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OSHA 1910.103

Hydrogen definitions and terms

Subpart H

50 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.103(a)(1)(i), what is a "gaseous hydrogen system"?

A gaseous hydrogen system is a supply system in which hydrogen is delivered, stored, and discharged in the gaseous form to the consumer's piping and includes the containers, regulators, relief devices, manifolds, interconnecting piping and controls up to the point where hydrogen first enters the consumer's distribution piping. See 1910.103(a)(1)(i).

Under 1910.103(a)(1)(ii)-(iii), what do the terms "Approved" and "Listed" mean for hydrogen equipment?

“Approved” and “Listed” mean that equipment has been accepted or certified by a nationally recognized testing laboratory unless the standard indicates otherwise. See 1910.103(a)(1)(ii) and 1910.103(a)(1)(iii); also refer to the definition of a nationally recognized testing laboratory at 1910.7.

Under 1910.103(a)(1)(iv), what does "ASME" refer to when used in hydrogen requirements?

“ASME” refers to the American Society of Mechanical Engineers, which is the consensus body whose codes (when referenced) set construction and testing requirements for pressure vessels and related equipment. See 1910.103(a)(1)(iv).

Under 1910.103(a)(1)(v)-(vi), what are "DOT Specifications" and how do they relate to hydrogen containers?

“DOT Specifications” are the U.S. Department of Transportation regulations in 49 CFR Chapter I that govern the design, construction, and testing of containers; hydrogen containers may be required to meet DOT Specifications where that option is allowed. See 1910.103(a)(1)(v) and 1910.103(a)(1)(vi).

Under 1910.103(a)(2)(i)(a)-(b), when does paragraph (b) NOT apply to a gaseous hydrogen system on consumer premises?

Paragraph (b) does not apply when the gaseous hydrogen system has a total hydrogen content of less than 400 cubic feet or when the site is a hydrogen manufacturing plant or a supplier-operated refilling operation for portable containers, trailers, mobile supply trucks, or tank cars. See 1910.103(a)(2)(i)(a) and 1910.103(a)(2)(i)(b).

Under 1910.103(a)(2)(ii)(b), when does paragraph (c) not apply to liquefied hydrogen containers?

Paragraph (c) does not apply to liquefied hydrogen portable containers with a capacity of less than 150 liters (39.63 gallons), nor to liquefied hydrogen manufacturing plants or supplier operations that store and refill portable containers, trailers, mobile supply trucks, or tank cars. See 1910.103(a)(2)(ii)(b).

Under 1910.103(b)(1)(i)(a), what standards must hydrogen containers meet?

Hydrogen containers must either be designed, constructed, and tested per the ASME Boiler and Pressure Vessel Code, section VIII - Unfired Pressure Vessels (1968), or be designed, constructed, tested and maintained in accordance with DOT Specifications and Regulations under which they are fabricated. See 1910.103(b)(1)(i)(a)(1) and 1910.103(b)(1)(i)(a)(2).

Under 1910.103(b)(1)(i)(b), how must permanently installed hydrogen containers be supported?

Permanently installed hydrogen containers must be provided with substantial noncombustible supports on firm noncombustible foundations to prevent settling or movement that could damage the container or piping. See 1910.103(b)(1)(i)(b).

Under 1910.103(b)(1)(i)(c) and 1910.253(b)(1)(ii), how must portable hydrogen containers be marked?

Each portable container must be legibly marked with the name "Hydrogen" in accordance with the marking requirements referenced in [1910.253(b)(1)(ii)]. See 1910.103(b)(1)(i)(c) and the related 1910.253(b)(1) material for marking details.

Under 1910.103(b)(1)(ii)(a)-(c), what are the rules for safety relief devices on hydrogen containers?

