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Hydrogen has a long history of being used in industry, for processes such as margarine, methanol and hydrogen chloride and metal production, and is now preferred as a clean, renewable energy source to support the green economy and reduce carbon emissions.

Renewable hydrogen is produced without the use of fossil fuels. It is typically generated from renewable energy sources like solar or wind power, making it carbon-neutral. Another way to produce renewable hydrogen is by using residual biomass from sources like municipal solid waste. When used within a fuel cell, it undergoes an electrochemical process that generates electricity without combustion, eliminating greenhouse gases (GHGs) and air pollutants.

With so many ways to produce hydrogen, it is common to differentiate between renewable hydrogen and other sources.

Hydrogen produced from water electrolysis and renewable energy is known as green hydrogen. This term is used to distinguish between carbon-neutral hydrogen and hydrogen produced from fossil fuels, known as brown hydrogen. Most global production has traditionally been brown hydrogen which is manufactured by steam methane reformation, where high-temperature steam (700°C–1,000°C) is used to produce hydrogen from a methane source, such as natural gas. Blue hydrogen is produced by incorporating carbon capture and storage into the steam methane reformation production processes. Gold hydrogen refers to naturally occurring hydrogen. Renewable hydrogen is seen as a step towards achieving carbon-free energy.

Renewable hydrogen could help achieve government emission targets through various processes, including:

  • using hydrogen as an energy grid stabiliser
  • as a supplement for natural gas
  • providing off-grid power solutions
  • utilising hydrogen as a transportation fuel
  • enhancing and supporting energy and fuel security.

Refer to more information in the Queensland Hydrogen Industry Strategy.

Hydrogen is a colourless, odourless gas at atmospheric conditions. It is lighter than air and will easily dissipate if not confined. The hydrogen molecule is very small in size and has low viscosity, making it difficult to contain with threaded and flanged joints. It is so small that it can even slowly disperse through the atomic matrix of solid metal (e.g. pipework) and impact the integrity of the material, causing embrittlement.

Liquid hydrogen has a density approximately 7 per cent compared to water and boils at a temperature of minus (-) 253°C. The liquid to gas expansion ratio of hydrogen is about 1:850. Unlike gaseous hydrogen, liquid hydrogen doesn’t disperse as readily when released to the atmosphere due to its low temperature.

When mixed with air, hydrogen has a wide flammability range of 4–75 per cent volume per volume (v/v) compared to:

  • liquefied petroleum (LP) gas, which is 2.1–9.5 per cent (v/v)
  • petrol, which is 1.2–7.4 per cent (v/v).

It is essential to keep air from mixing with hydrogen within confined spaces as there is a high likelihood that the atmosphere will be flammable.

Hydrogen has a low ignition energy, approximately 13 times lower than LP gas. This means it’s much easier to accidentally ignite and therefore requires suitably-rated electrical equipment to prevent a fire or explosion. Hydrogen heats up when it is depressurised, which can be sufficient to ignite vented hydrogen or cause inadvertent leaks. It will also easily detonate with minimal confinement compared to other flammable gases. It burns with an almost invisible flame, so can be hard to see without proper detection systems that can identify hydrogen leaks and fires.

In terms of fire and explosion safety, hydrogen is not as safe as natural gas. It has a broader explosive range, is more prone to leaking, has a lower ignition energy level and can produce higher explosion over-pressures. Hydrogen is buoyant, disperses more easily and does not produce carbon containing combustion products such as carbon monoxide and carbon dioxide.

The Work Health and Safety Act 2011 (WHS Act) covers health and safety duties for substances, plant and structures. The Work Health and Safety Regulation 2011 (WHS Regulation) outlines specific safety obligations for hazardous chemicals. Hydrogen, whether compressed or liquefied, is classified as a hazardous chemical under workplace health and safety (WHS) laws. Hydrogen carriers like ammonia, hydrides and methylcyclohexane (MCH) are also classified as hazardous chemicals under WHS laws.


