How to Use This Checklist
This compliance checklist is designed to serve as a working document for facility managers responsible for emergency generator systems. It covers the inspection, testing, maintenance, and documentation requirements established by NFPA 110 (Standard for Emergency and Standby Power Systems), the EPA RICE NESHAP (40 CFR Part 63, Subpart ZZZZ), the stationary diesel engine NSPS (40 CFR Part 60, Subpart IIII), and common AHJ expectations.
Where an item comes directly from a code or regulation, the reference column cites it. NFPA 110 section numbers are from the 2010 edition, which CMS enforces for healthcare facilities through NFPA 99-2012; numbering can differ in the edition your AHJ has adopted (the current edition is 2025). Items marked "Manufacturer" or "Best practice" are not specific code requirements but are part of a sound maintenance program. For the full testing requirements, see our NFPA 110 compliance guide. Use this checklist in three ways:
- As a routine audit tool to verify your ongoing maintenance program covers all required items
- As an inspection preparation guide when you know an AHJ visit is scheduled
- As a gap analysis to identify areas where your current program may be deficient
Items are organized by inspection frequency. The status column uses the following indicators:
- Pass = Item meets requirements
- Fail = Item does not meet requirements and needs corrective action
- N/A = Item does not apply to this installation
Weekly Visual Inspection Checklist
NFPA 110 requires the emergency power supply system (EPSS), including transfer switches, to be inspected weekly (Section 8.4.1). A weekly walk-around typically covers the items below.
| # | Inspection Item | Code Reference | Status |
|---|---|---|---|
| W-1 | Generator room or enclosure is clean and free of stored materials | NFPA 110 (EPS room not used for unrelated purposes) | ______ |
| W-2 | No visible fuel, oil, or coolant leaks present | NFPA 110, 8.4.1 | ______ |
| W-3 | Engine block heater is energized and maintaining the temperature the manufacturer specifies | NFPA 110 (engine heating); Manufacturer | ______ |
| W-4 | Battery charger is operating and indicating normal charge | NFPA 110, 8.4.1 | ______ |
| W-5 | Generator control panel shows no active alarms or fault codes | NFPA 110, 8.4.1 | ______ |
| W-6 | Ventilation louvers and air intake are unobstructed | NFPA 110, 8.4.1 | ______ |
| W-7 | Exhaust discharge point is clear and unobstructed | NFPA 110, 8.4.1 | ______ |
| W-8 | Emergency shutdown controls are accessible and properly labeled | Manufacturer; local codes | ______ |
| W-9 | Fire extinguisher is present, accessible, and current on inspection | NFPA 10; local fire code | ______ |
| W-10 | Hour meter reading recorded in operations log | Best practice; supports EPA hour records | ______ |
| W-11 | Fuel level in day tank and main storage tank meets the quantity required for your EPSS Class | NFPA 110, 8.4.1 | ______ |
| W-12 | Transfer switch inspected (position, indicators, no alarms) | NFPA 110, 8.4.1 | ______ |
| W-13 | Generator room door(s) secure with proper signage | Local codes | ______ |
Efficiency Tip
Create a laminated copy of the weekly checklist and mount it on a clipboard near the generator. Technicians can mark items with a dry-erase marker during rounds, then transfer results to the permanent log. A consistent weekly routine is one of the simplest compliance habits you can establish.
Monthly Exercise and Testing Checklist
NFPA 110 requires diesel generator sets to be exercised under load at least monthly for at least 30 minutes (Section 8.4.2). Healthcare facilities must run the monthly test 12 times a year at intervals of not less than 20 days and not more than 40 days. This checklist covers the exercise test and associated monthly inspections.
