These two definitions can produce very different results in the assessment of the technologies. For example, when considering the overall chain, the choice of a methanol combustion engine could be better than that of a battery-electric drive. This is the case if the production of the battery causes more emissions than the combustion of methanol. It is important to note that this type of consideration is also different for each ship and depends on its operating time and energy requirements.
Regulations
ES-TRIN
Under the ES-TRIN 2025 framework, derogations would only be necessary in case of solutions for methanol storage and engine room design technically deviating from the requirements laid down in Chapter 30 (in particular risk assessment and safety organisation), Annex 8, Section II, Chapter 2 (fuel storage methanol) and Annex 8, Section III, Chapter 3 (engine room design methanol).
ADN
Methanol propulsion systems in compliance with the requirements of ES-TRIN 2025 are covered by the general exemptions of paragraphs 7.1.3.31 (use of engines) and 9.x.0.31 (rules for construction), meaning that a separate derogation in accordance with section 1.5.3 of the ADN would not be necessary.
However, for methanol propulsion systems benefitting from a derogation under the ES-TRIN framework, an additional derogation under the ADN framework would be required for vessels intended to carry dangerous goods.
Methanol, UN 1230, is permitted to be carried in tank vessels as cargo in type N tank vessels, closed, integral cargo tank, water-spray system. Methanol is assigned to temperature class T2 and explosion group IIA, anti-explosion protection is required.
Passenger Vessels
There are no specific requirements applicable to passenger vessels with methanol propulsion systems, however, the presence of passengers on board has to be taken into account in the risk assessment to be performed in compliance with Article 30.04 of the ES-TRIN.
IMO Rules
For seagoing ships, the IMO Circular 1621 “Interim guidelines for the safety of ships using methyl/ethyl alcohol as fuel” contain functional requirements for all appliances and arrangements. Currently, the introduction of methanol and hydrogen internal combustion engines for the inland waterway sector faces on major barrier: so far, methanol and hydrogen have not yet been included as reference fuels in the NRMM directive. This means for the OEM that it is not allowed to bring these engines on the market.