Hydrogen Fuel Cells for Power at Health Care Facilities

May 1st, 2026

by Carl Rivkin, P.E., Shea Barrett-Rivkin, Prasad Prabhakar Joshi

There is potential value in using hydrogen fuel cells to provide backup and primary power at healthcare facilities. These hydrogen fuel cell systems may be an effective technology option in some applications where certain criteria are met but not in all potential applications. Here we address the basic code requirements for these systems as well as where hydrogen systems could be an effective solution for providing power at healthcare facilities, specifically:

Defining a basic hydrogen fuel cell power system
Describing the hazards and code requirements for these systems
Providing an economic and technical analysis showing where these systems could provide value

Health care facilities require reliable backup and primary power. There are systems that can not tolerate a power outage without endangering the lives of patients. As the grid sees additional demands, there is an increased need to find other technology options to provide the required power.

Basics of Hydrogen Fuel Cell Systems

There are several fuel cell technologies available for commercial deployment including anionic fuel cells, alkaline fuel cells, and Proton Exchange Membrane (PEM) fuel cells. This paper considers PEM fuel technology for the fuel cell system because PEM fuel cells can best meet the required performance parameters for health care facility backup power and primary power. The basic components of a hydrogen fuel cell system are:

Compressed hydrogen storage system- supply hydrogen
Fuel cell stack- produces electricity and water
Thermal management systems- control stack temperature
Compressor- compresses inlet air to required pressure
Humidifier- manages stack hydration

Backup power requirements for healthcare facilities must meet the following requirements:.

Rapid Activation: Backup power must be restored to required loads within 10 seconds of the primary power failure.
Sustained Operation: Hospitals must have the capacity to run their generators for at least 96 hours, either through on-site fuel storage or a secure fuel delivery agreement.
NFPA 110 Compliance: Generators and emergency power supply systems (EPSS) must be Type 10 systems as defined by NFPA 110, which sets the standards for emergency power.
Regular Testing and Maintenance: Systems require monthly load tests, annual testing, and ongoing maintenance by qualified technicians to ensure they function when needed.
Joint Commission Standards: The Joint Commission also mandates these requirements for healthcare facilities, focusing on the 96-hour fuel plan. The Joint Commission is an organization that sets standards for healthcare facilities.

Hydrogen PEM fuel cells offer a potentially valuable technology option for providing power because they can meet the following performance criteria:

Clean- no air pollutant emissions such as residual hydrocarbons produced by diesel generators
Quiet- basically no moving parts
Reliable- used for data centers and cell tower sites where power outages can not be tolerated
Fast start-up in the seconds range
No combustion process requiring siting restrictions and air quality permits
Require little space and make more locations viable due to no emissions and noise issues

These performance characteristics of hydrogen fuel cells allow them to meet several of the mandated performance criteria and make them a potentially valuable option for providing power at healthcare facilities.

Fuel Cell Safety and Code Compliance

The Regulations, Codes, and Standards (RCS) that address hydrogen fuel cell systems mitigate the system hazards. Hydrogen fuel cells produce electricity by separating the hydrogen and oxygen feed into electrons and protons and combining protons with the oxygen feed to produce water. The primary hazards of fuel cells are:

Flammability hazards associated with the hydrogen gas storage
Electrical hazards associated with high-voltage components

The fuel cell system does not typically contain hydrogen in amounts above the Maximum Allowable Quantity (MAQ) (as defined in IFC Section 202 General Definitions) for hydrogen set in the International Fire Code (IFC). The storage component of a hydrogen fuel cell system contains most of the hydrogen and presents most of the system flammable gas hazard. There are mature RCS that address hydrogen storage systems

The Regulatory Landscape can be broken down into a RCS hierarchy starting with Federal regulations and ending with local ordinances. Table 1. Key RCS gives an overview of the RCS that apply to hydrogen fuel cell systems. These requirements are comprehensive and established which should make regulatory compliance and permitting straight-forward.

Most of the safety requirements reside at the code and standard level of the regulatory hierarchy. The following diagram illustrates the regulatory progress from the building code and the key codes and standards that follow the initial Building code requirements.

