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HYDROGEN STORAGE, HANDLING AND PRODUCTION: MINING & CONSTRUCTION COMPLIANCE STANDARD
PURPOSE AND SCOPE
This standard establishes minimum safety, legal and environmental compliance requirements for hydrogen storage, handling, production and distribution activities in mining and construction operations in Australia. It applies to all operators, contractors, engineers and site personnel managing hydrogen facilities, refuelling stations, production plants, and fuel gas delivery networks on mine sites, construction projects, and associated industrial facilities.
1.0 PRE-PROJECT REGULATORY ASSESSMENT AND THRESHOLD DETERMINATION
1.1 Facility Type Classification and Regulatory Trigger Points
All hydrogen proposals must first be assessed against critical thresholds that determine which regulator(s) have jurisdiction and what licensing/approvals are required.
| Facility Type | Hydrogen Quantity Trigger | Applicable Legislation | Regulatory Pathway |
| Small on-site storage (cylinders, cryogenic tanks) | < 5,000 L water capacity* | Work Health and Safety Act (WHS Act); Dangerous Goods Safety Act 2004 (DGS Act) where applicable | WHS site-specific controls; DGS compliance assessment required |
| Hydrogen production site (electrolyser, steam reformer) | > 5,000 L total (storage + pipework) | DGS Act + Dangerous Goods Safety (Storage & Handling) Regulations 2007 (DGSH) in WA; Petroleum & Gas (P&G) Act in QLD | Dangerous Goods Site Licence (WA); Operating Plant SMS (QLD) |
| Major Hazard Facility (MHF) | > 5 tonnes hydrogen | Dangerous Goods Safety (Major Hazard Facilities) Regulations 2007 (MHF Regs) in WA; P&G Act in QLD | MHF Safety Report required; Chief Dangerous Goods Officer approval before operation |
| Hydrogen refuelling station | All quantities | DGS Act; Gas Standards Act 1972 (distribution); WHS Act | Dangerous Goods Site Licence; Gas safety compliance; Emergency response coordination |
| Hydrogen fuel gas delivery network (FGDN) | All quantities | P&G Act (QLD); DGS Act (WA); WHS Act | Operating Plant SMS; Safety Management System required |
| Hydrogen distribution pipelines (external facility boundary) | All quantities | DGS Act (WA); P&G Act (QLD); WHS Act | Pipeline registration; Safety assessment; External interference protection plan |
*Water capacity = total volume of all storage containers and pipework combined
Compliance Checklist – Regulatory Assessment Phase:
- Confirmed total hydrogen quantity (including storage + pipework water capacity)
- Identified state jurisdiction (WA, QLD, NSW, VIC, SA, TAS, NT, ACT) and relevant regulator(s)
- Determined if Dangerous Goods Site Licence required (WA: >5,000 L)
- Determined if Operating Plant SMS required (QLD: production, storage, refuelling, FGDN)
- Determined if Major Hazard Facility notification required (WA/QLD: >5 tonnes)
- Identified secondary legislative triggers (gas distribution, electrical safety, transport, WHS)
- Early engagement with relevant regulator(s) conducted (DGO meeting recommended for >1,000 L or complex facilities)
2.0 DANGEROUS GOODS SITE LICENCE APPLICATION (WA Example)
2.1 Application Pre-Submission Requirements
Before lodging a Dangerous Goods Site Licence application in WA, the following must be completed:
| Compliance Item | Verification Requirement | Responsible Party |
| Departmental Liaison | Early meeting with DGO from Department of Energy, Mines, Industry Regulation and Safety (DEMIRS); discuss proposal, application scope, timeline and information requirements | Applicant/Consultant |
| Accredited Consultant Engagement | If complex facility: engage Chief DGO-accredited consultant for application preparation and endorsement | Applicant |
| Facility and Site Information Documentation | Prepare facility overview, process flow diagrams, site maps (aerial), land-use zoning confirmation, separation distances to residential areas, schools, aged-care facilities | Applicant/Consultant/Engineer |
| Equipment Certification Package | Obtain manufacturer certifications for all hydrogen equipment (electrolysers, compressors, storage vessels, dispensers, fuel cells) demonstrating compliance with AS/NZS or ISO standards | Equipment Supplier/Applicant |
| Risk Assessment | Prepare documented dangerous goods risk assessment using approved template; if covered by approved code of practice, conduct clause-by-clause compliance check | Applicant/Safety Professional |
| Consequence Analysis | For storage/handling facilities: conduct consequence modelling (fire, explosion scenarios) assuming all active controls fail; model to HIPAP 4 criteria (overpressure ≤7 kPa; radiant heat ≤4.7 kW/m²) | Competent Engineer/Modelling Consultant |
| Emergency Services Liaison | Consult Department of Fire and Emergency Services (DFES); for sites >10× manifest quantity, prepare Emergency Response Guide and register with DFES (contact: feserg@dfes.wa.gov.au) | Applicant/Emergency Coordinator |
| Bushfire Risk Assessment | If facility in WA bushfire-prone area: confirm controls are in place to manage bushfire impact; liaise with DFES | Applicant |
Licensing Application Checklist (WA DGSH):
- Completed application form (available from DEMIRS website)
- Facility and site information documentation (layout diagrams, photos, zoning confirmation)
- Emergency management plan (contact DFES; reference AS 3745)
- Plant layout and site access/security plan (showing separation distances, hazardous areas, exclusion zones)
- Design and engineering controls documentation (P&ID, design philosophy, pressure relief systems, leak detection, emergency shutdown)
- Site management plan (competency matrix, training system, permit-to-work procedures, maintenance management, incident response)
- Dangerous goods risk assessment (first-principles or standards-based compliance check)
- Consequence analysis report (if applicable: fire/explosion modelling)
- Equipment certification packages (electrolysers per AS 22734; compressors/pumps fit-for-service; pressure vessels per AS 1210/AS 2030)
- Safety Management System summary (addressing all elements in DGSH Regulations Schedule)
- Evidence of bushfire mitigation (if in fire-prone area)
3.0 OPERATING PLANT SAFETY MANAGEMENT SYSTEM (QLD P&G FRAMEWORK)
3.1 Statutory Position Holder Appointments and Obligations
In QLD, hydrogen operating plant requires appointment of statutory position holders under the P&G Act s673–s692.
