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Tom McCrie
Hydrogen Infrastructure and Regulation Section
Department of Climate Change, Energy, the Environment and Water
Australian Government
GPO Box 3090
Canberra ACT 2601, Australia
To the Hydrogen Infrastructure and Regulation Section,
Re: National Hydrogen Regulatory Review (National Hydrogen Regulatory Guidebooks)
The Australian Hydrogen Council (AHC) welcomes this update to the National Hydrogen Regulatory Review and commends the Australian Government and the jurisdictions for collaborating on comprehensive guidebooks.
The AHC is the peak body for the hydrogen industry and our membership includes companies from across the value chain. Our members are at the forefront of Australia’s hydrogen industry, developing the technology, skills and partnerships necessary to ensure that hydrogen and its derivatives play a meaningful role in decarbonising and strengthening Australian industry.
We note that some of our members are responding directly to this consultation with the technical details and proposed amendments. We defer to their technical expertise and would instead like to take this opportunity to speak to the format of these Regulatory Guidebooks to maximise accessibility and use.
We value the extensive work done to collate these draft guidebooks but raise our concern that they may not be well utilised in their current format.
Although these draft guidebooks are comprehensive and substantial documents, nonetheless in their current format, it is difficult to see who the target audience is. Few parties will require this level of detail in this way, but most would benefit from a concise reference guide that can summarise the jurisdictional complexity and refer the reader to the details.[1] For example, it could be suggested that there are two key industry audiences: those that are already established in domestic hydrogen or gas markets, and those entering the Australian hydrogen market (local or international parties). The former would use the guidebooks to reference and reaffirm their established practice, and the latter requires accessible, practical, and digestible information to educate different stakeholders within their organisation. After several years of work in this space, the Australian Government has clear expertise in the sector and should strategically categorise the targeted users of the guidebooks, tailoring its presentation for that audience. In its current broad and lengthy form, the guidebooks run the risk of underutilisation.
Therefore, we would recommend the guidebooks be recut into a framework based on how the information will be used. This may translate to an interface dedicated to user experience, that is, an online tool with search capabilities and navigation menus rather than an extensive document.[2]
It is key that the guidebooks are communicated in a way that is highly approachable, easy to navigate online, and, most importantly, remains accurate. The more detail that goes into them increases the necessity to keep the information current. Therefore, it is concerning that the guidebooks mention no requirement for periodic or ongoing review to maintain the accuracy. If this remains the approach, we suggest that this central database should point to each location that the relevant information is kept updated.
Given these concerns and the original objective to be non-binding, it should be explicitly stated that the guidebooks (or compliance with them) should not be referred to in any legal context or be the basis for compliance enforcement, such as for contractual requirements or funding arrangements.
Recommendations
- The Australian Government needs to clarify the audience for the Regulatory Guidebooks and tailor the user experience based on how that party will use the information.
- Recut the Regulatory Guidebooks into a concise reference guide or online tool based on the needs of the identified audience.
- The Regulatory Guidebooks must be kept updated and accurate. If this is not feasible, it is paramount that reader knows where to find current information.
- The Regulatory Guidebooks should explicitly state that they cannot be used in a legal context (such as compliance for contractual requirements or funding arrangements) in lieu of the original laws.
We would be delighted to be involved in the next stage of development of the Regulatory Guidebooks into a streamlined reference tool that best stewards hydrogen parties through the relevant processes. We invite the Australian Government to utilise the AHC and its diverse membership in cocreation and testing of this product.
We look forward to engaging with you further through this process.
If you wish to discuss any element of this submission, please contact me at [email protected].
Kind Regards,
Natasha Cerexhe
Policy Manager
Australian Hydrogen Council
[1] The existing guides in Western Australia and Queensland were mentioned as useful models of reference documents: Department of Energy, Mines, Industry Regulation and Safety (2024) Dangerous Goods Safety Guide: Storage, handling and production of hydrogen, June, https://www.worksafe.wa.gov.au/system/files/documents/2025-01/DGS_HydrogenGuide.pdf and
Resources Safety & Health Queensland (2025) Hydrogen Safety Code of Practice, version 2.0, July, https://www.rshq.qld.gov.au/__data/assets/pdf_file/0003/1746453/Hydrogen-Safety-Code-of-Practice.pdf
[2] For example, a searchable interface for specific uses: CSIRO (2025) Hydrogen Refuelling Station, Standards Australia, https://research.csiro.au/hylearning/hystandards/hydrogen-refuelling-station/.