There is often confusion about whether the EC.02.05.07 EP3 SEPSS testing requirements apply to the ubiquitous hospital UPS’s that are powered by the emergency power “branches” (life safety branch, critical branch, and equipment system.)
The short answer is that a UPS that gets its power from an EPSS (Emergency Power Supply System) is not a SEPSS. Therefore SEPSS testing requirements do not apply to such UPS’s. Be careful though, you still need to maintain and test any of your non-SEPSS UPS’s that are critical for operations during a power failure in accordance with Note 1 of EC.02.05.07, EP3.
“Note 1: Non-SEPSS battery backup emergency power systems that the hospital has determined to be critical for operations during a power failure (for example, laboratory equipment or electronic medical records) should be properly tested and maintained in accordance with manufacturer's recommendations.”
NFPA Disclaimer: Although the author is Chair of the NFPA Technical Committee on Emergency Power Supplies, which is responsible for NFPA 110 and 111, the views and opinions expressed in this message are purely those of the author and shall not be considered the official position of NFPA or any of its Technical Committees and shall not be considered to be, nor be relied upon as, a Formal Interpretation. Readers are encouraged to refer to the entire text of all referenced documents. NFPA members can obtain NFPA staff interpretations at http://www.nfpa.org/.
TJC has been consistent in its responses to these questions:
Environment of Care® News September 2005, Page 6:
Question: Standard EC.7.40 states that an organization must test quarterly for five minutes (or as specified by its class) and annually for 60% of the duration for its class all stored emergency power supply systems (SEPSS) whose nonfunction may jeopardize an occupant’s life and safety. If an organization has an emergency generator that transfers within 10 seconds of power outage and a battery-operated, uninterruptible power supply (UPS) unit acting as a SEPSS, is the annual testing of the SEPSS at full load for 60% of duration for its class necessary, or are the quarterly five-minute tests, as defined above, required?
Answer: Assuming that the organization’s emergency generator is providing the emergency power needs for its facility per the requirements of NFPA 99, NFPA 110, NFPA 111, and NFPA 70 (National Electric Code), the UPSs you have are considered a “supplemental” utility backup system and not a “required” SEPSS. Therefore, neither test is required.
Environment of Care® News, April 2004, Page 7, Batteries:
Question: If a fire alarm system or a communication system is backed up by emergency generator power, are the batteries that keep these systems on line (while the generator is starting up) considered part of the Stored Emergency Power Supply System (SEPSS)? If so, would they be subject to the testing requirements stated in EC.7.40, EP 4?
Answer: No, the Joint Commission would not consider those batteries as part of the SEPSS, and they would not be subject to the testing requirements of EC.7.40, EP 4.
NFPA 111 is the standard covering SEPSS (Stored Electrical Energy Emergency and Standby Power Systems.) The NFPA Technical Committee clarified this issue as well in NFPA 111-2010 by excluding such UPS’s from the scope of NFPA 111 in new paragraph 1.1.4.1(6):
1.1.4.1 This standard shall not cover the following:
(1) Application of the SEPSS
(2) Distribution wiring
(3) Systems having total outputs less than 500 VA or less than 24 V, or systems less than Class 0.033
(4) Unit equipment
(5) Nuclear sources, solar systems, and wind stored-energy systems
(6) Uninterruptible power systems (UPS) supplied by an emergency power supply system (EPSS)
The NFPA 111 ROP (Report on Proposals) indicates the reasoning for this change as well as the acceptance of this clarification by the NEC® Technical Correlating Committee:
111-4 Log #CP9 EPS-AAA Final Action: Accept
(1.1.4.1)
TCC Action: Article Scope statements are the responsibility of the Technical Correlating Committee and the Technical Correlating Committee Accepts the Technical Committee action.
Submitter: Technical Committee on Emergency Power Supplies,
Recommendation: Add a new item (6) to read:
Uninterruptible power systems (UPS) supplied by an EPSS.
Substantiation: The UPS is bridging a time gap between the loss of normal power and operation of the EPSS. The UPS is redundant to the EPSS.
The NFPA 111 ROC (Report on Comments) also added a graphic (new Figure B.1) that further clarifies the difference between a SEPSS and a UPS that bridges the time gap between the loss of normal power and the operation of the EPSS.
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