Understanding the Dual-Standard Approach: BS EN 1838:2024 vs BS 5266-1:2016
UK emergency lighting compliance requires understanding two complementary but distinct standards that work together to ensure building safety. For designers seeking to provide compliant systems, it’s crucial to understand when and how to apply each standard.
BS EN 1838:2024: The Performance Standard
Purpose: Specifies the luminous requirements (what lighting levels must be achieved) for emergency escape lighting and standby lighting systems. This is a European performance standard that defines technical lighting targets.[1]
When to Use: BS EN 1838:2024 is referenced when determining:
Required illuminance levels for different areas
Measurement procedures and verification of lighting performance
Technical specifications for adaptive emergency escape lighting systems (AEELS)[2]
Compliance with European harmonised standards
Key 2024 Updates:
Full Width Route Illumination: Escape routes now require illumination across the entire route width, not just the centre line. For routes wider than 2m, exclude 0.5m borders; for routes 2m or narrower, exclude quarter-width borders[3]
Enhanced Points of Emphasis: Minimum 5 lux vertical illuminance at fire alarm call points, firefighting equipment, and door controls[4]
Adaptive Emergency Escape Lighting Systems (AEELS): New requirements for intelligent systems that can modify escape routes based on real-time conditions[5]
Local Area Lighting: Specific provisions for occupants remaining in buildings during power outages[6]
BS 5266-1:2016: The Code of Practice
Purpose: Provides comprehensive practical guidance for design, installation, commissioning, testing, and maintenance of emergency lighting systems. This is the UK’s complete application standard.[7]
When to Use: BS 5266-1:2016 is essential for:
System design and layout planning
Installation procedures and wiring requirements
Commissioning checklists and handover procedures
Testing protocols and maintenance schedules
Risk assessment guidance
Record keeping and documentation
Scope: Covers the complete project lifecycle from initial consultation through ongoing maintenance, with specific guidance for diverse UK building types.
Designer's Decision Matrix: When to Apply Each Standard
Design Stage | Use BS EN 1838:2024 For | Use BS 5266-1:2016 For |
---|---|---|
Performance Specification | Light levels, illuminance targets, measurement criteria | System classification, duration requirements, design procedures |
Layout Design | Full-width route illumination requirements, points of emphasis | Luminaire spacing, positioning, coverage areas |
System Selection | AEELS requirements, technical performance | Power supply selection, wiring methods, system types |
Installation | Measurement verification procedures | Installation methods, cable requirements, commissioning |
Compliance Verification | Illuminance testing and measurement | Testing schedules, documentation, certification |
Current Emergency Lighting Minimum Lux Levels (BS 5266-1:2016)
The lighting requirements now reflect both standards’ latest provisions:
Escape Routes: Minimum 1 lux across the full width of escape routes (excluding specified border areas), representing a significant change from centre-line-only illumination in previous standards.[8]
Open Areas (Anti-panic Lighting): Minimum 0.5 lux at floor level for areas greater than 60m², excluding 0.5m perimeter border. Industry guidance indicates future revisions will likely increase this to 1 lux minimum.[9]
High-Risk Task Areas: Not less than 10% of average normal lighting with minimum 15 lux.[10]
Points of Emphasis: Minimum 5 lux vertical illuminance at fire alarm call points, firefighting equipment, and safety devices – a key update in BS EN 1838:2024.[11]
Specific Applications: Treatment rooms require 50 lux, first aid rooms require 15 lux, and reception areas require 15 lux.[12]
Adaptive Emergency Escape Lighting Systems (AEELS)
BS EN 1838:2024 introduces mandatory consideration of AEELS for all building types. These intelligent systems can:[13]
Automatically modify escape routes based on real-time fire or hazard conditions[14]
Enhance signage visibility through dynamic directional indicators[14]
Integrate with building management systems for coordinated emergency response[14]
Revert to standard EN 1838 operation if system communication fails[14]
Design Implications: AEELS require additional infrastructure planning, including communication networks between control units and luminaires. Designers must ensure fallback compliance with standard emergency lighting requirements.[14]
UK Building Regulations Compliance Framework
Legal Requirements:
Regulatory Reform (Fire Safety) Order 2005: Mandates adequate emergency lighting provision[15]
Building Regulations Part B: Fire safety requirements for new and existing buildings[16]
Health and Safety Regulations: Workplace safety sign and signal requirements[17]
Standards Hierarchy:
BS EN 1838:2024: Technical performance requirements (European harmonised)
BS 5266-1:2016: UK code of practice and application guidance
BS EN 50172:2024: Testing and maintenance procedures[18]
BS EN 60598-2-22:2022: Luminaire safety and performance standards[18]
For UK Compliance: Projects must satisfy both the technical performance targets of BS EN 1838:2024 and the practical application requirements of BS 5266-1:2016.