| Position Holder | Qualifications Required | Key Responsibilities | Notice to Regulator |
| Operator / Operator’s Representative | PCBU duties under WHS Act; overall responsibility for operating plant safety | Appoint competent ESM and Site Safety Manager; ensure SMS compliance; notify RSHQ of commissioning/decommissioning ≥20 business days notice; manage formal safety assessment; ensure plant/equipment compliance | Commissioning/Decommissioning notice per s694A |
| Executive Safety Manager (ESM) | Tertiary qualification in relevant discipline + senior industry experience; or demonstrated competency through track record | Oversee SMS implementation; ensure statutory compliance; investigate incidents; report safety issues to operator; provide expertise on safety matters | Via Operator notification to RSHQ |
| Site Safety Manager | Minimum 3+ years operational experience in hydrogen facility; evidence of formal training in SMS and relevant standards | Daily site oversight; pre-start inspections; manage safe work method statements (SWMS); control permits to work; coordinate incident response; ensure WHS/SMS integration | Via Operator notification to RSHQ |
Statutory Position Holder Checklist:
- Operator identified and PCBU duties confirmed (company board/senior management)
- Executive Safety Manager appointed; qualifications verified (CPEng, RPEQ, or equivalent)
- Site Safety Manager appointed; competency and experience documented
- Notification to RSHQ issued (if commissioning) ≥20 business days prior
- SMS obligation holders briefed on their roles and responsibilities
- Escalation procedures defined (who reports to whom; escalation to Operator)
- Annual competency review of position holders scheduled
3.2 Safety Management System (SMS) Content Requirements
The P&G Act s675 mandates SMS content. Hydrogen operating plant SMS must address:
| SMS Element | What Must Be Included | Implementation Evidence |
| Leadership and Accountability | Clear statement of safety commitment from Operator; role clarity for all levels; defined reporting structure | Board/management endorsement; responsibility matrix; SMS governance plan |
| Hazard Identification and Risk Assessment | Systematic identification of hydrogen hazards (fire, explosion, cryogenic burns, pressure, leaks, confined space, electrical); formal risk assessment per s675(1)(e); risk registers by operational phase | HAZID/HAZOP studies; risk matrices; control measure effectiveness ratings (inherent/engineered/administrative/PPE) |
| Formal Safety Assessment | Documented assessment of all significant risks; technical and non-technical control measures; ALARP demonstration | Consequence modelling reports; separation distance calculations; design standards compliance documentation; control verification reports |
| Record Management and Document Control | Procedure for document control (creation, review, approval, distribution, retention, disposal); version control; retention periods (minimum 7 years for compliance documents, permanent for design/incident records) | Document control register; retention schedule; version-controlled document library |
| Safe Operating Procedures | Standard operating procedures (SOPs) for all operational phases: commissioning, normal operation, maintenance, emergency shutdown, decommissioning; hydrogen-specific procedures (pressure control, leak response, ventilation verification, confined space entry) | SOP library (indexed by system/operation); procedure review schedule; competency sign-off by operators |
| Work Control and Permit to Work System | Permit types: excavation (service protection), confined space entry (>2 m depth), hot works (welding/grinding), working at heights (>2 m), hydrogen work (pressure equipment, cryogenic handling) | Permit templates; issuing authority matrix; conditions and limitations per permit; suspension/cancellation procedures; permit register (minimum 5-year retention) |
| Training and Competency Management | Induction program (all site personnel); role-specific training (hydrogen operators, ESM, Site Safety Manager, maintenance, emergency responders); refresher training intervals; competency assessment | Training matrix by role; training records (attendance, competency verification); UEG Gas Industry Training Package references (UEGNSG902–906); third-party certification (where applicable) |
| Contractor Management | Contractor competency assessment prior to site entry; safety induction; work permit integration; incident reporting pathway; performance monitoring | Contractor register; pre-qualification checklist; safety performance records; audit schedule |
| Management of Change (MOC) | Procedure for assessing safety impact of facility modifications, process changes, equipment upgrades; requires SMS review and update if control measures affected | MOC register; change assessments; SMS update documentation; stakeholder sign-off (ESM/Site Safety Manager) |
| Procurement | Specification of plant and equipment safety requirements; verification of compliance with applicable standards; supplier notification duty (if defects become apparent) | Procurement checklist (standards references, certification requirements); supplier audits; equipment installation sign-off |
| Operational Readiness and Commissioning | Pre-commissioning safety verification plan; control function testing (detection, shutdown, relief); pressure testing; atmospheric verification (if confined spaces); personnel competency confirmation; formal sign-off | Commissioning checklist; test certificates; atmospheric test results; final commissioning approval from Operator/Site Safety Manager |
| Inspection and Maintenance Management | Preventive maintenance schedule (pressure vessels per design standards, detection systems monthly, pipework annually); corrective maintenance procedures; spare parts inventory (critical items); equipment defect reporting and tracking | Maintenance schedule; work order system; PM completion records; defect log (trending); third-party inspection reports (annual/5-yearly as per standards) |
| Incident and Injury Management | Incident reporting threshold (all hydrogen-related incidents, near-misses, environmental releases); investigation procedure (root cause analysis); corrective actions; notification to RSHQ if notifiable (unplanned release >5 tonnes, equipment failure, injury) | Incident register; investigation reports (retained 7+ years); corrective action tracking; RSHQ notification evidence |
| Emergency Response and Business Continuity | Emergency response plan (evacuation, shelter-in-place, emergency shutdown, communication); emergency contacts (DFES, utility authorities, emergency services); regular drills; post-incident communication | Emergency response procedure; personnel role cards; alarm system test records; drill records (annual minimum); contact directory (current) |
| Site Security | Access control (fencing, gates, security lighting); personnel identification; visitor management; prevention of unauthorised access to hydrogen equipment; security incident reporting | Security assessment; access control log; visitor register; CCTV/monitoring records (if applicable); security incident procedures |
| Periodic Review and Continuous Improvement | SMS effectiveness review (annual minimum); engagement with workforce; identification of improvement opportunities; updates to procedures, risk register, competency requirements | SMS review meeting minutes; employee feedback register; procedure update history; effectiveness metrics (e.g., near-miss reporting rate, training completion %) |
Safety Management System Checklist:
- SMS scope clearly defined (covers all hydrogen operating plant activities)
- Leadership commitment statement signed by Operator
- Hazard register and risk register established and maintained
- Formal safety assessment completed (ALARP documented); reviewed annually
- Document control procedure implemented; version control operational
- All required SOPs written, approved, accessible to personnel
- Permit-to-work system operational (forms, authorities, registers)
- Training matrix by role; training records current
- Contractor pre-qualification process established
- MOC procedure documented; changes logged since facility commissioning
- Procurement requirements for hydrogen equipment specified
- Commissioning checklist completed; sign-off obtained
- Preventive maintenance schedule operational; records retained
- Incident reporting procedure communicated; accessible at work face
- Emergency response plan current; contacts verified; drills conducted
- Security controls assessed and effective
- SMS review scheduled (annual minimum); improvements tracked
- Notifiable incident procedures understood by Site Safety Manager
- Integration with WHS Act obligations confirmed (no duplication; single SMS preferred)
4.0 HYDROGEN FACILITY DESIGN AND EQUIPMENT STANDARDS COMPLIANCE
4.1 Reference Standards by Facility Type
Hydrogen operating plant must be designed to and comply with applicable reference standards. Use of an approved standard will generally be accepted as meeting safety outcomes.
