DNV in its latest whitepaper “Safe introduction of alternative fuels: Focus on ammonia and hydrogen as ship fuels” explained the evolving regulatory landscape and safe implementation of ammonia and hydrogen fuels.
The whitepaper highlights how both hydrogen and ammonia pose new safety risks, necessitating greater emphasis on safety in ship design, construction, and operation and points out the absence of specific mandatory international regulations for vessels using these fuels that remains a barrier to their widespread adoption.
Safety considerations for ammonia and hydrogen as marine fuels
Both hydrogen and ammonia have properties that introduce new safety challenges, triggering the need for increased focus on safety in ship design, construction, and operation. A technology change driven by the transition to zero-emission fuels will have to coincide with a corresponding development of fuel-specific knowledge regarding seafarer and onshore organization competence and the maritime industry in general.
Compared with conventional fuels, the safety risks arising from the properties of the alternative fuels bring a new complexity to bunkering operations, onboard fuel storage, fuel distribution, energy conversion, and maintenance.
Safe onboard integration of the ammonia or hydrogen fuel technologies will affect the ship arrangement, necessitating the development of new ship design solutions. Ammonia and hydrogen have lower volumetric energy densities than fuel oils and necessitate independent storage tanks, which are difficult to integrate and impose limitations on the amount of fuel that can be stored on board.
Apart from storage, the additional safety barriers and arrangements required to integrate the fuel system will also affect the ship arrangement. The fuel installation typically includes the bunkering station, fuel tanks with tank connection spaces surrounded by fuel storage hold spaces, fuel preparation room, release mitigation systems, and double-walled pipes. Many of the basic principles are similar for onboard hydrogen installations depending on the storage condition of the fuel and the consumer.
Enabling seafarers to operate safely
To safely operate a hydrogen or ammonia-fuelled ship, the crew must thoroughly understand the hazards associated with handling these fuels. They must also know the safety features integrated into the design and their purpose, operation, and maintenance requirements. It is, therefore, vital to establish comprehensive training, operating procedures, and a robust safety culture to ensure the ship’s safe operation. This will require changes to the safety management system, generate the need for new competencies on board and ashore, and may also affect the organizational set-up.
Impact on the organization and the management system
The International Safety Management (ISM) Code sets clear objectives and requirements for shipboard operations. The entire ship Safety Management System will be influenced by the use of hydrogen or ammonia as fuel, encompassing normal operation, maintenance, and emergency preparedness.
The interim guidelines for ammonia align with the structure of the IGF Code and refer to the operational requirements found in the current IGF Code for natural gas.
The future interim guidelines for hydrogen are also anticipated to align with the IGF Code. Drawing on the experience of developing interim guidelines for methanol as fuel, further operational requirements tailored to the distinct hazards of ammonia and hydrogen may be implemented.
The current mandatory operational requirements specify that specific procedures must be provided on board the ship:
- Maintenance procedures and information for all gas-related installations. The maintenance procedures shall include an approved inspection/survey plan for the liquefied gas fuel containment system.
- Operational procedures, including a suitably detailed fuel handling manual, such that trained personnel can safely operate the fuel bunkering, storage, and transfer systems. The bunkering procedures shall also include interfaces between supplier and ship – for example, responsibilities, pre-bunkering verifications, safety checklists, communication, and post-bunkering documentation. The fuel handling manual shall also include enclosed space entry, system purging, and gas freeing as well as hot work procedures.
- Suitable emergency procedures.
It should also be noted that the IGF Code requires gas-related exercises and drills to be carried out on board at regular intervals.
Moreover, the ISM Code places obligations on ship operators to ensure that both the master and the crew are well-informed about the risks associated with the ship’s operations. Additionally, training for using ammonia and hydrogen as fuels must be established and overseen, as mandated in the Safety Management System.
The adoption of ammonia or hydrogen fuels, along with the related technologies, may also require changes within the ship operator’s organization, potentially resulting in the establishment of new roles and responsibilities on board and ashore. Establishing procedures for monitoring, maintaining safety barriers, and addressing any deviations or failures to ensure technical integrity will be important factors in operating safely.
Impact on seafarers
The shipping industry has recognized the need for seafarers to acquire new competencies to align with decarbonization goals. The IGF Code outlines the training and competence requirements for crew members, referencing the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW). The STCW specifies specific training criteria for personnel on ships governed by the IGF Code, and there are IMO STCW courses designed specifically around the IGF Code.
Furthermore, training for IGF Code compliance includes both basic and advanced model courses at an approved training facility, as well as minimum seagoing experience with onboard familiarization. Depending on their roles, duties, and responsibilities aboard the ship, personnel must meet either basic or advanced training and qualification standards.
Advanced training pertains to masters, engineer officers, and personnel directly responsible for the care and use of fuels and fuel systems, while basic training applies to seafarers responsible for designated safety duties related to onboard fuel care, use, or emergency response.
Currently, no STCW courses are available for ammonia or hydrogen as fuels. To operate ammonia- and hydrogen-fuelled vessels, seafarers will need to acquire new competencies, including understanding the specific hazards and risks associated with these fuels and handling new equipment and safety measures.
The IMO is expected to initiate in 2025 the development of training programmes for seafarers on ships utilizing these new fuels and technologies. Until STCW courses for seafarers on ships utilizing ammonia or hydrogen as fuels are in place, training should be developed based on existing resources in consultation with the Flag Administration.