ICC Hearing Actions Result in Win-Win for U.S. Building Regulatory Community and Hydrogen Industry
by Patrick Serfass
National Hydrogen Association
(Darren Meyers, ICC, contributing)


Results of the 2004/05 Cincinatti Public Hearings Affecting Hydrogen

(Click on the code number to jump to the applicable text.)

F27 industrial trucks AS	G19 general AM
F186 update 50A/B reference to NFPA 55 AS	FG14 piping protection AS
F187 separation distances & barrier walls AS	FG30 piping construction in other I-codes (Part I-D, Part II-AS, Part III-AS)
F188 cutoff rooms, where required AS	FG31 metal hydrides, references AS
F189 canopy storage auto vs. manual discharge D	FG32 natural ventilation, improvements AS
F190 venting, minimum rate of discharge AS	FG33 piping, marking and I.D. AM
F191 venting flow rate AS	FG34 piping, 300 series stainless AS
F192 "flammable" gas vs. natural gas detection AS	FG35 concealed piping not permitted AM
F213 DOTn containers for stationary storage AM	FG36 welded joints D
F214 PRD requirements-DOTn exemption? AM	FG37 joints and electrical continuity AS
F215 reformat underground LH2 storage D	M38 delete natural ventilation exception D
F217 seismic vacuum jacket design AS
F218 corrosion coatings & maintenance logs AM
F234 pyrophoric gases AS
F235 h2 systems connected as a building utility service AS
F236 delete metal hydride storage provision AS
F237 roof top storage D
F238 distance to flammable gas containers AM
F249 use of h2 in "closed system" AS
F256 cutoff rooms, relocate to IBC 419 AS

LEGEND

AS - Approved as Submitted
AM - Approved as Modified by the Code Committee at Code Development Hearing
D - Disapproved
ASF - Approved as Submitted by Assembly Floor Action at Code Development Hearing
AMF - Approved as Modified by Assembly Floor Action at Code Development Hearing
DF - Disapproved by Assembly Floor Action at Code Development Hearing
WP - Withdrawn by Proponent

Overall, the Public Hearings in Cincinnati this past week revealed a truly amazing show of support for hydrogen safety." said Darren Meyers, Manager of Contracts for International Code Council and Secretariat to the ICC's Ad Hoc Committee for Hydrogen Gas (AHC H2G). "For instance," said Mr. Meyers, "at this point during ICC's 2003/04 Cycle, there were but ten code changes submitted to various International Codes addressing hydrogen infrastructure issues. This year resulted in nearly 30 submissions from such groups as industrial chemical and gas manufacturers, energy companies, national testing laboratories, fuel cell manufacturers, technology development and product proponents." During the 2003/04 ICC Code Development Cycle, approximately 10 proposals affecting hydrogen issues were heard by the various ICC code development committees.

Brief Background on the ICC Code Development Process
The International Code Council uses the governmental consensus process to develop its building safety and fire prevention codes. New editions of the ICC International Codes™ are published triennially. This allows for two, complete code development cycles, each 18-months long, to take place in the interim, resulting in either a new edition of the ICC International Codes™ (International Fire Code (IFC), International Building Code (IBC), etc.), or a supplement edition. At the end of the current 2004/05 Cycle the 2006 editions of the ICC International Codes™ will be published.

During each 18-month cycle, there are two main events, the Public Hearings and the Final Action Hearings. At the Public Hearings, balanced code development committees, composed equally of academics, industry, builders, regulators and design professionals, review proposed changes, hear public testimony in open forum, and recommend an action-approval, disapproval or as modified- on proposed changes. After the Public Hearings, anyone may submit public comments to support or oppose the resulting recommendation. At the Final Action hearings, after hearing relevant testimony, final actions are determined by a simple vote of the ICC's voting membership-building safety and fire service professionals who, with no vested interest beyond public health and safety, voice the will of those charged with upholding that health and safety.

Bear in mind that the reported actions of the Public Hearings described in this article are merely recommendations of ICC's International Fire Code Development and Fuel Gas Code Development Committees to the voting membership of ICC. These actions could still receive dissenting public comments, and are not yet finalized until the conclusion of the 2004/05 Cycle held at the ICC Final Action Hearings, September 27th through October 1st, 2005, in Detroit, MI.

