Q: We have chosen to install some extra battery egress lights in our hospital that are not required. One of these areas is our stairways. 100% of the lighting in our stairways is served by the hospital’s generators including the circuits that feed the egress lights. We installed the battery egress lights to help keep people calm and avoid falls during the ~5 second transition to generator power. Do we need to do 90-minute annual testing on battery lights served by generator power? We will continue the 30-second monthly testing, but the 90-minute testing is difficult as all lighting in the stairway must be turned off during testing. Also, these lights will never see a 90-minute outage. NFPA 101 2012 184.108.40.206 says an annual test shall be conducted on every required battery-powered emergency lighting system for not less than 1 ½ hours. Since these are not required, I am hoping that as these lights do not need the annual test.
A: Well, I’m sorry to say, but section 220.127.116.11 of the 2012 LSC says if you have an existing feature of life safety that is not required by the LSC but is obvious to the public then you must maintain it or remove it. I think we’d all agree that battery powered emergency lights would be obvious to the public. According to the NFPA standards, maintaining it includes the monthly 30-second test and the annual 90-minute test.
You say the 90-minute test will be difficult since the normal power to the battery powered emergency lights are on the same circuit as the stairwell lighting. Well, I see your point. You cannot turn off the circuit to the stairwell lighting for 90 minutes… that would be the wrong thing to do. I suggest you install a toggle switch on the battery powered emergency light fixture, preferably on top where it cannot be inadvertently turn off. This toggle switch will turn off the normal power to the battery powered emergency lights and you can perform the 90-minute test without interrupting normal power to the stairwell lights.
So, you must test those battery powered lights, even if they are not required. Personally, I like your thinking… providing battery powered lights for the 5 seconds or so of darkness in the stairwell, even though you don’t have to.