Why Emergency Lighting Gets Written Up
Emergency lighting is a critical part of your building's life safety system. It only matters when the power goes out, so problems can sit unnoticed for months.
Fire marshal checklists in Texas include it. The Austin Fire Department's public assembly inspection guidelines list "Emergency Lighting operative." The Snyder Fire Marshal's Office names "missing or non-functional emergency lighting" among common fire code violations.
Most problems fall into four groups.
1. Missing or Incomplete Test Records
What the Code Says
NFPA 101, the Life Safety Code, requires the owner to keep written records of visual inspections and tests. The records must be available to the authority having jurisdiction (AHJ). Computer-based self-testing systems must be able to provide a history of tests and failures at all times.
Why It Fails
A light can work and still lead to a finding if there is no record that it was tested. In one Joint Commission summary of survey findings for its office-based surgery program, a surveyor note read: "There was no evidence that all of the battery-powered egress lights were tested for 90 minutes."
The Kansas State Fire Marshal's emergency lighting log asks for a test date each month, the tester's initials for each unit, and comments on failures and replacements.
How to Avoid It
- Log every monthly and annual test
- Record the date, who tested, which units, pass or fail, and repairs made
2. Units That Fail the 30-Second or 90-Minute Test
What the Code Says
NFPA 101 requires a monthly functional test of at least 30 seconds and, for battery-powered systems, an annual test of at least 90 minutes. The equipment must stay fully operational for the whole test.
At the end of 90 minutes, light levels may drop to no less than 0.6 foot-candle average and 0.06 foot-candle at any point.
Why It Fails
A unit that does not stay fully operational for the whole test has failed it.
Passing the 30-second test does not show that a battery can last 90 minutes. Only the annual test checks the full duration. The annual test does not replace the monthly one either. The Kansas State Fire Marshal's log states that the 30-second test is required every month, even in a month when you run the 90-minute test.
How to Avoid It
- Run both tests on schedule, not only when an inspection is coming
- Replace failed batteries or units promptly and retest
- Check exit signs with battery backup too. NFPA 101 applies the same testing rules to them
3. Missing Illumination in Required Areas
What the Code Says
NFPA 101 requires emergency lighting along designated exit access components, such as corridors, stairs and passages leading to an exit, and from the exit discharge to a public way. Emergency illumination must last at least 90 minutes. Initial levels must average at least 1 foot-candle along the path at floor level, with no point below 0.1 foot-candle.
For workplaces, OSHA 29 CFR 1910.37(b)(1) requires each exit route to be "adequately lighted so that an employee with normal vision can see along the exit route."
Why It Fails
Coverage can fall short after a renovation or layout change. The Brownsville Fire Marshal's Office inspection guidelines state that emergency lighting is required in rooms or buildings without windows or natural lighting.
How to Avoid It
- Walk your egress paths after any layout change
- Confirm each designated path has emergency coverage
- Ask your AHJ which areas they consider designated exit paths
4. Damaged or Non-Working Units
What Inspectors Look For
The DeSoto, Texas Fire Marshal's Office checklist says exit lamps shall be illuminated at all times, and inspectors check bulbs, batteries and backup operation using the test button or circuit breaker. The Mineral Wells Fire Department checklist asks whether emergency lighting is in place and operating properly, and whether fixtures have approved covers with no bare or exposed bulbs or wires.
OSHA 1910.37(a)(4) lists exit lighting among safeguards that must be in proper working order at all times.
How to Avoid It
- Look at every unit during monthly checks, not just the test result
- Replace missing covers, broken lenses and loose units
- Fix dark exit signs right away
How Automated Testing Helps
The ABB Emergi-Lite Nexus Pro system is a computer-based self-testing option. It addresses the record and test problems directly:
- Monthly 30-second and annual 90-minute tests run on a schedule or on demand
- Defective units trigger push notifications with the issue and the part number needed
- Reports in the ABB cloud cover test results, maintenance history and offline devices
Physical damage and coverage gaps still need eyes on the building. Ask your AHJ whether they expect visual checks alongside automated reports.
Key Takeaways
- Missing test records can lead to a finding even when the lights work
- Units must stay fully operational through the 30-second and 90-minute tests
- Emergency lighting must cover designated exit paths at required light levels
- Missing or non-functional emergency lighting is a common violation
- Automated testing handles the tests and records, but not physical damage or layout changes
LivSafe Solutions is an authorized ABB Emergi-Lite distributor and commissioning provider serving Austin and San Antonio.