May 29 2014

Generator Rooms

Category: BlogBKeyes @ 5:00 am

imagesCA0CNZZFNFPA 110 (1999 edition) requires generators to be located in a dedicated room, separated from all other areas and spaces by 2-hour fire rated barriers. NFPA 110 is very clear that nothing else may be located, stored or mounted inside the generator room, which includes normal power distribution equipment.

NFPA 110 (1999 edition) does say it is not a retro-active code, meaning existing conditions may remain except where the authority having jurisdiction determines that nonconformity presents a distinct hazard to life. This is the catch for most national authorities for healthcare applications. The concern is if a generator shares a room with other mechanical equipment, and the other mechanical equipment causes a fire that disables the contents of the room, then the generator is out of service, or at least compromised. Since emergency power is critically important to sustain life in hospitals, most national AHJs are evoking that clause and requiring existing generator rooms to meet the full requirements of NFPA 110 (1999 edition).

Keep in mind, the whole purpose of that 2-hour fire rated barrier separating the generator from the rest of the hospital, is to protect the generator from the rest of the hospital; not to protect the hospital from the generator. The conventional wisdom is, if a fire starts on the outside of the generator room, the generators will operate for 2-hours before the fire breaks through. That should be enough time for the firemen to extinguish the fire and to evacuate the building, if need be.

So, nothing may be stored in the generator room, but NFPA 110 does permit the following emergency power supply system equipment in the generator room:

  • Energy converter (generator)
  • Day tank of fuel
  • Support equipment for the room (HVAC equipment, lighting equipment, etc.)
  • Conductors
  • Disconnecting means
  • Overcurrent protective devices
  • Transfer switches
  • Control devices
  • Supervisory devices
  • Support devices needed for the system to operate as a safe and reliable source of electric power

 The last term (support devices) can be interpreted to include necessary manuals and tools to safely operate the generator, but does not include tools to perform repairs, repair parts, discarded materials, replacement filters and oil.

Battery powered emergency lights are required in the room, connected to the load side of the transfer switch, whereby the lights will illuminate during a normal power outage. The room must be maintained to a temperature of not less than 70°F, unless the generator is equipped with a water jacket heater that maintains the engine temperature at 90°F. Where the generator is equipped with a water jacket heater, the room must be maintained at a temperature of not less than 40°F.

imagesF3QUS2EBThe amount of fuel required to be stored onsite for the generator is based on the amount of run-time. For generators located in seismic risk areas designated as Zone 3 or Zone 4 of the Uniform Building Code (see map, or Google ‘UBC Seismic Risk Map”), a minimum of 96 hours of fuel supply is required to be stored onsite. For generators not located in seismic risk areas Zone 3 or Zone 4, 26 hours of fuel supply is required.


Mar 13 2014

Fire Alarm Monitoring of the Generator

Category: BlogBKeyes @ 6:00 am

imagesFWTL2IM2Does your fire alarm system monitor the emergency power generator? It may have to. Section 1-5.8.7 of NFPA 72 (1999) requires the fire alarm system to monitor the primary and secondary power supplies for the presence of voltage at the point of connection to the fire alarm system. Failure to monitor either connected power supply should result in a ‘Trouble’ signal. Under normal power conditions, the emergency power from the generator is not connected, and therefore is not monitored. But when the emergency power is connected, it must be monitored, according to NFPA 72. However, there is an exception to 1-5.8.7 that says:

“The power supply of an engine-driven generator that is part of the secondary power supply, provided the generator is tested weekly in accordance with chapter 7”.

So, that means if the generator is tested weekly, then the generator is not required to be monitored. But Table 7-3.2 of NFPA 72 (1999) says engine driven generators must be tested monthly, not weekly. So is this a conflict in the standard? I looked at the 2010 edition of NFPA 72, and apparently the technical committee thought it was, as they corrected their table (Table 14.4.5 which is comparable to Table 7-3.2 of the 1999 edition) which now says the generator must be tested weekly, and Table (of the 2010 edition) on Test Methods, says the test must be in accordance with NFPA 110.

