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The impact of the RRO on emergency lighting

Mar 07, 2007

The biggest change in fire safety legislation for many years – the Regulatory Reform (Fire Safety) Order – finally came into force last October. Peter Cook examines how it is affecting emergency lighting systems.

When the Regulatory Reform (Fire Safety) Order 2005 came into force on 1st October 2006, the responsibility for fire safety within most premises passed from the local fire authority to a ‘responsible person’, which in the workplace means the employer or any other person who may have control of any part of the building.

The fundamental requirements of the RRO are for the responsible person to carry out a fire risk assessment and to take reasonable steps to remove hazards and reduce risks so that people can escape safely in the event of a fire.

Government guides

To aid this process, the government has published a series of fire safety risk assessment guides, which emphasise the need for emergency lighting wherever escape routes are internal and without windows or if premises are used during periods of darkness.

The guides require that installation and any modification of an emergency lighting system should be carried out by a competent person in accordance with BS5266 Parts 1 and 8. Furthermore, the emergency lighting system must be fit for purpose, regularly tested and properly maintained.

In the old days before the RRO, a fire officer would check and approve each building’s fire safety systems – including the emergency lighting - and then issue a fire certificate. Once this had been done, building operators were deemed to have discharged their legal responsibilities.

But the RRO has changed all that by doing away with fire certificates for all but a very small minority of particularly high risk premises. Instead of being able to hide behind a fire certificate, the ‘responsible person’ now has to demonstrate that the emergency lighting system is, and continues to be, ‘fit for purpose’. The best way of achieving this is to make use of third-party certification schemes such as BSI Kitemarking and ICEL registration.

Indeed the government guides themselves strongly endorse the use of third-party certification schemes as they provide the fullest possible assurances with regard to product quality, reliability and safety: “Third-party quality assurance can offer comfort both as a means of satisfying you that goods and services you have purchased are fit for purpose, and as a means of demonstrating that you have complied with the law.”

Cheap luminaires

That being said, nobody wants to spend more than they need to on any product, and contractors can easily be tempted by the ready availability of some cheap emergency luminaires. However, these should be treated with great caution, and contractors should bear in mind that there are other ways to reduce the cost of an emergency lighting system without compromising quality, performance or safety. Moreover, although the legislation places primary responsibility on building owners and users, they in turn may take action against contractors who supply or install sub-standard equipment that fails to operate correctly when required.

BS6266 Part 7 defines the minimum illumination levels for various areas during emergency conditions. It is not enough simply to fit a number of emergency luminaires without ensuring that their combined performance produces adequate illumination. Since minimum illumination levels must be achieved in order to satisfy the legal requirements, emergency lighting schemes cannot be correctly planned or assessed without accurate performance data for the specific luminaires to be used.

Many cheap emergency luminaires are supplied from distant sources and will pass through various intermediaries on their route to market. The original manufacturer may be unaware of where products will finally be installed and cannot be expected to know or adhere to the technical and legislative requirements applicable to the final marketplace. At any point in the supply chain, performance claims made by suppliers are open to embellishment and may be subject to human error or misinterpretation, and so they cannot be relied upon as accurate unless verified by an independent third party.

In addition, cheaper luminaires present a number of other potential problems: as they often utilise lower-quality components, failures are likely to be more common, battery and lamp lives likely to be shorter, and maintenance costs are likely to be higher – not to mention the difficulties involved in sourcing any necessary spare parts.

BSI Kitemark

So, how can contractors be sure they are not buying an inferior product? There are stringent European product standards covering the design and manufacture of emergency luminaires, e.g. EN60598-1 and EN60598-2-22, and independent testing organisations such as the British Standards Institution (BSI) carry out thorough testing of products to ensure that they satisfy the requirements of these standards. When these tests have been successfully completed, the BSI allows the Kitemark symbol to be applied to the product as evidence that it is safe and fit for purpose. When buying life-safety systems such as emergency lighting, it is therefore wise to choose only products that carry the BSI Kitemark symbol.

The Kitemark shows that the product has been correctly designed and manufactured and can therefore be expected to provide reliable operation and the best possible life from the individual components. However, it does not verify the accuracy of performance claims made by the supplier.

ICEL approval

Independent confirmation of a luminaire’s performance can be provided by the product auditing and approval scheme run by ICEL (the manufacturers’ trade organisation). As well as verifying that the luminaire’s spacing tables are accurate and trustworthy, ICEL also carries out various checks on both the product and the supplier, and if these are successful, the luminaire is awarded ‘ICEL approved’ status and given an ICEL registration number.

If ICEL-approved luminaires are installed at the correct locations according to ICEL-verified spacing data and design guides, the resulting installation is considered to be adequate to ensure the safety of building users and to guard against possible legal action.

Luminaires that are not ICEL approved may still be fit for purpose, but building owners and their suppliers may have to find a way of demonstrating that they have complied with their duty of care, should tragedy or even a minor accident occur.

