May 29 2017

Emergency Lights in Generator Rooms

Category: Emergency Lights,Generators,Questions and AnswersBKeyes @ 12:00 am

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.

Jan 21 2016

Generator Batteries

Category: Generators,Questions and AnswersBKeyes @ 12:00 am

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.

Mar 09 2015

Engine Block Heaters

Category: Generators,Questions and AnswersBKeyes @ 6:00 am

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.

Dec 22 2014

NFPA 110

Category: Generators,LSC,Questions and AnswersBKeyes @ 6:00 am

Q: Which edition of NFPA 110 are we expected to follow? I read that we’re expected to comply with the 1999 edition, the 2005 edition and now the 2010 edition. Which is correct?

A: The 2000 Life Safety Code references the 1999 edition of NFPA 110. The 1999 edition of NFPA 99 also references the 1999 edition of NFPA 110. Since CMS is still on the 2000 LSC, then the 1999 edition of NFPA 110 governs. However, Joint Commission standards references the 2005 edition of NFPA 110 for the 3-year, 4-hour load test, because this load test is not required in the 1999 edition of NFPA 110. Apparently, the accreditor feels the 3-year, 4-hour load test has value and wants their clients to comply with the load test. Joint Commission can do this since the addition of the 3-year, 4-hour load test is not in difference to the 1999 edition of NFPA 110; it is just an addition, so CMS allows it. HFAP and DNV have written similar standards that reference the 3-year, 4-hour load test found in the 2005 edition of NFPA 110.

But last year, CMS issued categorical waivers in their S&C memo 13-58 that will permit hospitals, critical access hospitals, long-term care facilities, ambulatory surgical centers, and inpatient hospices to use the provisions found in the 2010 edition of NFPA 110 immediately without waiting for the new LSC to be adopted. The 2010 edition of NFPA 110 will allow you to reduce the annual load test from 2-hours down to 90-minutes when the monthly load tests do not meet the 30% load capacity of the nameplate value. All of the accreditation organizations recognize and support this CMS position, but be aware that some state agencies do not.

The 2010 edition of the NFPA 110 is referenced by the 2012 edition of the Life Safety Code and will become the rule once the 2012 LSC is adopted. So, for the most part, the 1999 edition of NFPA 110 is the one to use, unless you’re Joint Commission or HFAP accredited, then you must also follow the 2005 edition of NFPA 110 for the 3-year, 4-hour load test. Also, you have the option to use the 2010 edition of NFPA 110 for the annual load test through the use of the CMS categorical waivers. Sounds confusing, but everyone will be on the 2010 edition of NFPA 110 once CMS adopts the 2012 edition of the LSC.

To download your own copy of the CMS S&C memos, go to:

Jun 23 2014

Storage in Generator Rooms

Category: Generators,Questions and Answers,StorageBKeyes @ 5:00 am

Q: I cannot find a code reference that prohibits storage in the generator enclosure. Is there a specific reference for this in the 2000 edition of the Life Safety Code?

A: Sections 19.5.1 and 9.1.3 of the Life Safety Code (2000 edition) references NFPA 110 Standard for Emergency and Standby Power Systems, 1999 edition, section 5-2.1, which requires the generator to be installed in a separate room for Level 1 installations, which applies to hospitals. NFPA 110 does require a minimum 2-hour fire rating or the generator must be located in an adequate enclosure located outside of the building capable of resisting the entrance of snow and rain at a maximum wind velocity required by local building codes. No other equipment, including architectural appurtenances, except those that serve this space, is permitted in this room. In addition, section 5-2.2 of NFPA 110 does not allow generators to be installed in the same room where normal electrical equipment service is installed. These two sections are being interpreted by many national authorities whereby absolutely nothing is allowed in the same room as the generator. The good news (if there is any), the most recent edition of NFPA 110 (2010 edition) does allow small repair parts, tools and manuals in this generator room, but that edition will not be part of our accreditation process until CMS adopts the 2012 edition of the Life Safety Code. So for now, we must comply with the 1999 edition of NFPA 110.

