DOT Gap Analysis Revisited
Karen Hall, National Hydrogen Association

DOT has offered an opportunity to provide feedback on the DOT Report: "Hydrogen Infrastructure Safety Technical Assessment and Research Results Gap Analysis." To access this report, please click here.

Clearly DOT spent a lot of time on the report, and talked with many experts. The NHA certainly appreciates the need to look at potential gaps to ensure that existing regulations, or the lack of them, don't result in unanticipated delays in commercialization of hydrogen energy systems. In fact, the NHA has recently started a series of articles in the Hydrogen and Fuel Cell Safety Report to begin a dialog with industry, government, and SDOs/CDOs to identify gaps in the standards activities, and ensure the existing activities fully meet the needs of the end users and regulators.

The NHA Codes and Standards Steering Committee is a small group of NHA members and experts that represent the broadest spectrum of hydrogen producers, suppliers, and users. Each Steering Committee member, therefore, has interests in some aspects of the report. The Steering Committee has decided to spend a bit of time to address their areas of interest, consulting with industry peers, in order to provide their sector's list of key issues, with sufficient background and justification. In this way, the NHA hopes to put together a report that includes a comprehensive list of issues and recommendations that DOT can use as it moves forward.

We are interested in working with all stakeholders, including readers of the Hydrogen and Fuel Cell Safety Report, the USFCC, and other members of the National Coordinating Committee to provide concise and useful feedback. Please feel free to contact me with any input your organization may have based on the DOT report.

Our goal is to have input from the Steering Committee in advance of our next telecon, scheduled for July 18. We would then review what we have, and begin to put it together in a report. We are hoping to be able to provide that to DOT no later than the next In-Person meeting of the National Codes & Standards Coordinating Committee - which is tentatively being planned for the second half of September in conjunction with the ICC Public Code Hearings in Lake Buena Vista, Florida.

I am confident that the final result will be more useful to DOT and the hydrogen industry as we all move closer to a hydrogen energy economy.