According to hydrogen transport technology provider H2C Safety Pipe (H2CSP), the law closes a previous regulatory gap. State-level safety oversight of pure hydrogen pipelines outside the jurisdiction of the California Public Utilities Commission (CPUC) had not been clearly regulated. Operators had largely relied on rules originally developed for natural gas pipelines.
New requirements for materials, leakage minimization and monitoringThe SB 804 law requires pipeline operators to design and build hydrogen pipelines in such a way that leakage is reduced to the lowest level technically achievable. The materials used must be chemically compatible with hydrogen and demonstrate resistance to hydrogen-induced damage, including corrosion and embrittlement. In addition, the law mandates continuous measurement and monitoring systems capable of detecting deviations from normal operation early and in real time.
Operators and owners must keep operational records of hydrogen concentrations and confirmed leaks. They are required to report annually to the California Office of the State Fire Marshal on compliance. This agency takes over statewide oversight. Existing CPUC responsibilities for the utilities it regulates remain in place. In the event of conflicts between the new standards and CPUC regulations, the provision offering the higher level of protection applies.
California is thus one of the first jurisdictions with a dedicated safety law for hydrogen pipelines. In Europe, comparable technical requirements have so far been covered primarily by standards and technical codes, for example by DVGW code of practice documents (DVGW-Arbeitsblätter) issued by the German Technical and Scientific Association for Gas and Water. How stringent the California requirements will prove in practice depends on implementing regulations from the State Fire Marshal, which are still pending. Continuous measurement and monitoring in particular could become a sticking point.
Political support from Democrats and Republicans
“California has the opportunity to lead the United States and the world in the safe development of hydrogen infrastructure,” said State Senator Bob Archuleta. “SB 804 gives us the tools to do so.” The senator has chaired the Select Committee on Hydrogen Energy since 2021.
According to Robert M. Hertzberg, former Speaker of the California State Assembly and former Majority Leader of the California Senate as well as a member of the H2C Safety Pipe board of directors, there is broad support for the law: “Labor unions, environmental organizations and business representatives jointly advocated for the law, and both Democrats and Republicans voted unanimously in favor of it in both chambers.”
Pipe-in-pipe system intended to deliver especially high safety, but not mandated
The Santa Barbara-based company H2C Safety Pipe welcomes the law. It is developing a safety pipe technology that, according to its own statements, aligns with the principles enshrined in the law. The company relies on a pipe-in-pipe system: a hydrogen-carrying inner pipe made of composite material is installed within an outer safety pipe that serves as a secondary containment barrier. The annular space between the two pipes is purged with an inert gas and monitored using hydrogen sensors. However, such a design is not explicitly mandated by the law.
“From our perspective, what is particularly noteworthy about SB 804 is that the regulatory framework has evolved in the same direction as the technology H2C Safety Pipe has been working on for years,” said Martin L. Adams, board member of H2CSP and former General Manager and Chief Engineer of the Los Angeles Department of Water and Power.
Robert H. Shelton, President and CEO of H2CSP, sees the law as a possible model for requirements in other US states and beyond. However, the starting situation in Europe is different. There, many natural gas pipelines are to be repurposed as hydrogen pipelines. Whether existing steels could meet material requirements along California’s lines remains an open question.