| # | Inspection/Test Item | Code Reference | Status |
|---|---|---|---|
| M-1 | Generator exercised under load for minimum 30 minutes (cool-down not counted) | NFPA 110, 8.4.2 | ______ |
| M-2 | Load was at least 30% of nameplate kW, or maintained the manufacturer's minimum exhaust gas temperature | NFPA 110, 8.4.2 | ______ |
| M-3 | Transfer switch operated from normal to emergency | NFPA 110, 8.4.6 | ______ |
| M-4 | Transfer switch completed retransfer to normal | NFPA 110, 8.4.6 | ______ |
| M-5 | Power restored to load terminals within 10 seconds (Type 10 systems) | NFPA 110 (Type 10); NEC 700 | ______ |
| M-6 | Output voltage within the manufacturer's specified range (all phases) | Manufacturer | ______ |
| M-7 | Output frequency within the manufacturer's specified range | Manufacturer | ______ |
| M-8 | Engine oil pressure within manufacturer specification | Manufacturer | ______ |
| M-9 | Coolant temperature stabilized within normal operating range | Manufacturer | ______ |
| M-10 | Engine oil level is at or near full mark | Manufacturer | ______ |
| M-11 | Coolant level is adequate in expansion tank or radiator | Manufacturer | ______ |
| M-12 | Drive belts in serviceable condition (no cracks, glazing, or fraying) | Manufacturer | ______ |
| M-13 | Coolant and fuel hoses in serviceable condition | Manufacturer | ______ |
| M-14 | Air filter restriction within acceptable limits | Manufacturer | ______ |
| M-15 | Starting batteries inspected and tested | NFPA 110, 8.3.7.1 | ______ |
| M-16 | All exercise test parameters (date, duration, kW load, readings) recorded in the log | NFPA 110 records requirements | ______ |
| M-17 | Hours of operation logged and classified as emergency or non-emergency for EPA tracking | 40 CFR 63.6655(f); 40 CFR 60.4214(b) | ______ |
Important
If your diesel generator's monthly tests do not reach 30% of nameplate kW or the manufacturer's minimum exhaust gas temperature, NFPA 110 still requires monthly exercise with the available load, plus an annual supplemental load test: at least 30 minutes at 50% of nameplate followed by at least 60 minutes at 75% (Section 8.4.2.3). Consistent light-load testing without the supplemental test is a common finding.
Quarterly Inspection Checklist
NFPA 110 does not set a separate quarterly inspection list, but quarterly checks are a practical way to cover slower-degrading components between monthly tests and annual service.
| # | Inspection/Test Item | Code Reference | Status |
|---|---|---|---|
| Q-1 | Battery terminals cleaned, tight, and treated for corrosion | Manufacturer | ______ |
| Q-2 | Battery electrolyte levels checked (flooded cells) or case integrity verified (sealed batteries) | Manufacturer | ______ |
| Q-3 | Coolant freeze point and condition tested; additive concentration verified | Manufacturer | ______ |
| Q-4 | Exhaust system inspected for leaks, corrosion, and loose connections | Manufacturer | ______ |
| Q-5 | Emergency stop buttons tested and verified functional | Manufacturer | ______ |
| Q-6 | Engine and alternator vibration isolators inspected | Manufacturer | ______ |
| Q-7 | Fuel system inspected for leaks, including day tank and transfer piping | Manufacturer | ______ |
| Q-8 | Transfer switch manual operation capability verified | Manufacturer | ______ |
Annual Comprehensive Inspection Checklist
Annual tasks include the most thorough inspections and, where required, supplemental load testing. These items are typically performed by qualified service technicians.
| # | Inspection/Test Item | Code Reference | Status |
|---|---|---|---|
| A-1 | Supplemental load test (30 min at 50%, then 60 min at 75% of nameplate) if monthly tests did not meet the loading criterion | NFPA 110, 8.4.2.3 | ______ |
| A-2 | Load test readings recorded throughout the test | NFPA 110 records requirements | ______ |
| A-3 | Engine oil and filter changed (existing emergency engines at area sources: every 500 hours or annually) | Manufacturer; 40 CFR 63 Subpart ZZZZ, Table 2d | ______ |
| A-4 | Fuel filters replaced (primary and secondary) | Manufacturer | ______ |
| A-5 | Air cleaner inspected and replaced as necessary (every 1,000 hours or annually for existing emergency engines at area sources) | Manufacturer; 40 CFR 63 Subpart ZZZZ, Table 2d | ______ |
| A-6 | All hoses and belts inspected and replaced as necessary (every 500 hours or annually for existing emergency engines at area sources) | 40 CFR 63 Subpart ZZZZ, Table 2d | ______ |
| A-7 | Cooling system serviced per manufacturer schedule | Manufacturer | ______ |
| A-8 | Comprehensive transfer switch maintenance: contacts, sensing, timing, bypass | Manufacturer | ______ |
| A-9 | Fuel quality tested using ASTM standards or manufacturer's recommendations | NFPA 110, 8.3.8 | ______ |
| A-10 | Fuel tank cleaned or fuel polished if testing shows water or contamination | Best practice | ______ |
| A-11 | Alternator insulation resistance tested and compared with manufacturer criteria and prior readings | Manufacturer | ______ |
| A-12 | Power electrical connections inspected and torqued to specification | Manufacturer | ______ |
| A-13 | Engine protection sensors verified for calibration and function | Manufacturer | ______ |
| A-14 | Starting batteries replaced if test results or age warrant, per manufacturer recommendations | NFPA 110, 8.3.7.1; Manufacturer | ______ |
| A-15 | Generator enclosure or room weatherproofing and seals inspected | Best practice | ______ |
| A-16 | All signage verified current and legible | Local codes | ______ |
| A-17 | Level 1 systems: 4-hour load test completed within the last 36 months | NFPA 110, 8.4.9 | ______ |
Documentation Readiness Checklist
AHJ inspectors will review your documentation as thoroughly as they inspect the physical equipment. Ensure the following records are complete and accessible before any inspection.
