According to our recent research, more than 2,000 premises — including NHS hospitals — are failing fire inspections in a year, specifically because of inadequate emergency lighting.
Indeed, emergency lighting is vital in all non-residential premises but critical buildings such as care homes or hospitals, where potentially hundreds of patients, including those who are immobile, may need to be evacuated quickly and safely in the event of a power failure or serious event.
What is emergency lighting?
Emergency lighting is a life safety system required by the Regulatory Reform (Fire Safety) Order 2005 for non-domestic premises and residential buildings. Emergency lighting must activate instantly in the event of power failure, which could be caused by a power failure or more serious event such as a fire. Moreover, it must illuminate escape routes, and areas where occupants must pass through to leave the premises.
The physical and psychological value of emergency lighting are difficult to overstate. In daily life, it is surprisingly rare to encounter total darkness, meaning it is hard to imagine the extent of the disorientation and panic that can arise in the event of an unexpected power failure.
At Thorlux Head Office, we deliver an unforgettable, visceral experience that exposes the chilling reality of a power failure. Imagine, the lights suddenly die, you and your colleagues or family are plunged into absolute darkness. No guiding signage, no safe path forward, only disorienting darkness and uncertainty. In our fully scaled rooms and corridors, participants must navigate their way to the safe assembly point as if caught in a genuine evacuation. Every step echoes the chaos of the unknown.
Then, the scenario is repeated but this time, emergency lighting illuminates the route. The stark contrast is undeniable. What was once confusion and fear transforms into clarity and safety, underscoring in the most powerful way the life-saving importance of emergency lighting.
Though this experience unfolds within a controlled environment where we can halt the simulation and restore the lights at any moment the question lingers: what if it were real? What if the lights never came back? Imagine the added terror of smoke, the rising of crowd panic, the choking unbearable heat of fire.
By the end, every participant leaves with a profound understanding: emergency lighting is not a convenience, it is a lifeline. And in real-world settings such as hospitals, care homes, schools, offices, or commercial spaces, the absence of light in an emergency would not just be disorienting. It would be devastating.
While hospitals do have some form of uninterruptable power supply, emergency lighting is a key lifeline for patients, staff and visitors. Indeed, there are statutory requirements, not only relating to the mere fact of lighting, but also to its brightness, battery life, coverage, and an emphasis on escape routes, as well as the speed with which it activates.
Who is responsible for emergency
lighting compliance?
Within all organisations operating or occupying premises there is a responsible person. Together, they bear legal responsibility for compliance with statutory requirements.
The responsible person has overall legal responsibility for compliance with The Regulatory Reform (Fire Safety) Order 2005 (RRO) put in place to protect people within non-domestic or residential premises. In a workplace setting, such as a hospital, this will usually be the employer and so the most senior person in the organisation will be ultimately liable. In severe cases, failure to comply with the articles within 8-22 of the RRO 2005, can lead to a criminal prosecution of up to 2 years and/or fines of up to no maximum sum.
A competent person can be nominated and given the authority to complete maintenance and responsible for overall operation of the life safety system. They do not have to be part of the organisation but could be a third-party contractor and complete testing, reporting and maintenance of the premises emergency and fire system.
While the legal exposure of a competent person is arguably not as great as that of a responsible person, they are still legally responsible for ensuring works are undertaken competently. Failing to do so can lead to criminal prosecution and fines.
Crucially, both the responsible and competent persons must ensure they are aware of changes to standards and legislation that affect the compliance of their emergency lighting systems. They must also take into account that compliance is not simply a matter of installing a conforming system. Instead, it is an ongoing responsibility, requiring them to ensure the ongoing upkeep and monitoring of their emergency lighting systems. Ignorance is not an acceptable excuse if found guilty of non-compliance.
Which standards apply to
healthcare settings?
Due to its critical importance in an emergency, the precise requirements for emergency lighting are tightly defined. While this is the case for all premises open to the public, the requirements for healthcare premises are especially stringent. Estates and facilities managers must not only comply with rigorous statutory requirements, but also with Department for Health guidance.
The Department for Health guidance relating to emergency lighting in healthcare settings is provided in the HTM 06-01 technical memorandum, reflecting the statutory requirements contained in in the BS EN 1838:2024 emergency lighting standards, which have recently been updated.
