Notice

HSE’s role on 100% hydrogen heating

Published 18 March 2024

The Health and Safety Executive (HSE) is Great Britain’s national regulator for workplace health and safety. HSE’s mission is to protect people and places.

In line with its 10-year strategy, HSE is working to enable industries to innovate safely to prevent major incidents, supporting the move towards net zero, recognising that many of these technologies present challenges that businesses and society are less familiar with. As part of the UK government’s net zero targets to tackle climate change, HSE is applying its expert knowledge and capability to assess evidence on the safe distribution, storage and use of 100% hydrogen heating.

HSE’s role within 100% hydrogen heating is twofold:

• to guide the development of and review an appropriate evidence base to enable HSE to reach an authoritative view on the safety of using 100% hydrogen for heating to feed into government policy decisions in 2026
• to maintain regulatory oversight of hydrogen trials to ensure dutyholders manage the risks appropriately

How HSE assesses safety

For existing major hazards including gas safety, HSE assures safety against a mature regulatory framework. HSE has advised the Gas Distribution Networks that they should apply this framework to their evidence demonstration as a basis for compliance with health and safety law. At the heart of this framework and the British health and safety system is the concept of reducing risk to a level that is ‘As Low as Reasonably Practicable’ or ALARP for short.

Determining what is reasonably practicable involves weighing a risk against the trouble, time and money needed to control it, meaning that control measures should be proportionate to the risk. This principle applies to the current gas system and will be applied to any potential use of hydrogen for heating, including trials.

Gas distribution networks are seeking to demonstrate through their evidence submissions that the risks from hydrogen can be managed to a level that is as safe or safer than natural gas. While any like-for-like comparison is challenging between hydrogen and natural gas, this is likely to be an input into the ALARP demonstration that the networks will make.

Trial specific evidence

HSE does not have the powers to authorise or approve a hydrogen heating trial. Where HSE assesses trial evidence and is satisfied that the evidence demonstrates that the operators can run the trial safely, HSE will set out its conclusions to DESNZ, Ofgem and the operator. All parties will need to consider the conclusions of HSE’s assessment before the trial goes ahead.

HSE will maintain its role as independent regulator for workplace health and safety and will regulate any hydrogen trials in line with that role, including having the ability to take enforcement action, if necessary, to ensure compliance with health and safety law. Further information on how HSE regulates high hazard industries is available on its website.

Evidence assessment for a policy decision on the future of hydrogen heating

Alongside site-specific evidence generated and assessed for a trial, evidence is also being produced to support the demonstration of safety for a potential wider roll out of hydrogen heating. This evidence covers a much broader range of scenarios and potential end uses than those included in any trial area. Once HSE has completed its review of this evidence it will report its conclusions to DESNZ. This will then inform the government policy decision on hydrogen heating due in 2026.