Eyewash Stations at Generators
by Brad Keyes, CHSP, on Aug 19, 2020 12:00:00 AM
Q: We recently took a webinar that informed us that accreditation organizations have cited hospitals for not having "emergency eye/shower stations" at the generator for the lead-acid batteries (this could be expensive and if outside, require a shelter of some sort for the station). They further stated that going to the maintenance free batteries for emergency generators would make installing the stations not necessary. I've checked with our AHJ for CMS Fire Safety rep who has made reference to NFPA 110, 2010 edition, Section 188.8.131.52. I only see where the nickel-cadmium batteries may be questionable with the flip-top/flame arrester vent caps. I'm guessing with the lead-acid batteries we can go with a maintenance free type. Have you heard of this and is there an issue with going with maintenance free starting batteries for emergency generators (hospital)?
A: Yes, I’ve heard (and seen) sealed lead-acid batteries used as generator start batteries. Prior to the 2012 LSC being adopted, hospitals were on the 1999 edition of NFPA 110, which did not address sealed lead-acid batteries as generator start batteries. Actually, the 1999 edition did not prevent them from being used, but it also did not address them. Probably because they weren’t available for use as generator start batteries in 1999. Some state agency AHJs decided sealed lead-acid batteries could not be used as generator start batteries because the 1999 edition of NFPA 110 did not ‘allow’ them.
I disagree with that interpretation, but I respect the right of the AHJ to make their own interpretation. Then the 2012 LSC was adopted effective July 5, 2016, and it referenced the 2010 edition of NFPA 110, which does recognize sealed lead-acid batteries as generator start batteries. Section 184.108.40.206 says lead-acid batteries are acceptable to use as generator start batteries, but it does not limit lead-acid batteries to a specific type. Section 220.127.116.11 says battery conductance testing is permitted in lieu of testing specific gravity when applicable or warranted. That would be warranted when the battery is sealed and access to the acid is not possible. Therefore, sealed lead-acid batteries for use as generator start batteries are acceptable. And you’re right — it would be cheaper to have sealed lead-acid batteries than having non-sealed batteries and have to install eyewash stations.
Remember, you are required to replace the generator start batteries once every 30 months (section A.18.104.22.168.1 of NFPA 110-2010). As far as where eyewash stations are required, you won’t find a standard the specifically requires them at generator locations. The need for an eyewash station in any particular location is dependent on a risk assessment evaluating the risks associated with the probability of the caustic or corrosive chemical splashing into the eyes. If your risk assessment determines the risk is non-existent (or negligible), then an eyewash station is not required. Just remember though, a surveyor is not obligated to accept your risk assessment. If he/she disagrees, then you may still be subject to a finding.