Level 1 or Level 2 Generator? The Surveyor Knew…

Q: I have a question regarding emergency generators and Level 1 classification. I’m at a sister hospital and they went through a State Surveyor and he asked for proof that the emergency generator was a Level 1 generator. The documentation indicates that it meets NFPA 110 but nowhere does it indicate that it is Level 1. Now the hospital was approved by the State in 2009 and been open since then. This has never come up in past 9 years. I’ve contacted the maker of the Generator for supplemental documentation. Is there another way to prove that the generator meets level 1 classification? We have patients on ventilators. Please provide me with some wisdom to address this issue with the surveyor

 A: That surveyor is yanking your chain…. First of all, speaking in general terms, the use of the generator classifies whether it is a Level 1 or Level 2.

According to NFPA 110-2010, section 4.4.1 says Level 1 systems shall be installed where failure of the equipment to perform could result in loss of human life or serious injuries. Generators used in hospitals would be required to be Level 1. Section 4.4.2 says Level 2 systems shall be installed where failure of the EPSS to perform is less critical to human life and safety. There are different operational requirements based on whether the generator is classified as a Level 1 or Level 2.

A generator is a generator, and the manufacturer of that generator does not classify the use of that generator. It can say it qualifies for use as a Level 1 generator, but the actual use of the generator determines if it is a Level 1 or a Level 2.

Sounds like the surveyor is providing you a teachable moment by asking that question. He knew the answer before he asked.  


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.