EM Lights in MRI

Q: I have a question on the requirement for the battery backup lighting inside the MRI suites. We are in the process of building two new MRI centers and I am receiving a lot of push back from the Project Engineer.

This engineering group specializes in MRI projects and they tell me they never install battery backup lighting and that NFPA 99 does not require battery backup lighting anywhere outside of an operating room. I was told to reference 6.3.2.2.11.2 of NFPA 99-2012 which specifically mentions operating rooms. My reply was that 6.3.2.2.11.1 does not specify only operating rooms so it is much broader in scope and since we use anesthesia in the MRI it would be required.

Before I stir up the pot anymore with the engineering firm I wanted to make sure that if Anesthesia is being used in the MRI room that emergency battery backup lighting should be in place.

A: Yes, you are correct. NFPA 99-2012, section 6.3.2.2.11.1 requires one or more battery-powered lighting units within locations where deep sedation and general anesthesia is administered. That includes MRI areas, Cath Lab areas, and of course, Operating Rooms and Procedure rooms. ICUs and NICUs would typically not be included.

Just because the project engineer from the contractor has never been told to install battery-powered lighting units before does not preclude the fact that it is a requirement and it is enforced by CMS and the Accreditation Organizations. The engineer is mistaken.

 

EM Lighting in Out-Patient Facilities

Q: We have out-patient clinics classified as business occupancies. Are we required to have emergency egress lighting? If so what section of the 2012 or 2015 NFPA Life Safety Code outlines the requirement?

A: It depends. For new business occupancies section 38.2.9.1 of the 2012 LSC says emergency lighting shall be provided where any one of the following conditions exists:

  1. The building is three or more stories in height;
  2. The occupancy is subject to 50 or more occupants above or below the level of exit discharge;
  3. The occupancy is subject to 300 or more total occupants.

For existing business occupancies section 39.2.9.1 of the 2012 LSC says emergency lighting shall be provided where any one of the following conditions exists:

  1. The building is three or more stories in height;
  2. The occupancy is subject to 100 or more occupants above or below the level of exit discharge;
  3. The occupancy is subject to 1000 or more total occupants.

The emergency lighting must be installed in accordance with section 7.9, which discusses battery-powered emergency lights and those egress lights powered from generators. According to 7.9.2.2, new emergency power systems for emergency lighting shall be generator power, with a Type 10 (meaning no more than 10 seconds to transfer power), Class 1.5 (which means must provide emergency power for a duration of 90-minutes) and rated for Level 1 (which means the system shall be installed where failure of the equipment to perform could result in loss of human life or serious injury). Level 1 systems are described in NFPA 110 as rotating equipment energy converters powered by prime movers (i.e. generators). Existing condition emergency lights could be powered by battery-powered emergency lights.

Battery Powered Emergency Lights

Q: In the standards manual from our accreditation organization it states that every 12 months the critical access hospital either performs a functional test of battery powered lights on the inventory required for egress for a duration of 1½-hours or replaces the batteries and tests 10% of all batteries and records the results. Do we need a written inventory of these lights? If so, can these lights be labeled on a drawing? Or do these need to be listed out in a spreadsheet?

 A: First of all…. be careful which edition of the standards you are reading. That accreditation organization changed their standard on this issue in 2018 and eliminated the option of replacing the batteries annually, and only testing 10% of them. The requirement since January 1, 2018 is you must conduct the annual 90-minute test on all of the batteries.

But to answer your question…. Yes… the battery powered emergency lights do need to be listed on an inventory in order to be sure all of them were tested. You need to list them on a spread-sheet that identifies them by location and/or asset-tracking number, so you can demonstrate that your tested each device and whether or not it passed or failed.

To help your staff located the devices quicker, you should consider listing them on drawings so each location can be tracked.