| Facility Type | Mandatory/Reference Standards | Design Verification Required | Approval Authority |
| Hydrogen Production (Electrolyser) | AS 22734:2020 (Hydrogen generators – water electrolysis) + WHS Pressure Equipment Regulations | Equipment certification; inlet/outlet pressure ratings verified; gas purity output (AS ISO 14687:2020); electrical safety (AS 3000); hazardous area classification (AS/NZS 60079 series) | GDAA (gas work approval) or Operator SMS sign-off |
| Hydrogen Production (Steam Reformer) | AS 16110.1:2020 (Hydrogen generators – fuel processing) + relevant pressure equipment standards | Process safety assessment (HAZID/HAZOP for novel designs); fuel supply safety (natural gas/LPG); heat source control; vent system design (assume ignition) | GDAA approval or first-principles risk assessment + Operator SMS sign-off |
| Hydrogen Compressors/Pumps | HAZID/HAZOP study demonstrating design fit for hydrogen service; pressure vessel standard (AS 1210/AS 2030); material compatibility (embrittlement); sealing design (low-viscosity hydrogen) | Design review by competent engineer; material testing (if non-standard alloys); vibration analysis; relief system validation | Operator SMS sign-off; third-party inspection (recommended for high-pressure >50 MPa) |
| Hydrogen Storage Vessels | AS 1210:2010 (Pressure Vessels – General) or AS 2030.1 (Gas cylinders) + AS/NZS 1596 (LP Gas) for comparative separation distances | Pressure vessel design certification; NDT inspection; hydrostatic proof test at 1.5× working pressure; pressure rating nameplate; relief valve setting verification | Equipment manufacturer cert; third-party inspection pre-commissioning; annual visual inspection; 5-yearly hydrostatic retest |
| Cryogenic (Liquid Hydrogen) Storage | First-principles hazard assessment; consequence modelling (worst-case liquid release → vapour expansion at 1:850 ratio); pressure relief design (assuming ignition of vent); thermal design (boil-off management); spillage containment | Cryogenic engineer design review; thermal modelling; venting system design per ASME/EIGA guidance; insulation effectiveness verification; boil-off rate calculation; secondary containment bund sizing | Operator SMS; third-party cryogenic specialist review recommended |
| Dispensing/Refuelling Equipment | AS ISO 19880.1:2023 (Gaseous hydrogen – Fuelling stations, Part 1: General requirements); AS 19880.3 (Valves); AS 19880.5 (Hose assemblies); AS ISO 19880.8 (Fuel quality control) | Dispenser design per standard; quick-disconnect coupler type verification; pressure rating and flow rates; material compatibility; thermal design (heat of compression); hydrogen purity system | GDAA approval for gas device; installation per technical submission; commissioning per AS 19880.1 checklist |
| Pressure Relief Valves | Design per ASME B31.12 (Hydrogen Piping); assume relief venting can ignite; calculate vent pipe sizing for subsonic/sonic flow; locate vent outlet away from occupied areas and ignition sources; high-pressure designs (>50 MPa) require third-party review | Relief setting calculation per system design pressure; spring constant verification; material selection (suitable for hydrogen); manifold integration design; test certificate from supplier | Supplier certification; calibration record ≤12 months; pressure gauge calibration ≤12 months |
| Piping and Fittings | ASME B31.12 or AS/NZS 2885/4645 series (pipelines); material selection to prevent hydrogen embrittlement (austenitic stainless preferred; avoid high-strength carbon steel >600 MPa yield); joint design (welded preferred over threaded for high-pressure systems >10 MPa) | Pressure test at 1.5× operating pressure minimum; hydrostatic for liquid systems; helium leak test for critical systems; surface inspection (visual + dye penetrant if welded); material certs from supplier | Installer certification; test records retained per SMS document control procedure |
| Hydrogen Detection Systems | AS 26142:2020 (Hydrogen detection apparatus – Stationary applications); sensors to detect at <25% LEL (1% hydrogen in air); alarm thresholds defined in facility SOP (typically alarm at 1.25% H₂; shutdown at 2.5% H₂) | Detector location study (identify risk zones; place detectors at potential accumulation points = ceiling-mounted indoors, vent outlets); sensor type selection (catalytic or electrochemical); calibration procedure (quarterly minimum); replacement interval (per manufacturer) | Detection system installation SOP; calibration log; sensor replacement records; alarm testing (weekly minimum) |
| Fire Detection and Suppression | Flame detectors (UV/IR) for spaces where hydrogen flame may be invisible; fire suppression per NFPA 2 or EIGA guidance; sprinkler system design if in building; foam unsuitable (water-based foam ineffective on hydrogen); inert gas suppression (nitrogen) for enclosed cabinets | Fire risk assessment identifying protection strategy; detector type and location rationale; suppression system design pressure/flow; inspection and test certificates; personnel training on limitations of detection | Fire system annual inspection by competent provider; detector sensitivity test records; suppression agent inventory management |
| Electrical Equipment | AS/NZS 60079 series (Hazardous areas – Equipment classification and selection); intrinsically safe (IS) equipment preferred; hazardous area zone definition (Zone 1 or 2 if indoor hydrogen source); 10 m exclusion around outdoor dispenser; cable trays rated for hydrogen environment | Hazardous area plan showing Zone 1/2 boundaries; equipment certification to IS category; cable selection (not PVC sheathing in Zone 1); control panel design per standard; electrical maintenance procedure | Installation inspection; equipment certification records; hazardous area plan signed by electrical engineer; periodic re-assessment if facility modified |
Equipment Standards Compliance Checklist:
- Applicable reference standard(s) identified for each major component (production, storage, compression, dispensing, relief, piping, detection, suppression)
- Equipment manufacturer certifications obtained and reviewed (confirms design standard compliance)
- Pressure ratings and design parameters clearly marked on equipment and documented in design register
- Material selection verified suitable for hydrogen service (embrittlement risk assessed; austenitic stainless or low-carbon steel specified)
- Pressure testing certificates retained (1.5× working pressure minimum; helium leak test for critical systems)
- Relief valve design and setting certificates available; calibrated ≤12 months
- Detection system design documented (locations, sensor type, alarm thresholds); calibration schedule established
- Electrical equipment (if hydrogen environment) certified per AS/NZS 60079; hazardous area plan completed
- Fire protection assessment completed; suppression system design documented
- All design documentation and compliance certificates filed in SMS document control system
5.0 RISK ASSESSMENT AND CONSEQUENCE ANALYSIS REQUIREMENTS
5.1 Dangerous Goods Risk Assessment (WA Framework)
For facilities >5,000 L hydrogen, a documented risk assessment must demonstrate that all reasonable practical measures are in place to minimize risk ALARP.
