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Microsoft Word - Comments to ENERGY STAR Program Requirements for ExitSigns… Response to EPA Request for Comments

ENERGY STAR Program Requirements for Exit Signs

Public Comment #1
Energy Star Specification
1) Definitions: Below is a brief description of an exit sign and other terms as relevant to E
NERGY
S
TAR
.

A. Exit Sign: An internally-illuminated sign that is permanently fixed in place and used to identify
an exit from a building. A light source illuminates the sign or letters from within, and the
background of the exit sign is not transparent. The exit sign is connected to only one source of
power at a time (normal or emergency), and is designed to remain illuminated via an emergency
power source upon failure of the normal power supply. The emergency power source is typically
either a central back-up generator or an individual rechargeable battery included in each sign.

Public Comment: The definition of exit sign is inconsistent with Underwriters
Laboratories Standard for Safety for Emergency Lighting and Power Equipment, Eighth
Edition dated March 29, 1995 with revisions through and including July 11, 2002.

Section 4.18 of that nationally recognized standard for exit signs states that the definition
of EXIT SIGN is A general term used to refer to an Exit Light, Exit Fixture, and Self-
Luminous or Photoluminescent Exit Sign.

It is also inconsistent with the 2000 Edition of NFPA 101 Life Safety Code, the NFPA 5000

Building Construction and Safety Code
and the NFPA 101B, Code for Means of Egress
for Buildings and Structures.

The definition unjustly and unfairly discriminates against non-electrical exit signs (self-
luminous tritium and photoluminescent).

If the Energy Star Program is truly to be of benefit to the nation, then it must include all
exit signs that are capable of operating under reduced energy consumption in accordance
with EPA guidelines.


Public Comment #2
Energy Star Specification
2) Qualifying Products: Any exit sign that meets the definition in Section 1A is eligible for the
E
NERGY
S
TAR
label. This agreement does not apply to exit sign retrofit kits.

Public Comment:

If the Energy Star Program is truly to be of benefit to the nation, then it
must include all exit signs that are capable of operating under reduced energy
consumption in accordance with EPA guidelines.



Public Comment #3
Energy Star Specification
Visibility Characteristics
Letter size and letter spacing

Performance Specification
The sign shall have the word EXIT or other appropriate wording in plain legible letters not less
than 6 in. (15.2 cm) high with the principal strokes of letters not less that ¾ in. (1.9 cm) wide. The
word EXIT shall have letters of a width not less than 2 in. (5 cm) except for the letter I, and the minimum spacing between the letters shall be not less than 3/8 in. (1 cm). Signs larger than the
minimum established in this paragraph shall have letter widths, strokes, and spacing in proportion
to their height.
1

Luminance contrast Greater than 0.8

Average luminance Greater than 15 cd/m
2
measured at normal (0
°
) and 45
°
viewing angles.

Minimum luminance Greater than 8.6 cd/m
2
measured at normal (0
°
) and 45
°
viewing angles

Maximum to minimum luminance Less than 20:1 measured at normal (0
°
) and 45
°
viewing angles

Public Comment:

The Performance Specifications appear to come from UL 924. The
danger in repeating performance specifications from a UL Standard is that when UL
changes their performance specifications, there then becomes a discrepancy between
Energy Star Performance Specifications and UL 924 Performance Specifications.

Additionally, and perhaps more importantly, It also sets up a new battle ground at EPA for
manufacturers to lobby for changes in EPA Performance Specifications that may not have
been approved by Underwriters Laboratories.

EPA is not the proper forum for discussions of Exit Sign performance but rather the
energy consumption of exit signs. The proper forum for Exit Sign performance, other than
power consumption, is the model code and standards organizations such as NFPA and
UL, which provides a balanced consensus process that includes government regulators
and industry experts from all parts of the nation.

Therefore, we recommend that a better method of specifying performance specifications is
to simply require that Energy Star Exit Signs be listed in accordance with the latest edition
of UL 924, Standard for Safety for Emergency Lighting and Power Equipment, Eighth
Edition dated March 29, 1995 with revisions through and including July 11, 2002.

This will insure and verify that Energy Star Exit Signs have met all of the appropriate
safety, performance and quality control requirements as recognized within the industry,
NFPA and other model building codes.


Public Comment #4
Energy Star Specification
4) Test Criteria: Manufacturers are required to perform tests and self-certify those product
models that meet the E
NERGY
S
TAR
guidelines. To meet the specification, the exit sign model
must be tested under the following conditions, all performance measurements and calculations
must be completed as described herein, and all the results must comply with the requirements
stated in the Eligibility Criteria.

Conditions for testing
Testing shall be conducted in clear (non-smoke) conditions.

All measurements shall be made in a stable ambient air temperature of 25°C ± 5°C.

All voltages shall be provided within ± 0.5% by a constant voltage power supply.

Prior to input power or photometric measurements, the exit sign model shall be operated at the
rated input voltage for a period of 100 hours. In addition, exit sign model with an internal battery
shall be operated from the battery for one-and-one-half hours, the minimum period of emergency operation specified in NFPAs Life Safety Code
2
, and then recharged for the period specified by
the sign manufacturer.
1
As in current NFPA 101, Life Safety Code, 7-10.6.1.
2
As in current NFPA 101, Life Safety Code, 7-9.2.1.

All of the light sources in the sign must produce light throughout the first 100 hours of operation,
before any measurements are taken, in order to meet the requirements of this specification.

Input power measurement

The input power of the exit sign model in its entirety shall be measured with an appropriate True
RMS Watt Meter at the rated input voltage, which represents normal operation. For an exit sign
model that includes a battery, the battery circuit shall be connected and the battery fully charged
before any measurements are made.

Photometric measurements

Each of the photometric characteristics of the sign shall be measured at three voltages:

* The rated input voltage which represents normal operation.
* A voltage corresponding to the minimum voltage provided either by the internal battery or a
remote emergency power source after one minute of operation, as applicable.
* A voltage corresponding to the minimum voltage provided by the internal battery after the
marked rated operating time or at 87.5% of the rated emergency input voltage for signs intended
to be connected to a remote emergency power source. The level of illumination of the exit sign
shall be permitted to decline to 60 percent of the initial illumination level (specified in Section 3 of
the Eligibility Criteria) at the end of the emergency lighting time duration.

All measurements shall be taken with less than 0.01 footcandles of external illumination on the
face of the exit sign model.

The luminances shall be measured from two viewing angles: 1) from normal (0°) to the face of the
exit sign, and 2) from 45° to the face of the exit sign.

Luminance measurement positions

The positions where the luminances for the legend and background of the exit sign are to be
measured are shown below.
3
For instances in which exit sign model has a directional indicator,
the positions where the luminances for the directional indicator and its background are to be
measured are also shown below.
4

3
Measurement of exit sign luminance in NFPA 101, Life Safety Code, Figure A-7-10.6.3

4
Found in Figure 40.9 Directional indicator luminance measurement points in UL 924, Standard for
Safety: Emergency Lighting and Power Equipment, May 9, 1995.

Measurement of exit sign luminance
Measurement of directional indicator

The luminances for each numbered position in the legend and directional indicator shall be
measured over a circular area as large as possible while maintaining at least a 1.6 mm distance
between the perimeter of the circular area and the adjacent border. The positions for measuring
the luminances of the background shall lie within 25.4 mm of the legend and directional indicator
but no closer than 1.6 mm to the border.

Luminance calculations
Average luminance of the legend or background of the legend, whichever is higher, and where
applicable, the directional indicator or its background, whichever is higher. For each, the mean of
the luminances of all the positions measured.

Luminance contrast ratio: