In early August 2023, the Driver & Vehicles Standards Agency ('DVSA') posted a bulletin regarding statutory testing of Hydrogen powered vehicles.

What are Hydrogen Powered Vehicles?

As the name suggests, these are vehicles powered by hydrogen.  The vehicle uses a process known as 'reverse electrolysis' which takes place in a fuel cell within the vehicle.  The hydrogen gas comes from one or more tanks in the vehicle, similar to a normal petrol/diesel tank, while the second gas, needed to complete the process of reverse electrolysis, oxygen, is obtained from the ambient air.  The key benefit of hydrogen powered vehicles is that the reaction produces energy (in the form of electricity) to power the vehicle but no harmful (local) emissions are released from the vehicles exhaust system, making them relatively clean vehicles for use in urban areas, where the quality of air and the effect of diesel emissions has become a political hot potato in recent years.

Hydrogen Fuel Cell vehicles as they are correctly called are classified as "e-vehicles" by the DVSA but because of their need to take on-board hydrogen gas they also fall under "gas vehicles" such as Compressed Natural Gas (CNG), Liquefied Natural Gas (LNG) and Liquefied Petroleum Gas (LPG) vehicles which means that they must be "leak free" before entering the DVSA statutory test premises.

The DVSA's Response

Whilst the DVSA states that it understands that these vehicles are still very new and not widely used yet, they will still expect the drivers of these vehicles to be familiar with the basic hydrogen systems.  When the vehicles are presented at a DVSA facility for statutory testing, the requirement is that the vehicle will be leak free and that the drivers will know how to confirm that fact before being allowed to enter the facility.  DVSA personnel will be asking all drivers of Hydrogen Fuel Cell vehicles to demonstrate this capability before granting access.

It is therefore crucial that full training and information is given to any driver who will be driving hydrogen vehicles to ensure that they know how to fuel the vehicles correctly as well as how to check that the vehicle is safe and "leak free".  Although hydrogen gas is less explosive when compared to petrol (petrol can be explosive at oxygen concentrations of between just 1 and 3%, but being a liquid it is easier to contain) when it is mixed with oxygen in the air it has a very "broad flammability range" of between 4 - 75%.  Hence the need to ensure that hydrogen and oxygen are kept separate in confined spaces, where the concentration of hydrogen in the event of a leak would very quickly exceed safe levels.

As with any new technology it is going to take some time to work out all the new safety requirements that will be needed, but the DVSA having identified this one will definitely be looking to enforce the requirement for safety checks before statutory testing will take place.

If you would like any advice about the legal requirements regarding statutory tests, or general advice about any other part of your transport operation then click here to send an email, or call 01279 818280.  We are here to help.

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