May 05 2014

Fire Protection of Equipment Rooms

Q: What is the fire rating supposed to be in the walls of the hospital equipment rooms, such as the generator room, boiler room, chiller rooms, and electrical rooms? We have a disagreement as to what is required and your answer decides who is correct.

A: According to NFPA 110 (1999), section 5-2.1, generator rooms are required to have 2-hour fire rated barriers that protects the room from fire outside the room. Any 2-hour fire rated barrier is required to have 90-minute fire rated doors and frame and if there are any HVAC duct penetrations through the 2-hour barrier, then the HVAC duct opening needs to be protected in accordance with NFPA 90A Standard for the Installation of Air-Conditioning and Ventilating System, which would require a 90-minute fire damper. A boiler room is considered a hazardous area, and according to the 2000 edition of the LSC, sections 18/, the hazardous area is required to be protected with 1-hour fire rated barriers if it is considered new construction, or 1-hour barriers if it is considered existing and is not protected with sprinklers. Existing boiler rooms that are protected with sprinklers only require smoke resistant walls. All door openings in a 1-hour barrier are required to be ¾ hour fire rated, with fire rated frames. However, unlike the 2-hour barrier, a 1-hour fire rated barrier for a hazardous area is not required to have any fire dampers in a HVAC duct penetration, unless the HVAC penetration is not fully ducted. Electrical rooms typically are not required by the LSC to have fire rated barriers (walls), however NFPA 13 (1999 edition) Standard for the Installation of Sprinkler Systems, section 5-13.11 does permit an electrical room to be protected with 2-hour fire rated barriers in lieu of being protected with sprinklers. Therefore if the room does have fire rated barriers for any reason (including local or state building codes) then it would need fire dampers in the HVAC duct penetration if it is 2-hour fire rated or greater. Chiller rooms typically do not require fire rated barriers, unless the chillers are fuel-fired, then they would require the same protection as the boilers. As always, please check with your local and state authorities to determine if there are other regulations that may affect this situation.

Good Luck!

Jan 27 2014

Enclosures for Emergency Generators

Category: Fire Rated Barriers,Generators,Questions and AnswersBKeyes @ 6:00 am

Q: Do emergency power generators have to be located in a room by themselves? We have a generator that is located in a mechanical room which is shared with an air-handler, condensate pumps and other equipment. This generator was installed in the 1970’s, but a consultant told us we had to relocate the generator to a 2-hour room where it can be located by itself.

A: NFPA 110 (1999 edition), section 5-2.1 says the generator must be installed in a separate room with a 2-hour fire rating, and no other equipment is permitted in the room. However, section 1-3 of the same standard says NFPA 110 only applies to new installations and existing systems are not required to conform to the standards, unless the authority having jurisdiction (AHJ) determines that nonconformity presents a distinct hazard to life. If the generator has been installed since the 1970’s and no AHJ has cited you for nonconformity, then I suggest it is safe to assume the AHJs that have inspected your facility do not have a problem with the arrangement. If an AHJ attempts to cite this situation for non-compliance with NFPA 110 (1999 edition) section 5-2.1, then I would make the case that it is not required to since this room was constructed long before NFPA 110 was in existence. NFPA 110 was first adopted in 1984 by NFPA, so it was not part of the Life Safety Code until probably the 1985 edition.  Therefore, it may be assumed it met the standards that were in existence in the 1970’s when the building was constructed.

Mar 25 2013

Generator Load Tests

Category: Generators,Questions and Answers,TestingBKeyes @ 5:00 am

Q: Is it allowed to combine the 3-year 4-hour generator load test along with the annual 2-hour load test? Our generator test company plans on running the generator at 50% load for the first two hours and then elevate to 75% load for the last two hours. In your opinion would this satisfy both the 2 hour and the 4 hour load test?