Luminaire Performance Requirements under BS EN 60598-2-22:2020/2021
The standard BS EN 60598-2-22 has undergone significant updates, with the latest version being IEC 60598-2-22:2021 (adopted as BS EN 60598-2-22:2022) [19][20][21]. The key performance changes include:
Updated Requirements [20][21][22]:
Rest mode and inhibiting mode requirements have been updated and clarified
High temperature operation tests have been clarified with more specific testing procedures
New requirements for lithium batteries have been introduced to address modern battery technologies
Electric double layer capacitors (EDLCs) now have specific requirements
Resistance to heat, fire and tracking requirements have been clarified
Test facilities for self-contained luminaires have been clarified
Contrast measurements for exit signs test methods have been improved
The luminaires must comply with these performance standards to ensure reliable operation during emergency conditions[23][24].
Changes to Emergency Lighting Maintenance and Testing
Recent updates to maintenance and testing requirements have introduced more stringent procedures:
BS EN 50172:2024 Updates [25][26][27]:
Introduction of bi-annual testing requirements for emergency luminaires and externally illuminated safety signs
Enhanced initial verification requirements
Improved handover documentation standards
Modified maintenance and verification procedures
New guidance for system durations and activation times
Considerations for emergency lighting during lockdowns or prolonged power disconnections
Testing Frequencies [28][29][30]:
Daily tests: Only required for central battery systems
Monthly functional tests: Brief 30-second to 1-minute tests to verify operation [28][29]
Annual duration tests: Full 3-hour discharge tests to verify battery capacity [28][29]
Bi-annual inspections: New requirement to check for damage, dirt, dust, and material degradation
Fire-Resisting Cable and Circuit Routing Requirements
Emergency lighting cables must meet enhanced fire protection requirements [30][31]:
Cable Performance Standards:
Cables should have a minimum 60-minute survival when tested to BS EN 50200:2015 [31]
Standard cables (like FP200 Gold) are suitable for most applications including sprinklered buildings [30]
Enhanced cables (like FP PLUS) may be necessary for large, complex, un-sprinklered buildings [30]
Installation Requirements [32] [33]:
Fire-resisting supports are required for wiring systems in escape routes under BS 7671 Regulation 521.11.201 [32]
Segregation requirements when emergency lighting cables share containment with other services [31]
Non-combustible support methods are required – plastic clips, ties, or trunking cannot be the primary means of support [31]
Cables must be exclusive to the emergency lighting installation and separate from other circuits [31]
Emergency system wiring must be entirely independent of all other wiring, with limited exceptions [34] [35]
Two-hour fire protection is required for specific installations in assembly occupancies or buildings above 23m height [34]
Listed fire-rated assemblies or electrical circuit protective systems may be required
Updates from BSI and Emergency Signage
BS 9991:2024 Updates [36] [37] [38]:
The revised BS 9991:2024 (Fire safety in residential buildings) was published on November 27, 2024, introducing:
Expanded scope to include residential care homes
Enhanced guidelines for evacuation lifts
Revised height limits for sprinkler installation and single-stair buildings
European classifications for fire doors
Smoke control enhancements
BS EN 1838:2024 Updates [39] [40]:
The new emergency lighting standard, published December 31, 2024, includes:
Revised escape route lighting requirements to cover the entire route width
Adaptive Emergency Escape Lighting Systems (AEELS) recommendations for all building types
Enhanced specifications for points of emphasis and hazardous areas
5 lux minimum vertically at fire alarm call points and firefighting equipment
PLS (Photoluminescent Safety) Location Criteria
Photoluminescent safety systems are governed by the following standards [31] [32] [33]:
Key Standards:
CIBSE Updates
The CIBSE LG12 Emergency Lighting (2022) edition [37] [38] provides updated guidance emphasising:
Risk assessment-based approaches to emergency lighting design
Standardised terminology from BSI definitions
Enhanced design management procedures
Compliance documentation requirements for safety legislation
Updated equipment and system guidance
This guide reflects the evolution from prescriptive rules to risk-based design approaches, ensuring emergency lighting systems are optimised for specific building circumstances while maintaining full compliance with safety legislation [37] [39].