| Risk Assessment Step | Methodology | Acceptance Criteria | Documentation |
| 1. Hazard Identification | Systematic review of hydrogen properties (4–75% flammability range, 13× lower ignition energy than LPG, wide detonation potential, invisible flame) and facility operations (production, storage, compression, dispensing, venting, maintenance, decommissioning) | All credible hydrogen hazards identified (fire, explosion, cryogenic burns, pressure release, confined space, material compatibility, vent ignition) | Hazard register (linked to risk register); HAZID workshop minutes (if team-based study) |
| 2. Risk Identification | For each hazard, identify initiating events (equipment failure, human error, external event) and consequences (death, injury, property damage, environmental release) | Realistic scenarios developed covering normal operation, abnormal operation, maintenance, emergency events | Risk scenario table; frequency/consequence ratings assigned |
| 3. Risk Assessment | Quantitative (if data available) or semi-quantitative likelihood × consequence matrix; benchmarking against industry risk tolerability criteria | Individual Risk (IR) for fatality <10⁻⁶ per year acceptable; societal risk (F-N curve) evaluated for >1 potential fatality scenarios | Risk matrix; risk ranking by scenario; comparison to risk tolerability criteria |
| 4. Risk Control Selection | Apply hierarchy: eliminate (not feasible for hydrogen); substitute (fuel type change—rarely viable); engineering controls (isolation, containment, detection, relief); administrative controls (procedures, training, inspection); personal protective equipment | Multiple barriers approach: no single failure should lead to major incident; active controls backed up by passive controls | Control register (mapped to each significant risk scenario); barrier effectiveness notes |
| 5. Risk Control Validation | For each selected control, document: control description, effectiveness (how verified?), maintenance requirement, human dependency, testing frequency | All controls implemented and functional prior to commissioning; effectiveness demonstrated through design verification, commissioning testing, or operational history | Control validation report; commissioning sign-off; periodic inspection/test records |
| 6. Residual Risk Assessment | Re-assess risk post-control implementation; confirm residual risk is ALARP | Risk reduced to acceptable level; no further reasonably practical measures identified | Post-control risk matrix; ALARP justification statement; annual review procedure documented |
Dangerous Goods Risk Assessment Checklist (WA):
- Risk assessment team convened (includes Site Safety Manager, engineer, operations representative, maintenance lead)
- Hazard identification workshop conducted; all hazards listed and described
- Likelihood and consequence ratings defined (use DEMIRS framework or equivalent)
- Risk matrix populated; high-risk scenarios identified for detailed analysis
- For each significant risk, control measures documented (engineering and administrative)
- Controls validated (design verification reports, test certificates, operational evidence)
- Residual risk assessed; ALARP demonstrated (no further reasonably practical measures)
- Risk assessment report signed by Operator and Site Safety Manager
- Risk register maintained and reviewed annually (or when facility modified)
- Risk assessment linked to SMS (formal safety assessment per P&G Act s675(1)(e))
5.2 Consequence Analysis and Separation Distance Determination
For sites with significant hydrogen inventory (>1,000 kg), consequence modelling is expected to demonstrate adequate separation distances to sensitive receptors.
| Scenario Type | Analysis Approach | Acceptance Criteria | Output |
| Hydrogen Release (Worst-Case Credible) | Model unconfined release of stored hydrogen at design pressure/volume; assume all active controls fail; atmospheric dispersion at assumed wind speed | Concentration at property boundary <20% LEL (0.8% H₂) within 1 hour; or provide controlled shelter-in-place procedures | Consequence model report (using recognised software—e.g., PHAST, DNV, SAFETI); hazard distance map |
| Hydrogen Jet Fire | Model hydrogen release as pressurized jet (assume rupture of pressurized vessel); jet velocity and flame temperature computed; radiative heat calculated; distance to thermal impact zones determined | Overpressure: <7 kPa at protected places (residential, offices) = HIPAP 4 criterion (safe threshold for window breakage); Radiant heat: <4.7 kW/m² at protected places = safe (transient exposure) | Thermal impact distance map; overpressure analysis graph |
| Confined Explosion | If release occurs in confined space (building, machinery enclosure) with air mixing: model flame acceleration → detonation; peak overpressure calculated | Overpressure >20 kPa inside building assumed (major damage); ensure building design can withstand or isolate source; separation distance to adjacent building ≥1.5× event radius | Explosion overpressure/distance graph; building impact assessment |
| Cryogenic Liquid Release | Model liquid hydrogen spill (1:850 expansion ratio at atmospheric pressure and temperature); rapid vaporization; assume ignition of vapour cloud; flame envelope estimated | Thermal impact distances per HIPAP 4 criteria (overpressure and radiant heat limits at property boundary); consider wind direction (prevailing + worst-case) | Consequence model output; separation distance recommendations |
Consequence Analysis Checklist:
- Worst-case credible release scenario defined (size, pressure, duration)
- Consequence modelling software selected and validated (PHAST, DNV, SAFETI, or equivalent)
- Meteorological data for site location gathered (wind speed, atmospheric stability class)
- Thermal impact zones identified: fatality (radiant heat >4.7 kW/m²), injury (>1.6 kW/m²), awareness (>0.4 kW/m²)
- Overpressure impact assessed (7 kPa limit for protected places)
- Separation distances calculated to: residential areas, schools, child/aged-care facilities, public roads, adjacent industrial facilities
- Escalation and knock-on risks evaluated (hydrogen leak → explosion → impact on adjacent equipment)
- Land-use zoning confirmed (compliance with planning regulations regarding hazardous facility placement)
- Modelling report peer-reviewed by independent competent engineer
- Results communicated to emergency services (DFES consultation)
- Consequence analysis findings incorporated into SMS risk register and emergency response plan
6.0 SITE PREPARATION AND FACILITY COMMISSIONING
6.1 Pre-Commissioning Safety Verification Plan
Prior to introducing hydrogen to the facility, a comprehensive commissioning plan must be executed and documented.
| Commissioning Phase | Verification Activities | Acceptance Criteria | Responsible Person | Documentation |
| Mechanical System Integrity | Pressure test all gas-carrying components (pipework, vessels, equipment) at 1.5× operating pressure (hydrostatic or pneumatic); perform leak detection (helium sniff test for critical systems); inspect all welds (visual + dye penetrant if required) | All components hold test pressure with zero leakage; weld inspection reports indicate acceptability; material certs confirm hydrogen-compatible materials | Site Safety Manager + qualified mechanical inspector | Pressure test certs; leak test reports; weld inspection records; material certificates |
| Safety System Functional Testing | Test all safety-critical systems: pressure relief (set and lift check), emergency shutdowns (manual + automatic), detection systems (sensor response + alarm function), isolation valves (operation verified), vent system operability | Relief valve lifts within ±3% of setting; emergency shutdowns actuate <2 seconds; detection alarms trigger at set threshold; all isolation valves move freely and hold position; vent system clears at design flow rate | Site Safety Manager + systems engineer | Functional test certificates; test results spreadsheet; photo evidence of test execution |
| Electrical and Control System Commissioning | Verify all electrical circuits (control power, instrumentation, emergency circuits) are correctly installed per design; test all control logic (interlocks, permissives, shutdown sequences) | Control logic operates as designed (e.g., if pressure >threshold AND temperature <-30°C, then alarm 1 active; if manual emergency stop pressed, then all isolation solenoids de-energize); all meters and gauges calibrated | Electrical contractor + Site Safety Manager | Electrical inspection report; control logic test matrix; gauge calibration certs; control system as-built documentation |
| Atmosphere Verification (Confined Spaces) | Prior to first hydrogen introduction, verify confined spaces (equipment enclosures, pipework trench) have adequate natural or forced ventilation to prevent hydrogen accumulation; atmosphere test (O₂, LEL, H₂S, CO) if space >2 m deep | LEL in confined space remains <20% even with credible release scenario (ventilation adequate); O₂ levels 19.5–23.5% normal | Site Safety Manager + confined space competent person | Ventilation assessment report; atmospheric test results; confined space entry procedure approved |
| Personnel Competency Confirmation | Verify all operators, maintenance staff, and emergency responders have completed hydrogen-specific induction and are competent in their assigned roles; training records reviewed and signed | Training records current; competency assessments completed; roles and responsibilities understood; emergency procedures reviewed; permission to work system understood | Training coordinator + Site Safety Manager | Training attendance records; competency assessment checklists; role-specific procedure acknowledgements |
| Commissioning Safety Documentation | Compile final commissioning checklist (all items above); obtain formal sign-off from Operator, Site Safety Manager, and if applicable, third-party inspector; issue Commissioning Completion Certificate | All items in checklist verified; any non-conformances resolved or documented as accepted risks; formal sign-off obtained before hydrogen introduction | Site Safety Manager + Operator | Commissioning checklist (signed); photo evidence of completed work; equipment certificates filed in SMS; Commissioning Completion Certificate issued |
Pre-Commissioning Safety Verification Checklist:
- Commissioning plan documented and approved
- All mechanical systems pressure tested (1.5× operating pressure); test certificates retained
- Leak detection completed (helium sniff test on high-pressure/critical systems); all leaks remediated
- Weld inspection completed (visual + dye penetrant); reports filed
- Material certificates verified for all hydrogen-service components
- All safety systems tested and functional (relief, shutdowns, detection, isolation)
- Electrical systems verified correct per design; control logic tested
- All gauges and instruments calibrated ≤12 months
- Confined space ventilation verified adequate (atmospheric test completed if entry required)
- All personnel training completed and competency verified
- Emergency procedures reviewed with all staff; roles clarified
- Commissioning checklist completed and signed by Operator and Site Safety Manager
- Operator notification to regulator submitted (if QLD P&G Act applies)
7.0 SAFE WORK METHOD STATEMENTS (SWMS) AND PERMIT-TO-WORK SYSTEM
7.1 Hydrogen-Specific SWMS Requirements
All hydrogen-related work must be covered by a detailed Safe Work Method Statement (SWMS) that identifies hazards, control measures, and competency requirements.
