Jan 22 2015

Battery Powered Emergency Lights

Category: BlogBKeyes @ 6:00 am

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- of NFPA 99, 1999 edition. But only new healthcare occupancies are required to comply with this requirement, according to section 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.


Sep 11 2014

Exit Discharge Illumination

Category: BlogBKeyes @ 6:00 am

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/ 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.

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Sep 13 2012

Emergency Lighting in Anesthetizing Locations

Category: BlogBKeyes @ 5:00 am

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- (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.