Required Testing of Exit Lighting for Compliance

square sign with exit in red with large round light to left and right of square sign

Emergency lighting, including exit signage, is subject to a 30-second test every month and an annual 90-minute test to ensure that the system will function correctly in the event of an emergency.

Did you know that you are required by law to have and regularly test emergency exit & emergency lighting systems? Do not take a chance with such serious matters; avoid serious liabilities and fines by having, maintaining and testing adequate exit and emergency lighting systems in your building(s).

What’s Required

Illuminated paths that help occupants exit buildings during emergencies are mandated by multiple regulatory codes and standards, including the following:

OSHA Code of Federal Regulations

  • Requires adequate and reliable illumination for all exits
  • Requires proper maintenance to assure that exit lighting is in continuously proper operating condition

NFPA 70 – National Electric Code

  • Requires specific illumination and performance of emergency and exit lights
  • Provides functional standards for battery-powered emergency and exit lighting

NFPA 101 Code, Life Safety Code (shall be known as the Life Safety Code® )

  • Requires a monthly inspection of all emergency and exit lighting systems
  • Requires an annual 11/2 hour test of all emergency and exit lighting systems

International Fire Code

  • Requires proper illumination of means of egress
  • Requires assurance that emergency and exit lighting systems will provide illumination for at least 60 minutes

NFPA 1997 5-9.3

Periodic Testing of Emergency Lighting Equipment

  • An annual test shall be conducted for a 11/2 hour duration.
  • Equipment shall be fully functional for the duration of the test.

Standard Fire Prevention Code 1999

807.1.4 Exit Illumination and Signs

  • A functional test shall be conducted on every required emergency lighting system at 30-day intervals for a minimum of 30-seconds.

These various regulatory code requirements require monthly 30-second tests to be sure that the battery (on battery-powered emergency lighting systems) keeps the lamps lit brightly to ensure safe egress in the event of a power outage or other emergency. By just pushing the test button for a few seconds you are not testing the strength of the battery back-up power. The longer you hold the test button the better. Not only do you get a better idea of the condition of the battery, when you release the test button, the charger will come on and rejuvenate the battery. This process greatly increases battery life.

Life Safety Code® requirements also call for an annual 90-minute full-load-test to insure all of your emergency lighting systems will operate for a full 11/2 hour (in most states) in the event of an extended emergency. The process can be time consuming. However, if the emergency lighting is on a circuit breaker you can turn off the appropriate breakers and simulate a 90-minute power failure without going around to each individual unit.

Ultimately, these monthly and annual inspections and tests must be documented and subsequently retained on site by the owner of any facility for inspection by the regulatory authority having jurisdiction over the facility.

OSHA brings most of these codes together in 29 CFR 1910.35 which simply states:  “OSHA will deem an employer demonstrating compliance with the exit-route provisions of NFPA 101, Life Safety Code, 2009 edition, or the exit-route provisions of the International Fire Code, 2009 edition, to be in compliance with the corresponding requirements in §§ 1910.34, 1910.36, and 1910.37 (incorporated by reference, see section § 1910.6).”

Testing Options

NFPA 101 allows three methods of testing, though your choice will likely be dictated by what type of system is installed in your building.

  1. Fully manual testing requires you to walk the building, push the test button on every emergency fixture, and record the results.
  2. Self-diagnostic fixtures can run their own monthly tests, but you’ll have to manually conduct the annual 90-minute test and throw the breaker yourself.
  3. Automated systems with computer backup are capable of running both the monthly and annual tests and recording the results for you.

An average-sized maintenance staff can count on using the better part of a day to test a building with about 200 emergency lighting fixtures in it, such as a shopping center or large school. Most emergency fixtures are mounted between 7.5 and 20 feet from the floor, requiring a scissor lift or a ladder, so you can save yourself considerable annoyance by conducting the testing on a weekend when the building is unoccupied.

Are you compliant?


Published by Stephen Kovatch

Senior Client Manager  Stephen J. Kovatch focuses on assisting clients in establishing corporate regulatory compliance programs in the areas of air, water, and waste management. Mr. Kovatch also provides direction to industrial facility owners who are active in the transaction of contaminated property by defining objectives, coordinating soil and water sampling protocols, risk assessment, and remedial / cleanup activities. He frequently represents clients in property sales negotiations and regulatory agency and insurance proceedings.

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