For more information on International Code Development, visit:
http://www.iccsafe.org/news/pdf/factssheet.pdf or

For more information on Code Cycle procedures/schedules for the 2004/05 cycle, visit:
http://www.iccsafe.org/cs/codes/2004-05cycle/index.html

The following are brief descriptions of key outcomes from the 2004/05 Public Hearings in Cincinnati, OH:

F27-04/05 and F249-04/05: "Hydrogen-fueled industrial trucks and closed systems"
Committee Recommendation: (F27-AS), (F249-AS)
These two proposals recognize the use of fuel cells for powered industrial trucks, such as fork lifts, loading and people movers. The addition of a well-placed footnote to the International Fire Code's Maximum Allowable Quantity (MAQ) Table (T307.1) further clarifies that vehicles with closed fuel systems are to be treated no differently than machinery or equipment when considering the allowable quantities of hazardous materials in buildings. For example, fork lift trucks are to be considered vehicles, and the contents of their fueling tanks would not count towards the MAQ limits provided other applicable requirements of the fire code are followed. Moreover, when evaluating a parking garage with several hundred cars parked inside, the proposed change clarifies that regulators need not count the contents of the fuel tank of every parked vehicle.

F187-04/05: "Separation Distances Table 2209.3.2 & Barrier Walls"
Committee Recommendation: AS
Organizational and technical improvements were made to International Fire Code (IFC) Table 2209.3.1 to reduce the potential for non-uniform interpretation in enforcement. Revisions to the table incorporated terminology recognized by the International Building Code (IBC) and IFC in addition to making Table 2209.3.1 specific to the storage of hydrogen for motor fuel-dispensing operations. For sites constrained by lot size, the barrier wall construction provisions remain, but will exist as separate sections referred to by NEW tabular Footnote 'b' and related subsections. The more detailed barrier wall construction criteria were developed primarily to prevent direct jet flame impingement and exposure to radiant heat flux levels harmful to personnel. In addition to preventing confinement and pocketing of unignited flammable gases, the improvements allow for ventilation, service, maintenance and inspection of storage and utilization equipment. The actual length of any one barrier wall for radiant protection will vary based on the storage phase of hydrogen (i.e., liquefied vs. gaseous) and the type of tank installed (i.e., underground vs. above ground horizontal or vertical configurations).

F189-04/05: "Canopy storage, automatic vs. manual discharge"
Committee Recommendation: D
While nearly 80% of industry's proposed changes affecting hydrogen were successful, there were a few receiving disapproval. For instance, F189-04/05 revised the means by which canopy-top-based gaseous hydrogen storage is to be discharged. The defeated code change proposed to modify the current form of automatic release to a manual release, thereby allowing emergency responders to determine whether the system should be discharged. Comments and questions voiced during the 2003/04 Code Development Cycle,, caused the AHC to re-assess this particular issue.

Essentially, a manual release of the hydrogen was determined to provide a higher level of safety and control of the incident rather than automatically discharging the hydrogen when the sprinkler system is activated. The manual release would allow emergency responders to make an on-scene decision of whether or not the release of hydrogen is appropriate or prudent.

To automatically discharge the hydrogen gas upon the sprinkler system water flow signal, could potentially result in an unnecessary release of hydrogen. There could be numerous instances where the fire is controlled beneath the canopy and the automatic release of hydrogen would not be warranted or even wanted. In these situations where a small fire is controlled under the canopy, the automatic release of hydrogen could create a larger hazard. The manual release will provide the ability for the on-scene emergency personnel to make a decision based on the specific incident at the facility. This decision could be affected by the intensity of the fire, weather conditions, other exposures, etc.

Tying the discharge of the hydrogen to actuation of the sprinkler system, could also introduce the possibility of a single common point of failure. Specifically, if the sprinkler system fails to actuate for an actual fire, it may not trigger the discharge of hydrogen, with no means of manually bypassing this action.

Providing a manual means of discharge would allow the fire department to assess the need to discharge the hydrogen and to do so only when necessary. Unfortunately the IFC Code Development Committee did not see it this way. Based on the line of questioning coming from the code development committee dais, it was apparent that the Committee may not have understood that the hydrogen venting systems already required by the IFC in addition to the pressure and temperature relief devices found on the gaseous commodity containers provide a measure of safety and redundancy in the system. Although explained during testimony, it appeared that the Committee may have believed that the manual/automatic vent system discussed on the hearing room floor was the only way hydrogen could be vented in an emergency.

