1

This is a draft document and does not represent a definitive view of the agency on the questions
addressed

.

This and other guidance documents are accessible on the U.S. Department of Energy, Energy Efficiency & Renewable Energy web site at: http://www1.eere.energy.gov/guidance/default.aspx?pid=2&spid=1

.

Guidance Type: Test Procedures Category: Commercial and Industrial Equipment Equipment : Illuminated Exit Signs
Guidance Version: DRAFT
Issued: June 6, 2013

This guidance represents DOE’s interpretation of its existing regulations and is exempt from the notice and comment requirements of the Administrative Procedure Act. See 5 U.S.C. § 553(b ) (A). Nevertheless, given that the Department has not previously expressed its views on this issue, we are interested in receiving feedback from the public. Therefore, the Department is accepting comments and suggestions from the public until July 8, 2013

. Comm ents and suggestions should be provided in WordPerfect, Microsoft Word, PDF, or text file format by sending an email to IExS

- Guidance

- 2013

- CE

0078@ee.doe.gov . Please also include the docket numbe r: EERE

- 201 3

- BT

- CE

- 0078. At the end of the comment period, this draft guidance document may be adopted, revised

, or withdrawn.

Last Day for Comments: July 8, 2013.

Q: Are illuminated exit sign s with integrated egress light ing or other emergency functions covered by

F ederal energy conservation standards ?

A: Yes, the Federal energy conservation standards for illuminated exits signs apply to products with integrated egress lighting or other emergency functions (sometimes referred to as combination exit signs) . H owever, the standard applies to the exit sign, not to other component s (e.g., egress lighting, alarms) . M anufacturers of these products may require a waiver from the DOE test procedure to test
and generate representative results for the energy consumption of certain basic models

.

Federal energy conservation standards require that illuminated exit signs manufactured on or after January 1, 2006

, have an input power demand of 5 watts or less per face. 10 CFR § 431.206 ; see also

42 U.S.C. § 6295(w)

.

DOE understands that certain manufacturers of illuminated exit signs with integrated egress lighting or other emergency functions have been operating under a mistaken belief that F ederal energy

conservation standards d o not apply to such units. To clarify

, any illuminated exit sign that meets each
element of the relevant product definition 1 is a covered product under the statute and DOE’s

1 The t erm ‘‘illum inat ed exit sign’’ m eans a sign t hat

— (A) is d esigned t o b e p erm anent ly f ixed in p lace t o id ent if y an exit ; and (B) consist s of an elect rically p ow ered int egral light source t hat

— (i) illum inat es t he legend ‘‘EXIT’’ and any d irect ional ind icat ors; and (ii) p rovid es cont rast b et w een t he legend , any direct ional ind icat ors, and t he b ackground. 42 U.S.C. § 6291(37); 10 CFR § 431.202.2

regulations. The addition of an cillary features or hardware would not transform the illuminated exit sign

into a non

- covered product or otherwise move it beyond the applicable regulatory requirements

, although the added features or hardware are not subject to the energy conservation standard

.

DOE recognizes that us ing the current DOE test procedure to test illuminated exit signs that incorporate integrated egress lighting or other ancillary features may result in measured values that are not representative of solely the illuminated exit sign component ’s energy efficienc y

. In contrast to models without ancillary features such as egress lighting , t hese combination exit sign model s must have a larger battery capacity to operate the emergency lights for at least 90 minutes after the main power supply is disrupted , per National Fire Protection Agency (NFPA) requirements. NFPA 101 § 7.9.2.1. The onboard battery charger is an auxiliary power draw that , when charging, typically results in a n increase in the total input power demand beyond the power required to operate th e illuminated sign faces alone.

Because DOE’s current test procedure do es not provide a methodology for excluding the power consumed for charging the battery used to power features other than the exit sign faces , manufacturers
of basic models with this feature may seek a waiver from the DOE test procedures to test and certify
these models if they do not believe the result of the DOE test procedure is representative of the exit sign ’s energy efficiency . Additional details regarding how to obtain a test p rocedure waiver are available

in 10 CFR p arts 430 (consumer products) and 431 (commercial and industrial equipment)

.

It is DOE’s enforcement policy to refrain from pursuing an enforcement action while a test procedure waiver request is pending

. DOE has also initiated a test procedure rulemaking for illuminated exit signs, with related rulemaking documents to be subsequently published in the Federal Register and posted on
the DOE website.