| Work Activity | Hazards Addressed | Critical Control Measures | SWMS Requirements | Review Frequency |
| Hydrogen Production (Electrolyser Operation) | Pressure release, ignition of hydrogen vent, electrical hazard, thermal burns (heat generation), confined space (if production unit in enclosure) | Pressure relief operational (tested monthly); vent outlet minimum 2 m above surrounding ground/roof (hydrogen rises rapidly); electrical safety per AS 3000 (intrinsically safe equipment if Zone 1); thermal insulation/guarding around hot components | SWMS to include: pre-start checklist (pressure gauge verification, vent outlet clear, control interlocks tested); operational limits (inlet water pressure, oxygen output purity); emergency shutdown procedure; maintenance record keeping | Annually or if equipment modified |
| Hydrogen Compression | Pressurization hazards (high-pressure hose failure, oil carryover into hydrogen system, embrittlement of compressor internals), ignition risk during depressurization (hydrogen heats up), vibration/noise hazard | Pressure relief set below compressor rating; low-pressure hydrogen pre-filter (oil removal); pressure rating verification on discharge side; vibration isolation mounts; pressure gauges calibrated ≤12 months | SWMS to include: pressure limit settings (display on compressor); pre-start checks (oil level, vent clear); operation within design parameters; monitoring for abnormal noise/vibration; depressurization procedure (slow bleed via relief valve, not rapid discharge) | Annually |
| Hydrogen Storage Vessel Maintenance | Internal corrosion/embrittlement (if water/ice ingress), external corrosion, pressure relief valve degradation, connection/fitting tightness loss, hydrogen purity degradation | Visual inspection (monthly) for corrosion, leaks, pressure gauge indication; pressure vessel hydrostatic retest every 5 years (per AS 1210); relief valve calibration ≤12 months; connections hand-tightened + wrench backup after visual inspection every 6 months | SWMS to include: visual inspection checklist (corrosion, leaks, gauge function); pressure test procedure (hold test pressure 1–2 min); relief valve removal/cleaning/replacement protocol; isolation procedure before maintenance (isolation valve + double block and bleed); spill management (hydrogen venting to atmosphere, no ignition source within 10 m) | Annually |
| Hydrogen Pipeline Inspection and Maintenance | Hydrogen leak (invisible flame, odourless gas), confined space entry (if underground pipeline; trenches >2 m), service strike (if not properly marked/protected), pressure release during repair | Non-destructive testing (NDT) to verify pipeline integrity (ultrasonic wall thickness, pressure test); excavation permit + Dial Before You Dig (DBYD) consultation ≤5 business days before any ground penetration; pipeline marked clearly (signage every 50 m, at entry/exit points, at isolation valve locations); double block and bleed isolation before maintenance | SWMS to include: pipeline location verification (GIS map + physical mark-out); excavation permit coordination; service strike response (stop work, call utility authorities); isolation procedure (two isolation points minimum, verify isolation by opening upstream/downstream vent); pressure release management (slow vent to atmosphere, verify atmospheric dispersion adequate); leak detection procedure (bubble test with soap solution; hydrogen detectors used); repair/reinstatement documentation | Biennially or post-incident |
| Hydrogen Refuelling/Dispensing | Fuel incompleteness (incomplete vehicle tank fill), connection/disconnection hazards (pressure pulse, hose whip), vehicle ignition during refuelling (vehicle must be off, electrical systems isolated), cryogenic burns (liquid hydrogen systems), static discharge (bonding required) | Vehicle isolation (ignition off, electrical master switch off) verified before connection; quick-disconnect coupler design rated for maximum system pressure; pressure relief in hose assembly; temperature monitoring (cryogenic systems); bonding cables connected between dispenser and vehicle (static dissipation); refuelling procedure limits to 5 min per vehicle | SWMS to include: pre-dispensing checklist (vehicle condition, coupler compatibility, pressure relief operability); vehicle preparation procedure (driver instructed to leave engine off, windows down for vent); refuelling steps (connection, pressure build-up, flow initiation, completion check, disconnection); monitoring during refuelling (operator attendance, pressure monitoring); emergency shutdown procedure (red button, immediate isolation) | Annually |
| Hydrogen Confined Space Entry | Atmospheric hazard (oxygen-deficient atmosphere, explosive hydrogen concentration, toxic contaminants from production process—e.g., CO if steam reforming used), engulfment/immersion risk (liquid cryogen if liquid hydrogen system), isolation failure (unexpected hydrogen release), rescue difficulty (personnel in suit or harness) | Atmospheric testing before entry: O₂ 19.5–23.5%, LEL <10%, H₂S <10 ppm, CO <35 ppm; continuous monitoring during entry; forced ventilation (≥6 air changes/hour); double isolation (isolation valve + blank flange or mechanical isolation); rescue tripod with 5:1 mechanical advantage winch; standby person with communication | SWMS to reference AS 2865-2009 Confined Spaces (full compliance); include: permit application procedure (description of space, hazards, control measures, duration); atmospheric test protocol (pre-entry and continuous); isolation procedure (verification of isolation—open isolation valve, listen for sound/feel for pressure); entry-exit procedure (personnel equipped with harness, lifeline, communicator); rescue procedure (tripod setup, winch operation, rescue team alert); re-entry procedure post-incident | Per confined space entry (valid for 7 days or project-specific) |
| Pressure Relief Valve Removal and Testing | Pressure release (residual hydrogen), high-temperature discharge, mis-assembly (wrong spring/setting on re-installation), loss of isolation (if isolation valve downstream of relief) | System isolated and depressurized before removal; relief valve tagged with calibration setting; replacement only by competent person with certification; test house calibration record; storage in clean, dry location until re-installation | SWMS to include: isolation procedure (close upstream valve, open downstream vent, allow pressure to bleed naturally); valve removal technique (wrench size, direction); downstream isolation verification (no pressure indication); storage procedure (dust cap on ports, temperature controlled, inventory managed); re-installation (verify spring/seating correct per test house certificate); functional test post-installation | Per removal (testing interval per maintenance schedule—typically annual) |
| Hydrogen Dispenser Malfunction Response | Stuck nozzle (uncontrolled release), pressure build-up in hose, loss of pressure indication (gauge failure), refrigeration unit failure (temperature rise), communication failure (radio outage) | Daily pre-shift check: pressure gauge indication normal, nozzle latch smooth, temperature readout current, alarm system audible/visible, radio communication tested; if malfunction detected: isolate dispenser (isolation valve closed), permit issue, corrective action procedure initiated (service engineer call-out) | SWMS to include: daily pre-shift checklist (all items above); malfunction identification (what to look for); isolation procedure; sign-out procedure (dispenser tagged, warning signage posted, no use until repaired); temporary repair vs. component replacement authority (e.g., gauge change by trained operator; compressor repair by OEM service only) | Daily (pre-shift check); annually (full SWMS review) |
SWMS Checklist – Hydrogen Operations:
- SWMS prepared for each hydrogen-related work activity (production, storage, compression, dispensing, maintenance, repair, emergency response)
- Hazards specific to hydrogen identified in each SWMS (fire, explosion, pressure, cryogenic, invisible flame, material compatibility)
- Control measures documented and linked to risk register
- Competency requirements specified (training, certification, experience, supervision)
- Equipment and materials required listed (PPE, tools, test equipment, isolation devices)
- Emergency procedures referenced (emergency shutdown, personnel evacuation, emergency services contact)