There are specific duties outlined in the WHS Act that apply to those who design, manufacture, import, supply, install, construct or commission plant or structures associated with hydrogen (a ‘substance’). These duties include:

  • carrying out any calculations, analysis, testing or examination that may be necessary for the performance of the duty imposed
  • giving adequate information to each person who is provided with the design such as results of any calculations, analysis, testing or examination, including any hazardous properties of the substance identified by testing
  • any conditions necessary to ensure that the plant or structure is without risks to health and safety when used.

Refer to sections 20–26A of the WHS Act for specific details about these duties.

WHS Regulation

Hydrogen is defined as a hazardous chemical under the WHS Regulation because it meets the criteria for a flammable gas under the Globally Harmonised System for classification and labelling of chemicals (GHS). Chapter 7, Part 7.1 Hazardous chemicals of the WHS Regulation provides the requirements for hydrogen and its storage and handling systems.

GHS hazard categories will include Flammable Gas Category 1A and gas under pressure (compressed or refrigerated liquefied gas depending on its state).

Note: Always check the hazardous chemical classification and hazard information from the manufacturer’s Safety Data Sheet (SDS).

Note: Hydrogen is classified as dangerous goods (Division 2.1 flammable gas) under the Australian Dangerous Goods Code (ADG Code) for transport purposes in Queensland. Hydrogen can be identified in the ADG Code under different UN numbers including UN1049 HYDROGEN COMPRESSED and UN1966 HYDROGEN, REFRIGERATED LIQUID.

Under the WHS Regulation, the quantity of hydrogen to be used, stored, or handled will determine the applicable duties applied. For example:

  • a storage and handling system with a water capacity exceeding 200 litres will trigger placarding (e.g. cylinder store)
  • storage and handling systems with an aggregate water capacity exceeding 5,000 litres will be a manifest quantity and trigger additional duties
  • storing above 5 tonnes will require notification to Workplace Health and Safety Queensland (WHSQ) and assessment as a possible major hazard facility
  • storing above 50 tonnes will trigger a major hazard facility licence requirement.

These regulatory requirements are further described below.

Any quantity of hydrogen will be subject to Part 7.1 Hazardous chemical requirements under the WHS Regulation. This includes obligations for importers and manufacturers of hydrogen requiring hazard classification under the GHS, correct packing in containers, container labelling and provision of a SDS.

There are obligations for suppliers of hydrogen and persons conducting a business or undertaking (PCBU) storing, handling, using and generating hydrogen. Safety obligations for a PCBU under Part 7.1 include:

  • labelling of containers and pipework and safety signage
  • providing access to SDS and inclusion in a hazardous chemicals register
  • managing risks to health and safety including review of control measures
  • identification of physical or chemical reaction
  • fire and explosion prevention including hazardous areas classification and management
  • fire protection and firefighting equipment
  • safety and emergency equipment
  • emergency plans
  • control of risks from storage and handling systems (e.g. cylinders, tanks, pressure vessels and associated pipework and fittings)
  • where applicable, provision of a manifest, and notification to WHSQ as a manifest quantity workplace (MQW) or possible major hazard facility (MHF), and submission of the emergency plan to the primary emergency services authority (e.g. Queensland Fire and Emergency Services (QFES)) for review. This applies to MQW & MHF as detailed below.

Further, WHS laws require certain plant to be registered. Pressure vessels used to store hydrogen may require design registration and plant item registration.

A manifest quantity workplace (MQW) stores, handles or uses hazardous chemical quantities that exceed or likely exceed the prescribed quantities in the regulation. The prescribed quantity for hydrogen is 5000 litres. A flammable gas placard is required for 200 litres or more of hydrogen in a storage area. Volume of product is expressed in terms of litres water capacity for the container (e.g. cylinder, bulk pressure vessel). MQW obligations include:

  1. Preparing a manifest (including site plan) for use by emergency services.
  2. Providing the emergency plan to QFES for review.
  3. Notifying WHSQ via Form 73 Notification of a manifest quantity workplace.