Hydrogen containers must be equipped with safety relief devices required by the ASME Boiler and Pressure Vessel Code, section VIII, or by the DOT Specifications under which the container was fabricated; the devices must discharge upward and unobstructed to open air to avoid impingement, except for DOT containers with internal volume of 2 cubic feet or less; and relief devices or vent piping must be protected against moisture collection and freezing that would prevent proper operation. See 1910.103(b)(1)(ii)(a), 1910.103(b)(1)(ii)(b), and 1910.103(b)(1)(ii)(c).

Under 1910.103(b)(1)(iii), what materials and fittings are prohibited or required for hydrogen piping?

Piping, tubing, and fittings must be suitable for hydrogen service at the pressures and temperatures involved, and cast iron pipe and fittings shall not be used for hydrogen. See 1910.103(b)(1)(iii).

Under 1910.103(b)(1)(iii)(b)-(c), what codes and joining methods apply to hydrogen piping and tubing?

Hydrogen piping and tubing shall conform to the ANSI B31.1 Industrial Gas and Air Piping Code (with addenda) as incorporated by reference, and joints may be made by welding, brazing, or flanged, threaded, socket, or compression fittings; gaskets and thread sealants must be suitable for hydrogen service. See 1910.103(b)(1)(iii)(b) and 1910.103(b)(1)(iii)(c).

Under 1910.103(b)(1)(iv), what are the main equipment assembly requirements for hydrogen systems?

Valves, gauges, regulators, and other accessories must be suitable for hydrogen service; installations must be supervised by personnel familiar with hydrogen system practices; equipment must be readily accessible and protected from damage and tampering; control cabinets must be adequately ventilated; mobile supply units must be secured against movement and electrically bonded before discharge. See 1910.103(b)(1)(iv)(a)-(f).

Under 1910.103(b)(1)(v), what placard is required at hydrogen storage locations?

Hydrogen storage locations must be permanently placarded with “HYDROGEN - FLAMMABLE GAS - NO SMOKING - NO OPEN FLAMES” or an equivalent warning. See 1910.103(b)(1)(v).

Under 1910.103(b)(1)(vi), what testing is required after installing hydrogen piping and fittings?

After installation, all piping, tubing, and fittings must be tested and proved hydrogen gas tight at maximum operating pressure. See 1910.103(b)(1)(vi).

Under 1910.103(b)(2)(i)(a)-(e), what general siting rules apply to gaseous hydrogen systems?

Hydrogen systems must be readily accessible to delivery equipment and authorized personnel, located above ground, not placed beneath electric power lines, not located close to flammable liquid piping or other flammable gas piping, and, when near aboveground flammable liquid storage, be on higher ground unless dikes/diversion curbs or solid walls prevent liquid accumulation under the system. See 1910.103(b)(2)(i)(a)-(e).

Under 1910.103(b)(2)(ii)(a) Table H‑1, where should hydrogen systems of different sizes be located?

Table H‑1 ranks preferred locations by system size: systems less than 3,000 cubic feet should be located outdoors (I); systems 3,000 to 15,000 cubic feet preferably in separate buildings (II); systems over 15,000 cubic feet preferably outdoors or in specifically permitted locations—consult the table for the exact classification. See 1910.103(b)(2)(ii)(a).

Under 1910.103(b)(2)(ii)(b) and Table H‑2, what minimum distances must outdoor hydrogen systems maintain from exposures?

Minimum separation distances vary by system capacity and type of exposure; for example, a system under 3,000 CF must be 10 feet from a wood-frame building, while a system over 15,000 CF must be 50 feet. Table H‑2 lists detailed minimum feet distances for buildings, wall openings, flammable liquid storage, ventilation inlets, concentrations of people, and more. See 1910.103(b)(2)(ii)(b) and the full Table H‑2 in 1910.103(b)(2)(ii).

Under 1910.103(b)(2)(ii)(d)(1)-(8), what are the indoor siting and separation requirements for hydrogen systems under 3,000 CF?

