How to Bring Your Emergency Power System Into Full NFPA 110 Compliance
Why NFPA 110 Matters When the Lights Go Out
It’s 2 a.m., a summer storm lashes your facility, and the utility grid drops offline. The seconds are ticking. Life-safety systems, critical data racks, and HVAC all depend on the quiet metal box out back, your emergency generator. It roars to life… or does it? In 2023, hospital downtime due to generator failure cost an average of $8,662 per minute (Uptime Institute). The common thread in most post-incident investigations is the same: partial or complete non-compliance with NFPA 110.
NFPA 110 is the nationally recognized standard that dictates how Emergency Power Supply Systems (EPSS) must be designed, installed, tested, and maintained. Complying isn’t just a box to check. It is the difference between business as usual and catastrophic loss. In our 20 years commissioning EPSS for data centers and healthcare clients, Camali Corp engineers have rescued dozens of “compliant-on-paper” systems that would have failed in a live event. Below, we break down exactly how to achieve, and prove, full NFPA 110 compliance.
NFPA 110 Basics: Levels, Classes, and Types Explained
| Term | What It Means | Quick Example |
| Level 1 | Protects life-safety loads (e.g., OR lighting, fire alarm) | Hospital operating room |
| Level 2 | Protects less-critical loads where failure is non-life-threatening | Office HVAC |
| Class | Hours of on-site fuel (Class 48 = 48 hours) | Data center with 2-day fuel |
| Type | Seconds to restore power (Type 10 = 10 seconds) | Generator must pick up ≤10 s |
Example: A Type 10 Class 48 Level 1 EPSS must restore power within 10 seconds, run for 48 hours on stored fuel, and serve life-safety loads.
Real-World Failures & Costs
An Arizona hospital lost both primary and backup power in 2024 when a clogged fuel filter, never inspected during monthly tests, starved the generator. Surgery suites went dark; 47 patients had to be evacuated. The fine for violating NFPA 110 testing clauses exceeded $220,000.
7-Step Roadmap to NFPA 110 Compliance
- Assess System Classification – Map every load your generator supports and assign the correct Level, Class, and Type. Misclassification is the #1 error we see during audits.
- Document a Written EPSS Plan – NFPA 110 §8.2 requires a documented program covering procedures, personnel, spare parts, and safety precautions.
- Install Code-Compliant Equipment –
- Generators: Listed to UL 2200
- Automatic Transfer Switch (ATS): UL 1008
- Fuel tanks: UL 142 or UL 2085 plus local clearance rules.
- Pro tip: 80 percent of retrofit failures stem from inadequate combustion air.
- Perform Acceptance Testing – NFPA 110 Chapter 7 mandates factory “white-box” tests, site commissioning, and a 2-hour full-load run. Camali’s test sets log, graph, and store data for 10 years.
- Set Up Monthly & Annual Maintenance –
- Monthly: 30-minute unloaded generator run, ATS exercise, and battery check
- Quarterly: Fuel sampling for microbes
- Annual: 2-hour full-load test, Infrared scan, and breaker primary injection
- Keep Training & Records – Logbooks or digital equivalents must be available to the AHJ within 24 hours and retained 36 months.
- Schedule Third-Party Audits – Have an external specialist evaluate testing, fueling infrastructure, and documentation every three years. Camali’s auditors flag an average of 14 action items, even on “compliant” systems.
Costs, ROI, and Risk Reduction
| Cost Item | Typical Range | Why It Pays |
| Documentation & staff training | $3 k – $10 k | Cuts fines & inspection delays |
| Controls or ATS upgrade | $12 k – $50 k | Meets UL 1008 withstand specs |
| Recurring maintenance | 2–4% of CAPEX/yr | Extends generator life ~30% |
ROI: NFPA 110-compliant sites see 82% fewer unplanned outages (Uptime Institute, 2024). Insurers may trim premiums 5–8% for documented compliance. Factor in reputation risk, and ROI can exceed 300% over system life.
How Camali Corp Helps You Pass With Confidence
At Camali Corp we live and breathe critical power. Our engineers hold NFPA 110, IEEE, and ASHE certifications, and we maintain a live feed of code updates. Services include:
- Gap analysis & classification study
- Design-build retrofits for UL 2200/1008 compliance
- On-site acceptance testing with certified load banks
- 24/7 monitoring and automated monthly test runs
