Inmovilizado intangible

7.10.9 Testing and Maintenance. 7.10.9.1 Inspection.

Option 1: Delete 7.10.9.1 entirely.

Option 2: Exit signs that don't have their own power source shall be visually inspected for operation of the illumination sources at intervals not to exceed 30 days or shall be periodically monitored in accordance with 7.9.3.1.3.

7.10.9.2 Testing.

Exit signs connected to, or provided with, a battery-operated emergency illumination source, where required in 7.10.4, shall be tested and maintained in accordance with 7.9.3.

Statement of Problem and Substantiation for Public Comment

I don't know what the committee means when they say in their rejection of PI-343 that 7.10.9.1 is to apply to exit signs that don't have their own power source, but if that solves the problem, I have made that change as option 2. Please identify in the committee substantiation what that is supposed to mean.

However, I think option 1 to delete the requirement is still the best option.

Some are interpreting 7.10.9.1 to inspect the illumination source of all exit signs every thirty days even when they are not battery operated or when they are externally illuminated. There is no reason to inspect an exit sign for the illumination source unless the exit sign is battery operated and that inspection for a battery operated exit sign is already required under 7.10.9.2. There are provisions in the code (4.6.12) that require building owners to fix/repair /replace the illumination source of exit signs when the required illumination source is broken, but there is no reason to require an owner to inventory 1000s of exit signs and inspect them for the illumination source every 30 days. This is an unnecessary burden especially since many facilities are using LED light sources for exit signs which last a very long time.

The American Society for Health Care Engineering did a study to determine the failure rate of exit signs. This study surveyed 86 health care facilities in regards to exit sign inspections over a one-year period with a specific request for the variations between LED and non-LED exit signs. Eighty-six respondents performed an average of 3,545 yearly LED exit sign inspections along with an average of 2,860 Non-LED exit sign inspections. With an average per year LED failure of 1.29 signs and Non-LED of 10 signs the study concluded that the failure rate of LED exit signs was 0.0004% (1.29/(3,545*86))and for non-LED exit signs the failure rate was 0.004% (10/(2860*86)). This study indicates that the technological advancements of these devices using LED signs has reduced the failure rate of exit signs from 0.004% to 0.0004%. However, if 99.996% of all exit signs, even those that are not LED signs, pass this inspection, clearly a routine inspection is not warranted and this requirements should be deleted. Even if an exit sign illumination source is not working, there is a very good chance that an occupant will still be able to see the sign due to the illumination from the lighting that is required in the means of egress so having one or two nonworking signs will have almost no affect on the occupants of a building.

Note that battery operated exit signs will still be tested and inspected on a 30 day interval as required by 7.9.3, even if 7.10.9.1 is deleted.

See ASHE study below:

Exit Sign Inspection & Burden Survey: Pt 1: Quantitative Data: (n = 86)

Testing Cost Analysis. Eighty-six surveyed campuses reported a median of 154 (Mean = 310, SD = 397.42, Range 0 – 2,100) operational LED exit signs, and a median of 2 operational NON-LED exit signs (Mean = 88.60, SD = 202.76; Range = 0 - 1200). These reports represent a significant skew, particularly with NON-LED exit signs, as approximately half of the respondents surveyed stated that their facility did not have any Non-LED signs. In addition, respondents reported a median of 1,782 LED light inspections (Mean = 3545.46, SD = 4710.66, Range = 0 – 25,200), and a median of 90 Non-LED exit light inspections across the year (Mean = 2859.60, SD = 11940.35,

National Fire Protection Association Report

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Range = 0 -80,808).

On average, staff spent a median of approximately 49 hours (Mean = 246.38, SD = 809.5, Range 0 - 6912 with extreme scores) per year conducting exit sign inspections. Furthermore, the individuals conducting these inspections were paid a median wage of $22 an hour (Mean = $27.07, SD = 23.99, Range $0 - $208 hourly rate); which translates to approximately $1326.43 in staffing costs per year.

All respondents conducted monthly exit sign inspections internally; none of them reported having costs related to an independent contractor. Furthermore, roughly three-quarters of the sample (73.3%) reported that they participated in a Zone or Maintenance program.

Testing & Failure Rate Comparisons. The median number of failures for the past year for LED exit signs was 0 (Mean = 1.29, SD = 3.219, Range = 0 – 20) and non-LED exit signs was 10 (average = 0, SD = 68.68, Range = 0 – 600). Alternatively explained, approximately 51% of Non-LED exit sign inspections had zero failures, and three quarters had less than 1 or 2 failures per year (for both Non-LED ad LED Exit signs). All of these analyses indicate an extremely low failure rate across the entire sample; especially when a couple extreme data points are removed from the analysis5.

Between Variable Relationships. Two-tailed bivariate correlations were conducted, yet no statistically significant relationships were found. Number of inspection failures was not related to number of exit signs tested for either type of exit sign. Number of exit sign inspections were also found not to be related to staffing hours or total staffing costs, or whether or not a facility participated in a Zoning Program. This findings may potentially illustrate that there may be external factors that play a much larger role in exit sign failures.

Pt 2 - Qualitative Data Analysis: (n = 40)

Forty respondents included open-ended comments in their Exit Sign Inspection surveys. Of these comments, 31 voiced concrete support for changing current monthly testing standards; and of these, 16 respondents even suggested specific time frames for testing; such as every two-months (n = 2), quarterly (n = 3), and semi-annually (n = 3). However, most individuals supported an annual testing time frame for exit signs (n = 7), or even biannual testing (n = 2). Conversely, only one respondent voiced support for current monthly inspection timeframes. Furthermore, several themes came through in the open-ended commentary: the explanation that separate and specific exit sign inspections were a waste of resources, no longer applicable with the newer, more advanced LED technologies, no longer applicable because signs are connected to emergency power. Some respondents also used the space to advocate for a more risk-based inspection approach. Comments of interest included: “Required monthly inspections are ridiculous. We instinctively react to any failed exit sign through years and years of security awareness,” “With the new LEDs it’s almost not necessary to test them. They are either working or are off if not working,” “…we did this 25 years ago when we had incandescent bulbs, the only failure we have now is when someone hits a light with a cart. NOT a good use of our resources,” “staffing levels will not be adjusted for the increase in work due to non-effective regulations. It would be more cost effective to force everyone to change their fixtures to LED,” “All but 15 of our signs are connected to E-power. The 15 are battery back-up in ORs and other mechanical spaces.”

Related Item

• PI-343, PC-128

Submitter Information Verification

Submitter Full Name: Peter Larrimer

Organization: US Department of Veterans Affa

Street Address: City:

State: Zip:

Submittal Date: Tue Apr 30 15:04:16 EDT 2019

Committee: SAF-MEA

National Fire Protection Association Report

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