Hydrogen systems under 3,000 CF located inside buildings and exposed to other occupancies must be in an adequately ventilated area, at least 20 feet from stored flammable materials or oxidizing gases, 25 feet from open flames and other ignition sources, 25 feet from concentrations of people, 50 feet from ventilation intakes and other flammable gas storage, protected against falling object damage, and multiple small systems must be separated by at least 50 feet if more than one is installed in the same room. See 1910.103(b)(2)(ii)(d)(1)-(8).

Under 1910.103(b)(3)(ii)(b)-(c), what ventilation and explosion venting requirements apply to special rooms containing hydrogen systems?

Special rooms must provide adequate ventilation to the outdoors with inlet openings near the floor and outlet openings at the high point; inlet and outlet openings must each have at least 1 square foot per 1,000 cubic feet of room volume. Explosion venting must be provided to exterior walls or roof with vent area equal to at least 1 square foot per 30 cubic feet of room volume, and venting may be walls of light noncombustible material, lightly fastened hatch covers, outward-opening doors, or designs that relieve at a maximum pressure of 25 psf. See 1910.103(b)(3)(ii)(b) and 1910.103(b)(3)(ii)(c).

Under 1910.103(b)(3)(ii)(e), what electrical classification must electrical equipment in special hydrogen rooms meet?

Electrical equipment in special rooms must comply with Subpart S of 29 CFR 1910 for Class I, Division 2 hazardous locations, which addresses electrical equipment and wiring methods suitable for atmospheres where flammable gases may occasionally be present. See 1910.103(b)(3)(ii)(e) and the broader 1910 provisions for Subpart S.

Under 1910.103(b)(3)(iii)(a), what fire-resistance rating is required for the floor, walls, and ceiling of a special room for hydrogen systems?

Special rooms housing hydrogen systems must have floors, walls, and ceilings with a fire-resistance rating of at least 2 hours. See 1910.103(b)(3)(iii)(a).

Under 1910.103(b)(1)(iv)(f), what bonding is required for mobile hydrogen supply units before discharge?

Each mobile hydrogen supply unit used as part of a hydrogen system must be electrically bonded to the stationary system before discharging hydrogen to prevent static or stray currents that could create ignition sources. See 1910.103(b)(1)(iv)(f).

Under 1910.103(b)(1)(ii)(b), when is the upward, unobstructed discharge requirement for relief devices not required?

The requirement that safety relief devices discharge upward and unobstructed to open air does not apply to DOT Specification containers that have an internal volume of 2 cubic feet (about 56.6 liters) or less; all other containers must discharge upward and unobstructed. See 1910.103(b)(1)(ii)(b).

Under 29 CFR 1910.119 and OSHA guidance, when could stored hydrogen quantities trigger the Process Safety Management (PSM) standard?

If stored hydrogen on site in one location reaches or exceeds the PSM threshold quantity (10,000 pounds) and hydrogen meets the Category 1 flammable gas definition, the storage and on-site activities (use, storage, handling, movement) qualify as a PSM-covered process and subject the site to 29 CFR 1910.119. OSHA's interpretation about aggregating flammable gases toward the PSM threshold explains that pre‑charged equipment stored on-site can be included when the aggregate quantity exceeds the threshold. See 1910.119 and OSHA's interpretation on flammable gas aggregation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06.

Under 1910.103(b)(1)(ii)(c), how should relief devices and vent piping be protected against freezing?

Relief devices and vent piping must be arranged or located so that moisture cannot collect and freeze and interfere with the proper operation of the device; locate vents to avoid water traps and consider insulation or heat tracing where freezing is possible. See 1910.103(b)(1)(ii)(c).

Under 1910.103(b)(1)(iv)(c)-(d), how must hydrogen storage and control equipment be located and ventilated?

Storage containers, piping, valves, regulators and accessories must be readily accessible and protected against physical damage and tampering; cabinets or housings containing hydrogen control or operating equipment must be adequately ventilated to prevent gas buildup. See 1910.103(b)(1)(iv)(c)-(d).

Under 1910.103(b)(2)(ii)(d)(5)-(6), how close can hydrogen systems be to ventilation intakes and other flammable gas storage?