| # | Documentation Item | Code Reference | Status |
|---|---|---|---|
| D-1 | Operations log with all start/stop events, hours, and reasons for operation | NFPA 110 records requirements | ______ |
| D-2 | Maintenance log with all PM activities, parts, and technician information | NFPA 110 records requirements | ______ |
| D-3 | Monthly exercise test records showing date, duration, load, and operating parameters | NFPA 110, 8.4.2 | ______ |
| D-4 | Annual supplemental load test report (if required) and most recent 36-month test report (Level 1) | NFPA 110, 8.4.2.3 and 8.4.9 | ______ |
| D-5 | EPA operating hour log from the non-resettable hour meter, with emergency/non-emergency classification and the reason for each emergency run | 40 CFR 63.6655(f) | ______ |
| D-6 | Year-to-date maintenance/testing plus non-emergency hours (100-hour limit), with non-emergency situations separately (50-hour limit) | 40 CFR 63.6640(f); 40 CFR 60.4211(f) | ______ |
| D-7 | Fuel records showing fuel meets applicable specifications, including 15 ppm nonroad diesel where required | 40 CFR 60.4207(b); 40 CFR 63.6604 | ______ |
| D-8 | Current fuel quality test report | NFPA 110, 8.3.8 | ______ |
| D-9 | Oil analysis reports (if used to extend Table 2d oil change intervals) | 40 CFR 63.6625(i) | ______ |
| D-10 | Transfer switch inspection and test records | NFPA 110, 8.4.1 and 8.4.6 | ______ |
| D-11 | Battery inspection and test records | NFPA 110, 8.3.7.1 | ______ |
| D-12 | Generator nameplate data (kW rating, voltage, engine serial number, model year, EPA certification) | Best practice | ______ |
| D-13 | Copy of operating permit or registration (if required by state/local authority) | State/local | ______ |
| D-14 | Manufacturer's operation and maintenance manual on-site | Best practice | ______ |
| D-15 | Previous AHJ inspection reports with corrective action documentation | Best practice | ______ |
EPA Compliance Verification Items
These items address federal requirements for emergency stationary compression-ignition (diesel) engines. Existing engines at area sources (most commercial sites) follow Subpart ZZZZ directly; new or reconstructed engines at area sources comply with Subpart ZZZZ by meeting NSPS Subpart IIII (40 CFR 63.6590(c)). See our guide to EPA emissions standards for backup generators for details.
