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), and common AHJ expectations.
Each item includes a reference to the applicable code section so you can verify requirements against the current edition of the standard. 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
These items should be verified at intervals not exceeding seven days per NFPA 110 Section 8.3.4.
| # | Inspection Item | Code Reference | Status |
|---|---|---|---|
| W-1 | Generator room or enclosure is clean and free of stored materials | NFPA 110, 8.3.4 | ______ |
| W-2 | No visible fuel, oil, or coolant leaks present | NFPA 110, 8.3.4 | ______ |
| W-3 | Engine block heater is energized and maintaining temperature above 100degF | NFPA 110, 8.3.4 | ______ |
| W-4 | Battery charger is operating and indicating float charge | NFPA 110, 8.3.7 | ______ |
| W-5 | Generator control panel shows no active alarms or fault codes | NFPA 110, 8.3.4 | ______ |
| W-6 | Ventilation louvers and air intake are unobstructed | NFPA 110, 7.9 | ______ |
| W-7 | Exhaust discharge point is clear and unobstructed | NFPA 110, 7.9 | ______ |
| W-8 | Emergency shutdown controls are accessible and properly labeled | NFPA 110, 7.5 | ______ |
| W-9 | Fire extinguisher is present, accessible, and current on inspection | NFPA 10 | ______ |
| W-10 | Hour meter reading recorded in operations log | NFPA 110, 8.3.4 | ______ |
| W-11 | Fuel level in day tank and main storage tank is adequate | NFPA 110, 7.9 | ______ |
| W-12 | 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. This takes less than 20 minutes per week and is the single most effective compliance habit you can establish.
Monthly Exercise and Testing Checklist
Monthly testing under load is required by NFPA 110 Section 8.4.2. This checklist covers both the exercise test and associated monthly inspections.
| # | Inspection/Test Item | Code Reference | Status |
|---|---|---|---|
| M-1 | Generator exercised under load for minimum 30 minutes | NFPA 110, 8.4.2 | ______ |
| M-2 | Load during exercise was at least 30% of nameplate kW rating | NFPA 110, 8.4.2.1 | ______ |
| M-3 | ATS initiated automatic transfer on simulated power loss | NFPA 110, 8.4.2 | ______ |
| M-4 | ATS completed retransfer after power restoration | NFPA 110, 8.4.2 | ______ |
| M-5 | Generator started within 10 seconds (Level 1 systems) | NFPA 110, 4.1.1 | ______ |
| M-6 | Output voltage within plus or minus 2% of rated voltage (all phases) | NFPA 110, 4.3 | ______ |
| M-7 | Output frequency stable at 60 Hz plus or minus 0.5 Hz | NFPA 110, 4.3 | ______ |
| 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 | NFPA 110, 8.3.4 | ______ |
| M-11 | Coolant level is adequate in expansion tank or radiator | NFPA 110, 8.3.4 | ______ |
| M-12 | Drive belts in serviceable condition (no cracks, glazing, or fraying) | NFPA 110, 8.3.4 | ______ |
| M-13 | Coolant and fuel hoses in serviceable condition | NFPA 110, 8.3.4 | ______ |
| M-14 | Air filter restriction within acceptable limits | Manufacturer | ______ |
| M-15 | All exercise test parameters recorded in operations log | NFPA 110, 8.4.2 | ______ |
| M-16 | Reason for operation and hours logged for EPA tracking | 40 CFR 63, Subpart ZZZZ | ______ |
Important
If your building loads do not consistently reach 30% of the generator's nameplate rating during monthly tests, you must either add supplemental loads via a load bank or document why the actual building load is representative. AHJ inspectors will verify that your monthly test records show adequate loading. Consistent no-load or light-load testing is a common citation.
