NFPA 110 compliance is not just about having a generator that starts. It is about proving, on paper, that the system was maintained and tested to standard. When an inspector walks in – or when something fails during an outage – the documentation is what determines whether you pass or whether you have a problem. This checklist covers the fuel-related records that consistently come up short.
What NFPA 110 requires, in plain terms
NFPA 110 establishes minimum performance requirements for emergency and standby power systems. For Level 1 systems (where failure would affect life safety), requirements include monthly exercise runs under load, annual full-load tests with recorded runtime and performance data, documented fuel quality testing at defined intervals, fuel level verification as part of routine inspections, and transfer switch testing and documentation.
Fuel-related documentation checklist
Delivery records (maintain for minimum 3 years):
- Date and quantity of each delivery
- Fuel type (ULSD, diesel, bioblend percentage if applicable)
- Supplier name and contact
- Tank level before and after delivery (where monitored)
Fuel quality records:
- Laboratory test results for stored fuel (ASTM D975 compliance)
- Date of last fuel sample and who performed it
- Fuel polishing records if performed (date, provider, pre/post test results)
- Any biocide treatments applied (date, product, quantity)
Tank inspection records:
- Date and findings of last tank inspection
- Water accumulation checks (bottom sampling)
- Vent and fill cap condition
- Spill containment inspection
Generator exercise and test logs:
- Date and duration of each monthly exercise
- Load percentage during exercise (or note if unloaded)
- Fuel level at start of test
- Fuel consumed during test (calculated or metered)
- Annual load test data: date, load percentage, continuous runtime, fuel consumption, technician signature
Where fuel suppliers fit into NFPA 110 documentation
Your fuel supplier should be able to provide, on request: delivery history reports by date range and property, certificates of analysis for fuel quality (not all suppliers offer this – ask before you need it), and tank monitoring logs showing fuel level history (if a monitoring system is installed and integrated).
If your current supplier cannot produce delivery records in a usable format, that is worth addressing. Inspectors and insurance carriers increasingly ask for this documentation and a verbal “we have that somewhere” is not sufficient.
Common documentation gaps found during inspections
- Monthly exercise logs missing for several months (common when a generator tech transitions)
- No fuel quality testing on record for the stored fuel
- Annual load test performed but load percentage not recorded
- Delivery records held by the fuel supplier but not maintained on-site in the equipment file
- Transfer switch test results documented in a format that does not show retransfer to normal
Practical recommendation
Keep a dedicated binder or folder per generator – physical or digital – that contains all of the above. Request delivery summaries from your fuel supplier annually and file them with the equipment records. Before any planned inspection or certification, pull the binder and run through the checklist above. The gaps are almost always findable before the inspector finds them.
Questions about fuel delivery for your facility?
Call (215) 659-1616 or get a quote online. Fox Fuel serves commercial accounts across Pennsylvania and New Jersey from our Willow Grove location – family-owned since 1981.