| # | EPA Compliance Item | Regulatory Reference | Status |
|---|---|---|---|
| E-1 | Engine meets the definition of an emergency engine and is operated within the emergency limits | 40 CFR 63.6675; 40 CFR 63.6640(f) | ______ |
| E-2 | Non-resettable hour meter installed and operational | 40 CFR 63.6625(f); 40 CFR 60.4209(a) | ______ |
| E-3 | Maintenance/testing plus non-emergency hours at or under 100 per calendar year, with non-emergency situations at or under 50 | 40 CFR 63.6640(f); 40 CFR 60.4211(f) | ______ |
| E-4 | Diesel fuel meets 40 CFR 1090.305 nonroad specification where required (new NSPS engines; existing engines over 100 hp used under the financial-arrangement provision) | 40 CFR 60.4207(b); 40 CFR 63.6604(b) | ______ |
| E-5 | Engine operated and maintained per manufacturer's emission-related instructions or your own maintenance plan | 40 CFR 63.6625(e); 40 CFR 60.4211(a) | ______ |
| E-6 | Table 2d management practices completed (existing engines at area sources) | 40 CFR 63.6603(a); Table 2d | ______ |
| E-7 | Records kept for at least 5 years | 40 CFR 63.6660 | ______ |
| E-8 | Notification status confirmed (initial notification not required for existing emergency engines at area sources or for emergency engines under NSPS Subpart IIII) | 40 CFR 63.6645(a)(5); 40 CFR 60.4214(b) | ______ |
| E-9 | Engine EPA certification documented (2007 and later emergency engines certified to Tier 2 or Tier 3 standards for their model year and power) | 40 CFR 60.4202; 40 CFR 60.4205(b) | ______ |
| E-10 | State/local air quality permit or registration obtained (if required) | State/local | ______ |
| E-11 | DPF backpressure monitor functional and corrective actions recorded (engines with a DPF) | 40 CFR 60.4209(b); 40 CFR 60.4214(c) | ______ |
| E-12 | DEF system functional and fluid level adequate (engines with SCR) | Manufacturer | ______ |
Red Flag Items: Common Causes of Failed Inspections
The following items are common reasons generators draw findings during inspections. Address these proactively to avoid citations.
Critical Red Flags
| Red Flag | Why It Fails | How to Fix It |
|---|---|---|
| No monthly test records | NFPA 110 Section 8.4.2 requires monthly exercise, and missing records are usually treated as missing tests | Implement monthly testing immediately; never backfill records |
| Light-load testing without a supplemental test | Monthly tests below 30% of nameplate (or the manufacturer's minimum exhaust temperature) require an annual supplemental load test under Section 8.4.2.3 | Arrange for a portable load bank for the annual test, or add load to monthly tests |
| Dead or weak starting batteries | Batteries are a frequent cause of failure to start, and inspectors may witness a start attempt | Inspect and test batteries on the NFPA 110 schedule; replace based on test results and age |
| No supplemental or 36-month test report | Where required, the annual supplemental test (8.4.2.3) and the Level 1 36-month, 4-hour test (8.4.9) must be documented | Schedule and perform the test; retain the detailed report |
| Missing operations log | Inspectors expect a chronological record of every operating event | Start a log immediately; maintain it consistently going forward |
| Block heater not functioning | A cold engine may not start and accept load within 10 seconds on a Type 10 system | Check block heater operation weekly; repair immediately if failed |
| Fuel quality not tested | NFPA 110 requires an annual fuel quality test, and degraded fuel causes filter clogging and starting problems | Test fuel annually using ASTM standards or the manufacturer's recommendations; remediate if quality is marginal |
| Transfer switch not fully tested | Transfer switches must be operated monthly; many facilities skip retransfer verification | Include the full transfer and retransfer cycle in every monthly test |
| EPA hour tracking absent | Hour records separating emergency and non-emergency operation are required, and without them you cannot show the engine qualifies as emergency | Record hours from the hour meter and classify each operating event |
| Stored materials in generator room | NFPA 110 does not permit the EPS room to be used for unrelated purposes, and combustible storage is a fire hazard | Remove all non-essential items; post signage prohibiting storage |
Immediate Action Required
If any of the critical red flag items above apply to your facility, address them before your next AHJ inspection. Multiple findings in a single inspection can lead to follow-up inspections, increased scrutiny, and in some jurisdictions, fines.
How to Prepare for an AHJ Inspection
When you know an AHJ inspection is approaching, or as part of your routine annual preparation, follow this structured approach to maximize your chances of a clean inspection.
30 Days Before the Inspection
-
Complete your annual maintenance. Perform the annual service, including any required supplemental load test, before the inspection date. Having fresh service records demonstrates active compliance.
-
Audit your documentation. Walk through the Documentation Readiness Checklist above. Identify and fill any gaps. Organize records chronologically and make them easy to navigate.
-
Conduct a self-inspection. Use the weekly, monthly, quarterly, and annual checklists in this guide to perform a thorough self-assessment. Document any deficiencies found and the corrective actions taken.
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Verify all signage. Confirm that generator room signage, emergency shutdown labels, and hazard warnings are in place, legible, and compliant with local requirements.
