Call for Evidence on 100% Hydrogen Heating – Future Regulation

Overview

Hydrogen as a low carbon heating alternative

Replacing natural gas with low carbon hydrogen in all or in parts of the gas grid is a potential option for decarbonising heat in buildings. However, unlike more established technologies such as heat pumps and heat networks, 100% hydrogen for heat is not yet an established option.

HSE’s role in assessing the safety of hydrogen for heating 

HSE will provide an authoritative view on the safety of using 100% hydrogen for heat across Great Britain to feed into Government policy decisions in 2026.

HSE is engaged with Ofgem, Department for Energy Security and Net Zero and gas distribution networks on the proposed Neighbourhood and Village hydrogen heating trials. HSE is working to ensure that the risks associated with hydrogen for heat are properly understood and managed by the networks. HSE has a process in place to review safety evidence before the trials begin, mirroring current regulatory processes such as requirements to submit safety evidence to HSE before the operation of a natural gas network.

HSE will continue to maintain its role as the independent regulator for workplace health and safety during the trials and before any community trial can go ahead, HSE will need to be satisfied that the trial will be run safely.

Alongside the review of safety evidence for the hydrogen trials, HSE has set up a future hydrogen regulatory workstream to assess the suitability of HSE enforced regulations beyond the limited circumstances of the trials. This work needs to consider if any regulatory changes may be required to enable a potential broader roll out of 100% hydrogen for heating, the scale of which is yet to be determined. HSE will develop options for any necessary amendments to the health and safety regulatory framework. This will contribute towards a policy options study for future safety regulation in September 2024, followed by final written advice which will be presented to the Department for Energy Security and Net Zero in March 2025.

Call for evidence

A future hydrogen regulatory framework will need to effectively regulate the safe distribution, storage and subsequent use of 100% hydrogen gas in domestic, industrial and commercial premises. HSE has commissioned this call for evidence to seek views from stakeholders on the implications of the introduction of hydrogen for heat on the suitability of the current HSE regulatory regime and the impact of any potential changes.

The call for evidence seeks to understand:

• Whether existing health and safety regulations are suitable for the effective regulation of 100% hydrogen for heating  
• Whether any amendments may be required, and why. 
• Whether there are any regulatory gaps,  
• Any consequences of these potential approaches to amending the regulatory framework 

What is in scope of this review?

Following an internal review of its own regulatory framework under the Health and Safety at Work Act etc. 1974 (HSWA), HSE has identified regulations which may require amendments to support a conversion of the natural gas network to 100% hydrogen in the event of a policy decision to support a wider roll out of hydrogen for heating. The regulations identified are:  

• Gas Safety (Management) Regulations 1996 (GSMR) 
• Gas Safety (Installation and Use) Regulations 1998 (GSIUR)  

We are also interested in views on the following regulations to helps us consider if any amendments may be necessary or if any other non-regulatory changes might be required, such as additional guidance:  

• Control of Major Accident Hazards Regulations 2015 (COMAH)  
• The Pipelines Safety Regulations 1996 (PSR)  

The regulation of a wider hydrogen economy (including the process of hydrogen production) is not within scope of this study and HSE is not seeking views beyond those relating to 100% hydrogen heating. However, we note that consideration of the regulatory framework for a roll out of 100% hydrogen heating may have wider applicability for a hydrogen economy.

At this stage, only regulations made under HSWA are within scope of this call for evidence. However, we may seek future engagement on legislative changes such as potential changes to the building regulations and associated guidance in support of the Government policy decision on 100% hydrogen heating in 2026.

HSE does not intend to start the process of changing regulations prior to any Government policy decision on 100% hydrogen heating. Any legislative change would likely entail further evidence gathering, public consultation and the development of relevant impact assessment(s). 

Invitation to comment

This call for evidence will be one element of HSE's information gathering to inform our open and transparent approach to decision-making. The responses to this call for evidence will be considered by HSE to support the safety policy options study for the Department for Energy Security and Net Zero.

Confidentiality and GDPR (General Data Protection Regulations)

HSE tries to make its call for evidence procedure as thorough and open as possible. Information provided in response to this call for evidence may be subject to publication or disclosure in accordance with the access to information regimes (these are primarily the Freedom of Information Act 2000 (FOIA), the General Data Protection Regulations (GDPR) and the Environmental Information Regulations 2004 (EIR)). Statutory Codes of Practice under the FOIA and EIR also deal with confidentiality obligations, among other things. 

If you would like us to treat any of the information you provide as confidential, please make this clear in your response. If we receive a request under FOIA or EIR for the information you have provided, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will be disregarded for these purposes. Requests for confidentiality should be made explicit within the body of the response. 

HSE will process all personal data in accordance with the GDPR. This means that personal data will not normally be disclosed to third parties and any such disclosures will only be made in accordance with the Regulations. 

• HSE’s Privacy Policy Statement

How to submit comments

Responses must be received by 11.59pm, 27 October 2023. For enquiries, please contact hhpevidence@hse.gov.uk.

Comments should be submitted by using the link below, no later than the deadline above.

An offline version of the questions is also available.