Published on July 1, 2020.

In Compliance | NFPA 101

Verifying the emergency lighting and exit marking when reopening a building


As government officials begin to develop and release reopening procedures for businesses and buildings that have been relatively vacant for the past few months due to the COVID-19 pandemic, building owners and facility managers are now trying to determine what needs to be done to the building prior to reintroducing occupants.

During this unique time, NFPA has encouraged the maintenance of all fire protection and life safety systems. However, it is possible that many of the ongoing inspection, testing, and maintenance (ITM) activities required by locally enforced codes and standards may not have been completed for a variety of reasons. Regardless of the level of ITM performed during this interval, it is imperative that building owners and facility managers verify the performance of all building fire protection and life safety systems prior to reoccupying the building.

One of the life safety systems that needs to be verified is the emergency lighting and exit marking within the building. NFPA 101®, Life Safety Code®, requires emergency lighting to be provided in designated stairs, aisles, corridors, and passageways leading to an exit in occupancies such as, but not limited to, assembly, educational, hotels, mercantile, and business. The emergency lighting is designed to automatically illuminate for at least 90 minutes upon the loss of power, the opening of a circuit breaker, or a manual act such as the opening of a switch to the normal lighting so the occupants can egress the building safely.

Emergency lighting for buildings is provided in two primary ways. One is to provide the building with an emergency generator and automatic transfer switch that will power a portion of the building’s lights upon loss of power. If that is the case in your building, the ITM performed on the generator must be completed per NFPA 110. The second method consists of providing separate emergency lighting units within the building that connect to the building’s power in order to charge the units’ batteries. Upon loss of power to the unit, the on-board battery then powers the emergency lights. In the case of these separate units, we need to perform ITM to ensure that the batteries are holding a charge, that the bulbs work, and the charge held can operate the lights for the required 90 minutes.

There are three techniques that can be used to ensure that the emergency lighting is operational: manual, self-test, and computer-based. Using the manual method, the emergency lights are operated monthly for at least 30 seconds by utilizing the manufacturer’s procedure—typically a test button that disconnects the main power to the unit—to ensure that the battery is holding more than a residual charge and to ensure that the lights are working. The emergency lights need to be operated on an annual basis for a minimum of 90 minutes to test the full capacity of the batteries.

In the self-test method, the units can test themselves and indicate an issue on the unit via an indicator light. These units do not need to be manually tested monthly or annually, but they need to be inspected every 30 days to make sure they are not damaged and that no indicator lights are on. In the computer-based method, a visual inspection is not required every 30 days, since any issues with the lights encountered during their self tests will be reported and logged via a computer.

NFPA 101 also requires egress signage to be provided in most occupancies—including, but not limited to, assembly, educational, hotels, mercantile, and business—on exits other than main exterior doors that are not obvious and identifiable as exits. These markings need to be visible from any direction of the exit access and are required to be internally or externally illuminated. The illumination of the exit markings needs to be confirmed via a visual inspection at intervals not exceeding 30 days. If the occupancy is also required to have emergency lighting, these illuminated exit signs need to be provided with emergency power. The same methods of testing the emergency lighting can be used for testing the exit marking illumination emergency power as well.

As building owners and facility managers prepare to reopen their buildings to occupants, all required inspection, testing, and maintenance on emergency lighting and exit signs should be up to date. This includes the monthly 30-second test and inspection as well as making sure that the full 90-minute test was completed within the last 12 months. As with all ITM, proper documentation is a must with these tests to verify that all the work was done and to ensure that no required testing is overlooked.

Shawn Mahoney, P.E., is a Technical Services engineer at NFPA. NFPA members and AHJs can use the Technical Questions tab to post queries on NFPA 101 at