Do you really know if your generator alarms comply with NFPA 110?
By: Allan Evora
Lack of compliance with NFPA 110 Level 1 safety indications and alarms is an inherent problem in the healthcare industry. In my experience, a large majority of older Level 1 emergency generator installations (~50%) do not meet the standard with respect to safety indications and alarms.
While the NFPA 110 Level 1 standard is very clear when it comes to specific safety indications and shutdown alarms required, we find many emergency generator installations are deficient when it comes to: 1) having all alarms required and 2) meeting the remote annunciation requirement.
Even more disturbing is that many owners may not even know they’re out of compliance with NFPA 110.
This finding may come as a surprise for two reasons.
- Most design engineers are very aware of NFPA 110’s applicability, which is the electrical standard for Emergency and Standby Power Systems. This standard is typically referenced within the design specifications for installations that require emergency generators.
- The industry is regulated. Regular scheduled, as well as unannounced, inspections are conducted by the authority having jurisdiction (AHJ) within a locale.
Unfortunately, ignorance is not an excuse. We recently helped a hospital customer faced with a $25,000/day fine from an AHJ audit. Working with the generator service partner, our engineers discovered the existing system did not include several of the safety indications and alarms. This customer was specifically missing low coolant level, low fuel level, and battery charger AC fail. A plan was put in place to upgrade the existing control panels to address missing alarms and then fully test and verify each alarm and remote annunciation.
What are the NFPA 110 alarming standards?
According to the 2016 version of NFPA 110 standards, the following 19 items are required on a control panel mounted visual for Level 1 hospitals. Some of these are required to shut down the generator1 and some are required to remotely annunciate2 at a location manned 7x24x365.
- Overcrank 1 and 2
- Low water temperature 2
- High engine temperature pre-alarm 2
- High engine temperature 1 and 2
- Low lube oil pressure 1 and 2
- Overspeed 1 and 2
- Low fuel main tank 2
- Low coolant level 2
- EPS supplying load
- Control switch not in automatic 2
- High battery voltage
- Low cranking voltage 2
- Low voltage in battery
- Battery charger ac failure
- Lamp test
- Contacts for local and remote common alarm 2
- Low starting air pressure (if applicable to generator installation)
- Low starting hydraulic pressure (if applicable to generator installation)
- Air shutdown damper when used (if applicable to generator installation) 1 and 2
I’ve heard when auditors conduct their inspection, some hospital owners say their generators are grandfathered into some previous version, implying their requirements may not be the same. However, this portion of the NFPA 110 standards hasn’t changed since at least 2005, which means if your generator was installed in the last 10-15 years, that excuse probably isn’t valid.
Affinity Energy engineers have seen plenty of generators installed in the last few years that still don’t have visual alarm indicator requirements that have been part of NFPA 110 for the last decade.
Why is the NFPA 110 noncompliance problem so pervasive?
It all stems from a cycle of misinformation or assumptions:
- Design engineers assume generator manufacturers understand what NFPA 110 regulations are. (Problem #1: manufactures don’t know that generator is being installed in a Level 1 hospital, so how would they know which regulations it must comply with?)
- Owners assume design engineers take care of any compliance requirements as part of the contract. (Problem #2: Design engineers rely too heavily on the OEM and contractors to know and comply with standards.)
- Commissioning personnel don’t test for "complete" NFPA 110 compliance during commissioning, and they’re not held accountable if they miss something. (In the case of older hospitals, formal commissioning wasn’t even on the radar 15 years ago.)
- As I already stated, some owners who understand a little about NFPA 110 believe that their generators are grandfathered in to older versions of NFPA 110.
One would think that even if a generator did not get properly commissioned, it would certainly be identified as deficient during an annual inspection or AHJ audit. The problem is that most audits do not involve complete testing of all alarms. The inspector or auditor will ask owners to demonstrate alarms that are easy to generate, for example, alarms like "control switch not in auto" or "remote emergency stop". The ability to demonstrate alarms such as "high engine temperature" or "low lube oil pressure" would require the assistance of the OEM or generator service partner to create the alarm condition.
It boils down to education
At the end of the day, I believe it comes down to education. In some cases, owners are simply not knowledgeable on the alarms their emergency generators are required to generate. This is evident by the fact that in some installations, the remote annunciator panel does not even have a place holder or visual indication for required alarm(s). Not only do owners need to be educated on the NFPA 110 Level 1 alarm standard, they need to have access to the applicable standard at the time the emergency generator was first installed. Depending on when your generator was installed, alarm requirements may have been more lenient.
Another problem is that regulation is somewhat subjective. Check out this excerpt straight from NFPA 110:
“This document applies to the installation of EPSS, except that the requirements of Chapter 8 shall apply to new and existing systems. Existing systems shall not be required to be modified to conform, except where the authority having jurisdiction determines that nonconformity presents a distinct hazard to life…”
The standards really leave decisions up to the authority having jurisdiction. If the authority views the absence of low coolant level could potentially have life safety implications, even if you think your generator was grandfathered in to some 20-year-old standard, it might not matter.
Lastly, if any major work is performed on your emergency power supply system, you may be expected to bring existing generators into compliance with the current standard. For example, if you add a fourth generator to your central energy plant and do a significant upgrade and modification to the paralleling switchgear.
How to ensure you’re in compliance
What would happen if a generator didn’t start because the oil pressure was low, and the power plant staff were unaware because there was no alarm initially added to the generator control panel, and/or there was no remote alarm annunciation?
Take a proactive stance as an owner. Fix this on your own time and under your own terms. If you wait until you get caught, you’ll pay a premium.
Allan D. Evora is a leading expert in control systems integration and president of Affinity Energy with over 20 years of industry experience working in every capacity of the power automation project life cycle. With a background at Boeing Company and General Electric, Allan made the decision to establish Affinity Energy in 2002. Allan is an alumnus of Syracuse University with a B.S. in Aerospace Engineering, graduate of the NC State Energy Management program, and qualified as a Certified Measurement & Verification Professional (CMVP).
Throughout his career, Allan has demonstrated his passion for providing solutions. In 1990, he developed FIRST (Fast InfraRed Signature Technique), a preliminary design software tool used to rapidly assess rotary craft infrared signatures. In 2008, Allan was the driving force behind the development of Affinity Energy's Utilitrend; a commercially available, cloud-based utility resource trending, tracking, and reporting software.
Allan has been instrumental on large scale integration projects for utilities, universities, airports, financial institutions, medical campus utility plants, and manufacturing corporations, and has worked with SCADA systems since the early ‘90s. A passion for data acquisition, specialty networks, and custom software drives him to incorporate openness, simplicity, and integrity into every design in which he is involved.