Quarterly Inspection Checklist
Quarterly items address slower-degrading components and systems that require periodic verification beyond the monthly cycle.
| # | Inspection/Test Item | Code Reference | Status |
|---|---|---|---|
| Q-1 | Starting battery load test or impedance test performed | NFPA 110, 8.3.7 | ______ |
| Q-2 | Battery terminals cleaned, tight, and treated for corrosion | NFPA 110, 8.3.7 | ______ |
| Q-3 | Battery electrolyte levels checked (flooded cells) or case integrity verified (VRLA) | NFPA 110, 8.3.7 | ______ |
| Q-4 | Coolant freeze point and pH tested; SCA concentration verified | Manufacturer | ______ |
| Q-5 | Exhaust system inspected for leaks, corrosion, and loose connections | NFPA 110, 8.3.4 | ______ |
| Q-6 | All emergency stop buttons tested and verified functional | NFPA 110, 7.5 | ______ |
| Q-7 | Engine and alternator vibration isolators inspected | NFPA 110, 8.3.4 | ______ |
| Q-8 | Fuel system inspected for leaks, including day tank and transfer piping | NFPA 110, 8.3.4 | ______ |
| Q-9 | ATS exercised in manual mode to verify manual transfer capability | NFPA 110, 8.4.3 | ______ |
Annual Comprehensive Inspection Checklist
Annual tasks include the most thorough inspections and the critical full-load bank test. These items are typically performed by qualified service technicians.
| # | Inspection/Test Item | Code Reference | Status |
|---|---|---|---|
| A-1 | Full load bank test at 100% of nameplate kW for minimum 2 hours | NFPA 110, 8.4.2.3 | ______ |
| A-2 | All load bank test parameters recorded at 15-minute intervals | NFPA 110, 8.4.2.3 | ______ |
| A-3 | Engine oil and filters changed | Manufacturer | ______ |
| A-4 | Fuel filters replaced (primary and secondary) | Manufacturer | ______ |
| A-5 | Air filter element replaced | Manufacturer | ______ |
| A-6 | Cooling system flushed and refilled with fresh coolant | Manufacturer | ______ |
| A-7 | Thermostat tested or replaced | Manufacturer | ______ |
| A-8 | Comprehensive ATS inspection: contacts, sensing, timing, bypass | NFPA 110, 8.4.3 | ______ |
| A-9 | Fuel quality tested per ASTM D975 standards | NFPA 110, 8.3.4 | ______ |
| A-10 | Fuel tank cleaned or polished to remove water and contaminants | NFPA 110, 8.3.4 | ______ |
| A-11 | Alternator insulation resistance tested (megohmmeter, minimum 2 megohms) | IEEE 43 / Manufacturer | ______ |
| A-12 | All power electrical connections torqued to specification | NFPA 70, 110.14 | ______ |
| A-13 | All engine protection sensors verified for calibration and function | Manufacturer | ______ |
| A-14 | Starting batteries replaced if beyond service life (3 years VRLA, 5 years flooded) | NFPA 110, 8.3.7 | ______ |
| A-15 | Generator enclosure or room weatherproofing and seals inspected | NFPA 110, 7.2 | ______ |
| A-16 | All signage verified current and legible | Local codes | ______ |
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, 8.3.4 | ______ |
| D-2 | Maintenance log with all PM activities, parts, and technician information | NFPA 110, 8.3.4 | ______ |
| D-3 | Monthly exercise test records showing date, duration, load, and operating parameters | NFPA 110, 8.4.2 | ______ |
| D-4 | Annual load bank test report | NFPA 110, 8.4.2.3 | ______ |
| D-5 | EPA operating hour log with emergency/non-emergency classification for each event | 40 CFR 63, Subpart ZZZZ | ______ |
| D-6 | Total non-emergency operating hours year-to-date (must not exceed 100 hours) | 40 CFR 63, Subpart ZZZZ | ______ |
| D-7 | Fuel purchase records confirming ULSD (15 ppm sulfur maximum) | 40 CFR 63, Subpart ZZZZ | ______ |
| D-8 | Current fuel quality test report | ASTM D975 | ______ |
| D-9 | Oil analysis reports (if enrolled in oil analysis program) | Best practice | ______ |
| D-10 | ATS inspection and test records | NFPA 110, 8.4.3 | ______ |
| D-11 | Battery test records (quarterly load tests or impedance tests) | NFPA 110, 8.3.7 | ______ |
| D-12 | Generator nameplate data sheet (kW rating, voltage, engine serial number, EPA Tier) | NFPA 110, 7.1 | ______ |
| 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 | NFPA 110, 8.3.4 | ______ |
| D-15 | Previous AHJ inspection reports with corrective action documentation | Best practice | ______ |
EPA Compliance Verification Items
These items specifically address EPA RICE NESHAP requirements for emergency stationary compression-ignition engines.