- SWMS accessible at work face (printed + digital access)
- Personnel sign-off on SWMS understanding (induction records)
- Review schedule established (annual minimum; more frequent if equipment/process changes)
- Non-conformances or hazards discovered during work logged and SWMS updated accordingly
7.2 Permit-to-Work Framework
All hydrogen work must operate under the following permit system:
| Permit Type | Applicable Activities | Authority | Duration | Conditions |
| Excavation Permit | Ground penetration within 1 m of hydrogen pipeline; potholing to locate utilities before pipeline work | Site Safety Manager or Excavation Permit Issuer | 28 days | Dial Before You Dig (DBYD) consultation mandatory ≤5 business days prior; non-destructive digging (vacuum excavation or hand digging) only within 1 m of utility; hydrogen pipeline marked above-ground; exclusion zone 10 m; emergency contact numbers for pipeline operator |
| Confined Space Entry Permit | Entry to spaces >2 m depth (e.g., pipeline trench, hydrogen storage enclosure); entry to any enclosed space identified as confined space in facility SOP | Confined Space Coordinator (trained and competent) | 7 days or project-specific | Atmospheric testing completed pre-entry; continuous monitoring during entry; rescue equipment in place; standby person assigned; supervisor at work face |
| Hot Works Permit | Welding, cutting, grinding, brazing on hydrogen facility equipment or near pipelines; work generating temperature >200°C within 10 m of hydrogen source | Hot Works Permit Issuer | 1 day (specific date/time) | Hydrogen isolation verified (closed isolation valve + open vent, no pressure indication); fire watch assigned (during + 1 hour post-work); fire extinguisher (9 kg ABE minimum) within arm’s reach; fire suppression system checked operational (if building); no hot works within 3 m of hydrogen dispenser or vent outlet |
| Working at Heights Permit | Work >2 m above ground level on hydrogen facility (e.g., pressure vessel inspection platform, roof vent outlet maintenance) | Work at Heights Coordinator | 7 days or project-specific | Fall protection system (harness + lanyard + anchor point) verified; platform certification (structural inspection); weather conditions checked (no work in high wind >40 km/h); rescue plan documented |
| Hydrogen Work Permit | Any work involving direct contact with hydrogen system pressurized components (pressure equipment, high-pressure hose, compressor, relief valve); nitrogen purge/pressure test of hydrogen system | Hydrogen Work Permit Issuer (Site Safety Manager or competent supervisor) | 1 day or specific duration | System isolated (isolation valve closed, vent open); pressure relief tested operational; pressure gauge reading zero; hydrogen detector checked for function; isolation verified by second person check-off; nitrogen supply for purging confirmed available and pure (99.9%+ purity, moisture <50 ppm dew point) |
| Permit Coordination Meeting | When multiple permits required concurrently (e.g., excavation + confined space + hot works for pipeline repair in trench) | Site Safety Manager + permit issuers | Pre-work meeting | All hazards and controls reviewed; sequencing confirmed (e.g., excavation first, then hot works only after hydrogen isolation verified); emergency response coordination; all personnel briefed on complete work scope |
Permit-to-Work System Checklist:
- Permit templates prepared for all applicable permit types
- Permit issuing authorities identified and trained
- Conditions and limitations for each permit type clearly defined in procedure
- Work suspension criteria documented (e.g., weather >40 km/h wind = work at heights suspended)
- Permit register maintained (chronological record of all permits issued; minimum 5-year retention)
- Permit display locations established (work face, facility entry point)
- Cancellation procedure documented (who can suspend/cancel; communication to personnel)
- Multi-permit coordination procedure established (meeting convened if >1 permit required)
- Emergency permit (for urgent repairs) defined (expedited approval authority; post-incident review mandatory)
8.0 TRAINING, COMPETENCY AND EMERGENCY RESPONSE
8.1 Hydrogen-Specific Training Requirements
All personnel with exposure to hydrogen must complete induction and role-specific training. The Australian Government UEG Gas Industry Training Package (UEGNSG902–906) is the reference framework.
| Training Level | Target Audience | Content | Competency Assessment | Certificate Retention |
| General Hydrogen Induction (All Site Personnel) | All site workers (operators, maintenance, supervisors, visitors, contractors) | Hydrogen properties (flammability, ignition, cryogenic hazard, invisible flame); site-specific hazards (facility type, control measures); emergency procedures (evacuation, shelter-in-place, emergency shutdown); incident reporting; responsible behavior (no hot work near hydrogen, no ignition sources) | Induction form signed + verbal Q&A (minimum 80% pass) | 1 year from last induction |
| Hydrogen Operator Competency (UEG Units UEGNSG902–906) | Hydrogen production/storage/dispensing operators; fuel gas delivery network personnel | Hydrogen chemistry and safety; hazard identification specific to facility type; safe operating procedures; equipment operation (pressure control, leak detection, emergency shutdown, relief valve function); pressure systems safety; confined space procedures (if applicable) | Formal competency assessment per UEG training package (on-job demonstration + written assessment) | Annually or per vocational training scheme requirements |
| Maintenance Technician Competency | Maintenance staff working on hydrogen equipment/pipelines | All content above plus: pressure vessel inspection and testing; pipeline inspection and integrity verification; electrical/instrumentation maintenance (hazardous area equipment); equipment repair/replacement protocols; preventive maintenance scheduling; root-cause analysis of equipment failures | Competency sign-off by supervisor after training + demonstrated safe work practices (observed on site) | Annually or after significant maintenance task |
| Emergency Response Coordinator | Site Safety Manager, emergency responders, first responders | Hydrogen incident scenarios (leak, fire, explosion); personal protective equipment (self-contained breathing apparatus for hydrogen fire response; standard PPE inadequate); emergency shutdown procedures; evacuation routes and muster points; external emergency services interface (DFES contact, information to provide, access routes); confined space rescue (if applicable); post-incident site security/investigation | Scenario-based training + functional drill (annual minimum) | Annually; additional certification if specialised (confined space rescue, HAZMAT response) |
| Supervisor/Manager Training | Site Safety Manager, Site Supervisors, Operator representatives | All content above plus: SMS responsibilities; incident investigation; management of change (MOC) process; permit-to-work system operation; contractor management; WHS Act compliance; notifiable incident criteria; regulator communication | Certification in hydrogen facility supervision or evidence of 3+ years facility experience + formal training completion | Annually |
Training and Competency Checklist:
- Training matrix prepared by role (operator, maintenance, emergency response, supervisor, visitor)
- Induction procedure documented (delivery method, content, assessment, sign-off)
- UEG Gas Industry Training Package references incorporated into facility training framework
- Training providers selected (in-house training + external provider for formal certifications)
- Training schedule established (induction before first hydrogen exposure; annual refresher; competency assessment interval)
- Competency assessments conducted and results documented (assessment criteria clear; pass/fail criteria defined)
- Training records maintained for all personnel (name, role, date completed, competency level, certification number if applicable)
- New hazards or equipment changes trigger re-training (management of change documented)
- Competency gaps identified and remedial training provided
- Annual training effectiveness review (review incident reports; assess if training prevented recurrence)
8.2 Emergency Response Procedures and Drills
Hydrogen facilities require comprehensive emergency response plans with regular testing via drills.
