Hydrogen projects - compliancy and conformity (C&C) study
A compliancy and conformity (C&C) study is a study to clarify which items need to be delivered by whom during the engineering and construction of the site in order to meet the legal requirements for a new (greenfield projects) or a modified installation (retrofit and brownfield projects).
It additionally provides insight into the statutory commissioning inspections that are required and who should and can carry them out. It also mentions for which documents a licensing authority should be contacted for approval and/or for consultation.
Thanks to this insight, it becomes transparent for the various stakeholders involved in compliance and conformity (such as the asset owner, EPC(m), subcontractors, government), with whom they should enter into a contractual connection for which scope (approval and/or inspection) in order to comply with applicable legislation.
Consequently, the outcome of this exercise is always client-specific and project-specific.
Important to understand the added value of the outcome of this exercise is the insight that the scope of a local legislation (such as e.g. an electrical inspection) changes depending on the approach to comply with CE legislation at assembly/composite level of the installation.
It follows, therefore, that it is wise to first clarify whether the final product will be marketed as an assembly or if not, it will be built directly in the plant on-site.
During this exercise, questions will be answered such as (not exhaustive):
- Will the finished product be marketed as an assembly with CE?
- Are there specific requirements applicable for the safe use of the finished product and are these taken into account by the manufacturer in his design?
- Does the manufacturer go for type approval or unit verification to complete his conformity procedure?
- If assembly is done on site, is it under the manufacturer's responsibility?
- Who is responsible for the on-site assembly of the installation and under which legislation will this be done? Are there different options in this and if so, what are they and what are the advantages and disadvantages of my choice?
- Who contracts the 3rd party inspector, the asset owner or the contractor, or possibly a subcontractor?
- Does the design need to be approved to comply with local environmental legislation or is an approval by e.g. a NoBo (if applicable), sufficient?
