Generator Starting Batteries

Q: I’m getting conflicting answers as to when generator batteries need to be replaced. Some say in a hospital they need to be replaced every 5 years unless the hospital is a trauma center then it is every 3 years. I have also been told that it doesn’t matter if it is a trauma center; hospital or nursing home; the batteries need to be replaced every 3 years. Can you please tell me what is correct?

A: The correct answer as to how often generator starting batteries need to be replaced in hospitals depends on which authority having jurisdiction you’re talking to. That may be why you are receiving conflicting answers. The typical hospital has 5 or 6 different authorities having jurisdiction (AHJ) that enforce the Life Safety Code:

  • CMS                                             (Medicare/Medicaid)
  • Accreditation Organization    (i.e. Joint Commission)
  • State health department
  • State fire marshal
  • Local fire inspector
  • Insurance company

Any one of these AHJs may have a requirement for testing/inspection/replacement of generator starting batteries that the other AHJs may not have. The hospital would have to comply with the most restrictive.

First… I cannot find any specific requirements in the NFPA codes and standards for generator starting batteries to be replaced at a different frequency if the generator serves a trauma center or not. But the hospital’s state or local AHJ may have a specific requirement that addresses trauma centers that I am not aware of.

Second… According to NFPA 110-2010, the hospital is required to replace lead-acid batteries used for generator starting every 24 – 30 months. This would be enforced by the CMS standards and the accreditation organization (AO) standards. This is found in the Annex section A.5.6.4.5.1 of NFPA 110-2010, and CMS and the AOs usually (not always) enforces the Annex section requirements of the NFPA standards.

I checked the 1999 edition of NFPA 110 and the Annex section in that edition recommended replacing the batteries every 24 – 30 months, so I don’t see anything in current or past NFPA standards that would support your 5-year frequency to replace generator starting batteries.

NFPA 101-2012 Life Safety Code requires all healthcare occupancies and ambulatory healthcare occupancies to comply with NFPA 110-2010, so this means all hospitals, nursing homes, and trauma centers, would have to have their generator starting lead-acid batteries replaced every 24 – 30 months, according to CMS and AO standards.

I suggest you contact the hospital’s state and local authorities to determine if they have more restrictive requirements.

Generator Annual Load Test

Q: My client installed a generator in a Phase 1 project that does not and will not for some time be able to meet the requirements for the 30% load during the monthly test due to low current loading. As I understand it, 8.4.2.3 in NFPA 110 allows you to do the monthly test as is and do a supplemental annual test yearly as outlined which would then meet the requirement for the monthly test. Is that the proper interpretation as the generator will not meet the 30% requirement until some unknown future date?

A: Yes… section 8.4.2.3 of NFPA 110-2010 is the correct reference when any one of the monthly tests cannot meet the requirement for at least a 30% load. The annual test must be conducted within 12 months of the first monthly test that was incapable of meeting the 30% load requirement, and then no more than 12 months from the last annual load test.

Your client should continue to conduct the monthly load tests (not less than 20 days and not more than 40 days) with the available load. For the annual load test, a supplemental load (i.e. load bank) of not less than 50% of the nameplate kW rating for 30-minutes and a supplemental load of 75% of the nameplate kW rating for 60-minutes must be conducted, for a total test of 90 continuous minutes.

The cool-down period for the generator is not part of this 90-minute test.

Generator Testing

Q: Does our hospital have to test the generator for 30 minutes every week, and then 1-hour once a month? We have programmed our generators to operate every Wednesday at 12 noon and run for 30 minutes. We do ATS test once a month and record information when running.

A: According to section 9.1.3.1 of the 2012 Life Safety Code, emergency power generators must be tested in accordance with NFPA 110. Section 8.1.1 of NFPA 110-2010 says the routine testing of the emergency power generators must be based on all of the following:

  • Manufacturer’s recommendations
  • Instruction manuals
  • The requirements of NFPA 110
  • The AHJ’s requirements

While NFPA 110 does not have any requirements to operate the generator on a weekly basis, there may be manufacturer requirements or AHJ requirements that do. Section 8.4.1 of NFPA 110-2010 specifically says generators must be inspected weekly but operated under load on a monthly basis. Section 8.4.2 requires the monthly load test to operate for 30 minutes. I suggest you check with your generator manufacturer and your state and local AHJs to see if they have specific weekly run-tests of the generator.

Generator Fuel Testing

Q: What are the guidelines on the diesel fuel test for the generator as far as having it treated or a sample sent off for testing?

A: The new 2012 Life Safety Code references the 2010 edition of NFPA 110, the standard for emergency and standby power systems. Section 8.3.8 of the NFPA 110-2010 requires the fuel for the generators to be tested annually for quality. According to more recent editions of NFPA 110, this test is to be conducted in accordance with ASTM D975, Standard Specification for Diesel Fuel Oils. You may purchase a copy of the standard direct for the ASTM website https://www.astm.org/Standards/D975.htm

Generator Testing

Q: We have a generator that doesn’t meet the 30% load for the monthly run so we have to do an annual run with the load at 50% for 30 min and 75% for 60 min for a 90-minute continuous run. Our contractor did the annual run but he ran it with 52 % for 30 min , 75% for 30 min and 81% for 30 min, then he continued to run it for 2½ more hours dropping the percentages as he went for 4 continuous hours at not less than 30%. My question is does these meet the intent of the standards for both an annual and a 3-year load test?

A: Yes… I would say the test as you described meets both the annual requirements and the 3-year test requirements. The generator load testing requirements are minimum load settings, and it is permitted to exceed these minimums.

Generator Testing

Q: In a business occupancy and an ambulatory occupancy do we need to test our generator on load each month or can we do a load bank test once per year?