Hydrogen systems under 3,000 CF inside buildings and exposed to other occupancies must be at least 50 feet from ventilation or air-conditioning intakes and at least 50 feet from other flammable gas storage. See 1910.103(b)(2)(ii)(d)(5)-(6).

Under 1910.103(b)(3)(i)(c), what electrical rules apply to electrical equipment within 15 feet of an outdoor hydrogen location?

Electrical equipment within 15 feet of an outdoor hydrogen location must comply with the electrical provisions of Subpart S of 29 CFR 1910 to ensure equipment and wiring are suitable for the hazard presented. See 1910.103(b)(3)(i)(c) and consult 1910 Subpart S requirements.

Under 1910.103, what labeling is required for manifolded hydrogen supply units?

Each manifolded hydrogen supply unit must be legibly marked with the name "Hydrogen" or with a legend such as "This unit contains hydrogen" so that the contents are clear to personnel. See 1910.103(b)(1)(ii) marking text and related provisions.

Under 1910.103(b) — Walls, partitions, windows and doors: What are the basic room construction requirements for areas that store or handle hydrogen gas?

You must build storage/handling rooms with walls or partitions that are continuous floor-to-ceiling, securely anchored, and include at least one exterior wall. See 1910.103(b).

  • Openings to other parts of the building are not permitted; windows and doors must be in exterior walls and positioned for emergency access.
  • Windows must be glass or plastic in metal frames.
  • These requirements help contain hazards and provide a safe route for emergency access and ventilation.

Under 1910.103(b)(3)(iii)(b) — Ventilation: What ventilation requirements apply to hydrogen storage rooms?

Ventilation must be provided as required in 1910.103(b)(3)(ii)(b), and rooms must follow the specific ventilation design called out by 1910.103(b)(3)(iii)(b).

  • In short: design ventilation to prevent accumulation of hydrogen and to meet the criteria in the referenced paragraph.
  • Ensure ventilation outlets and inlets are arranged to avoid creating pockets of gas, and follow any quantitative airflow or exhaust-location details in the referenced subparagraph.

Under 1910.103(b)(3)(iii)(c) — Explosion venting: Are explosion vents required and where do I find the specification?

Yes — explosion venting must be provided as specified in 1910.103(b)(3)(ii)(c), and 1910.103(b)(3)(iii)(c) points you to that requirement.

  • Follow the venting design and sizing rules in the cited paragraph so that vents will relieve pressure safely without directing blast or flammable material toward personnel or other structures.

Under 1910.103(b)(3)(iii)(d) — Ignition sources: Are open flames, electrical equipment, or heating equipment allowed in hydrogen areas?

No — there shall be no sources of ignition from open flames, electrical equipment, or heating equipment in those hydrogen areas per 1910.103(b)(3)(iii)(d).

  • This means you must eliminate or strictly control anything that could ignite hydrogen, including pilot lights, exposed heating elements, and non-rated electrical devices.
  • Use intrinsically safe or properly classified equipment where electrical devices are required (see related electrical classification rules in the standard).

Under 1910.103(b)(3)(iii)(e) — Electrical equipment: What electrical classification applies to equipment in hydrogen areas?

Electrical equipment must meet the requirements of subpart S for Class I, Division 2 locations as required by 1910.103(b)(3)(iii)(e).

  • Use electrical installations and devices rated for Class I, Division 2 atmospheres unless the standard provides an approved alternative.
  • See the related liquefied-hydrogen electrical rules at 1910.103(c)(1)(ix) for more specific distance- and class-based requirements near connection points and containers.

Under 1910.103(b)(3)(iii)(f) — Heating: What heating methods are allowed in hydrogen storage locations?

Heating, if provided in hydrogen storage areas, must be by steam, hot water, or indirect means as required by 1910.103(b)(3)(iii)(f).

