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3 min read

Healthcare Emergency Power Systems Navigating Reliability, Compliance, and Risk

Healthcare Emergency Power Systems Navigating Reliability, Compliance, and Risk

Emergency power systems are the last line of defense when healthcare facilities lose utility power. Steve Works, EPSS expert and NFPA technical committee member, sees the latest updates to NFPA 110 as important guidance for healthcare facilities evaluating generator starting systems and battery performance. As hospitals and other critical care facilities prioritize resilience, reliability, and regulatory compliance, understanding these changes are increasingly important.

Here, Steve breaks down the major modernizations in the newly adopted 2025 edition, including changes to battery requirements and a greater emphasis on performance-based testing methods.

NFPA 110 (2025 Edition): Newest Language on Battery Types & Testing

The NFPA 110 2025 edition is now the active standard being adopted into 2026 compliance cycles. Key updates are confirmed in industry summaries and code update analyses. While the CMS accreditors may be clinging to older versions of NFPA 110 (as well as NEC, NFPA 101 & NFPA 99), CMS has also directed Level 1 & Level 2 healthcare facilities to adhere to the ‘All-Hazards’ approach outlined in 2016. At the highest levels, this encourages facilities to adopt safety-driven changes centered around patient care and infrastructure. 

Observing the safety, reliability, and budgetary concerns of the healthcare industry, Stored Energy Systems (SENS) has provided a ‘tip-of-the-spear’ solution for two of the key changes made to 2025 NFPA 110.

1. Expanded acceptable starting battery types

NFPA 110 (2025) now explicitly allows safer, modern battery chemistries, not just lead acid or NiCd.
Newly permitted battery chemistries:

  • Nickel zinc (NiZn)

  • Lithium ion (Li-ion)

  • Traditional lead acid and nickel cadmium remain allowed

These newer chemistries are permitted as long as they meet cranking performance criteria for Level 1 or Level 2 EPSS systems.

This is the first major modernization of NFPA 110 battery language in decades.

2. Cranking voltage drop as the “safest and best” battery performance metric

Why it’s the gold standard under NFPA 110 (2025):

  • Real world stress test: Cranking voltage drop measures battery voltage during actual engine cranking, not just open circuit or float voltage. It shows whether the battery can deliver high current when the generator must start—exactly what CMS and NFPA care about.

  • Direct tie to NFPA 110 (2025): Annex language (A.8.3.6.1.2) explicitly calls out cranking voltage drop as the preferred way to verify starting battery performance, instead of relying only on traditional capacity tests or static readings.

  • Safer across chemistries: With NFPA 110 (2025) allowing lead-acid, NiCd, NiZn, Li-ion, and other stored energy technologies, a performance-based test (cranking voltage drop) is the most chemistry agnostic and safety aligned way to prove readiness. 

How to frame it in your program language

Risk based statement (CMS all hazards):
The facility uses cranking voltage drop testing during generator start as the primary indicator of starting battery health, because it directly measures battery performance under emergency start conditions and supports the All-Hazards objective of reliable power restoration

Technical requirement (NFPA 110 aligned):
For each EPSS starting battery, the facility shall record battery voltage immediately prior to crank and minimum voltage observed during crank and compare to manufacturer and NFPA 110 based thresholds. Any abnormal or trending degradation triggers corrective action under the Reliability Centered Maintenance plan. 

This does not include ‘locked-rotor’ voltage drop sensed during the first few milliseconds of the crank signal; rather, we’re observing the actual voltage sag for the duration of the first crank attempt. If for some reason the prime mover fails to start during the first cranking cycle, we’ve already missed the 10-second response for emergency power provision (noted in the appendix of NFPA 110).

How has SENS addressed these changes? 

  • The SuperTorque® 8Z platform utilizes nickel-zinc batteries for a safer alternative to lead-acid, NiCad, or other platforms. There are no hazmat considerations or limitations on shipping and handling.

  • The package includes a built-in battery charger with an HMI (Human-Machine Interface) that captures cranking voltage drop.

  • The platform has a 10-year factory warranty with a replacement cycle at 15 years, similar to existing NiCad platforms. When compared to the previous allowed batteries (lead-acid & NiCad), the cumulative cost savings over this ten-year period are tremendous.

In closing, the SENS SuperTorque 8Z has already been implemented at critical data retention centers nationwide. With the changes made to NFPA 110; and observance of the CMS ‘All-Hazards’ directive, I have confidence that this platform will be folded into N+1 redundant EPSSs and Level 2 facilities immediately. Whether I am performing on-site hospital checks, conducting hospital EPSS design-phase reviews, or participating in speaking engagements, I ensure this product is part of the conversation.

 

About the Author

Steve Works* is Principal Consultant at Works Power - Critical Energy Consulting and a member of the NFPA technical committees responsible for NFPA 110 and NFPA 111. With nearly four decades of experience in emergency power systems, he has supported healthcare facilities, government agencies, utilities, and mission-critical infrastructure projects worldwide. Steve specializes in EPSS assessments, training, design reviews, and reliability-focused maintenance programs.

Steve Works | LinkedIn

*Although a Member of the Technical Committees Responsible for NFPA 110 & 111, the context & contents of this article do not necessarily reflect those of the Committee(s). No part of this article may be shared, duplicated, or edited without expressed written permission by the author.

 
2025 NFPA 110 changes

This complimentary SENS report covers 2025 updates, including the 7 key categories impacted. Details provided on battery type regulation changes, cranking voltage drop requirements, and more.

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