A: You are allowed to combine the 2-hour load test and the 4-hour load test. The 2-hour load test is required to be conducted once per year when the generator cannot meet the load test of 30% of nameplate rating every month. When this occurs, you still conduct the monthly load tests but once per year you need to conduct a 2-hour load test (usually by connecting the generator to a resistive load bank) that consists of the following sequences:

  • 25% load for 30 minutes, then
  • 50% load for 30 minutes, then
  • 75% load for 60 minutes for 2 continuous hours.

The scenario that you described allowed 50% load for the first two hours and then a 75% load for the last two hours. This would be acceptable in meeting both test requirements since the percentages listed in the standards are minimum settings, and you are permitted to exceed them. But you need to be careful, because if you combine these two tests and start out at 25% load (as required for the 2-hour load test) for the first 30 minutes, then you are out of compliance with the 4-hour test, unless you run an extra 30 minutes after you reach or exceed 30%.


Oct 15 2012

Circuit Breaker Testing

Category: Generators,Questions and Answers,TestingBKeyes @ 5:00 am

Q: During a recent survey, the inspector cited us for not exercising our circuit breakers downstream of our generator. Does the LSC require annual exercising of all circuit breakers between the generator and the connected load?

A: The LSC section 9.1.3 does require emergency power generators to comply with NFPA 110 Standard for Emergency and Standby Power Systems, 1999 edition. Section 6-4.6 of NFPA 110 requires the main and feed circuit breakers between the generator and the transfer switch terminals to be exercised annually with the generator in the off position. This appears to me that all emergency source circuit breakers are required to be exercised annually.  This would include the generator output breaker and all downstream distribution breakers, up to and including any breakers that feed the emergency feed side of the automatic transfer switch (ATS).  I believe that would exclude any loads connected to the load side of the ATS such as motors, lights, pumps, etc.  The process is a simple one because all affected breakers are normally in a de-energized state. I do not recall ever seeing a reason for this procedure published, although I’m sure there is a good reason.  In my experience though, breakers that are not exercised regularly can be extremely (if not impossible) to reset, even though the internal trip mechanism may work perfectly. This may lead an organization to not conduct this annual test, which may result in them being cited for noncompliance. Some organizations will purchase replacement circuit breakers and have them available on a shelf in case the breaker will not reset. While this is a very proactive approach to testing and a quick response to potential repairs, it can be rather costly as the large current breakers are a bit pricey. While this issue may not come up very often during a survey, it is a LSC requirement and the surveyor has the obligation to cite the issue if he or she sees it as being noncompliant.

Sep 01 2011

Combined load tests on generators

Category: Generators,Questions and AnswersBKeyes @ 8:34 pm

Q: The AHJs who inspect my hospital require that I conduct a three-year, four-hour load test, which we do simultaneously with our annual load bank test. One AHJ says this is acceptable while another AHJ doesn’t like it and says the annual load test is required to be conducted at varying loads of 25%, 50%, and 75%, and the three-year test is required to be conducted at 30% load. Which one is correct, and where do I find the standards for this testing requirement?

A: Both The Joint Commission and CMS require the three-year, four-hour generator load test, which was introduced in the 2005 edition of NFPA 110, Emergency and Standby Power Systems. This test was further explained in the following 2010 edition of the same NFPA 110 standard. Section 8.4.9 of NFPA 110 requires the three-year test to be conducted at 30% of the nameplate rating of the generator for four continuous hours. The annual load test is only required when the monthly load tests cannot meet the 30% nameplate rating capacity. The annual load test is required to operate the generator at 25% capacity for 30 minutes, 50% capacity for 30 minutes and 75% capacity for 60 minutes for 2 continuous hours. If you combined these two load tests, then the one AHJ is correct; 25% capacity is not equal to 30% capacity for the first 30 minutes of the load test, and that AHJ would be correct for refusing to accept this combined test as evidence of meeting the three-year, four-hour load test. An easy solution to this would be to operate the first 30 minutes of the combined test at 30% capacity, as the load values given are minimum values and may be exceeded.

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