
UNDERWRITERS LABORATORIES AND YOUR SYSTEM
In order for you to make an informed decision regarding your Emergency Lighting needs, we have included information which is very important for you to know. We have found during our 23 years in this business that many of our customers have little idea of the requirements and responsibility surrounding Emergency Lighting Life Safety Equipment.
Emergency Lighting Equipment is different from other types of backup power equipment. It is designed and tested for use in Life Safety Emergency situations. Its performance is critical to the safe evacuation and movement of people in case of a power outage and is therefore held to and tested to a higher standard than other backup power systems.
Emergency Lighting Equipment used in this country is required to be tested by an independent Underwriter's Laboratories (UL). This means that the product has been submitted for evaluation and testing in accordance with the Life Safety Emergency Lighting Standard # UL924. All aspects of the product construction, material and performance are documented in a Report, which is kept on file at UL.
Any unauthorized changes to the product whether at the factory or in the field voids the UL listing. This UL listing mark is important because the local inspection authorities rely on this to determine that an Emergency Lighting product is acceptable for installations which require this type of equipment. The type of installation is determined by the National Electrical Code (NEC), Article 700 and the National Fire Protection Association (NFPA) Life Safety Code #101. These two codes dictate the installation and maintenance requirements for this equipment. If this equipment is not installed, maintained, and serviced in accordance with these code requirements, the building owner can be cited and the building shut down until corrections are made.
Finally, if repairs are required, (including battery replacement) they should be made using the proper material as noted in the original UL listing report and they must be accomplished in a timely manner. If this is not done, the UL listing no longer applies. Failure to do so can result in the following consequences:
• The system may not properly fulfill its function during an emergency, thus causing injury or fatality. • Additional damage to the system may result. • The inspection authority may cite or fine the owner, or actually shut down the building. • If an injury occurs, an Insurance company may deny claim for damages since this could be seen as negligence. The person who made the decision regarding the repair or non-repair of the Life Safety equipment could be held liable.We hope that this information helps you to make a proper and informed decision regarding the repair and maintenance of your Emergency Lighting System. If you have any specific questions regarding this information or your Quote, please let us know.
UNDERWRITERS LABORATORIES Q&A REGARDING BATTERIES IN EMERGENCY LIGHTING EQUIPMENT
This is an excerpt from a letter from Mr. Wayne Menuz dated March 12, 1998 in response to questions submitted regarding the practice of substituting alternate batteries in Emergency Lighting Equipment. Mr. Menuz is Underwriters Laboratories Managing Engineer, and Industry Advisory Committee Chairman for UL 924 based at the Santa Clara, CA offices.
Is it a requirement in the UL Standard governing Emergency Lighting Equipment that Markings on the unit indicate the Specific Battery to be used for replacement?
Yes! The "Standard for Safety, Emergency Lighting and Power Equipment" UL924 does have the following requirement in clause 68.1.18: "Equipment incorporating or intended to incorporate batteries shall be marked with 'CAUTION: Replace battery only with (blank) part number (blank).' The first blank is to be filled in with the battery manufacturer or equivalent identification and the second blank is to contain the catalog designation."
If so, what is the reason for requiring this Marking as part of the Listing?
Emergency lighting or power equipment must not only be safe (i.e., not be a fire or shock hazard) but must be reliable in its performance in order to satisfy requirements in Codes such as NFPA101, NEC articles 700 and 701, NFPA99, etc. that mandate a Life Safety product. That is, safety demands that the products produce minimum levels of power or light during an emergency. Therefore, UL924 contains many performance tests. UL's experience is that even "similar" batteries can perform differently when used in the same equipment. It is not uncommon for one battery part number to cause a product to not pass the performance tests, while a different (but very similar) battery passes. It is not just the discharge characteristics, but the influence of the product's charging/discharging circuits that influence the performance. Consequently, the only assurance one can have that a particular battery manufacturer's product will deliver the minimum life safety performance in a specific Emergency Lighting/Power product, is to test it.
Can just any UL Recognized battery be used for replacement in a UL Listed Emergency Lighting unit if it is not marked on the unit?
No! The UL Recognition program for batteries (UL guide: BAZR2) is primarily intended to enable the vent testing of batteries that is required in UL924, to be conducted at the battery manufacturers' facilities rather than being repeated at each Emergency Lighting/Power manufacturer's location. It is NOT intended that a UL Recognized battery has been evaluated by UL as being acceptable for replacement use in the field unless the Emergency Lighting/Power product is marked with its catalog or part number.
What is the difference between a battery that has been supplied with a UL Listed unit as compared to one that is UL Recognized?
The battery supplied with a UL Listed unit, and any additional battery part numbers marked on the product, have been determined to meet the minimum life safety performance in that unit. A UL Recognized battery with a different part/model number has not been evaluated for performance in that unit, and it is not known to UL whether the unit would comply with the minimum performance requirements.
Are there any possible Code Violations involved with modifying UL Listed Emergency Lighting Equipment?
There are several Codes that address legally required Emergency Lighting/Power Equipment, including NFPA101, NFPA90 (the NEC), the Uniform Fire Code, etc. I am not aware that there is a general prohibition of the modifying of Listed products, though the onus of determining whether the modified product is acceptable would be placed on the Authority Having Jurisdiction (AHJ) and the person doing the modifying. However, your question may be aimed at whether Codes have any reference to the Markings/Instruction provided with Listed equipment. In NFPA70 (the NEC), in section 110-3, it states the following: (b) Installation and Use - Listed or labeled equipment shall be installed, used, or both, in accordance with any instructions included in the listing or labeling. All UL electrical standards are written with the expectation that AHJs will enforce all markings and installation instructions associated with a product, as specified in the NEC. Certainly, safe use of products and reliance on Life Safety products depends on all markings and instructions being followed.