Nov 02 2017

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 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 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.

May 29 2017

Emergency Lights in Generator Rooms

Category: Emergency Lights,Generators,Questions and AnswersBKeyes @ 12:00 am

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.

May 26 2017

Egress Lighting and Battery Powered Emergency Lights

Category: Emergency Lights,Questions and AnswersBKeyes @ 12:00 am

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 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 of NFPA 99 (2012 edition), but that only applies to new healthcare occupancies as described in 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, 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 of the 2012 LSC, because section 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.

Mar 24 2017

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/, 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.

Jul 28 2014

Emergency Lighting

Category: Emergency Lights,Questions and AnswersBKeyes @ 6:00 am

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- 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.

Aug 20 2012

Business Occupancy Emergency Lights

Category: Emergency Lights,Questions and AnswersBKeyes @ 5:00 am

Q: Are battery powered emergency lights required in business occupancies? We have a small clinic that does not have battery powered emergency lights (or battery powered “Exit’ signs for that matter) and I have a manager at that building that says we need to have them. I can’t find in the LSC where we need them.

A: The requirement for emergency lighting in business occupancies is found in section of the 2000 edition of the LSC. This section qualifies the requirement for emergency lighting depending on the number of stories in the building and the number of occupants in the building. Emergency lighting must comply with section 7.9 in any business occupancy building:

  1. Where the building is two or more stories above the level of exit discharge; OR
  2. If the occupancy is subject to 100 or more occupants above or below the level of exit discharge; OR
  3. The building is subject to 1,000 or more total occupants.

If your business occupancy meets any one of those three conditions, then you must comply with section 7.9 for emergency lighting. If it does not meet any of the above three factors, then emergency lighting is not required and compliance with section 7.9 is not required either. According to section 39.2.10, the marking of the means of egress (or ‘Exit’ signs) must comply with section 7.10 no matter how many stories or number of occupants. However, the need for ‘Exit’ signs to be powered by an emergency source is dependent on whether or not if emergency lighting is required. So, for business occupancies that do not meet any of the three conditions cited above for emergency lighting, then the ‘Exit’ signs do not need emergency power either. While this may seem a bit complicated, the LSC is providing a break for the smaller clinics and not require them to have emergency lighting or emergency power for the ‘Exit’ signs. You will need to determine if your clinic meets the conditions cited in section for emergency lighting. Also, check with your local authorities to determine if they have requirements that exceed the LSC.