Finding Prompts Proposed Changes to Federal Requirements Governing Emergency Power in Hospital and Nursing Homes
Powered for Patients (P4P), a 501c3 non-profit that helps jurisdictions identify and mitigate emergency power vulnerabilities in hospitals and nursing homes, is sounding the alarm about outdated hospital emergency power systems based on the discovery of seriously outdated generators in a number of Los Angeles County hospitals.
P4P conducted a census of the emergency power systems in 80 LA County hospitals as part of a multi-year emergency power resilience initiative launched by the Los Angeles County Emergency Medical Services (EMS) Agency. P4P was hired as the project consultant and P4P founder and project director, Eric Cote, conducted the census which captured data on 271 generators.
Overall, 87 generators or 32 percent of the total, were in excess of thirty years of age including 40 generators between 40 and 49 years of age, 9 between 50 and 59 years of age and 6 between 60 and 65 years of age. The percentage of generators in excess of 30 years of age among the 14 single generator hospitals included in the census was twice as high, at 64 percent. The useful life of a generator is considered 30 years of age[1].
The problem of outdated generators is not limited to hospitals. In 2023, a series of severe weather events prompted the U.S. Department of Health and Human Services (HHS), Office of the Inspector General, to conduct onsite inspections of emergency power systems in 154 nursing homes across eight states. The audit found numerous facilities with generators more than 30 years old.
Current federal requirements do not limit the age of emergency power system components but mandate monthly testing for hospital and nursing home generators and every three years, generators must be operated for a four-hour period at various percentages of their rated capacity.
P4P Convenes Expert’s Panel to Discuss Risks Posed by Outdated Emergency Power Equipment and Mitigation Solutions
In response to its discovery of outdated generators in LA County, P4P teamed up with the California Society of Healthcare Engineering (CSHE) to convene an Expert’s Panel that took place on December 4, 2025. Panelists discussed the LA County findings, the risks associated with outdated healthcare facility generators and potential mitigation strategies. Panelists included experts on federal and state generator performance and testing requirements for hospitals and nursing homes, hospital facility directors and generator service providers.
One panelist, Robert Solomon, P.E., currently serves as the Chief Development Officer in the Boston office for SOCOTEC, a global construction and infrastructure consulting firm. Solomon was previously a Director at the National Fire Protection Association (NFPA) and led the team at NFPA responsible for development of several of the fire protection and life safety codes referenced in the Centers for Medicare & Medicaid Services (CMS) Emergency Preparedness (EP) Rule.
The EP Rule establishes base standards for generator performance, inspection, testing and maintenance (ITM) in hospitals and nursing homes to protect patients, residents, staff and visitors during power outages. The EP Rule designates the 2012 edition of NFPA 99, Health Care Facilities Code and the 2010 edition of NFPA 110, Standard for Emergency and Standby Power Systems as its requirements for emergency power systems in hospitals and nursing homes, as well as other facilities governed by the EP Rule.
Given the discovery of aging generators in LA County, Solomon is suggesting that it may be time to consider different or enhanced testing of aging emergency power system components. “When CMS first published its proposed Emergency Preparedness Rule, generator age wasn’t a consideration, and at the time as well as now, neither NFPA 99 or NFPA 110 had any limits on the life span of the generator components,” said Solomon. “The inspection, testing and maintenance requirements embodied in NFPA 110 have been seen as the best way to safeguard against generator failures. In retrospect, given the discovery of older generators in LA County, generator component age is something that I believe should be evaluated for future code changes and state or federal regulation.”
The LA County findings have already spurred another proposed change to NFPA 110. During the August 2025 meeting of the NFPA 110 Technical Committee, a committee member, Skip Gregory, AIA, who was on the December 4th panel, reported on the discovery of outdated generators in LA County which prompted a proposed new annex section (Annex D) for the next edition of NFPA 110. The Annex language, as proposed, would, among other things, call attention to the need to provide additional scrutiny to older components of an emergency power supply system that may be approaching or even past their expected life cycle.
Among the recommendations that emerged from the Expert’s Panel is requiring single generator hospitals to install quick connect devices that would allow a rapid connection of a temporary generator. Panelists also discussed requiring single generator hospitals to install commonly available monitoring equipment that would provide an automated, real-time alert to designated individuals anytime the generator experiences a problem while operating.
Without a second generator, patients in single generator hospitals face a higher risk of emergency evacuation if the facility’s only generator fails. The risk of generator failure is higher for facilities that fall behind on the routine maintenance recommended by generator manufacturers. Adding fault detection and diagnostic (FDD) equipment that provides real time alerts about a serious threat to emergency power would accelerate response by facility personnel and service providers. This early warning could also accelerate response by local government agencies, which could include readying evacuation assistance or deploying a temporary, portable generator.
LA County EMS Agency Response to Discovery of Outdated Generators Offers Blueprint for Other Jurisdictions
LA County EMS Agency officials were alarmed by the discovery of outdated generators and enlisted P4P’s help to develop a series of new, groundbreaking protocols to accelerate emergency power status reporting by hospitals during a power outage, and to help hospitals identify problems that may not be detected during routine generator testing. The EMS Agency also implemented the first confidential risk-rating of hospital emergency power systems initiated by a health agency. The risk rating makes it easier for EMS Agency officials to maintain closer vigilance during power outages of hospitals with outdated generators, limited onsite fuel storage capacity or only a single generator.