Major hazard facilities (MHF) store above threshold quantities of chemicals listed in schedule 15 of the Work Health and Safety Regulation 2011. Note: The quantity units of measure for Schedule 15 values are in tonnes.

  • A facility storing or handling more than 50 tonnes will be a MHF.
  • A facility storing or handling more than 5 tonnes is referred to as a possible MHF under the WHS Regulation and may be determined as a MHF after undergoing a determination process. Note: They are also referred to as “Hazardous Chemical Facility” under the Planning Act 2016. Refer to Planning laws below for more information.

MHF have specific safety requirements, including licensing, operator duties, risk identification and management, and implementing a safety management system. Form 69 Notification of a facility exceeding 10 per cent of Schedule 15 threshold is used to notify WHSQ of a possible MHF.

Chapter 12 of the WHS Regulation applies to the storage and handling of hydrogen even if it is not at a workplace or not being used for work. The duty holder has a primary duty of care and must:

  • apply due diligence
  • notify reportable incidents
  • preserve incident scenes.

If storing or handling more than 100 litres as the water capacity of the container/s of hydrogen at a non-workplace, specific hazardous chemical regulations under chapter 7 of the regulation apply.

A hazardous area is a three-dimensional space in which an explosive atmosphere is or may be expected to be present or form. As a flammable gas, hydrogen can generate hazardous areas.

Operators of facilities storing, handling or using hydrogen must take precautions (i.e. install, operate and maintain suitable risk control measures) to manage the risks to ensure the health and electrical safety for workers and community. For example, gas detection systems provide ways to monitor hydrogen leaks and fires. Where employed, how they interact with hazardous area design, and other fire safety systems, needs to be assessed and understood. WHSQ and the Electrical Safety Office (ESO) have regulatory oversight.

The Electrical Safety Act 2002 (ES Act), the Electrical Safety Regulation 2013 (ES Regulation), related codes of practice and referenced Australian Standards provide an electrical safety framework. This framework ensures electrical design, equipment, installations, use and maintenance of equipment/installations is performed safely. This includes situations where electrolysers use electricity to produce hydrogen and the fuel cells use the hydrogen to create electricity.

The ES Act places duties on designers of equipment and installations, manufacturers and importers and suppliers of equipment, installers of electrical equipment or installations, and users to ensure electrical safety is obtained and maintained.

The ES Act and ES Regulation requires that electrical work be performed by persons with an appropriate electrical work licence. If contracting for the performance of electrical work, then an electrical contractor licence is required.

Electrical installations must be electrically safe and comply with AS/NZS 3000 (the Wiring Rules).

Electrical equipment must be electrically safe and comply with AS/NZS 3820 Essential safety requirements of electrical equipment. Compliance with AS/NZS 3820 generally requires the equipment complies to the relevant Australian equipment safety standard. If there is no relevant Australian equipment safety standard, then apply the relevant IEC equipment safety standard, considering Australian conditions. Note: There will be situations that may require several equipment specific safety standards to be applied.

There are specific requirements for electrical equipment in a hazardous area including that such electrical equipment must be IECEx certified. The equipment must be rated for the relevant hazardous area classification and be installed in line with Australian Standards (e.g. AS/NZS 60079.14 Design selection, erection, and initial inspection) including effective earthing where required. Ignition risks must be adequately controlled. An accredited auditor must inspect electrical installations in hazardous areas prior to connection or reconnection. ESO oversees hazardous area accredited auditors.

Evaluation of what may be necessary to apply to verify electrical safety of installations and equipment is required to be undertaken by a competent person. It is important that a competent person undertakes a hazardous area classification to inform fire and explosion prevention measures for hydrogen.

Note: Where there are no prescriptive standards to follow in Queensland, professional engineering services must be performed by, or under the supervision of, a Registered Practicing Engineer Queensland (RPEQ) with appropriate expertise in the relevant discipline. Such engineering services may include for example, design and verification work of electrical equipment and installations.

