Regulations, Codes & Standards Q&A: Battery-powered emergency lights

Q: In the standards manual from our accreditation organization it states that every 12 months the critical access hospital either performs a functional test of battery powered lights on the inventory required for egress for a duration of 1½-hours or replaces the batteries and tests 10% of all batteries and records the results. Do we need a written inventory of these lights? If so, can these lights be labeled on a drawing? Or do these need to be listed out in a spreadsheet?

A: First of all.... be careful which edition of the standards you are reading. That accreditation organization changed their standard on this issue in 2018 and eliminated the option of replacing the batteries annually, and only testing 10% of them. The requirement since January 1, 2018 is you must conduct the annual 90-minute test on all of the batteries.

But to answer your question.... Yes… the battery powered emergency lights do need to be listed on an inventory in order to be sure all of them were tested. You may list them on a spread-sheet that identifies them by location and/or asset-tracking number, or you may list them on drawings. Both would be best.

Brad Keyes, CHSP, is the owner of KEYES Life Safety Compliance, and his expertise is in the management of the Life Safety Program, including the Environment of Care and Emergency Management programs.