Battery Powered Emergency Lights

Q: NFPA 101-2012, section 7.9.3 requires 1½-hour testing of battery powered emergency lights annually. The Joint Commissions wording of EC.02.05.07 EP-2 states to do that OR the hospital replaces all batteries every 12 months and performs a random test of 10% of all batteries for 1½-hours. Because NFPA 101 does not give that second option, can we really do that (the second option) and be compliant? We’ve felt it’s easier to replace the batteries annually and test a random 10% during that time period than to test all of the over 100 battery powered emergency lights we have. Secondly, NFPA 101-2012, section 7.9.3 does not mention egress vs. task battery powered emergency lighting. Seeing it is located in chapter 7 ‘Means of Egress’, is it implied it only means battery powered emergency lights used for egress? Joint Commission specifically says egress lighting. Several of our battery powered emergency lights are task lights and this would allow us to cut down on monthly and annual testing. Do we need to be as stringent on task lighting as we are on egress lighting to remain compliant?

A: First of all, Joint Commission dropped the option of replacing the batteries and testing 10% of the battery powered emergency lights, in the 2018 CAMH manual, standard EC.02.05.07, EP 2. Starting January 1, 2018, you need to conduct monthly tests and annual tests of all battery powered emergency lights.

I am aware that Joint Commission tries to give the hospitals a break by saying only the battery powered emergency lights used for egress and Exit signs need to be tested. And in their 2018 manual, standard EC.02.05.07, EP 2 they inserted a new section that says battery powered emergency lights in new construction/renovated sedation and anesthetizing areas are tested for 30 minutes annually. But please understand that Joint Commission’s standards are not compliant with the 2012 Life Safety Code, section 7.9.31.1 (3) which requires 90-minute annual test. If you follow Joint Commission’s standards on this issue, you may be cited by a state surveyor for not complying with the annual testing requirements of section 7.9.3.1.1 (3).

Section 4.6.12.3 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 whether they are used to supplement the EM powered egress lighting or if they are used for task lighting in certain areas. According to the 2012 LSC, section 7.9.3, maintaining it includes the monthly 30-second test and the annual 90-minute test.

To be compliant with the 2012 LSC, you need to test the battery powered emergency lights monthly and annually. I suggest you re-evaluate the need for all of the battery powered emergency lights that you have, and invest into self-diagnostic units to eliminate the monthly test requirements.

Battery Powered Emergency Lights

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 7.9.3.1 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 4.6.12.3 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.

Business Occupancy Emergency Lighting

Q: I have a question concerning an ambulatory surgery center that is now converted over to a business office only. We are not doing any patient care in this facility. We currently have a generator that supports the egress lighting and exit signs. What are our requirements for testing and maintaining this generator for a business occupancy?

A: Since you say the building is now classified as a business occupancy, we need to look at Chapter 38 in the 2012 LSC for direction. Section 38.2.9.1 says emergency lighting must be provided in accordance with section 7.9 where one of the following conditions exist:

  • The building is three or more stories in height
  • The occupancy is subject to 50 or more occupants above or below the level of exit discharge
  • The occupancy is subject to 300 or more total occupants

If you do not meet one (or more) of the above conditions, then emergency lighting is not required, and therefore testing and maintenance of the generator is not required. However, if you do meet one (or more) of the above conditions, then you must comply with section 7.9 for emergency lighting. Section 7.9.2.2 says new emergency power systems for emergency lighting must be provided by emergency generators in accordance with NFPA 110, and you must continue to maintain weekly inspections, monthly load tests, and 3-year load tests.

Emergency Lights in Generator Rooms

Q: In regards to emergency generator backup lights, I seek clarity how long does the battery have to last? I’m assuming that the battery should be able to be tested annually for 90 minutes like those inside my hospital.

A: Section 7.9.3 of the 2012 LSC is clear: All required battery powered emergency lights must be tested monthly for 30 seconds and annually for 90 minutes. The NFPA 110 requires a battery powered emergency light in the generator room, so it is a required light that needs monthly and annual testing.

The code requires the light to operate for 90 minutes.

Egress Lighting and Battery Powered Emergency Lights

Q: The egress lighting in our facility is connected to our generator through the life safety circuit and the light fixtures have no batteries. The task lighting in our operating rooms, the generator room, and the transfer switch room do have battery powered emergency lights. Is task lighting in the OR considered egress lighting? Does the requirement for monthly testing requirement for egress lighting still apply? Does the LSC have an exception for egress lighting that is connected to the emergency generator?