The EMS Agency also offered funding to its 14 single generator hospitals to deploy generator monitoring equipment as part of a pilot project. Two of the hospitals deployed the equipment and Powered for Patients monitored real time alerts for an 18-month period.
The new EMS Agency protocols were published in the Agency’s Healthcare Facility Emergency Power Resilience Playbook, a resource that can serve as a guide for other jurisdictions interested in boosting emergency power resilience for hospitals.
“The LA County EMS Agency should be applauded for initiating a thorough review of the emergency power systems in its hospitals and for moving swiftly to address the vulnerabilities we discovered,” said P4P’s Eric Cote. “It’s very likely that what we found in LA County reflects the state of emergency power in hospitals across California and the rest of the country. This represents a hidden danger that should be promptly addressed by emergency managers and public health officials. At a minimum, jurisdictions should conduct a census of the emergency power systems in their facilities so they can identify facilities with significant risk factors.”
P4P has added a number of resources to its website to help jurisdictions assess and mitigate vulnerabilities, including a Good, Better, and Best Guide to Bolstering Emergency Power Resilience, an Emergency Power Resilience Resource Kit that includes many of the universally applicable elements of the LA County Playbook, and guidance on conducting a census of emergency power systems in hospitals and nursing homes.
Experts Attest to Challenges Posed by Outdated Equipment and Poorly Maintained Diesel Fuel
The December 4th Expert’s Panel included generator service providers who attested to the serious challenges hospitals and nursing homes face when relying on outdated equipment or when failing to properly treat tanks of diesel fuel to prevent bacterial growth that can hinder the operation of generators.
Quinn Power Systems, the local Central and Southern California Caterpillar dealer, services a number of the hospital generators in LA County. Andrew Salem, Quinn Power Systems’ Product Support Sales Manager, took part in the panel discussion. “We take care of quite a few hospital generators, including some that are relatively new and others that are very old,” said Salem. “Among the biggest challenges for clients relying on outdated generators is finding parts in a timely fashion when repairs need to be made. We’ve seen situations where a client will have to wait for months for the factory to make a part that is no longer kept in stock. In these cases, our clients end up incurring huge rental costs that could have been invested in replacing outdated equipment.”
Brandon Morales, the service manager for Collicutt Energy Services, which services hospitals and nursing homes across California, underscored the importance of proper fuel maintenance. “We had a hospital client that hadn’t properly treated its diesel fuel tank which allowed bacteria to grow to the point where the generator wouldn’t start during a routine test,” said Morales. “The entire tank had to be emptied, and then properly cleaned and refueled. The client also faced the avoidable expense of having to replace fuel filters and fuel pumps.”
Sal Martorana, the founder and President of Global Power Group, and a panelist, said California’s stringent air quality standards and seismic requirements for emergency power systems in hospitals and nursing homes makes the cost of replacing outdated generators unaffordable for many facilities. “We work with clients all the time that want to update their emergency power system but simply cannot secure the funding from leadership they need,” said Martorana. “With hospital finances so tight, limited resources are going to investments that can generate revenue, like new MRI machines, instead of updating emergency power system components.”
Steve Works, a Caterpillar technical expert who works with Blanchard Energy, the CAT dealer in South Carolina, has studied hospital emergency power failures across the country for years. Works shared some of his findings with other panelists. “In my experience, an emergency power system that experiences problems in its first ten years of service often reflects flaws in the design, execution of the design, or commissioning of the design,” said Works. “Problems that don’t arise until a system is ten years old or older are usually caused by the failure to conduct proper predictive maintenance and updates of emergency power supply system components.”
Narsimha Irrinki, MS, PE, CHFM, CPE, the Enterprise Director of Facilities at Santa Clara Valley Healthcare, a four-hospital system based in San Jose, CA, took part in the Expert’s Panel. He said securing funding for emergency power modernization is very difficult, in part due to the added expense tied to California’s stringent environmental regulations of diesel generators. Irrinki discussed his growing use of fault detection and diagnostic equipment to stretch the capabilities of his engineering staff, which is smaller today than in previous years. “We recently installed monitors in many of the elevators in our four hospitals so we can now remotely see the operating status of these elevators during a power outage, said Irrinki “We’re looking to deploy this same technology to better monitor our HVAC system and our emergency power systems.”
“Aging hospital infrastructure is a challenge facing virtually every hospital across the country, and so we applaud the LA County EMS Agency and Powered for Patients for their model work addressing emergency power vulnerabilities,” said Joe Brothman, the Director of General Services at UCI Medical Center, a 459-bed acute care hospital in Orange, CA. Brothman, who along with Irrinki, is a member of the CSHE Executive Committee, took part in the panel discussion. “It’s important that experts and policy makers continue to have conversations about the challenges hospitals face in safeguarding emergency power and whether the current regulatory framework adequately addresses the risks posed to patients from outdated emergency power systems.”
[1] Based on a recommendations included in Roadmap to Resiliency, a white paper on emergency power resilience authored by P4P Project Director Eric Cote and Jonathan Flannery of the American Society for Healthcare Engineering.