Operational Safety in Low-Emission Hydrogen Production

The enactment of Law No. 14,948 of August 2, 2024, established the National Low-Emission Hydrogen Policy, assigning the ANP comprehensive regulatory authority over the hydrogen supply chain. In this context, Subgroup IV of the PNH2 prepared a comprehensive report to guide future technical regulations.

International and National Outlook

Analysis of global regulatory trends (Europe, Americas, Asia, and Oceania) demonstrates a clear shift from purely prescriptive rules toward risk- and performance-based frameworks, such as the Seveso Directive. In Brazil, the ANP regulatory framework organized around the SGSO (Operational Safety Management System) incorporates instruments aligned with the new legal requirements.

Incident Analysis

Data from international safety databases (HIAD, H2Tools) indicate that hydrogen incidents predominantly stem from design errors (inadequate metallurgy and material selection), management system gaps, incomplete operating procedures, and deficient maintenance. This highlights the critical necessity of process safety management and layered barrier defense.

Core Recommendations

• Adoption of a phased, risk-based regulatory roadmap.
• Inclusion of targeted regulatory actions in the ANP agenda, harmonizing standards with upstream E&P best practices.
• Implementation of regulatory sandbox mechanisms throughout the transitional phase.
• Updating standards for mandatory incident notification and root-cause reporting.