F192-04/05: "'Flammable' gas vs. natural gas detection"
Committee Recommendation: AS
This particular code change revised both the IFC and International Mechanical Code (IMC) to address the wider range of gases being used as motor vehicle fuels (i.e., LNG, NG and H2). It was determined that the terminology included in sections requiring mechanical ventilation and commensurate detection needed to be revised. Worth noting was an attempt by Underwriters Laboratories, Inc., to suggest a friendly modification to the proposal which would refer to the UL 2075 - 04, Gas and Vapor Detectors and Sensors Standard. Referencing UL 2075 was originally considered in the drafting of F192-04/05, but at the time the standard was not an ANSI standard. Since that time, the standard has met the criteria of an ANSI standard.

F236-04/05: "Metal hydride storage, (deletion w/o replacement)"
Committee Recommendation: AS
The committee's recommendation to approve of this proposal eliminated the language that recognized metal hydride storage systems to be considered-from a hazardous materials standpoint-based solely on the gaseous hydrogen commodity stored, rather than the pyrophoric materials resident in the system. This language which was adopted in the previous cycle, as reported in the June 2004 issue of the Hydrogen Safety Report: http://www.hydrogensafety.info/archives/2004/jun/1.html was requested to be deleted by another interest party in this cycle. NHA staff, NREL, Texaco Ovonics and Jadoo Power Systems all spoke in opposition of the proposal. NHA Staff believes that the unfortunate result was primarily due to the lack of any contemporary, nationally-developed standard to list or label these systems, but also relative to the public's perception of this emerging storage technology.

While there was compelling evidence by the hydrogen industry to disapprove the proposal, including showing that both the United Nations Sub-Committee of Experts for the Transport of Dangerous Goods and DOTn groups have each, independently established positions to treat metal hydride systems, the way the code language originally was approved, the Committee was unwilling to keep the language.

F256-04/05: "Cutoff rooms, relocate to IBC 419"
Committee Recommendation: AS
In general, this proposal moved the construction requirements for hydrogen cutoff rooms from the International Fuel Gas Code (IFGC) to the International Building Code (IBC). It was further recommended and accepted that the requirements for locating indoor operations involving motor vehicle fueling be maintained by the IFC Code Development Committee. In light of these changes, Section 706 of the IFGC has been rewritten to make it clear that hydrogen cutoff rooms are only necessary in certain instances and the primary focus is installations involving the use and dispensing of gaseous hydrogen indoors. Outdoor installations are specifically addressed in Chapter 22 of the IFC for consistency.

FG35-04/05: "Concealed piping not permitted"
Committee Recommendation: AS
This particular proposal recognized the constant evolution of gaseous hydrogen technologies and systems which utilize pressures far greater than the 5 psig as initially envisioned and modeled after natural gas piping systems. The newly suggested provisions eliminate the potential for hydrogen piping systems to be concealed, thereby greatly enhancing safety issues associated with locating hydrogen piping indoors.

Other code change recommendations affecting hydrogen include: F186, F188, F190-F191, F213-F214, F216-F218, F234-F235, F237-F238; M38; FG14, FG30-FG33, and FG37. Visit ICC's web-site at www.iccsafe.org for further information on the successful outcome of these code changes.

Since August of 2000, the ICC, by way of the AHC H2G, has worked collaboratively with the U.S. Department of Energy and its Office of Hydrogen & Fuel Cell Infrastructure Technology. Such support has been at the direction of its Fuel Cell and Hydrogen Programs Manager and focused on addressing the safe use of hydrogen as a fuel in motor vehicle-related infrastructure (i.e., refueling and service stations, repair garages, parking garages) and in portable utilization and power generating scenarios (i.e., dispensers, compressors, generators, portable devices and appliances used in and around buildings, and fueled by hydrogen) as well as the facilitation of market acceptance of the technology through coordinated codes and standards activity.

The AHC continues to work together with a diverse group of technical and advisory parties to review current codes and standards applicable to hydrogen, determine the adequacy of its coverage in the ICC International Codes, and propose changes, as necessary, to the International Building, Fire, Fuel Gas and Mechanical codes through the ICC Code Development Process consistent with their findings.

The next meeting of the AHC H2G will take place June 1-2, 2005, at the Chicago District office of ICC, Country Club Hills, IL 60478. For more information on attending this meeting contact Darren Meyers at dmeyers@iccsafe.orgor directly at 1-888-ICC-SAFE x4307.

For a full list of the Public Hearings Results on the 2004/2005 Proposed Changes to the International Codes, visit:
http://www.iccsafe.org/cs/codes/2004-05cycle/pdf/ccr2004-05.pdf

The International Code Council, a membership association dedicated to building safety and fire prevention, develops the codes used t o construct residential and commercial buildings, including homes and schools. Most U.S. cities, counties and states that adopt codes choose the International Codes developed by the International Code Council.