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They’re Coming! How will International
Standards Interplay with Global Technical Regulations?
by Robert L. Mauro
Independent consultant on international codes and standards
for the U.S. Department of Energy
Within the next few months Working Party 29 of the United Nations
Economic Commission for Europe (UN ECE WP.29) will decide to
initiate the development of global technical regulations (GTRs)
for hydrogen fuel cell vehicles and the supporting infrastructure.
Additionally, by the end of the 2004, WP.29 will likely decide
whether or not ISO and IEC codes and standards will be included
by citation, in whole or in part, in the GTRs. Given the positive
comments about ISO and IEC by the GRPE, one of WP.29’s
standing committees, it is possible and maybe even likely that
ISO and IEC standards will be embedded in some form into the
new GTRs. The uncertainty of how these different documents will
interplay justifies a new look at international standard development.
Background
GTRs are legally binding requirements among the signatory countries
of the 1998 Agreement, the agreement under which GTRs will be
developed. In general, legal requirements, (like GTRs) that
must be voted upon to be repealed or amended are very difficult
to change.
International standards on the other hand, are not legal requirements,
but are often included in them. For example, the United States
uses codes. Different states adopt different codes and many
of the codes cite certain standards which detail specific requirements
such as the safety of a piping system or the performance of
a pressurized tank. Law requires U.S. companies to follow guidelines
set in the code.
Because GTRs are new and there is no empirical experience to
draw upon, it is difficult to determine their ultimate form
and content. How easy will it be to change them? What will their
impact be on the development of fuel cell and hydrogen vehicle
technology?
As in any process this complex, there will be unintended consequences.
Their impact will affect the development and direction of global
hydrogen fuel cell vehicle and infrastructure development. For
the purpose of this article, I will just focus on the uncertainty
of the ability to change GTRs and how this affects current international
standard development.
The First Hydrogen GTRs
Tanks
Germany proposed two tank requirements in 2001 to be the first
hydrogen- and fuel cell-related GTRs. The U.S. and others have
objected to moving forward with these standards for two reasons:
first, the tank is one part of the overall vehicle and there
are safety considerations which can only be addressed with the
complete vehicle (e.g., tank behavior in crash-testing); second,
the proposed tank standards are too prescriptive to be accepted
as GTRs. Fortunately, the members of WP.29 generally feel that
GTRs should be performance-based whenever possible, so these
may change.
Hydrogen Specification
With this as background, let me turn to the Japanese proposal
to amend the ISO international standard titled, Hydrogen: specification.
The proposal adds an additional grade of hydrogen for PEM fuel
cells with a focus on fuel cell propelled vehicles. The Japanese
desire to have a standard as quickly as possible to assure that
the fuel used in fuel cell vehicles does not shorten the fuel
cell life. They recognize that they will require longer testing
of the contaminants that they have tested as well as testing
additional contaminants that have not been tested. As a result,
this process will require at least one additional amendment
to their proposed standard to incorporate the new contaminant
data. Their view is that an amendment to the current standard
is better than what exists today.
The U.S. agrees on the need for more research on contaminants,
but it does not want to amend the standard now. The U.S. also
agrees that an amended standard would be somewhat better than
the one we currently have. However, the U.S. would prefer that
the Japanese withdraw their proposed amendment, and instead
work on a joint research activity on contaminants to create
either a technical report or a publicly available specification
under ISO. The Japanese feel the need to amend the existing
standard now.
Why the difference in positions when there is general agreement
on the state of knowledge and the nature of the additional data
required? The Japanese see a near term domestic fuel cell hydrogen
vehicle market driven by government policy and requiring the
best possible hydrogen standard as quickly as possible. The
U.S. sees hydrogen fuel cell cars further on the horizon and
is concerned about the GTRs need for a hydrogen specification
for fuel cell vehicles; they will likely seize upon an interim
ISO international standard to fulfill that requirement. The
uncertainty of changing GTRs in the face of incomplete technical
information is what drives the U.S. position. This causes the
U.S. to want an interim document that is recognized as such
(technical specification, TS, or publicly available specification,
PAS). This would make it far less likely that an interim hydrogen
specification would be adopted as a GTR when we know already
that it will need to be changed soon.
The challenge that UN WP.29 faces in developing GTRs is how
to handle evolving technical information contained in the GTR
in a manner which makes it meaningful and enforceable, while
allowing new technical data to be rapidly validated and incorporated.
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