Building  Owners  and  Managers  Association  International

Building Owners and Managers Association International

Luminous Egress

BOMA POSITION

BOMA International opposes mandates for luminous egress path markings in existing buildings.

Background

Luminous egress path markings, also known as exit stair path markings, are markings on stairs, walls, floors, and doors that help illuminate the egress path in exit enclosures. Following 9/11, luminous egress path markings were recommended by the World Trade Center Building Code Task Force in 2002, and first became a requirement for high-rise buildings in New York City. Since then, new requirements were added to the 2009 editions of the International Building Code (IBC), the 2009 International Fire Code (IFC), and NFPA 101 – The Life Safety Code. The IBC requires luminous egress path markings in exit enclosures and exit passageways of high-rise buildings that house Group A – Assembly, B – Business, E – Educational, I – Institutional, M – Mercantile, and R-1 – Residential occupancies. They are not required for buildings that are not high-rise buildings or in other occupancies even if the building is a high-rise. A high-rise building is defined as a building having an occupied floor located more than 75 feet above the lowest level of fire department vehicle access.

These building codes are designed for new construction, but when undergoing the local code adoption process, some jurisdictions are proposing that the luminous markings be mandated on existing buildings as well. BOMA recommends that jurisdictions maintain a principled preference for not adopting retrofits for existing buildings that were built to the code in place at time of construction without strong and overwhelming evidence that there have been a demonstrated need or actual incidents and significant risks to justify the costs.

BOMA International opposes luminous marking mandates for several reasons. First, there is no demonstrable need for this regulation; high-rise office buildings are among the safest places to be. There were no fire deaths in high-rise office buildings across the U.S. between 2005 and 2009 (the most recent year available), and only $4.7 million in damages. Conversely, it is estimated that the cost to retrofit existing high-rises with the rigid luminous material exceeds $0.35 per square foot – nationwide the estimated cost is two billion dollars. In addition, almost all high-rises have backup generators, emergency egress lighting, pressurized stairways, sprinkler systems, and regularly tested fire systems. Furthermore, the paint and soft tape options do not hold up to the foot traffic, yet the vastly more expensive rigid material in metal tracks significantly increases the trip and fall hazard where installed retroactively after construction across the leading edge of the stair. Installation in new construction allows for recessed flush installation.

Some jurisdictions that have considered these mandates have found them to be unnecessary and extreme. The City of Philadelphia recently adopted the 2009 International Fire Code with a provision requiring all high-rise buildings, new as well as existing, to mark the stair towers with photo luminescent paint or tape. After careful review, the Philadelphia Fire Department felt comfortable with BOMA’s position to amend the requirement to exempt those buildings in which: (1) a sprinkler system is installed throughout the building; and (2) the building's exit stairway lighting is connected to an emergency generator or other secondary power supply.​