Designer's Compliance Checklist
Pre-Design Phase:
□ Conduct risk assessment per BS 5266-1:2016 guidance[39]
□ Determine building classification and occupancy type[40]
□ Assess requirement for AEELS per BS EN 1838:2024[41]
Design Phase:
□ Apply BS EN 1838:2024 illuminance requirements[42]
□ Follow BS 5266-1:2016 design procedures[43]
□ Ensure full-width route illumination compliance[44]
□ Specify points of emphasis lighting (5 lux vertical)[45]
Installation Phase:
□ Use BS 5266-1:2016 installation guidance[46]
□ Implement fire-resistant cabling per requirements[47]
□ Complete commissioning per BS EN 50172:2024[48]
Handover Phase:
□ Verify illuminance levels per BS EN 1838:2024[49]
□ Complete BS 5266-1:2016 documentation requirements[50]
□ Establish testing and maintenance schedules
Two-Hour Fire Protection Requirement
The requirement for two-hour fire protection in emergency lighting and associated circuits is a key safety measure in high-risk environments. This is primarily applied to:
Assembly occupancies (buildings used for gathering people, such as theatres, halls, large restaurants)
Buildings above 23 metres (75 ft) in height (about 7–8 storeys and above)
These settings present unique evacuation challenges due to high occupancy or complex layouts, which can necessitate prolonged evacuation times.
Why Two-Hour Fire Protection?
Purpose: To ensure emergency systems—especially escape lighting, alarms, and evacuation controls—remain operational long enough for safe evacuation, even under severe fire conditions.
Evacuation Complexity: High-rise buildings and assembly spaces may require staged or delayed evacuations, necessitating longer circuit integrity.
Regulatory Basis: This minimum is reflected in British Standards such as BS 5266-1 (emergency lighting) and referenced in wiring regulations and circuit design practice for life safety systems [51] [52] [53].
Where Two-Hour Fire-Rated Circuits Are Required
Emergency lighting circuits in large assembly spaces and buildings over 23 metres
Fire alarm cabling and control circuits for critical fire safety systems
Evacuation lift supplies, smoke control, and firefighting equipment circuits in high-rise or assembly buildings
Fire resistance must be ensured either by:
Cables with at least 120 minutes (PH120) fire resistance (tested typically at 830°C, complying with BS EN 50200/BS8434-2 or BS 8519 for control circuits)
Or installation within a fire-resisting enclosure, fire-protected shaft, or concrete encasement giving minimum two-hour protection [52] [53] [54] [55]
Methods of Achieving Two-Hour Protection
Solution Type | Examples & Notes |
---|---|
Fire-resistant cable | Enhanced fire-resistant cables (PH120) such as those complying with BS 7629-1, BS 8491, or BS 8434-2 |
Mineral-insulated (MI) | MI cables listed as fire-resistive, typically with 2-hour rating |
Protected containment | Installation in fire-protected shafts, ductwork, or concrete encasement with 2-hour fire rating |
Listed assemblies | Specially tested assemblies or trays with documented 2-hour circuit integrity |
Regulatory Guidance
As per BS 5266 and related commentary, the application of two-hour-rated cable or protection is required in:
Assembly occupancies where evacuation is complex, phased, or where large numbers delay escape
High-rise (typically above 23m/75 ft) buildings, to allow for delayed or progressive evacuation
Enhanced fire resistance (two hours) is also recommended where evacuation cannot be immediate or is undertaken in stages [52] [53] [54].
Summary Table: Circuit Fire Protection for Emergency Systems
Installation Scenario | Minimum Circuit Fire Rating |
---|---|
Standard buildings (normal risk) | 1 hour (PH60) inside escape routes |
Assembly occupancy/high-rise (>23m) | 2 hours (PH120) throughout circuit |
Unsprinklered, complex evacuation | 2 hours (PH120), enhanced specification |
Practical Application Examples
Example 1: Office Building Corridor (3m wide)
BS EN 1838:2024: Requires 1 lux across full 2m central band (excluding 0.5m borders)
BS 5266-1:2016: Provides luminaire spacing and mounting guidance for achieving this requirement
Example 2: High-Risk Manufacturing Area
BS EN 1838:2024: Specifies minimum illuminance levels for safe shutdown procedures
BS 5266-1:2016: Details installation methods for harsh industrial environments
Example 3: Large Assembly Hall with AEELS
BS EN 1838:2024: Defines AEELS performance requirements and fallback provisions
BS 5266-1:2016: Provides system design methodology and integration guidance
Summary for UK Designers
Key Takeaways:
Both standards are required for UK compliance – they are complementary, not alternatives
BS EN 1838:2024 defines “what” (performance targets) while BS 5266-1:2016 defines “how” (practical implementation)
Full-width route illumination is now mandatory – update existing design practices
AEELS consideration is required for all new projects
Enhanced documentation requirements under updated testing standards
For Immediate Implementation:
Update design templates to reflect full-width illumination requirements
Include AEELS assessment in project specifications
Ensure measurement verification procedures align with BS EN 1838:2024
Maintain BS 5266-1:2016 design and installation practices
Related Standards:
BS 5266-1:2016: Emergency Lighting Code of Practice
BS EN 1838:2024: Lighting Applications – Emergency Lighting
BS EN 50172:2024: Testing and Maintenance
BS 8519: Fire-resistant Cable Systems
BS EN 50200, BS 8434-2: Fire Testing of Cables
UK Building Regulations, Section B for Fire Safety