Table. 1 Key RCS for Hydrogen Fuel Cell Systems
RCS	Compliance
Federal regulations- OSHA Process Safety Management (PSM) and EPA Risk Management Plan (RMP) – both triggered by 10,000 lb. storage	Not likely to apply to fuel cell storage.
OSHA 29 CFR § 1910.103 Hydrogen- hydrogen safety	Worker safety regulations must be met.
State Regulations- for example California CUPA for hazardous materials and State Health Department Regulations for installations at healthcare facilities	Facilities in California will likely have to file a California Environmental Reporting system application that should not require significant effort.
Local Permitting Jurisdiction- regulatory requirements start with the adopted Building and Fire Code
Most Jurisdictions in the US adopt an edition of the International Building Code (IBC) and International Fire Code (IFC) -(“the Fire Code”) The IBC and IFC reference NFPA codes including NFPA 2 Hydrogen Technologies Code	Most systems are outdoors and do not require construction of a building meaning the applicable requirements will be in the Fire Code.
IFC
Chapter 50 of the International Fire Code (IFC).	Sets requirements for hazardous materials storage including hydrogen which is addressed as a flammable gas.
Section 1206 Stationary Fuel Cell Power Systems of the IFC is essentially a replication of the requirements found in NFPA 853 Standard for the Installation of Stationary Fuel Cell Power Systems.	Sets requirements for the installation of fuel cell systems including the requirement that system be certified in accordance with CSA/FC1
NFPA 2
NFPA 2 Hydrogen Technologies Code, addresses fuel cells chapters 4,6,7, & 12 and is actually more comprehensive coverage than in NFPA 853 because it addresses hydrogen storage where most of the system’s hydrogen resides and where there is the greatest risk of significant hydrogen releases.	NFPA 2 sets safety requirements that address all of the hazards of hydrogen storage and use in the fuel cell system including: ● High-pressure gas storage including vessel design, piping, pressure relief devices, and venting ● Ignition source control ● Electrical safety ● System testing and maintenance
Chapter 4 General Safety Requirements- administrative and general requirements similar to Chapter 50 of the IFC	Administrative requirements such as inventory management and emergency response plans
Chapter 6 General Hydrogen Requirements- requirements that apply across all systems such as the use of ASME codes for piping design and CGA standards for venting and pressure relief.	Component design and other requirements that would apply to any system.
Chapter 7 Gaseous Hydrogen – hydrogen storage system requirements including container design, safety setbacks, and installation in hydrogen equipment enclosures.	Control of high-pressure gas storage hazards including requirements for using hydrogen in Hydrogen Equipment Enclosures (HEEs).
Chapter 12 Hydrogen Fuel Cell Power Systems – an extraction of key requirements for hydrogen fuel cells from NFPA 853.	Requirements mirror section 1206 of the IFC and include siting, installation, and certification requirements.
NFPA 99 Health Care Facilities Code
Requirements for power delivery time and power duration.	Requirements are based on the category rating of the system with Category 1 Systems power outage leading to serious injury or death.

In summary, the RCS for hydrogen fuel cell systems are well defined and should not present a serious barrier to deploying these systems at most healthcare facilities.

Strengths and Weaknesses/Technical Analysis

For a project in the right location fuel cells can be cost effective. Factors to consider include the following shown in Table 2. Fuel Cell System Evaluation:

Table 2. Fuel Cell System Evaluation
Strength	Weakness
	Cost of hydrogen may be higher than alternative fuels
	Cost of fuel cell system may be higher than alternative technologies
Reliability of fuel cells is higher than most other technology options reducing likelihood of downtime
Fuel cell is quieter than most other technology options
Fuel cell does not produce any regulated pollutants
Fuel cell may be funded through clean energy incentives
	Fuel cell systems need to be operated regularly to ensure that the fuel cell stack does not degrade
Fuel cells for power can be operated at lower pressures than vehicle fuel cells eliminating the need for a compressor and reducing system costs.	Sets requirements for installation and operation of fuel cell systems. Also, requires that system systems be designed, tested, and listed in accordance with ANSI/CSA FC1, Fuel Cell Technologies — Part 3-100: Stationary Fuel Cell Power Systems — Safety. This requirement means systems can not just be approved by the AHJ, they must be listed by a NRTL.

Key Takeaways

Hydrogen fuel cells can be a technology option at health care facilities that require backup power. Hydrogen fuel cell systems will likely be a more expensive option than existing technologies but the advantages of hydrogen fuel cell systems may justify the higher cost. There are commercially available hydrogen fuel cell systems that can be deployed and there are a small number of healthcare facilities that have deployed hydrogen fuel cell systems.

The RCS for hydrogen fuel cell technologies are well developed which means there is an established regulatory compliance and permitting path. The hazards and safety measures required to design, install, and operate hydrogen fuel cell systems are established and may present improvements in safety and environmental impacts over existing technology options.

As the demand for electricity increases and the availability of electricity decreases, hydrogen fuel cell systems may prove to be a viable technology to provide power at healthcare facilities.