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Hydrogen and Fuel Cell Global Technical Regulations
By Robert Mauro, General Manager, PATHInternational standards are
designed to facilitate trade between countries by allowing countries to adopt
common international standards. Products that conform to these standards are
generally meet acceptable levels of safety and performance. This provides the
user with the confidence needed to purchase foreign products. International
standards are minimums for acceptability and therefore many countries add other
requirements to use of products in their country. With the growth in global
trade, international standards are increasingly being used as an easy means of
assuring the acceptability of products.
Since the early 1950s Europe has been strengthening the European Union whose
goal is to provide Europe with a common market for goods and services. The
Economic Community of Europe (ECE) has been working toward development of
regional requirements for Europe. As a regional organization it is also a part
of the UN. Under the UN, there are a number of working parties, which originally
focused on Europe, to address various issues. One of these is WP 29, which
operates under a series of agreements related to transportation. Recently WP 29
was mandated to address global harmonization of domestic and regional standards.
The first standards for hydrogen and fuel cell vehicles were proposed for
on-board hydrogen fuel tanks in 2001. These proposals initiated a process
through which global technical regulations (GTRs) on hydrogen fuel cell vehicles
will likely be authorized by the members of WP.29 before the end of 2004. Along
with authorizing the GTRs, WP 29 will likely decide upon a list of components
and systems that will have to have GTRs written about them.
The focus of GTRs will be in the areas of safety and performance. Safety will
require a GTR be written for the vehicle as well as its components and systems.
There is a question on whether safety requirements will favor U.S. or European
safety requirements. Ideally it should satisfy both, but this may be difficult
unless both can be shown to have equivalent levels of risk. With regard to
performance, the question really turns to that of design philosophy. Are very
tight performance requirements written which, if followed, make component and
system failure unlikely or are somewhat looser component standards written with
the systems designed to mitigate any failures in the system components? It is
possible that something between these two extremes may be written. With rapid
changes in technical and product information, how much technical content will
there be in the GTR? How difficult will it be to change a GTR, including its
technical content?
In addition to how global technical regulations are going to be formulated,
there is a question of what role standards development organizations will play
in this process. One option is that GTRs could be cited by reference in
international standards. This would be similar to the U.S. approach for code
development where standard is referenced, and then language is added for
additional safety and other considerations. A variation on this would be to
refer to specific sections of the code and add much more extensive technical
language to the code. A third approach would be only to cite tests embedded in
international standards and write the GTRs from scratch. Finally, will the
standing committees for WP.29 be able to direct ISO and IEC Technical Committees
to produce standards on a schedule for use in a needed GTR? It is an open
question as to whether GTRs will strengthen or weaken the existing international
standards organizations.
After November when the development of GTRs for hydrogen fuel cell vehicles and
supporting infrastructure are approved, we will be embarking on a process which
will answer many of these questions and raise additional ones.
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