| # | EPA Compliance Item | Regulatory Reference | Status |
|---|---|---|---|
| E-1 | Engine classified as emergency per 40 CFR 63.6675 definition | 40 CFR 63, Subpart ZZZZ | ______ |
| E-2 | Non-resettable hour meter installed and operational | 40 CFR 63, Subpart ZZZZ | ______ |
| E-3 | Total non-emergency hours tracked and under 100-hour annual limit | 40 CFR 63.6640 | ______ |
| E-4 | Only ULSD fuel used (15 ppm sulfur maximum) | 40 CFR 63.6604 | ______ |
| E-5 | Maintenance performed per manufacturer recommendations | 40 CFR 63.6603 | ______ |
| E-6 | Operating records maintained for minimum 5 years | 40 CFR 63.6660 | ______ |
| E-7 | Initial notification submitted to delegated authority (if required) | 40 CFR 63.6645 | ______ |
| E-8 | Engine EPA Tier certification documented | 40 CFR Part 1039 | ______ |
| E-9 | State/local air quality permit obtained (if required for engine size) | State SIP | ______ |
| E-10 | DEF system functional and fluid level adequate (Tier 4 Final engines) | Manufacturer | ______ |
| E-11 | DPF regeneration system functional (Tier 4 Final engines) | Manufacturer | ______ |
Red Flag Items: Common Causes of Failed Inspections
AHJ inspectors see the same deficiencies repeatedly. The following items represent the most common reasons generators fail compliance 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 is explicit about monthly testing. Missing records are treated as missing tests | Implement monthly testing immediately; backfilling records is not acceptable |
| Light-load or no-load testing only | Running the generator without at least 30% load does not satisfy NFPA 110 Section 8.4.2.1 | Arrange for a portable load bank if building loads are insufficient |
| Dead or weak starting batteries | Batteries are the most common single point of failure. AHJ inspectors may witness a start attempt | Test batteries quarterly; replace proactively based on age and test results |
| No annual load bank test report | The annual full-load test per NFPA 110 Section 8.4.2.3 is a specific, documented requirement | Schedule and perform the test; retain the detailed report with 15-minute interval data |
| Missing operations log | Inspectors expect to see a chronological record of every operating event | Start a log immediately; maintain it consistently going forward |
| Block heater not functioning | A cold engine may fail to start within the required 10-second window for Level 1 systems | Check block heater operation weekly; replace immediately if failed |
| Fuel quality not tested | Degraded diesel fuel causes injector failure, filter clogging, and starting problems | Test fuel annually per ASTM D975; implement fuel polishing if quality is marginal |
| ATS not tested independently | The transfer switch must be tested as part of the monthly exercise; many facilities skip the retransfer verification | Include full ATS cycle (transfer and retransfer) in every monthly test |
| EPA hour tracking absent | Inability to demonstrate compliance with the 100-hour non-emergency limit is a regulatory violation | Record hours and classify each operating event as emergency or non-emergency |
| Stored materials in generator room | Combustible storage near a diesel engine and fuel system is a fire code violation | 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 red flag findings in a single inspection can trigger more frequent follow-up inspections, increased scrutiny, and in some jurisdictions, fines or requirements for third-party commissioning.
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
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Complete your annual maintenance. Perform the full annual service, including the load bank 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.
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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.
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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
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Have documentation ready. Print or prepare digital access to your operations log, maintenance log, test records, fuel receipts, 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. Many AHJ inspectors will want to see the generator start and the ATS transfer. Verify that the system is in automatic mode and ready for a live demonstration.
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Know your system. Be prepared to state the generator's kW rating, voltage configuration, fuel type, EPA Tier, and installation date. Know the nameplate details of your ATS. Inspectors respect facility managers who understand their systems.
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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.
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.
