Tips to Comply with OSHA Emergency Lighting Requirements

Emergency lighting is one of the best ways to help people safely leave a building in the instance of an accident or catastrophic event happening. Having proper illumination and directions for people to see clearly and be able to find the nearest exit is essential in these types of situations. The Occupational Safety and Health Administration (OSHA) has created requirements around emergency lighting within buildings to ensure the safety and healthful working conditions of men and women to ensure they have exit paths that are adequately lighted so that employee’s with normal vision are able to see a visible exit route in case of emergency. OSHA has also co-opted the requirements set forth by the National Fire Protection Association (NFPA), making reference to the acceptance of the NFPA’s emergency exit requirements under 1910.35, where it states that employers who are following the exit provisions of NFPA 101 Life Safety Code, meet OSHA requirements. Therefore, to ensure the proper operation of emergency lighting, building owners should adhere to NFPA emergency exit light policies, as well as following OSHA’s Code of Federal Regulations, these are both essential to ensure building patrons and workers are safe in case of power failure and emergency exit situation. OSHA also acknowledges that those following the International Code Council’s, International Fire Code, satisfy OSHA’s compliance requirements. Some quick tips to ensure you are meeting OSHA and NFPA emergency lighting requirements include:

  1. Brightness/Illumination Guidelines

    • Ensure you have adequate and reliable illumination for all your exit signs. Under OSHA’s requirements 1910.37(b) it states that exit routes must be properly lighted so that an employee with normal vision can see along the exit route and each exit must be clearly visible and marked by a sign reading “Exit.” OSHA regulation 1910.36(b) (6) also states that adequate and reliable illumination must be provided for all exit facilities of buildings or structures. NFPA 101 Life Safety Code Section 7.9.2.1 states that emergency illumination shall be provided for not less than 1-1/2 hours in the event of failure of normal lighting. If your building has photoluminescent exit signs, when fully charged they meet sign code requirements to be clearly visible for 90 minutes (1-1/2 hours) in a power outage or when the lights go out.
    • Emergency lighting facilities shall provide initial illumination that is not less than an average of 10.8 lux (1 ft.-candle) and, at any point , not less than 1.1 lux (0.1 ft.-candle), measured along the path of egress at floor level. Illumination levels shall be permitted to decline to not less than an average of 6.5 lux (0.6 ft.-candle) and, at any point, not less than 6.5 lux (0.06 ft.-candle) at the end of the 1-1/2 hours. A maximum-to-minimum illumination uniformity ratio of 40 to 1 shall not be exceeded. This is in accordance with NFPA 101 Life Safety Code Section 7.9. If you have emergency lighting that is self-luminous or electroluminescent, it must have a minimum luminance surface value of .06 foot lamberts or higher.
  2. Proper Maintenance and Performance

    • Emergency lighting must be provided automatically in the event of a power failure.
    • Tips to Comply with OSHA Emergency Lighting Requirements

    • Brightness testing on emergency exit signs is required for battery backup emergency exit signs every 30 days. You will need to use the small “push to test” button located on the casing for thirty seconds to test the bulbs. Testing for a minimum of thirty seconds will ensure they don’t just have a surface charge but are strong enough to last numerous hours. Functional testing shall be conducted annually for not less than 1-1/2 hours if the emergency lighting system is battery powered. The emergency lighting equipment shall be fully operational for the duration of the tests and written records of visual inspections and tests shall be kept by the owner for inspection by the authority having jurisdiction. If you have photoluminescent exit signs, you should not need to perform this testing as they run completely off the light they absorb and do not require batteries, but check with your local authorities to confirm any specific requirements or changes to ensure you are in compliance.
    • NFPA Life Safety Code Section 7.9.2.3 states that the emergency lighting system shall be arranged to provide the required illumination automatically in the event of any interruption of normal lighting due to any of the following: failure of a public utility or other outside electrical power supply, opening of a circuit breaker or fuse, or manual act(s), including accidental opening of a switch controlling normal lighting facilities.
    • If you have photoluminescent emergency lighting and exit signs, you will find they require virtually no maintenance, but should still be inspected on a regular basis and kept free of dirt and debris with simple cleaning off with soap and water.
    • When servicing the building or business’ lighting system, there must be a means for keeping illumination uninterrupted
  3. Emergency Exit Sign Specific Requirements

    • Exits must be marked with approved signs that are visible all the way along the evacuation path.
    • Emergency exit signs must have the word “EXIT” in clear and legible letters not less than six inches (15.2 centimeters (cm)) high, with the principal strokes of the letters in the word “Exit” not less than 3/4- inch (1.9 cm) wide.
    • OSHA gives no requirement for specific colors of the emergency exit signs, but simply that it must be distinctive in color from the background. NFPA 101 Section 7.10.1.8 states “signs must be of a distinctive color and design that is readily visible and shall contrast with decorations, interior finish and other signs.”
    • NFPA Life Safety Code 101 Section 7.10.8.3.1 states that a “No Exit” sign is needed where any door, passage, or stairway that is neither an exit nor a way of exit access and that is located or arranged so that it is likely to be mistaken for an exit.
    • Always make sure that you specify an exit sign that is UL 924 listed.

Frequently Asked Questions About Building Emergency Lighting and Exits

How will I know what my exit routes are in my building in order to place my emergency lighting?

OSHA defines an “exit route” as a “continuous and unobstructed path of exit travel from any point within a workplace to a place of safety (including refuge areas)” under 29 Code of Federal Regulation (CFR) 1910.34(c). The exit route consists of an:

  • Exit Access: this is the route that leads to the exit. An example would be a corridor that leads to a two-hour fire resistance rated stairway (the Exit).
  • Exit: this is the part of the exit route that is separated to provide a protected travel to the exit discharge. This would be the two-hour fire resistance rated stairway that leads people to the outside of the building.
  • Exit Discharge: consider this the part of the exit route that leads people directly outside or to a refuge area with access to outside. The door at the bottom of the two-hour fire resistance rate stairway is an example of this.

Your exit routes must be free of obstructions and signs should be posted along the exit route if the direction to the exit or exit discharge is not apparent. If there are doorways along the exit route that could be mistaken for an exit but are not the true exit, they need to be marked “Not an Exit” or identified with their actual use (e.g. “Storage Closet”).

Are there penalties for being non-compliant with emergency lighting?

Yes, OSHA will issue penalties for commercial buildings not adhering to the NFPA standards. Building owners can face fines from several hundred dollars, all the way up to hundreds of thousands of dollars. For example, a willful code violation can run upwards of $70,000 or if the violation results in the death of a worker the owner can be facing up to $250,000, plus potential jail time. Corporations can also be faced with fines, generally even heftier in amounts.

Are photoluminescent egress systems in compliance with OSHA and NFPA?

Yes, they can be. You will want to ensure exit signs are UL 924 listed and photoluminescent egress path markings are UL 1994 listed—which meet OSHA and NFPA requirements —like the Jessup GloBrite line does. Installing photoluminescent exit signs and egress systems are becoming more common due to their eco-friendly, low maintenance and low-cost nature.

When it comes to emergency lighting requirements, OSHA is just one of the regulating authorities. As mentioned, OSHA adheres to the National Fire Protection Association (NFPA) requirements, while other authorities include the International Building Code, International Fire Code and most importantly your local authority having jurisdiction (AHJ). Your local AHJ is in charge of monitoring and enforcing local building codes and/or fire codes. The local fire marshal or fire inspector is a great place to start to ensure you are meeting all your city or town requirements for exit signs and emergency lighting.lg

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