A: Yes… Monthly load tests are required for emergency power generators at ambulatory healthcare occupancies and business occupancies. According to the 2012 Life Safety Code, sections 20/21.5.1.1 for ambulatory healthcare occupancies and 38/39.5.1 for business occupancies, compliance with section 9.1 on utilities is required (just like healthcare occupancies).

Section 9.1.3 requires compliance with NFPA 110-2010 regarding emergency power generators, and section 8.4.1 of NFPA 110 requires monthly load tests.

Now… there is an exception to all of these testing requirements…. Section 9.1.3 says emergency generators, where required for compliance by the LSC, must be tested and maintained in accordance with NFPA 110-2010. So, if you are not required to have emergency power generators at the ambulatory healthcare occupancy or the business occupancy, then you do not have to maintain them according to NFPA 110.

Generator Testing at Business Occupancies

Q: Does a diesel generator that is located in a business occupancy require the same testing frequencies as the one at our hospital requires?

A: It depends if the generator is required by the Life Safety Code. Sections 38/39.5.1 of the 2012 Life Safety Code says utilities in business occupancies must comply with section 9.1. Section 9.1.3 says emergency generators, where required for compliance with the Life Safety code, must be tested and maintained in accordance with NFPA 110, which is the same standard requirement for healthcare occupancies.

So, the question now becomes, is the generator in your business occupancy required by the LSC? Business occupancies do not automatically require emergency power like healthcare occupancies do. For business occupancies, it depends on a variety of issues.

For new business occupancies, emergency lighting is required where any one of the following is met:

  • The building is two or more stories in height above the level of exit discharge;
  • The occupancy is subject to 50 or more occupants above or below the level of exit discharge;
  • The occupancy is subject to 300 or more total occupants.

For existing business occupancies, emergency lighting is required where any one of the following is met:

  • The building is two or more stories in height above the level of exit discharge;
  • The occupancy is subject to 100 or more occupants above or below the level of exit discharge;
  • The occupancy is subject to 1000 or more total occupants.

When emergency lighting is required it must meet the requirements of section 7.9 of the 2012 Life Safety Code. Section 7.9 does not mandate that emergency lighting be powered by a generator, but section 7.9.2.4 does say if the emergency lighting is powered by generators, then the generators must be tested and maintained in accordance with NFPA 110.

So, if your business occupancies are required to provide emergency lighting, and the emergency lighting is powered by generators, then the generator must be tested and maintained in accordance with NFPA 110, which is the same requirement as hospitals.

Emergency Lights in Generator Rooms

Q: In regards to emergency generator backup lights, I seek clarity how long does the battery have to last? I’m assuming that the battery should be able to be tested annually for 90 minutes like those inside my hospital.

A: Section 7.9.3 of the 2012 LSC is clear: All required battery powered emergency lights must be tested monthly for 30 seconds and annually for 90 minutes. The NFPA 110 requires a battery powered emergency light in the generator room, so it is a required light that needs monthly and annual testing.

The code requires the light to operate for 90 minutes.

Generator Batteries

Q: Recently I attended a meeting with our State Fire Marshall Department. One item which became a HOT topic of discussion was the monthly Specific gravity testing of the battery used to start up the generator. The Federal Regulation states that the cap should be unscrewed and then tested. Batteries are now sealed. The Fire Marshall’s response was that you peal off the sticker then pry the caps off. This triggers all kinds of issues, from a safety issue for employees to warrantees on the batteries. There are 3 battery monitoring procedures. 1. The annunciator for the generator monitors Low Battery and Low Charge. 2. Weekly monitoring of the 30 min test. 3. Monthly Load Testing I contend that this should be enough to support the monthly checking “Specific Gravity” checking. How do you see this to be?

A: What you’re referring to are newer style batteries that are sealed, and access to the electrolyte is not available, or necessary. But it really doesn’t matter what you contend or what I contend… it only matters what the State Fire Marshall will allow. It appears that they insist on specific gravity tests (i.e. electrolyte levels) so that is what you must do. You make a good case that opening a sealed battery is dangerous and voids the warranty of the battery. But NFPA 110-1999 Annex section A-6-3.6 says the specific gravity in the batteries must be recorded on a weekly basis.

However, section 1-4 of the same document does say that nothing in the document is intended to prevent the use of systems of equivalent or superior quality. You make a good point that the newer style sealed batteries are better than the older style that have caps and access to the electrolyte levels. One could argue that they are better than the older style. But this must be approved by the AHJ, which in this case is the fire marshal. Present a written plan to the fire marshal’s office and see if they will approve your plan to use sealed lead-acid batteries. Make sure it identifies the hardship, both financial and safety risk to staff, in using the older style batteries.

If they do not approve your plan, then I see no other choice that you have to purchase lead-acid batteries that has access to test the electrolyte levels as required by the AHJ. They are the authority and if you want their approval, then you have to do what they say. It is their prerogative to interpret the standards the way they see fit.

Engine Block Heaters

Q: A consultant told me that emergency generator rooms are required to be maintained at least 40 degrees F. Do I need to maintain that temperature if I have block heaters on the engine?

A: Yes, you do need to maintain at least 40° F ambient room temperature especially when you have engine water jacket heaters that maintains the temperature of the engine water at a minimum of 90° F. Section 5-6.7 of NFPA 110 (1999 edition) clearly states that the emergency power supply (EPS) room temperature must be at least 70° F unless you have water jacket heaters that maintains the water temperature of the engine at 90°F; then you are allowed to lower the EPS room temperature to 40°F. So, this would mean the room needs to be maintained at a minimum of 40°F.