But NFPA 110 does not require weekly operational tests, only weekly inspections. They do require monthly tests of the generators. Again, is this another conflict? Perhaps not, as the frequency of the generator test (weekly) is determined by NFPA 72, but the methods and parameters of the test are determined by NFPA 110.

This is what is apparent to me: NFPA 72 requires the fire alarm system to monitor the voltage at the point of connection on both primary and secondary power supplies. The exception to this requirement for monitoring is if the generator is being tested weekly, but not many organizations are testing their generators weekly. If you are not testing the generators weekly, then make sure your fire alarm system is monitoring the voltage output of the generators when they are connected to the fire alarm system.

Is any national AHJ currently enforcing this issue at the moment? I am not aware that any of them are, but it is a NFPA requirement and healthcare organizations are required to be compliant with all NFPA standards referenced by the Life Safety Code. Better to be on top of this and have your fire alarm system compliant before one of the AHJs asks to see your documentation.


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Nov 07 2013

Changes to Joint Commission Standards for 2014: Part 2

Category: BlogBKeyes @ 5:00 am


As mentioned in last week’s posting, The Joint Commission announced changes to their standards that takes affect January 1, 2014. We discussed already the change they are making with time defined which will have a significant impact on scheduling fire drills, and other quarterly activities. This week we will look at the other change that the accreditor announced: Monthly generator load testing.

During a recent webinar which was sponsored by ASHE, George Mills, the Director of Engineering for The Joint Commission, announced starting in 2014, monthly generator load testing will be permitted to be accomplished anytime during the month, rather than the current requirement of no less than 20 days and no more than 40 days from the previous monthly load test. Why this change? George did not explain why, but perhaps it is Joint Commission’s attempt to make it easier on the facility manager.

But if that is the case, then I’m not sure it is a favor, as this latest move by the accreditor is not consistent with the Life Safety Code (LSC) for new construction, nor is it consistent with the Centers for Medicare & Medicaid Services (CMS) Conditions of Participation.

But why did The Joint Commission have the 20 day/40 day requirement for generator monthly load test in the first place? Because it is a requirement of NFPA 99 Health Care Facilities (1999 edition), section 3-, and the LSC (2000 edition) section requires compliance with NFPA 99. Now, chapter 18 is for new healthcare occupancy construction, and chapter 19, which regulates existing healthcare conditions, does not have the same requirement. So, you might think the 20 day/40 day window for monthly testing only applies to new construction (since March 1, 2003) and not existing. Well, I wouldn’t bet on that.

Enter the CMS Conditions of Participation, paragraph 482.41(a)(1) interpretive guidelines says: “The hospital must comply with the applicable provisions of the Life Safety Code…and applicable references such as NFPA 99…for emergency lighting and emergency power.” This CoP standard applies to all healthcare occupancies, regardless whether they are new or existing and is required to be assessed by the LSC Survey Report Form CMS-2786, also known as the K-Tags. Tag K-144 says the following: “Generators inspected weekly and exercised under load for 30 minutes per month and shall be in accordance with NFPA 99, 3-4.4.1, NFPA 110,8-4.2.” This means CMS requires the generator monthly load tests to be conducted within the 20 day/40 day window of opportunity.

As a deeming authority who has been approved by CMS, Joint Commission is required to have standards that are at least equal to or greater than CMS’s CoP. This new change announced by Joint Commission appears to establish their standards less than what CMS’s CoP requires. Will CMS hold them accountable to this difference? If history is an indication of future events, I suspect they won’t.

As a side-note, during the Q&A session of the ASHE sponsored webinar, my good friend George Rivas of TSIG Consulting asked George Mills if Joint Commission surveyors will allow monthly generator load tests conducted on the 30th of one month, and then next on the 1st of the following month, essentially just 1 day apart. Mills kind of hesitated and said he wouldn’t know why a facility manager would want to do that, but he agreed it would be permissible.

So… What does all this mean? Joint Commission can do what they want, and they often do. But this change to their standards will only provide temporary relief for the healthcare facility managers. On this issue, CMS has more restrictive requirements, so it would be wise for facility managers to continue to conduct their generator monthly load tests within the 20 day/40 day window, so they are ready if the CMS approved state agency inspectors show up to do a validation survey.

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