The Petroleum and Gas (Production and Safety) Act 2004 and Petroleum and Gas (Safety) Regulation 2018 (collectively referred to as the P&G safety laws) apply when hydrogen is used, or intended to be used, as a fuel. Resources Safety and Health Queensland (RSHQ) administer this legislation.

The final draft of the Hydrogen safety code of practice (the Code) has been prepared to inform industry of current approval pathways and safety requirements for hydrogen when used as a fuel.

The Code aims to:

  • identify activities and facilities regulated by the P&G safety laws when hydrogen is used or intended to be used as a fuel gas
  • provide guidance on how to comply with the P&G safety laws
  • outline policy proposals for alternate means of achieving safe outcomes where current requirements are not achievable.

Further, licensing for working on hydrogen gas systems is administered by RSHQ. Gas device approvals (e.g. Type A and B gas devices) are available through approval authorities. Further information is available at RHSQ.

PCBUs have a duty to eliminate or reduce, so far as is reasonably practicable, risk to public safety from hazardous chemicals. Appropriately locating and designing a facility can significantly reduce the risks to community.

WHSQ is a technical referral agency under the Planning Act 2016 and Planning Regulation 2017 for hazardous chemical facilities (HCF) and other significant chemical stores. WHSQ provides advice to planning authorities on the appropriate location, conditions (if any) and acts to enforce those conditions to help reduce risk to the public.

A HCF is the use of a premises for a facility at which a prescribed hazardous chemical is present or likely to be present in a quantity that exceeds 10 per cent of the chemical’s threshold quantity under Schedule 15 of the WHS Regulation. This is the same prescribed quantity used to trigger notification as a possible MHF, under the WHS Act.

The Queensland Hydrogen Investor Toolkit is available to assist private sector proponents. It contains information on developing hydrogen projects and an overview of the planning laws in Queensland.

Queensland Hydrogen Industry Strategy

Hydrogen in Queensland

Queensland Hydrogen Investor Toolkit

Final Draft – Hydrogen safety code of practice

Resources Safety and Health Queensland- Petroleum and gas safety and health

Hydrogen safety regulation in Queensland

Renewable energy – Electrical safety and WHS

Managing risks of hazardous chemicals in the workplace code of practice 2021 (PDF, 1.21 MB)

Dangerous Goods Safety Guide – Storage, handling and production of hydrogen (Department of Mines, Industry Regulation and Safety, Western Australian Government)

Emergency planning under WHS laws

Fire and explosion risks

Electrical safety laws

Electrical licences

Equipment safety

Hazardous area classification

Hazardous areas under electrical safety laws

Accredited auditors under ES laws

Hazardous chemicals consultants

Notification requirements under WHS laws

Development approvals and planning legislation – WHSQ role

Board of Professional Engineers Queensland

Australian Standards for hydrogen (Note: This list is not exhaustive. Due to the evolving nature of this industry, new standards may be published or updated from time to time that are relevant to your storage and handling system and workplace that are not identified here. Several standards are provided as examples of what is available.)

  • AS22734: Hydrogen generators using water electrolysis – Industrial, commercial, and residential applications
  • AS16110.1 & 2: Hydrogen generators using fuel processing technologies
  • AS ISO 19881: Gaseous hydrogen – fuelling stations
  • AS ISO/TR 15916: Basic considerations for the safety of hydrogen systems
  • AS ISO 26142: Hydrogen detection apparatus- stationary applications
  • AS/NZS 60079.29.2 Gas detectors – Selection, installation, use and maintenance of detectors for flammable gases and oxygen
  • AS/NZS 60079.29.3 Gas detectors – Guidance on functional safety of fixed gas detection systems
  • AS/NZS 4641 Electrical equipment for detection of oxygen and other gases vapours at toxic levels – General requirements and test methods

In addition, electrical safety standards include:

  • AS/NZS 60079 series Explosive atmospheres
  • AS/NZS 3000 The Wiring Rules
  • AS/NZS 3820 Essential safety requirements of electrical equipment