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U.S. Dept. of Labor Attn: R. Davis Layne Subject: Your letter dated May 4, 2001 Dear Mr. Layne, Regarding the NFPA’s response to OSHA: I was surprised by Mr. Cote’s response to my March 16th letter (dated March 26th and follow-up letter dated April 10th). NFPA has been advised by Underwriters Laboratories at least twice in public meetings that the adoption of the 2000 Life Safety Code would result in UL Listed exit signs that are considerably dimmer than what the Means of Egress Committee had become accustomed to seeing. In fact, UL’s current direction has removed the minimum requirement for measured luminance of an exit sign entirely! The new minimum luminance requirement is zero, and the suitability test requires that the test subjects (persons) spend five minutes in total darkness becoming "dark adapted" before they are asked to determine whether they can see the sign or not. This, coupled with UL’s statement to the NFPA (I believe) will (as you stated) "jeopardize the safety of persons escaping from a fire"… This new direction also jeopardizes the safety of persons who become involved with events such as Oklahoma City, the World Trade Center, hurricanes, tornado’s, etc., etc. Attached, please find a copy of a letter response I received from Dr. Belinda Collins at NIST. I am certain that you will find that Dr. Collins has considerable experience and research knowledge in this subject area. Dr. Collins conclusions substantively and agrees with the position that I have presented. Further, Dr. Peter Boyce of the Lighting Research Center at Rensselaer Polytechnic Institute authored the requirements adopted by the EPA "Green Lights" program. Those requirements call for minimum luminance levels that, again, substantively agree with my position and the position established by Dr. Collins. I congratulate the Dept of Labor, OSHA, NIST and the EPA for recognizing that the brightness of an exit sign does relate to our ability to see it and read it. Life safety is an important issue. Within the next few months, UL is intending to convene a "Standards Technical Panel" (STP) for the Emergency Lighting and Power Equipment Standard (UL-924). UL has told me that this group will decide direction by majority rule. UL will provide the secretariat services, but will have only one vote. Since OSHA has such a large stake in the issue of employee safety, I would hope that you would see fit to ask for a seat on this panel. The contact person at UL is Mike Shulman at the Santa Clara, CA UL Laboratory. His contact information is as follows:
NEMA, the National Electrical Manufacturers Association, will soon release a white paper that will include luminance measurements of exit signs. These tests were conducted by an NRTL and compliment the balance of the white paper. As soon as this is available, I will see that you are included in its initial distribution. Again, thank you for your response to my letter, and I trust that we will have the opportunity to meet with DOL/OSHA in the very near future. Sincerely, Thomas W. Burnet |