  • Direct-fired or open-flame heaters are not permitted because they present ignition risks.
  • Indirect heating keeps combustion products and open flames away from hydrogen.

Under 1910.103(b)(4) — Operating instructions: What are the requirements for operating instructions for hydrogen installations?

You must keep legible operating instructions at the operating locations for any installation that requires user operation, per 1910.103(b)(4).

  • Instructions should be readable, available at the control points, and cover safe startup, shutdown, and emergency actions.
  • Regularly review and update instructions to reflect equipment or procedure changes.

Under 1910.103(b)(5) — Maintenance: What maintenance obligations apply to charged gaseous hydrogen systems?

All charged gaseous hydrogen equipment must be maintained in a safe operating condition in accordance with the section's requirements, as stated in 1910.103(b)(5).

  • This includes scheduled inspections, repairs, and keeping safety devices functional.
  • Document maintenance activities and immediately correct defects that create hazards.

Under 1910.103(c) — Clearance: How close can combustible material or vegetation be to hydrogen containers?

The area within 15 feet of any hydrogen container must be kept free of dry vegetation and combustible material as required by 1910.103(c).

  • Maintain clear zones, remove debris, and control nearby storage to prevent fuel for fires.
  • Regularly inspect the 15-foot clearance and document housekeeping activities.

Under 1910.103(c)(1)(i) — Containers: What design and construction standards must liquefied hydrogen containers meet?

Stationary storage containers must meet ASME Boiler and Pressure Vessel Code, Section VIII (1968) or applicable API Standard 620 provisions, and portable containers must meet DOT specifications, per 1910.103(c)(1)(i)(a) and 1910.103(c)(1)(i)(b).

  • Use certified, code-stamped vessels for stationary tanks and DOT-approved cylinders or containers for portable units.
  • Follow the referenced codes incorporated by 1910.6 for details.

Under 1910.103(c)(1)(ii) — Supports: What support and foundation requirements apply to permanently installed liquefied hydrogen containers?

Permanently installed containers must be on substantial noncombustible supports securely anchored to firm noncombustible foundations, and steel supports over 18 inches high must have a protective coating with a 2-hour fire-resistance rating as required by 1910.103(c)(1)(ii).

  • Design foundations to resist settlement or movement and protect supports from corrosion or heat.
  • Use appropriate fire-resistive coatings for taller steel supports.

Under 1910.103(c)(1)(iii) — Marking: What marking is required on liquefied hydrogen containers?

Each liquefied hydrogen container must be legibly marked “LIQUEFIED HYDROGEN - FLAMMABLE GAS” as required by 1910.103(c)(1)(iii).

  • Markings should remain readable under normal conditions and be replaced if damaged or faded.
  • Complement container markings with site placards described in 1910.103(c)(2)(i)(f).

Under 1910.103(c)(1)(iv) — Safety relief devices: What are the sizing, discharge, and freezing-prevention requirements for relief devices on liquefied hydrogen systems?

Safety relief devices must be sized per CGA Pamphlet S-1 for stationary containers or DOT requirements for portable containers, must discharge unobstructed to the outdoors to avoid impingement, and must be arranged to prevent moisture freeze interference, as required by 1910.103(c)(1)(iv)(a)(1), 1910.103(c)(1)(iv)(a)(2), 1910.103(c)(1)(iv)(b), and 1910.103(c)(1)(iv)(c).

  • Venting must prevent liquid or gas from impinging on the container, nearby structures, or people.
  • Design vent piping and device locations so moisture cannot collect and freeze, which could block the device.

Under 1910.103(c)(1)(iv)(d) — Safety relief devices in piping: When must piping have relief devices?

Safety relief devices must be provided in piping wherever liquefied hydrogen could be trapped between closures, per 1910.103(c)(1)(iv)(d).

  • This prevents pressure buildup in isolated piping sections that could lead to failure.
  • Evaluate piping layouts and add reliefs where valves or closures can create trapped volumes.

