Emergency Lighting RAMS: What Electrical Contractors Must Document Under BS 5266

Table of Contents

• Why Emergency Lighting RAMS Matter
• BS 5266 and Your Documentation Obligations
• Key Hazards in Emergency Lighting Installation
• Live Working Controls
• Working at Height for Luminaire Installation
• What Your Emergency Lighting RAMS Must Cover
• Frequently Asked Questions
• Next Steps

Why Emergency Lighting RAMS Matter

Emergency lighting installation sits at the intersection of electrical work and fire safety — making it one of the most scrutinised trades on commercial and multi-occupancy projects. Principal contractors and fire safety engineers look closely at emergency lighting RAMS because failures during installation can compromise life safety systems that must function reliably during an emergency.

Under CDM 2015, electrical contractors installing emergency lighting are duty holders who must produce a project-specific RAMS before work begins. On projects subject to the Building Safety Act 2022 — including residential buildings over 18 metres — emergency lighting records form part of the Golden Thread of safety information that must be maintained for the life of the building.

This guide explains what a compliant emergency lighting RAMS must include, with particular focus on the live working and working at height controls that are most frequently deficient in submitted documents.

Browse all trade RAMS templates on the RAMS AI trade hub — covering 22 specialist construction trades.

BS 5266 and Your Documentation Obligations

BS 5266-1:2016 ("Emergency Lighting — Code of Practice for the Emergency Escape Lighting of Premises") is the primary design and installation standard for emergency lighting in UK non-domestic buildings. Your RAMS should reference this standard and confirm that the installation will comply with its requirements. Key provisions that affect your RAMS include:

• Luminaire classification and siting — Emergency luminaires must be positioned to illuminate escape routes, exit signs, and areas of high risk. Your method statement should confirm that siting has been agreed with the designer or fire safety engineer before installation begins.
• Duration requirement — Most commercial emergency lighting installations must provide a minimum 3-hour duration (or 1 hour for low-risk premises). Your RAMS should confirm the specified duration and the battery specification to be installed.
• Testing and commissioning — BS 5266-1 requires a completion certificate signed by a competent person confirming that the system has been installed, tested, and commissioned in accordance with the standard. Your RAMS should include the testing procedure and confirm the format in which records will be provided to the principal contractor.

In addition to BS 5266, emergency lighting wiring and fixings must comply with BS 7671 (the IET Wiring Regulations). Your RAMS should confirm which edition applies and that the installation design has been prepared by a suitably qualified person.

Key Hazards in Emergency Lighting Installation

Your risk assessment must identify all significant hazards. For emergency lighting installation, these typically include:

• Electrical hazard — live conductors — Working on or adjacent to live electrical circuits is the primary life safety risk in emergency lighting installation. Controls must comply with the Electricity at Work Regulations 1989.
• Working at height — Emergency luminaires are typically installed at ceiling level — above 2.0 m in most commercial buildings. Working at height is therefore present throughout the installation and testing phases.
• Ceiling void access — Cable routing often requires entry into ceiling voids, which may contain asbestos-containing materials (ACMs), hidden services, and restricted working space.
• Drilling and fixing into structural elements — Fixing luminaires and cable containment into concrete soffits or masonry generates silica dust and noise.
• Occupied building working — Emergency lighting installation frequently takes place in occupied commercial buildings, requiring dust and noise management and segregation of the work area from building users.

Live Working Controls

The Electricity at Work Regulations 1989 (EWR) require that live working is avoided except where it is unreasonable to do so. Your RAMS must demonstrate that:

• Dead working is the default — the installation will be carried out with the circuit isolated and proved dead using an approved voltage indicator (AVI) before any live conductors are touched. Lock-off procedures and multi-lock hasps should be used where multiple trades share the same distribution board.
• Live working justification — where live working is unavoidable (for example, when connecting into a live distribution board in an occupied building), your RAMS must provide a specific written justification for why dead working is unreasonable for that task. This justification must be reviewed and countersigned by a senior person in your organisation.
• Live working controls — where live working proceeds, the controls must include: insulated tools, rubber insulating matting, appropriate PPE (insulated gloves rated to the voltage, face shield), a second person present as stand-by, and a clear emergency procedure in the event of contact.
• Isolation verification — the sequence for proving dead must be specified: test the AVI on a known live source, test the isolated conductors, test the AVI on the known live source again. This two-stage check must be documented in your method statement.

Working at Height for Luminaire Installation

All luminaire installation and cable fixings above floor level are subject to the Work at Height Regulations 2005. Your RAMS must apply the hierarchy:

• Collective protection — mobile access towers (PASMA-trained operatives) or scissor lifts (IPAF category 3a) are preferred for sustained ceiling work in open areas. Specify the type to be used for each phase of the installation.
• Ladders and step ladders — only appropriate for brief access tasks where a stable platform is impractical, and only when a three-point contact technique can be maintained and tools can be safely carried. Not appropriate as the primary working platform for luminaire installation over significant areas.
• Floor loading checks — confirm that the structural floor can accept the point load of any MEWP used in the area.

Your RAMS must also address ceiling void access: the hazards of entering false ceiling voids (head injury from structure, restricted space, potential ACM), and the controls including pre-work asbestos checks and appropriate PPE.

What Your Emergency Lighting RAMS Must Cover

• Standard references: BS 5266-1, BS 7671, CDM 2015, EWR 1989
• Live working assessment: default dead working, justification for any live working, isolation verification sequence
• Lock-off and permit procedures for shared distribution boards
• Working at height: access equipment type, PASMA/IPAF requirements, ceiling void access
• Asbestos check: confirmation that an asbestos survey has been obtained for the building before ceiling void work begins
• Silica dust controls for drilling: on-tool extraction or RPE
• Occupied building controls: dust suppression, noise management, work area segregation
• Testing and commissioning procedure: duration test, functional test, record format
• CDM pre-start briefing record
• Emergency procedures and first aid location

Frequently Asked Questions

Does emergency lighting installation always require live working?

No. The majority of emergency lighting installation — cable containment, cable pulling, luminaire fixing, and wiring — can and should be carried out dead. The only phase that typically requires interaction with live conductors is the final connection to the distribution board or existing circuit. Even this can often be scheduled during a planned outage. Your RAMS must demonstrate that dead working has been adopted wherever reasonably practicable before any live working justification is made.

What asbestos checks are needed before entering ceiling voids?

Before entering any ceiling void in a building constructed before 2000, you must confirm that an asbestos management survey (or, where ceiling voids will be disturbed, a refurbishment survey) has been carried out and that the relevant areas are clear of ACMs, or that the ACMs present have been assessed as low-risk and do not require disturbance. This confirmation should come from the building owner or the principal contractor as part of the pre-construction information. Do not enter ceiling voids in pre-2000 buildings without this confirmation.

Who signs off the BS 5266 completion certificate?

The completion certificate under BS 5266-1 must be signed by a competent person responsible for the installation. In practice, this is typically a qualified electrician with specific knowledge of emergency lighting systems — ideally holding a relevant third-party accreditation such as ELECSA or NICEIC. The certificate is handed to the duty holder (building owner or their representative) and retained as part of the building's fire safety records.

Next Steps

Your emergency lighting RAMS should be reviewed for every project to confirm that the specific building's live working conditions, access equipment requirements, and testing protocols are documented. RAMS AI generates comprehensive emergency lighting risk assessments pre-populated with the hazards and controls in this guide.