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Keyes Q&A: LED lighting, travel distance, drywall screws, testing frequencies

Healthcare Life Safety Compliance, April 12, 2020

This is an excerpt from a member only article. To read the article in its entirety, please login or subscribe to Healthcare Life Safety Compliance.

Editor’s note: Each month, Brad Keyes, CHSP, owner of Keyes Life Safety Compliance, answers your questions about life safety compliance. Follow Keyes’ blog on life safety at www.keyeslifesafety.com for up-to-date information.  

LED lighting units

Q: NFPA 101-2012 (Life Safety Code®), section 7.8.1.4 states: “Required illumination shall be arranged so that the failure of any single lighting unit shall not result in an illumination level of less than 0.2 foot-candle in any designated area.” So if a single bulb fixture failing is an issue, can LED lighting be utilized for illumination of a discharge exit and comply with the LSC?

A: This will be an interpretation by the respective authorities having jurisdiction (AHJ). For a long time (meaning decades), the interpretation was that two lamps needed to be present either in the form of two light fixtures, or one light fixture with two lamps, to illuminate the path of egress. As far back as the 1994 edition of the LSC, the section actually referred to “electric bulbs.” But beginning with the 1997 edition, this section was changed to refer to “lighting units” rather than electric bulbs. But surveyors did not always grab onto this change and were often evaluating compliance based on the older version of two “electric bulbs,” rather than the newer version of two “lighting units.”

That brings us to the issue of LED light fixtures. The premise of an LED light fixture is it has many, many tiny diodes that emit light (hence the acronym “LED” for light-emitting diode). Are these individual tiny diodes considered to be lamps? I don’t know what the technical answer is, but according to section 7.8.1.4 of the 2012 LSC, it doesn’t matter, as it requires more than one lighting unit for proper illumination of the means of egress.    

I have come full circle now, and I believe that a single LED light fixture in the means of egress does not meet the requirements of section 7.8.1.4 of the 2012 LSC because the LED unit is a single “lighting unit” even if it has multiple light-emitting diodes. But not all AHJs will enforce this issue the same way. Some AHJs may consider that a single LED light fixture meets the definition of 7.8.1.4 since it has many different light-emitting diodes.

This is an excerpt from a member only article. To read the article in its entirety, please login or subscribe to Healthcare Life Safety Compliance.

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