Under 1910.103(c)(1)(v) — Piping, tubing, and fittings: What material and joint requirements apply for liquefied hydrogen piping and how do you protect personnel from cold surfaces?

Piping, tubing, fittings, and sealants must be suitable for hydrogen service at the pressures and temperatures involved; joints should preferably be welded or brazed (flanged, threaded, or compression fittings allowed), and means must be provided to minimize personnel exposure to low-temperature piping, as required by 1910.103(c)(1)(v) and 1910.103(c)(1)(v)(c).

  • Use codes cited (ANSI B31 series) as guidance for design and materials.
  • Insulate or shield cold piping and prevent air condensate contacting surfaces not suitable for cryogenic temperatures.

Under 1910.103(c)(1)(v)(e) — Insulation: What insulation materials and design features are required for liquefied hydrogen piping and equipment?

Only insulating materials rated nonburning per ASTM D1692-68 may be used; insulation must have a vapor-tight outer seal to prevent air condensation and oxygen enrichment, and insulation and shields must prevent attrition, per 1910.103(c)(1)(v)(e).

  • Avoid installing uninsulated cryogenic piping over asphalt or other combustibles; use drip pans where needed to collect and vaporize condensed air.
  • Design insulation and outer coverings to resist wear from normal operations.

Under 1910.103(c)(1)(vi) — Equipment assembly and shutoff valves: What are the requirements for valves, remote shutoffs, and ventilated control cabinets?

Valves, gauges, regulators, and other accessories must be suitable for liquefied hydrogen service; a shutoff valve must be located as close to the container as practical, and containers over 2,000 gallons must have a remote control shutoff with no intervening connections, while cabinets or housings with hydrogen control equipment must be ventilated, per 1910.103(c)(1)(vi)(a)-(d).

  • For tanks >2,000 gallons: remote control shutoff requirements restrict flanges or appurtenances between the valve and inner container.
  • Make control equipment accessible, protected against damage/tampering, and ventilated to avoid gas accumulation.

Under 1910.103(c)(1)(vii) — Testing and inspection: What testing is required after installation and for containers out of service more than one year?

After installation, all field-erected piping must be tested and proved hydrogen gas-tight at operating pressure and temperature; containers out of service for over one year must be inspected and tested similarly and safety relief devices checked for operation and set correctly, per 1910.103(c)(1)(vii)(a)-(b).

  • Maintain test records and repair any leaks or defective safety devices before returning containers to service.
  • Periodic checks of relief-device settings and operability are required after prolonged idle periods.

Under 1910.103(c)(1)(viii) — Vaporizers: What requirements apply to liquefied hydrogen vaporizers and their piping?

Vaporizers must be anchored, have sufficiently flexible connecting piping to accommodate thermal expansion/contraction, be protected with safety relief devices on hydrogen and heating-media sections, use indirect heat (air, steam, water), and include a low-temperature shutoff in the discharge piping to prevent flow if the heat source is lost, as required by 1910.103(c)(1)(viii)(a)-(d).

  • Provide appropriate flex hoses or expansion joints engineered for cryogenic cycles.
  • Design the low-temperature shutoff so it reliably prevents cold liquid flow that could damage downstream systems or create hazards.

Under 1910.103(c)(1)(ix) — Electrical systems: What electrical classification and distances apply near hydrogen connections and containers?

Electrical wiring and equipment within 3 feet of regularly made/broken connections must meet subpart S for Class I, Group B, Division 1; except as noted, wiring and equipment within 25 feet of such connection points or within 25 feet of a liquid hydrogen storage container must meet Class I, Group B, Division 2 requirements per 1910.103(c)(1)(ix)(a)-(b).

  • When Class I Group B equipment is not commercially available, alternatives are allowed if purged/ventilated per NFPA 496-1967, or if equipment is intrinsically safe or approved for Class I Group C atmospheres (see 1910.103(c)(1)(ix)(b)(1)-(3)).
  • Bonding and grounding of containers and piping is required by 1910.103(c)(1)(x).