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 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.

Brad Keyes
Brad Keyes, CHSP

Brad is a former advisor to Healthcare Facilities Accreditation Program (HFAP) and former Joint Commission LS surveyor. He guides clients through  organizational assessment; management training; ongoing coaching of task groups; and extensive one-on-one coaching of facility leaders. He analyzes and develops leadership effectiveness and efficiency in work processes, focusing on assessing an organization’s preparedness for a survey, evaluating processes in achieving preparedness, and guiding organizations toward compliance. 

As a presenter at national seminars, regional conferences, and audio conferences, Brad teaches the Keyes Life Safety Boot Camp series to various groups and organizations. He is the author or co-author of many HCPro books, including the best-selling  Analyzing the Hospital Life Safety Survey, now in its 3rd edition. Brad has also authored a variety of articles in numerous publications addressing features of life safety and fire protection, as well as white papers and articles on the Building Maintenance Program. Currently serving as the contributing editor of the monthly HCPro newsletter Healthcare Life Safety Compliance  gives Brad further insight into the industry’s trends and best practices.