A: To begin with, the Life Safety Code (LSC) says all required emergency lighting systems to be tested at 30-day intervals for not less than 30 seconds (see section 7.9.3.1.1 of the 2012 LSC). In addition, this section says every required battery-powered emergency lighting system must be tested annually for 90 minutes. Egress lighting without battery back-up that is connected to the life safety branch of the EESS emergency power circuits receives the monthly test when the generators are load tested and the ATS are transferred on a monthly basis. Since the EESS generator system is not a battery back-up system, then it does not have to have a 90-minute annual test.

The phrase ‘required’ sometimes hangs people up as to which battery powered emergency light is required and which is not. To be sure, battery-powered emergency lights are required in anesthetizing locations (ORs, procedures rooms) according to section 6.3.2.2.11 of NFPA 99 (2012 edition), but that only applies to new healthcare occupancies as described in 18.5.1.3. That requirement is not found in chapter 19 of the 2012 LSC, which is for existing healthcare occupancies. So the question remains, are the batter powered emergency lights in the OR required per 18.5.1.3, or are they just non-emergency lighting that is not required to be tested in accordance with NFPA 99? It depends on when the emergency powered battery lights were installed. If the Life Safety Code required compliance with NFPA 99 at the time the battery powered emergency lights were installed, then they are ‘required’, and they must be tested monthly and annually.

Also, battery powered emergency lights located in generator rooms are required according to section NFPA 110 (2010 edition). So, those lights also would have to be tested monthly and annually since they are required lights.

But what about those battery power emergency lights in areas where the LSC (and other reference NFPA standards) does not specifically require them? Are they exempt from the monthly and annual tests? Probably not. Most national authorities having jurisdiction require all battery powered emergency lights receive the same monthly and annual tests required in 7.9.3.1.1 of the 2012 LSC, because section 4.6.12.2 of the 2012 LSC says existing life safety features obvious to the public that are not required by the LSC, must be maintained or removed. Therefore, based on that logic, all battery powered emergency lights must be tested monthly and annually.

The phrase ‘task lighting’ that you used is not found in the LSC and NFPA 70 (National Electric Code). It is found in the Annex section of NFPA 99 and is used only to reference light fixtures in bariatric chambers. It is not used in any way connected to egress lighting or emergency powered lighting.

Emergency Illumination in Mechanical Rooms

Q: Is emergency lighting required for mechanical rooms?

A: The answer depends on whether the mechanical room has a designated aisle, the occupancy classification of the building, and whether it is an underground or widow-less structure. According to section 7.8 of the 2012 Life Safety Code the means of egress is required to be illuminated in the following locations in any occupancy:

  • Designated stairs
  • Designated aisles
  • Designated corridors
  • Designated ramps
  • Passageways leading to an exit.

As far as a mechanical room is concerned, if the room is large enough that there would be a designated aisle in the room, then it would require illumination.

But does the illumination in the mechanical room need to be connected to emergency power? According to section 7.9, emergency illumination room is dependent upon any one of the following:

  • If required by the occupancy chapter;
  • If the building is an underground or windowless structure;
  • If the building is a high-rise building;
  • At doors equipped with delayed egress locks;

Healthcare occupancies and ambulatory healthcare occupancies do require emergency illumination (see 18/19/20/21.2.9.1), but business occupancies only require emergency illumination if the building is two or more stories in height above the level of exit discharge; if the occupancy is subject to 100 or more persons above or below the level of exit discharge; and if the occupancy is subject to 1,000 or more persons.

If the mechanical room is located inside a healthcare occupancy, then it would have to be connected to a Type 1 essential electrical emergency power system, which means the emergency illumination must be provided by onsite generators.

So, it depends where the mechanical room is located. But if it is located inside a hospital, and the mechanical room is large enough to have an aisle, then yes, emergency illumination would be required.

Battery Powered Emergency Lights

images[1]I was recently an interested bystander in a group discussion concerning the proper testing and inspection of a battery powered emergency light fixture located in an operating room. A question was raised as to what the testing and inspection frequency should be for those devices. The person who provided the initial response pointed out that The Joint Commission already made an interpretation on this subject in the June 2007 issue of “The Environment of Care News”. While the EC News is not considered an official interpretation from The Joint Commission, it is an indication on how they survey hospitals on particular issues. [The only ‘official’ interpretations from The Joint Commission are from one of the following sources: 1) The Joint Commission standards; 2) The Joint Commission publication “Perspectives”; 3) The Joint Commission Frequently Asked Questions (FAQs) posted on their website.]

In the June 2007 issue of EC News, The Joint Commission states that battery lighting devices in an anesthetizing location (i.e. operating rooms) in existing healthcare occupancies are considered to be task lighting rather than emergency lighting since they are intended to maintain a minimum level of illumination during the period of power interruption and the establishment of emergency power. They are not considered illumination of the means of egress in that location. The Joint Commission encourages the health care organization to identify them as task lights and determine the appropriate inspection and maintenance procedures and frequency to assure reliable operation when needed.

