The Vital Role of Documentation and Recordkeeping in Maintaining NFPA 110 Compliance for Commercial Generators

Maintaining your emergency backup power system’s operational readiness is essential to ensuring the uninterrupted power supply in critical situations. For businesses and facilities like hospitals, data centers, and emergency services, generators are lifelines when utility power fails. However, it’s not enough to simply install and occasionally test these systems; they must be consistently maintained to meet the standards set by the National Fire Protection Association (NFPA) in its NFPA 110 code.

One often overlooked yet crucial aspect of NFPA 110 compliance is documentation and recordkeeping. Proper documentation is the backbone of a well-maintained system, as it not only helps keep the generator operational but also ensures it meets all regulatory requirements. In this blog, we’ll explore why meticulous recordkeeping is so important and how it ties into maintaining NFPA 110 compliance.

Why Documentation Matters for NFPA 110 Compliance

The NFPA 110 code governs the performance, maintenance, and testing of emergency and standby power systems, including generators. It lays out a framework designed to ensure that these systems are reliable and ready to deliver power when needed. Regular maintenance, testing, and inspections are key components of this framework. However, merely performing these actions isn’t enough; they must be meticulously documented.

Documentation serves several critical functions when it comes to compliance:

1. Proof of Compliance
   Regulatory authorities require documentation to verify that maintenance activities have been performed as mandated by NFPA 110. During an inspection or audit, records provide evidence that the EPS has been serviced, tested, and maintained according to the required schedule. In the absence of this documentation, even if the EPS is in good working condition, a facility could face penalties for non-compliance.
2. Historical Data for Performance Tracking
   Detailed records allow facility managers and maintenance teams to track the commercial generator’s performance over time. By reviewing historical data, teams can identify trends that might indicate an underlying issue, such as increased fuel consumption or slower startup times. These insights can guide more focused maintenance efforts and preempt potential failures. NFPA 110 requires a proactive approach to maintenance, and keeping records helps meet that standard.
3. Ensuring Timely Maintenance
   NFPA 110 specifies regular intervals for maintenance, testing, and inspections. Without proper records, it’s easy for important service dates to slip through the cracks, especially in facilities with multiple systems to manage. Good recordkeeping helps ensure that no scheduled service is missed, keeping the EPS in peak operational condition.
4. Meeting Insurance and Legal Requirements
   In the unfortunate event of a power failure during an emergency, having proper documentation can be essential from a legal and insurance perspective. If a generator fails and causes a business interruption or safety risk, the facility may face litigation or insurance claims. Well-kept records of maintenance activities can serve as a legal safeguard, proving that the facility took all reasonable steps to maintain your emergency backup power system according to NFPA 110 standards.

What Should Be Included in Maintenance Records?

Now that we’ve covered why documentation is so important, let’s explore what kind of information should be included in your records to meet NFPA 110 standards. The goal is to ensure that each entry is comprehensive and clear enough to demonstrate full compliance.

1. Maintenance Logs
   Each time the generator is serviced, a detailed log should be created. This log should include the date and time of the service, the name of the technician who performed the work, and a summary of the tasks completed. Whether it’s an oil change, filter replacement, or battery inspection, every detail matters. The log should also note any potential issues found during the service and the actions taken to address them.
2. Test Results
   NFPA 110 mandates regular testing of emergency power systems, including load bank testing and monthly start-up tests. The results of these tests should be carefully recorded. For example, when performing a load bank test, the documentation should include the load levels applied, the duration of the test, and any performance issues observed during testing.
3. Inspection Reports
   Inspections should be conducted at regular intervals, and each inspection needs a corresponding report. These reports should detail the components inspected (such as the battery system, exhaust, and ventilation), the condition of each component, and any necessary corrective actions. Inspection records help ensure that the generator remains compliant with NFPA 110 by identifying and addressing potential problems before they lead to system failures.
4. Corrective Actions and Repairs
   Whenever a fault is found in the system—whether during a test, inspection, or regular operation—documentation should include the nature of the issue, the date it was identified, and the steps taken to correct it. Keeping a record of all repairs is essential to ensuring that the generator is operating safely and within compliance parameters.
5. Fuel and Coolant Levels
   One of the most common reasons an EPS fails during emergencies is inadequate fuel or cooling. NFPA 110 includes provisions for maintaining appropriate fuel levels and coolant system integrity. Documenting each instance of fuel tank refills and coolant checks will help prevent these types of failures. Be sure to log the fuel type, amount added, and the frequency of refueling, as well as any maintenance performed on the cooling system.
6. Automatic Transfer Switch (ATS) Testing
   The ATS is responsible for transferring the load from utility power to the generator during an outage. NFPA 110 mandates regular testing of this switch to ensure it operates reliably under emergency conditions. Document each test and any issues or delays in switching that might need attention.

Moving Toward Digital Recordkeeping for Compliance

In the digital age, relying on paper records can be cumbersome and prone to errors. Many facilities are transitioning to digital recordkeeping systems, which offer numerous advantages in maintaining NFPA 110 compliance. Digital systems can send automatic reminders for upcoming maintenance tasks, making it easier to stay on schedule. They also provide a secure, easily accessible record of all maintenance activities, inspections, and tests.
Cloud-based systems, in particular, offer the added benefit of being accessible from any location, making it easier for regulatory authorities to audit records remotely. This can be particularly valuable for large facilities with multiple backup systems spread across different sites.

Conclusion

Consistent, thorough documentation and recordkeeping are fundamental to ensuring NFPA 110 compliance for commercial generators. By keeping detailed logs of all maintenance activities, inspections, and tests, facility managers can not only meet regulatory requirements but also ensure that their generators will perform reliably when needed. In the end, good recordkeeping isn’t just about compliance—it’s about safety, reliability, and peace of mind.

Electro-Motion is here to help you by providing regular maintenance visits at an affordable cost. Regardless of your budget, give us a call at (650) 321-6169 or schedule a free consultation to help avoid costly downtime, protect your operations, and ensure the safety and reliability of your emergency power system.