The EHA and the European Industrial Gases Association, EIGA, have prepared a joint position paper to ask the EU Commission for its consideration of the impacts of the current Seveso II Directive that dates from 1996 on to he commercial use of hydrogen as a clean energy carrier. The EHa and EIGA more specifically suggest that hydrogen be deleted from the list of specifically named substances in Annex 1 of the Direci, so that it is exclusively covered by the “extremely flammable” category. Thresholds for hydrogen are currently 5 and 50 tons in the Seveso II Directive ; comparable to those of “Very Toxic” substances (5 and 20 tons). Even Chlorine has a higher threshold of 10 tons, and those for “Liquefied extremely flammable gases (including LPG) and natural gas” are 50 and 200 tons. At the current lower limit of 5 tons, road vehicle fuelling stations could fall under the scope of the Seveso directive, severely and unjustifiably compromising the development of the hydrogen refuelling infrastructure necessary to support the commercialisation of hydrogen vehicles projected from 2015 onwards, as indicated above.
With the change proposed the lower limit for hydrogen would be raised to 10 tons in the new Directive. This remains quite conservative, as the consequences of an accidental release of hydrogen are not worse overall than for other flammable gases.