While I respect the individuals who were involved in this discussion, I don’t see the issue that same way. First of all, why do we tend to go to The Joint Commission as if they are the final authority on all issues concerning Life Safety in healthcare organizations? While they are the largest accreditor of healthcare organization, they are not the final authority, since they are not the only authority for healthcare organizations. The typical healthcare organization may have as many as 5 or 6 different authorities that enforce the Life Safety Code at their facility:

  • The state authority on design and construction
  • The state fire marshal
  • The local fire inspector
  • The healthcare organization’s accreditor
  • The federal agency on Medicare & Medicaid: CMS
  • The healthcare organization’s liability insurance company

No one authority having jurisdiction (AHJ) over-rides another AHJ. If one AHJ wants to interpret the Life Safety Code a specific way, that does not mean the other AHJs have to do so as well.

Normally, battery powered emergency lights would require monthly 30-second tests and annual 90-minutes tests to ensure the batteries are charged. This requirement is found in section 7.9.3 of the 2000 Life Safety Code, but it specifically says it applies to required emergency lighting. The requirement to have battery powered emergency lights in operating rooms is found in section 3-3.2.1.2 of NFPA 99, 1999 edition. But only new healthcare occupancies are required to comply with this requirement, according to section 18.5.1.3 of the 2000 LSC for new healthcare occupancies; this is not found in the existing healthcare occupancy chapter 19. And Joint Commission did say “existing” healthcare occupancies in their interpretation. This implies that battery powered emergency lights in existing operating rooms are not required, and therefore are not subject to the testing requirements in section 7.9.3.

But what date does “existing” apply? In this case, it would be when the hospital had to comply with the 1994 edition of the LSC, which referenced the 1993 edition of NFPA 99. The 1993 edition of NFPA 99 was the first edition to require emergency lighting in anesthetizing locations. This means, for Joint Commission accredited hospitals, the term “existing” is any date prior to January, 1994. So if the battery powered lights were installed since January, 1994, they would be considered “required” and have to be tested monthly and annually.

Ironically, while The Joint Commission did adopt the 1994 edition of the LSC, the federal agency CMS (or the fore-runner of CMS) never did. They went straight from the 1985 edition to the 2000 edition on March 11, 2003. While the 1985 LSC did reference NFPA 99, it appears to me that the requirement to install battery powered emergency lights in anesthetizing locations did not appear until the 1993 edition of NFPA 99.

If a facility manager wanted to take the time to ask each of their AHJs how they interpret if the battery powered light fixture in their operating rooms are required or not, that would be one way to decide. But even if all but one AHJ says the light is not required an one AHJ says it is required, then the organization is obligated to comply with the most restrictive interpretation, and test the fixture monthly and annually.

My advice is to determine what the most restrictive interpretation would be and follow that. In this case, that would mean the battery powered emergency lights would have to be tested monthly and annually.

Exit Discharge Illumination

images3LU8KUQ0I was talking to a hospital facility manager recently and he was miffed that a surveyor cited him for not having emergency power lighting on the exit discharge outside the hospital. He has been at this hospital for nearly 30 years and takes any deficiency as a personal affront to his abilities as a facility manager. Besides, he told me, this has never been a problem before so why is it a problem now? (I hear that a lot!)

Section 7.8.1 of the 2000 Life Safety Code requires the exit discharge to be illuminated all the way to the public way. Sections 18/19.2.9.1 requires emergency lighting in accordance with section 7.9, which requires emergency power for illumination of the exit discharge to the public way. The definition of public way is:

“A street, alley, or other similar parcel of land essentially open to the outside air deeded, dedicated, or otherwise permanently appropriated to the public for public use and having a clear width and height of not less than 10 feet.”

Under most interpretations from the accreditation organizations, the parking lot of a hospital can be considered to meet the requirements of a public way, even though it may not be “deeded to the public”. So, the path of the exit discharge to the parking lot would need to have illumination that is fed from normal power and emergency power. But the illumination for the parking lot would not have to be emergency power illumination, since the requirement is to have emergency power illumination only to the public way, not at the public way. This is a generalized interpretation, and it may or may not apply to all situations. You need to determine before your next survey if your exit discharge lighting meets this requirement.

Also, the illumination source needs to be arranged so the failure of any single lighting unit does not result in an illumination level of less than 0.2 foot-candles. This means you need two-bulb fixtures, or multiple single-bulb fixtures. The issue of LED fixtures is an interesting one. Technically, a LED fixture is comprised of many LED lamps, so I could see a single LED fixture as qualifying as a multiple lamp fixture. I haven’t heard of any authority say anything to the contrary, at least.