Emergency Response Plan Checklist:
- Emergency response procedure written for each credible scenario
- Personnel roles defined (evacuation coordinator, emergency shutdown coordinator, first aid, communication)
- Emergency contact numbers current (DFES, police, ambulance, Site Safety Manager, Operator, EPA, utility authorities, facility manufacturer)
- Evacuation assembly points identified and signposted
- Emergency equipment inventoried and location marked (fire extinguisher, first aid kit, spill kit, rescue tripod, breathing apparatus, hydrogen detector)
- External stakeholder coordination established (DFES emergency response guide—if required; community consultation if public risk)
- Incident hotline/communication system tested (radios, alarm system, mobile coverage)
- Emergency drills conducted minimum annually (full or tabletop; deficiencies addressed in SWMS updates)
- Post-incident procedure documented (investigation, reporting, recovery, regulator liaison)
- Emergency response plan review scheduled (annual or post-incident)
9.0 NOTIFIABLE INCIDENTS AND REGULATOR REPORTING
9.1 Notifiable Incident Criteria and Reporting Obligations
Certain hydrogen incidents must be reported to WHS regulators (WorkSafe) and/or dangerous goods regulators (DGS/P&G Inspectorate) within prescribed timeframes.
| Incident Category | Notifiable to | Timeframe | Information Required | Evidence |
| Hydrogen Release >5 Tonnes (WA) | Department of Energy, Mines, Industry Regulation and Safety (DEMIRS) | Immediately (within 24 hours) | Date/time of release; volume released; cause (equipment failure, human error, external event); immediate response taken; ongoing risk assessment; estimated timeline for remediation | Release documentation; atmospheric dispersion monitoring; regulator incident form completed |
| Facility Damage >$100,000 (WA) | DEMIRS (DGS regulator) | Within 7 days | Asset damage description; facility system affected; cause; remediation plan; target re-commissioning date; interim safety measures | Damage assessment report; cost estimate; repair plan; photo evidence |
| Unplanned Release to Waterway >1,000 L (WA/All States) | Environment Protection Authority (EPA) + DGS regulator | Within 2 hours (EPA); within 7 days (DGS) | Release date/time; volume; location; environmental impact assessment; remediation measures; monitoring plan | Spill notification form; water quality testing results; environmental cleanup plan |
| Injury/Fatality (All Jurisdictions) | WorkSafe (WHS regulator) + Police | Immediately (within 24 hours) | Description of incident; nature of injury; affected person details; witness information; equipment/material involved | First aid records; hospital admission details; police incident number; photographic evidence of scene |
| Unplanned Operating Plant Shutdown (QLD P&G) >4 Hours | RSHQ (P&G Inspectorate) + Chief Inspector | Within 2 business days | Date/time of shutdown; cause (equipment failure, safety concern, regulatory compliance); duration; actions taken; regulator approval for restart if safety-related | Incident report; maintenance records; safety assessment report; approval from Chief Inspector (if required) |
| Pressure Vessel Failure/Structural Damage | WHS regulator + DGS regulator | Within 7 days | Vessel identification; failure mode (rupture, leakage, deformation); cause; remediation | NDT inspection results; replacement vessel certification; design review (if defect identified) |
| Confined Space Entrapment >30 Minutes | WorkSafe (WHS) | Within 24 hours | Personnel details; space description; duration trapped; rescue method; injury outcome; root-cause (why entry made? why isolation failed?) | Rescue report; confined space entry procedure review; regulator investigation cooperation |
Notifiable Incident Checklist:
- Notifiable incident criteria understood by all site personnel (Site Safety Manager, supervisors, emergency response team)
- Reporting flowchart posted at workplace (who reports, to whom, within what timeframe)
- Contact numbers for WHS regulator and DGS regulator current
- Incident documentation procedure established (initial report + investigation + formal notification)
- Internal escalation defined (Site Safety Manager → Operator → regulator)
- Investigation timeframe: incident root-cause analysis completed within 5–7 days; formal notification within legal timeframe
- Corrective action plan prepared and regulator provided with timeline
- Site closure authority identified (when can facility recommence after notifiable incident? Regulator approval required if major structural damage or fatality)
10.0 ROLES, RESPONSIBILITIES AND COMPETENCY MATRIX
| Role | Qualifications/Experience | Key Responsibilities | WHS/DGS Act Reference |
| Operator / PCBU | PCBU status (company board/senior management); ultimate accountability for site safety | Appoint competent Statutory Position Holders (ESM, Site Safety Manager); approve SMS; authorize expenditure for safety improvements; ensure adequate funding and resources; final approval for project commissioning; notifiable incident response | WHS Act s36; P&G Act s673; DGS Act s8 |
| Executive Safety Manager (ESM) | Tertiary qualification in relevant discipline (engineering, chemistry, environmental science, occupational health) + senior industry experience (10+ years hydrogen/fuel gas); or CPEng registration | Oversight of SMS compliance; approval of formal safety assessment; authorization of major work permits (pressure >50 MPa, cryogenic systems, confined space >5 m); incident investigation; communication with regulator | P&G Act s687–688; WHS Act s36 |
| Site Safety Manager | Minimum 3+ years operational experience on hydrogen facility; formal hydrogen safety training; demonstrated competency in SMS application, permit system, incident response | Daily site management; pre-start safety meetings; coordination of SWMS and permit-to-work system; supervision of contractors; health & safety inspection; incident investigation initiation; reporting to Operator/ESM | P&G Act s692; WHS Act s36 |
| Hydrogen Operator | High-school education minimum; UEG Gas Industry Training Package competency (UEGNSG902–906) or equivalent hydrogen operator certification; annual competency review | Safe operation of hydrogen production/storage/compression/dispensing equipment per SWMS; daily pre-start checks; pressure monitoring; leak detection; emergency shutdown; record keeping (hourly logs, maintenance alerts) | WHS Act s36; Competency Standards (UEG Training Package) |
| Maintenance Technician | Trade qualification (mechanical, electrical, instrumentation); hydrogen-specific training (pressure vessel inspection, pipeline NDT, hazardous area equipment); competency assessment | Preventive maintenance (pressure tests, relief valve calibration, control system testing, electrical circuit checks); corrective maintenance (equipment repair/replacement); record retention; root-cause analysis of failures; competency renewal annually | WHS Act s36; Equipment-Specific Standards (AS 1210, AS/NZS 60079) |
