(NJ) Whole Building Generator - Emergency Lighting

[rmerz01]

We had an inspector fail us for a particular situation and I'm trying to find the code reference as they neglected to site it. The inspector is an absolute hard-a$$ and while I believe this is a design issue, I'm inclined to not bother the guy because he's that bad.
The building has a back-up generator that essentially serves all of the loads, even the normal lighting. The inspector said that if the utility source is gone and the building is on generator, all emergency & egress lighting must be lit. The only way the lighting control system can determine that there's an issue is when the UL924 devices sense a loss of "normal" power. Since the normal power for lighting is backed up by a generator, it doesn't "know" it's in an emergency condition. The issue arose in areas that have emergency lights but may be locally switched off because of one or another (no occupancy, timed out, turned off on purpose, etc.). The AHJ wants all emergency lighting on in every area, regardless of occupancy, in the event of primary source loss and the generator turning on because it is an emergency situation.
I've been trying to find specific code references for this but I can't seem to find anything definitive. How would you achieve it after the lighting system has been installed, programmed, etc.? We installed it as designed so if we spend any money doing this, it's going to be a CO. I just would like a little NEC code help here if it has to go that far.

 

[gadfly56]

We had an inspector fail us for a particular situation and I'm trying to find the code reference as they neglected to site it. The inspector is an absolute hard-a$$ and while I believe this is a design issue, I'm inclined to not bother the guy because he's that bad.
The building has a back-up generator that essentially serves all of the loads, even the normal lighting. The inspector said that if the utility source is gone and the building is on generator, all emergency & egress lighting must be lit. The only way the lighting control system can determine that there's an issue is when the UL924 devices sense a loss of "normal" power. Since the normal power for lighting is backed up by a generator, it doesn't "know" it's in an emergency condition. The issue arose in areas that have emergency lights but may be locally switched off because of one or another (no occupancy, timed out, turned off on purpose, etc.). The AHJ wants all emergency lighting on in every area, regardless of occupancy, in the event of primary source loss and the generator turning on because it is an emergency situation.
I've been trying to find specific code references for this but I can't seem to find anything definitive. How would you achieve it after the lighting system has been installed, programmed, etc.? We installed it as designed so if we spend any money doing this, it's going to be a CO. I just would like a little NEC code help here if it has to go that far.

Call the DCA and explain the situation. Give them the name of the inspector. They guys down in Trenton really hate it when locals decide to make up their own rules. I know sometimes you don't want to get into a beef with inspectors because you have to do repeat work in the town, but once they get slapped down a couple of times, they get the message.

 

[kec]

Does the exit and emergency lights have a battery backup?

 

[rmerz01]

Call the DCA and explain the situation. Give them the name of the inspector. They guys down in Trenton really hate it when locals decide to make up their own rules. I know sometimes you don't want to get into a beef with inspectors because you have to do repeat work in the town, but once they get slapped down a couple of times, they get the message.

What's strange is that it's the second time an inspector has done this. It's a different municipality though. I don't think they're making anything up so I'm trying to dig around. Maybe there's a NJ-specific addendum in the IBC, NFPA 70 or 101?
What's strange to me is if it's being locally enforced, how come engineers aren't keen to this issue yet? The other time it happened was almost a year ago so either there's a contingent of inspectors doing it wrong, or the engineers designing these jobs are doing it incorrectly.

 

[rmerz01]

Does the exit and emergency lights have a battery backup?

They don't but I don't believe it would matter if it did. If all of the lighting in the building is backed up by an emergency generator, then it wouldn't know the difference between utility or backup power.

 

[ron]

There are several things at play. Not all generators are emergency generators (Article 700).

Is the egress / exit lighting circuited separate from general lighting or other non-emergency (optional standby) loads? Are there separate ATSs?

 

[gadfly56]

There are several things at play. Not all generators are emergency generators (Article 700).

Is the egress / exit lighting circuited separate from general lighting or other non-emergency (optional standby) loads? Are there separate ATSs?

Isn't this generally a bad idea? If you have a complete building blackout, it doesn't matter, but if you have a partial blackout, you want the emergency lights to come on in that area. If the emergency lights are wired into the light circuits that serve the area in which the lighting circuits are placed, that happens automatically. Otherwise, you need complicated detections schemes to turn the emergency lights on for a partial blackout.

