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Keyes Q&A: Generator lighting, fire dampers, eyewash stations, ISLM fire drills

Healthcare Life Safety Compliance, January 14, 2021

This is an excerpt from a member only article. To read the article in its entirety, please login or subscribe to Healthcare Life Safety Compliance.

Editor’s note: Each month, Brad Keyes, CHSP, owner of Keyes Life Safety Compliance, answers your questions about life safety compliance. Follow Keyes’ blog on life safety at www.complianceonegroup.com/lifesafety for up to date information.   

Generator lighting

Q: Now that NFPA 110-2010, section 7.3.1 clarified a battery-powered light is not required at the generator if located outside, my colleague and I are having a disagreement on the standard for a task light at the generator. NFPA 99-2012, section 6.4.2.2.3.2 states: The life safety branch shall supply power for lighting, receptacles, and equipment as follows: (4) Generator set location, (a) task illumination. This is reiterated under a Type 2 EES, section 6.5.2.2.2.1 (6). My colleagues say you only need task illumination at the generator if required per NFPA 110. I say the NFPA 99 code is very clear and requires it. We agreed to seek your interpretation. By the way, it’s odd that NFPA 110-2010, section A.7.3.3 states: Where units housed outdoors are used, it is recommended that a flashlight or battery-powered light with a flexible cord be maintained in the housing. Do the folks who write NFPA 110 ever talk with the folks who write NFPA 99, so they would all be on the same page?

A: As a matter of fact, the folks who write the different codes and standards at NFPA often do not talk to one another. It is VERY frustrating at times!

I do not agree with your statement that section 7.3.1 of NFPA 110-2010 does not require battery-powered lighting in outdoor generator locations. Section 7.3.1 says:

“The Level 1 or Level 2 EPS equipment location(s) shall be provided with battery-powered emergency lighting. This requirement shall not apply to units located outdoors in enclosures that do not include walk-in access.”

So, outdoor generator sets that are the walk-in type do require battery-powered lighting.

You did not explain why you are looking at Type 2 EES requirements in NFPA 99-2012; if you are a hospital, you need to be looking at Type 1 EES requirements under section 6.4.2.2.3.2(4). But anyway, Type 1 and Type 2 EES requirements are the same in regard to requiring task illumination and receptacles to be connected to the life safety branch in the generator housing.

This is an excerpt from a member only article. To read the article in its entirety, please login or subscribe to Healthcare Life Safety Compliance.

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