-
Clean the generator area. Remove any stored items, sweep the floor, clean up oil drips, and ensure the space looks well-maintained. First impressions set the tone for the entire inspection.
The Day of the Inspection
-
Have documentation ready. Print or prepare digital access to your operations log, maintenance log, test records, fuel records, and permits. Do not make the inspector wait while you search for records.
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Assign an escort. Designate a knowledgeable staff member to accompany the inspector. This person should be able to explain your maintenance program, answer questions about operating history, and demonstrate generator operation if requested.
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Be prepared for a witnessed start. Some inspectors will want to see the generator start and the transfer switch operate. Verify that the system is in automatic mode and ready for a live demonstration.
-
Know your system. Be prepared to state the generator's kW rating, voltage configuration, fuel type, EPA certification, and installation date. Know the nameplate details of your transfer switch.
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Do not argue findings. If the inspector identifies a deficiency, acknowledge it professionally and ask for clarification on the required corrective action. Request the finding in writing with the specific code reference. Disputes are resolved through the appeals process, not during the inspection.
After the Inspection
- Review the inspection report carefully for accuracy and completeness.
- Develop a corrective action plan for any cited deficiencies, with specific timelines and responsible parties.
- Complete corrective actions before the deadline specified by the AHJ.
- Document the corrective actions taken, including photographs where applicable.
- Submit documentation of corrective actions to the AHJ if required.
- Update your maintenance program to prevent recurrence of any cited deficiencies.
Maintaining Ongoing Compliance
Compliance is not a once-a-year event that coincides with your AHJ inspection. It is the result of a disciplined, year-round program that integrates inspection, testing, maintenance, and documentation into your regular facility management operations. Our weekly, monthly, and annual maintenance schedule and printable NFPA 110 test log can help.
The checklists in this guide provide the framework. Your job as a facility manager is to assign responsibility, establish accountability, and verify execution. When your program runs consistently throughout the year, AHJ inspections become confirmations of what you already know: your emergency power system is compliant, well-maintained, and ready to protect your facility and its occupants.
Sources and References
- NFPA 110: Standard for Emergency and Standby Power Systems -- National Fire Protection Association. https://www.nfpa.org/codes-and-standards/nfpa-110-standard-development/110
- NFPA 110 Emergency Generator Compliance Guide (section references and testing intervals) -- FacilityComplianceHub. https://facilitycompliancehub.org/generators/nfpa-110-emergency-generator-compliance-guide
- 40 CFR Part 63, Subpart ZZZZ -- EPA RICE NESHAP for Stationary Reciprocating Internal Combustion Engines. https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-63/subpart-ZZZZ
- 40 CFR 63.6625 -- Monitoring, installation, operation, and maintenance requirements -- Legal Information Institute, Cornell Law School. https://www.law.cornell.edu/cfr/text/40/63.6625
- 40 CFR 63.6640 -- Emergency engine operating limits -- Legal Information Institute, Cornell Law School. https://www.law.cornell.edu/cfr/text/40/63.6640
- 40 CFR 63.6655 -- Recordkeeping -- Legal Information Institute, Cornell Law School. https://www.law.cornell.edu/cfr/text/40/63.6655
- 40 CFR 63.6660 -- Record retention -- Legal Information Institute, Cornell Law School. https://www.law.cornell.edu/cfr/text/40/63.6660
- 40 CFR 63.6645 -- Notifications -- Legal Information Institute, Cornell Law School. https://www.law.cornell.edu/cfr/text/40/63.6645
- Table 2d to Subpart ZZZZ -- Requirements for Existing Stationary RICE at Area Sources -- Legal Information Institute, Cornell Law School. https://www.law.cornell.edu/cfr/text/40/appendix-Table_2d_to_subpart_ZZZZ_of_part_63
- 40 CFR Part 60, Subpart IIII (60.4202, 60.4207, 60.4209, 60.4211, 60.4214) -- Legal Information Institute, Cornell Law School. https://www.law.cornell.edu/cfr/text/40/60.4211
- ASTM D975: Standard Specification for Diesel Fuel -- ASTM International. https://store.astm.org/d0975-26b.html
- NFPA 10: Standard for Portable Fire Extinguishers -- National Fire Protection Association. https://www.nfpa.org/codes-and-standards/nfpa-10-standard-development/10