Reducing costs

So, using emergency luminaires that are BSI Kitemarked and ICEL registered will provide peace of mind that legal obligations have been met, but the inevitable assumption is that the emergency lighting scheme will cost more. This is not necessarily the case.

Although the unit price of a well designed, high-quality stand-alone emergency luminaire may be slightly higher, such products very often provide a significantly higher light output and better spacing performance than cheaper alternatives, which means that fewer luminaires are required in order to achieve the necessary illumination levels. As well as reducing the total capital outlay for the fittings, this helps to cut installation costs.

Also, higher-quality luminaires often incorporate features specifically designed to reduce installation time, including first-fix bases, plug-in gear trays and self-locking snap-on lenses. In short, using emergency luminaires with a higher price tag can actually result in a lower installed system cost.

The use of higher-quality fittings will also pay dividends once the emergency lighting system is up and running. Higher-quality luminaires, batteries and lamps generally have a longer life and therefore need replacing less frequently, which saves money on spares and reduces maintenance costs.

All self-contained emergency luminaires (even non-maintained types) require a constant unswitched mains supply to maintain the rechargeable standby battery in a fully charged state. By using a smaller quantity of higher-performing emergency luminaires, significant savings in running costs can be achieved.

So, while it may be tempting to opt for the cheapest emergency lighting available, there are now a number of compelling reasons for choosing products that are both BSI Kitemarked and ICEL registered.

Continued compliance

Another important aspect of the RRO is the requirement for the emergency lighting system to be fit for purpose not only when it is commissioned but also throughout its life. Emergency lighting is first and foremost a life-safety system, and if it fails to function properly, then responsible individuals can be prosecuted and employers’ insurance policies may be rendered invalid. The bottom line is this: if the equipment does not work, the responsible person will be just as guilty as if the equipment had not been installed at all.

Under these circumstances, many building operators are reviewing the type of emergency fittings they choose. Take the maintained exit sign, for example. In the past, the 8W fluorescent lamps used in these fittings had a design life of around 6000 hours and needed replacing every 8-9 months. Since building operators have a legal responsibility to ensure that emergency lighting is maintained in full working order, the use of new light sources having much longer working lives is a major benefit in this respect.

LED technology

In particular, exit signs utilising LED technology are increasing in popularity as they provide a design life of more than 50,000 hours. White LED technology has progressed rapidly in recent years, and single devices are now available with power ratings of several watts, making them an attractive alternative to traditional fluorescent light sources for the relatively low illumination levels required for emergency lighting.

Major benefits

As well as helping building operators to comply with the RRO requirements, the long working life of an LED-based exit sign also translates into major benefits with regard to maintenance costs and environmental impact.

Whereas the fluorescent lamps in maintained exit signs need replacing every 8-9 months, with battery replacement every 4-5 years, the only maintenance requirement for a maintained
LED-based exit sign is a single replacement of the battery and light source every 4-5 years. This dramatically reduces the disruption caused by lamp changes and means that an LED-based exit sign can end up costing the building operator significantly less than a fluorescent equivalent over the lifetime of the product.

In terms of environmental benefits, the LED-based exit sign contains no mercury, it eliminates the waste and energy consumption associated with frequent lamp changes, and it provides ongoing energy savings: a maintained LED exit sign typically uses 20% less energy than a maintained fluorescent exit sign.

Emergency luminaires

Following the successful implementation of LEDs in exit signs, the technology is now being used to produce very compact and unobtrusive emergency luminaires. Whereas the design of traditional emergency luminaires was constrained by the size and shape of the 8W fluorescent lamp, LEDs are such compact devices that the light source no longer determines the shape and dimensions of the luminaire.

Allowing accurate directional control of the light source so that there is very little ‘wasted’ light, some of the latest generation of LED-based products have been optically engineered to provide maximum performance when mounted axially, thus complementing the typical mains lighting layout.

One such product, the innovative Briteway luminaire, uses purpose-designed optical lenses and dual LEDs to achieve a distribution that is optimised for escape route illumination, with maximised spacings between luminaires (typically 8m). When used in maintained mode, products like Briteway are ideal for nightlighting or background illumination applications in, for example, hospitals, student accommodation and places of entertainment.

Other innovative designs concentrate on delivering unobtrusive and aesthetically pleasing emergency lighting using tiny circular low-profile luminaires with diameters of just a few centimetres, thereby avoiding the need for bulkhead luminaires on a ceiling. Luminaires such as the JSB Micropoint provide a versatile solution that can combine the role of emergency lighting with mood lighting in say hotels, pubs, nightclubs, reception areas and retail interiors.


Although the RRO represents a significant change in emergency lighting legislation, the use of Kitemarked and ICEL-approved products not only provides peace of mind regarding legal obligations but can also result in a lower installed cost. In addition, LED-based emergency fittings will help to achieve continued compliance while providing long-term cost, maintenance and environmental benefits.


Peter Cook is product marketing manager at Cooper Lighting and Security, with responsibility for product development and marketing of the company’s Menvier and JSB ranges of central battery systems, emergency lighting and fire detection systems. He has over 20 years’ experience with the company.