| Confined Space Rescue Specialist | High-Risk Work Licence (HRWL) Confined Space Entry; rescue equipment operation training (tripod, mechanical advantage winch, harness); first aid + CPR | Rescue equipment maintenance and setup; rescue operation coordination; personnel extraction; casualties management; scene safety post-rescue | WHS Act s143–154; AS 2865-2009 |
| Emergency Response Coordinator | Incident command/emergency management training (preferably formal certification); communication/leadership skills; site facility knowledge | Emergency scenario response; personnel evacuation coordination; external emergency services liaison (DFES); incident hotline; post-incident site security; regulator notification | WHS Act s36; Emergency Management Act (state-specific) |
| Contractor Supervisor | Valid induction completion; WHS site induction competency; communication skills | Coordination of contractor team; safety briefing before work start; permit compliance; incident reporting; communication with Site Safety Manager | WHS Act s36 |
| Competent Person (External Inspector/Engineer) | Professional Engineer registration (CPEng, RPEQ, equivalent) + hydrogen facility experience (5+ years); or equivalent competency demonstration (university degree + professional development) | Design verification (pressure vessel, piping, pressure relief); risk assessment peer-review; facility commissioning certification; third-party inspection of critical systems; expert witness in incident investigation | WHS Act s36; Professional Engineers Act (state-specific) |
11.0 LEGAL REFERENCES AND STANDARDS
Commonwealth and State WHS Legislation
- Work Health and Safety Act 2011 (QLD, ACT); Work Health and Safety Regulation 2011
- Work Health and Safety Regulation 2025 (NSW, NT); Work Health and Safety Act 2011
- Work Health and Safety Regulation 2012 (SA)
- Work Health and Safety Regulations 2022 (TAS)
- Work Health and Safety (General) Regulations (WA); Work Health and Safety Act 2020
- Occupational Health and Safety Regulations 2017 (VIC); Occupational Health and Safety Act 2004
- Work Health and Safety (Petroleum and Geothermal Energy Operations) Regulations 2022 (WA, if applicable to hydrogen blending in pipelines)
Dangerous Goods Safety Legislation (WA)
- Dangerous Goods Safety Act 2004 (WA)
- Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 (DGSH Regs)
- Dangerous Goods Safety (Major Hazard Facilities) Regulations 2007 (MHF Regs)
- Australian Dangerous Goods Code – Edition 7.8 (ADG Code; transport by road)
Petroleum and Gas Safety Legislation (QLD)
- Petroleum and Gas (Production and Safety) Act 2004 (P&G Act)
- Petroleum and Gas (Safety) Regulation 2018 (P&G Safety Reg)
- Petroleum and Gas (General Provisions) Regulation 2017 (P&G GP Reg)
Australian and ISO Standards for Hydrogen Safety
- AS 22734:2020 – Hydrogen generators using water electrolysis – Industrial, commercial, and residential applications
- AS ISO 16110.1:2020 – Hydrogen generators using fuel processing technologies – Part 1: Safety
- AS ISO 14687:2020 – Hydrogen fuel quality – Product specification
- AS ISO 16111:2020 – Transportable gas storage devices – Hydrogen absorbed in reversible metal hydride
- AS ISO 19881:2020 – Gaseous hydrogen – Land vehicle fuel containers
- AS 19880.1:2023 – Gaseous hydrogen – Fuelling stations, Part 1: General requirements
- AS 19880.3:2020 – Gaseous hydrogen – Fuelling stations, Part 3: Valves
- AS ISO 19880.5:2021 – Gaseous hydrogen – Fuelling stations, Part 5: Dispenser hoses and hose assemblies
- AS ISO 19880.8:2021 – Gaseous hydrogen – Fuelling stations, Part 8: Fuel quality control
- SA TS 5359:2022 – The storage and handling of hydrogen
- SA TR 15916:2021 – Basic considerations for the safety of hydrogen systems
- AS 62282.2.100:2022 – Fuel cell technologies, Part 2.100: Fuel cell modules – Safety
- AS 62282.3.100:2021 – Fuel cell technologies, Part 3.100: Stationary fuel cell power systems – Safety
- AS 62282.3.300:2021 – Fuel cell technologies, Part 3.300: Stationary fuel cell power systems – Installation
- SA TS 19883:2020 – Safety of pressure swing adsorption systems for hydrogen separation and purification
Pressure Equipment and Installation Standards
- AS 1210:2010 – Pressure vessels – Design and manufacture
- AS 2030.1:2009 – Gas cylinders – General requirements
- AS/NZS 1596:2014 – Gases – Handling and storage of LP Gas
- AS/NZS 2885 Series – Pipelines – Gas and Liquid Petroleum
- AS/NZS 4645 Series – Gas distribution networks
- AS 3000:2018 – Australian/New Zealand Wiring Rules (electrical installations)
- AS/NZS 60079 Series – Hazardous areas – Equipment classification and selection
- ASME B31.12 – Hydrogen Piping and Pipelines (reference)
Confined Space and Emergency Management
- AS 2865-2009 – Confined spaces – Safety requirements and guidance
- AS 3745:2010 – Planning for emergencies in facilities
- AS 1418.1:2015 – Cranes, hoists and winches – General requirements
Training Framework
- UEG Gas Industry Training Package (Australian Government; units UEGNSG902–906 for hydrogen competency)
International Standards (Guidance)
- NFPA 2 – Hydrogen Technologies Code 2020 (supplementary guidance)
- ISO 19880-1:2020 – Gaseous hydrogen – Fuelling stations, Part 1: General requirements (reference; AS 19880.1:2023 adopted version)
- SAE J2578 – Recommended Practice for General Fuel Cell Vehicle Safety
- SAE J2579 – Standard for Fuel Systems in Fuel Cell and Other Hydrogen Vehicles
DOCUMENT ATTRIBUTION AND USAGE
This standard is copyright-free under Creative Commons CC0 1.0 Universal. You may freely use, share, adapt, and distribute this document with your team, industry peers, and the broader WHS community.
Attribution required: HSE Direct (www.hsedirect.com.au)
HSE Direct | Workplace Health & Safety Consulting
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- Email: contact@hsedirect.com.au
Mission: Protecting People | Protecting Planet | Protecting Prosperity
REFERENCES
- Dangerous Goods Safety Guide: Storage, handling and production of hydrogen. Department of Energy, Mines, Industry Regulation and Safety (DEMIRS), Western Australia. June 2024.
- Hydrogen Safety Code of Practice. Petroleum and Gas Inspectorate, Resources Safety and Health Queensland (RSHQ). Version 2.0, July 2025.
- Work Health and Safety Act 2011 (Commonwealth and state/territory editions).
- Dangerous Goods Safety Act 2004 (Western Australia).
- Petroleum and Gas (Production and Safety) Act 2004 (Queensland).
- Australian Standards: AS 1210, AS 22734, AS/NZS 2885, AS/NZS 4645, AS 19880 series, AS 62282 series, SA TS 5359, AS 2865-2009.
- UEG Gas Industry Training Package – Units UEGNSG902–906 (Australian Government, Department of Employment).