The routine maintenance and operational testing program shall be based on the minimum requirement of NFPA 110 (Chapter 8), manufacturer’s recommendations, instruction manuals, and the authority having jurisdiction.
The paragraph below is essentially the genesis of all maintenance and testing (M/T) protocols. Why? Because while other standards are concerned with maintenance and testing, all refer to NFPA 110, and paragraph 8.1.1 marks the beginning. Paragraph 8.1.1 is just one sentence in length, but what does it mean? We think it means that the final “authority” is the manufacturer and what is contained in its equipment manuals.
NFPA 110, 8.1.1 The routine maintenance and operational testing program shall be based on all of the following:
- Manufacturer’s recommendations
- Instruction manuals
- Minimum requirement of this chapter
- The authority having jurisdiction
NFPA 110, A.8.1 The continuing reliability and integrity of the EPSS are dependent on an established program of routine maintenance and operational testing.
How each facility responds to this simple statement is what complicates the equation, because while manufacturers’ recommendations should be the basis of the M/T program, manufacturers cannot control what M/T programs are ultimately followed by the end user.
Your responsibility is to see that an M/T program which adheres to the intent the manufacturer put into place. If your facility, along with your EPSS contractor is successful in this, you will avoid the undesired involvement of other parties: attorneys, anyone injured, or worse, because of EPSS failure, the media, more attorneys––you get the picture.
If you are not confident that your equipment is being maintained and tested according to manufacturer’s guidelines, your first step to ensuring compliance should be to meet with your EPSS contractor to review and compare the recommendations in the equipment manuals with your current procedures. Don’t be surprised if omitted items such as megger tests and valve lash adjustments are not in the M/T protocol.
In addition to confirming the service technician follows all M/T procedures, you should include a paragraph in your M/T agreement with the contractor stating, “All Maintenance and Testing Procedures will be carried out according to the latest edition of NFPA 110.” This statement should lock the contractor into any proceedings that may follow an accident.