hydrogen.