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George D. Miller, President Subject: Your letter dated Dear Mr. Miller, I read your "first response" editorial in the May/June issue of the NFPA Journal with great interest. "Start a prairie fire of public opinion"… indeed! I am trying to follow your lead! I empathize with Cassandra who was "doomed never to be believed". I thought from the very beginning that help would come from the NFPA. It seems now that if this were to be the case, this help must come from you! To date, NFPA actions prefer the implementation of a "performance based standard" to reasonable and logical issues involving public safety. Here’s the problem: 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. 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 the NFPA has both experience and expertise in code development, 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 the NFPA in the very near future. Sincerely, Thomas W. Burnet Manager of Product Development
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