Federal Emergency Management Agency
Emmitsburg, MD 21727
Attn: Kenneth O. Burris, Jr.
Acting U.S. Fire Administrator

Subject: Your letter dated May 2, 2001

Dear Mr. Burris,

Thank you for your May 2, 2001 response to my letter to FEMA Director Allbaugh. I agree that in most cases, changes in code requirements are forward thinking. In life safety terms, the emergency lighting industry has made very long strides in producing efficient systems that meet the new requirements while reducing energy consumption. For example, today’s interior exit signs are typically illuminated by high brightness LED light sources and require less than 10% of the energy of the typical sign produced just a few years ago. Some of us have been producing the LED type exit for nearly 15 years.

Not all Code changes are for the best. 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 jeopardize the safety of persons escaping from a fire or become involved with events such as Oklahoma City, the World Trade Center, hurricanes, tornado’s, etc., etc.

Regarding NIST……… 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 the visibility of exit signs. Dr. Collins conclusions substantively agree 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.

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 FEMA has both experience and expertise in code development and the USFA, (certainly a large stake in the issue of safety and safety regulations/requirements), 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:

Mike Shulman (x32770)
Senior Staff Engineer
Conformity Assessment Services
SANTA CLARA OFFICE
phone 408 985 2400 x32770
fax 408 556 6062
email michael.s.shulman@us.ul.com

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 FEMA in the very near future.

Sincerely,

Thomas W. Burnet

Manager of Product Development