For Maritime projects involving the fueling of new H2 ferries, CFC Section 2310 addresses Marine Motor Fuel-Dispensing Facilities, but this section appears to be primarily focused on liquid fuels, not gaseous fuels, and does not specifically address H2.  CFC Section 2309 on the other hand, addresses H2 Motor Fuel-Dispensing Facilities specifically, but appears to be focused primarily on land-based vehicles.  Are there any conflicts or issues with applying both of these sections to any future Marine H2 Motor-Fuel Dispensing Facilities? 

Neither section is a perfect fit for marine hydrogen fueling, but that is often the case with applying Codes. The most prudent approach is to draw from the most relevant provisions of both CFC Sections 2309 and 2310, disregarding requirements that clearly do not align with marine fueling practices. For example, CFC Section 2309 requires a vehicle to be parked on a concrete fueling pad—something impractical for marine craft. Until a dedicated hydrogen marine fueling section is developed, this “adapt and apply” approach is needed and mirrors how early hydrogen fueling stations were addressed before formal Code provisions existed.

That said, none of the codes currently referenced contain enough detail to safely design, operate, maintain, or install a marine hydrogen fueling system. Existing codes provide a starting point, but hydrogen introduces special requirements that must be evaluated. For maritime applications, starting references could include NFPA 2, API 520/521, and various Compressed Gas Association (CGA) standards, which can be adapted to address marine-specific needs.

Marine fueling also presents unique challenges compared to land-based vehicles, particularly when considering differences between high-pressure GH2 and LH2. These include changing fill and use locations, the need for longer fueling hoses, limited control of the fueling area at docks, increased corrosion risks, and vessel movement during fueling. Addressing these issues will require active involvement from maritime engineers in the codes and standards development process and review via a robust risk-based mitigation approach and hazard analysis.