Executive level leaders, estates and facilities managers must be aware of the key changes in BS EN 1838:2024 as they mean certain emergency lighting set-ups and processes that would previously have been compliant can no longer be assumed to be. The statutory duties on organisations and specific individuals within those organisations mean failure to comply can amount to corporate and personal criminal offences.
What’s new in BS EN 1838:2024?
The changes contained in BS EN 1838:2024 are wide ranging and encompass modifications to the requirements relating to escape route illumination, points of emphasis and hazardous areas, local area lighting, system integrity and testing and maintenance.
One of the more notable changes from the previous BS EN 1838:2013 standards is the requirement for a minimum of one lux across the full width of the escape route and not just the centre line. For escape routes wider than two metres, borders of 0.5 metres can be excluded while routes that are two metres and narrower can have a quarter. Related to this, the new standards include clarification as to how light levels should be measured, particularly in stairwells.
The new standards also outline more specific requirements for the illumination of points of emphasis and hazardous areas. This includes specifying that points such as fire alarm call points, fire equipment and refuge areas have at minimum five lux of illumination.
Similarly, BS EN 1838:2024 provides more detail about requirements for open area lighting, known also as ‘anti-panic lighting’. This must be based on a risk assessment and at minimum, provide 0.5 lux of illumination. High risk areas must provide at least 10% of the required normal maintained illumination and should not be less than 15 lux.
The nature of a hospital setting means it is more likely than is the case for other buildings that there will be occupants who are immobile and therefore cannot evacuate immediately. BS EN 1838:2024 requires dedicated risk assessments to be undertaken. In a hospital environment, estates and facilities professionals will need to liaise with clinical teams in order to understand the nature of those risks and ensure that risks are identified and mitigated adequately.
While the new standards do not apply retrospectively to existing installations, they apply to refurbishments and to new installations. That means luminaires and configurations that would previously have been compliant cannot be assumed to still be so.
Compliance goes beyond luminaires and configurations
Illumination and configuration are not the only aspects of compliance that building owners and occupiers need to be aware of. There are further requirements the responsible person must consider. Daily visual inspections for centrally powered systems, monthly short functional tests for every emergency luminaire and an annual full-duration test are required.
A yearly visual inspection of all the luminaires physical working condition and appearance is also required and must be recorded. This demonstrates that each luminaire can sufficiently operate for the required duration period. BS 1838:2024 now requires a five-year verification lighting level check to ensure the luminaires are achieving the minimum illuminance level and if degradation from pollution and natural lighting source degradation has occurred.
All testing and maintenance must be recorded in the logbook with evidence retained for auditing purposes. A competent person can be nominated by the responsible person to complete these duties.
For a large hospital site, ongoing compliance is a substantial undertaking. The labour-intensive requirement to inspect individual luminaires can put significant pressure on maintenance teams. The sheer volume of luminaires to be inspected also opens up the prospect of human error, with the risk of individual luminaires or even entire sections of buildings being missed.
How to achieve compliance
Thankfully, emergency lighting systems have become increasingly sophisticated, with longer battery life, self-testing capabilities and automatic data recording. Indeed, the latest generations of emergency lighting offer digital log-books that provide an accurate and consistent record of testing. This offers both valuable safety benefits and protection for responsible and compliant persons.
Luminaires have also become more advanced with the aid of optical lenses focusing the light further along escape routes – reducing the quantity of luminaires required to achieve compliant design schemes.
It remains crucial that systems are configured correctly, maintained accordingly, and the responsible and competent person is aware of their responsibilities and duties. Ignorance is not an acceptable excuse if found non-compliant.
Liam Greene
Liam Greene is Thorlux’s emergency lighting product manager. Over the past decade, Liam has brought together expertise in both Product Design and Product Management, underpinned by a BA (Hons) in Product Design.
At Thorlux Lighting, he has led and contributed to several key strategic projects and product launches, with the past three years dedicated specifically to the design, development, and training within the Emergency Lighting sector.
A central focus of Liam’s work is the promotion of awareness around Emergency Lighting standards, legislation, and compliance. This commitment is evident not only in his contributions at Thorlux Lighting but also in his broader engagement with both the UK and European Emergency Lighting markets, where he collaborates closely with an experienced network of industry professionals across Europe.