Emergency Lighting

Q: Is there a NFPA standard for emergency lighting placement in an anesthetizing location? A specific requirement where on the wall or ceiling it must be mounted? Do the self-check devices still require a manual 30 second and 90 minute test?

 A: NFPA 99 (1999 edition) section 3-3.2.1.2(a)(5) discusses electrical needs in anesthetizing locations. Basically, all it says is one or more battery-powered emergency lighting units must be installed in accordance with NFPA 70, article 700-12 (e), which describes the electrical requirements for an emergency lighting fixture, such as:

  • A rechargeable battery
  • A battery charging means
  • Provisions for one or more lamps mounted on the equipment
  • A relay device to energize the emergency lighting upon loss of normal power

Article 410 of NFPA 70 discusses lighting fixtures and locations in general. Basically, they address wet, damp, corrosive locations, and mounting fixtures in closets, ducts and hoods, showers and near combustible materials, but does not address on where they need to be mounted for anesthetizing locations. A further review of NFPA 99 does not reveal anything about location of emergency lighting. Neither NFPA 110 nor NFPA 111 addresses emergency lighting locations. Section 7.9 of the 2000 edition of the LSC does discuss emergency lighting, and it uses the term ‘means of egress’ to describe where emergency lighting needs to be located, but specific as to walls or ceiling mounting.

Ironically, this section does not require battery-powered fixtures for emergency lighting needs and references NFPA 110 if emergency lighting is powered by generators. Therefore, in this case, NFPA 99 would supersede the LSC and you would need to install battery-powered emergency lighting in anesthetizing locations, even if you had generator powered emergency lighting. But section 7.9.3 of the LSC does require 30 second testing of battery-powered emergency lighting fixtures at 30-day intervals, and 90 minute tests annually. However, in lieu of the regular monthly 30-second tests, the exception to 7.9.3 does allow self-diagnostic battery powered emergency lighting equipment which automatically performs a test for not less than 30 seconds not less than every 30 days and indicates failures by a status indicator is exempt from the 30-day functional test, provided a visual inspection is performed at 30-day intervals.

Emergency Lighting in Anesthetizing Locations

A question came up recently asking what the NFPA requirements are for installing battery-powered emergency lighting in anesthetizing locations. For purposes of clarification, NFPA 99 (1999 edition), section 2-2 defines anesthetizing location as:

“Any area of a facility that has been designated to be used for the administration of nonflammable inhalation anesthetic agents in the course of examination or treatment, including the use of such agents for relative analgesia.”

And relative analgesia is defined as:

“A state of sedation and partial block of pain perception produced in a patient by the inhalation of concentrations of nitrous oxide insufficient to produce loss of consciousness (conscious sedation).”

So, NFPA 99 (1999 edition) section 3-3.2.1.2 (a) (5) discusses electrical needs in anesthetizing locations. Basically, all it says is one or more battery-powered emergency lighting units must be installed in accordance with NFPA 70, article 700-12 (e), which describes the electrical requirements for a EM lighting fixture, such as:

  • A rechargeable battery
  • A battery charging means
  • Provisions for one or more lamps mounted on the equipment
  • A relay device to energize the EM lighting upon loss of normal power

Article 410 of NFPA 70 discusses lighting fixtures and locations in general. Basically, they address wet, damp, corrosive locations, and mounting fixtures in closets, ducts and hoods, showers and near combustible materials, but nothing on where they need to be mounted for anesthetizing locations. A further review of NFPA 99 does not reveal anything about location of EM lighting. NFPA 110 and NFPA 111 do not address EM lighting.

Section 7.9 of the 2000 edition of the LSC discusses EM lighting. They use the term ‘means of egress’ to describe where EM lighting needs to be located but it includes aisles in rooms. Ironically, this section does not require battery-powered emergency lighting for EM lighting needs and references NFPA 110 if EM lighting is powered by generators. Therefore, NFPA 99 would supersede the LSC and you would need to install battery-powered emergency lighting in anesthetizing locations, even if you had generator powered EM lighting.

But section 7.9.3 of the LSC does require 30 second testing of battery-powered emergency lighting fixtures at 30-day intervals, and 90 minute tests annually. However, in lieu of the regular monthly 30-second tests, the exception to 7.9.3 does allow self-diagnostic battery powered emergency lighting equipment which automatically performs a test for not less than 30 seconds not less than every 30 days and indicates failures by a status indicator is exempt from the 30-day functional test, provided a visual inspection is performed at 30-day intervals.