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.

Brad Keyes
Brad Keyes, CHSP

Brad is a former advisor to Healthcare Facilities Accreditation Program (HFAP) and former Joint Commission LS surveyor. He guides clients through  organizational assessment; management training; ongoing coaching of task groups; and extensive one-on-one coaching of facility leaders. He analyzes and develops leadership effectiveness and efficiency in work processes, focusing on assessing an organization’s preparedness for a survey, evaluating processes in achieving preparedness, and guiding organizations toward compliance. 

As a presenter at national seminars, regional conferences, and audio conferences, Brad teaches the Keyes Life Safety Boot Camp series to various groups and organizations. He is the author or co-author of many HCPro books, including the best-selling  Analyzing the Hospital Life Safety Survey, now in its 3rd edition. Brad has also authored a variety of articles in numerous publications addressing features of life safety and fire protection, as well as white papers and articles on the Building Maintenance Program. Currently serving as the contributing editor of the monthly HCPro newsletter Healthcare Life Safety Compliance  gives Brad further insight into the industry’s trends and best practices.