 

[infinity]

The inspector said that if the utility source is gone and the building is on generator, all emergency & egress lighting must be lit. The only way the lighting control system can determine that there's an issue is when the UL924 devices sense a loss of "normal" power. Since the normal power for lighting is backed up by a generator, it doesn't "know" it's in an emergency condition. The issue arose in areas that have emergency lights but may be locally switched off because of one or another (no occupancy, timed out, turned off on purpose, etc.). The AHJ wants all emergency lighting on in every area, regardless of occupancy, in the event of primary source loss and the generator turning on because it is an emergency situation.
I've been trying to find specific code references for this but I can't seem to find anything definitive.

What code section did he cite?

 

[augie47]

Looking at Part IV of Art 700 I think the inspector might have some valid points

 

[gadfly56]

Looking at Part IV of Art 700 I think the inspector might have some valid points

I'm not seeing clear support for the inspector's position. It is arguable that the generator energizes the normal power circuits, and therefore the transfer of power to the emergency circuits is not required. And, it's just plain silly on the face of it. All the lights in the building go off and come back on, and the emergency lights stay energized.

 

[infinity]

If the generator is sized to carry the entire load then can't everything be considered to be a EM circuit?

It sounds like this inspector is requiring that all of the designated EM lights come on when the normal power goes out.

 

[don_resqcapt19]

Isn't this generally a bad idea? If you have a complete building blackout, it doesn't matter, but if you have a partial blackout, you want the emergency lights to come on in that area. If the emergency lights are wired into the light circuits that serve the area in which the lighting circuits are placed, that happens automatically. Otherwise, you need complicated detections schemes to turn the emergency lights on for a partial blackout.

That would not be typical for a generator supplied Article 700 emergency system.

 

[augie47]

I guess my concern comes from the OP where he indicates some unoccupied areas have not lighting (switched off). In the event of an emergency the generator would still be supplying power to those areas so no emergency lighting would be activated even though that might be an emergency egress route.
As

 

[don_resqcapt19]

If the generator is sized to carry the entire load then can't everything be considered to be a EM circuit?

It sounds like this inspector is requiring that all of the designated EM lights come on when the normal power goes out.

Only the loads specified in the building codes can be on emergency circuits and those circuits must be completely separate from all other circuits. It the Article 700 generator supplies loads other than Article 700 loads, additional transfer switches are required.

 

[dkidd]

I guess my concern comes from the OP where he indicates some unoccupied areas have not lighting (switched off). In the event of an emergency the generator would still be supplying power to those areas so no emergency lighting would be activated even though that might be an emergency egress route.
As

Emergency lighting could be locally controlled if UL 924 transfer devices are incorporated. In the event of a power outage they would be turned on.

 

[dkidd]

Only the loads specified in the building codes can be on emergency circuits and those circuits must be completely separate from all other circuits. It the Article 700 generator supplies loads other than Article 700 loads, additional transfer switches are required.

I agree. A separate transfer switch and separate wiring are required for Article 700 loads.

 

[ron]

Isn't this generally a bad idea? If you have a complete building blackout, it doesn't matter, but if you have a partial blackout, you want the emergency lights to come on in that area. If the emergency lights are wired into the light circuits that serve the area in which the lighting circuits are placed, that happens automatically. Otherwise, you need complicated detections schemes to turn the emergency lights on for a partial blackout.

I am not a fan of using an Article 700 generator for EM lighting, but it is permitted and will only turn on when the sensing point at an ATS calls for it. If there is some breaker in the distribution downstream that trips, there would be no indication to an Art 700 generator to start.

 

[d0nut]

I am not a fan of using an Article 700 generator for EM lighting, but it is permitted and will only turn on when the sensing point at an ATS calls for it. If there is some breaker in the distribution downstream that trips, there would be no indication to an Art 700 generator to start.

If it is a breaker trip on the normal lighting side, your EM panel will still have power from the normal side of the ATS and there is no need to start the generator. If it is a breaker trip on the EM panel side, the normal lighting in the area will still have power and allow a safe egress from the building. This is why two sources of power (normal and emergency) are required for egress lighting in an egress path. You can lose either one, but not both, and will still be able to egress in the light.