Emergency Lighting Installation Risk Assessment: Working Live, Ceiling Access & Testing Requirements

Table of Contents

• Introduction: The Three Areas Principal Contractors Check First
• Live Working: Documentation and Justification
• Ceiling Void Hazards: Asbestos, Services, and Restricted Access
• BS 5266 Testing and Certification Requirements
• What Your Risk Assessment Must Say
• Frequently Asked Questions

Introduction: The Three Areas Principal Contractors Check First

Emergency lighting RAMS submitted to principal contractors are reviewed against a mental checklist of the hazards most likely to cause serious harm or compliance failure on a commercial project. The three areas that consistently receive the most scrutiny are:

1. How live working is documented and justified under the Electricity at Work Regulations 1989
2. Whether ceiling void access hazards — particularly asbestos — have been properly addressed
3. Whether the testing and commissioning methodology is aligned with BS 5266-1

This guide addresses each area in turn and explains exactly what your emergency lighting RAMS must say to satisfy a competent review.

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

Live Working: Documentation and Justification

The Electricity at Work Regulations 1989 Regulation 14 states that no person shall work on or near a live conductor unless: it is unreasonable for it to be dead, it is reasonable to work live, and suitable precautions are taken to prevent injury. This is a high bar — the default must always be dead working.

Your RAMS must make one of two statements about each phase of the installation:

• "This phase will be carried out dead" — confirm the isolation method, the lock-off/tag-out procedure, and the voltage verification sequence (AVI on known live → test isolated conductors → retest AVI on known live).
• "Live working is required for this phase — justification:" — document specifically why dead working is unreasonable. "The client does not want the power off" is not a justification. Valid justifications include: maintaining life safety systems during installation in an occupied building where a power outage would create its own safety risk; or the technical impossibility of identifying and isolating a specific circuit without de-energising an unacceptably large area of the building.

For emergency lighting specifically, the most common live working scenario is connection into a live distribution board or existing maintained emergency circuit in an occupied building. Your RAMS must describe this precisely and specify the protective equipment (insulated gloves to the appropriate rating, face shield, insulated screwdrivers and pliers, rubber insulating matting) and the stand-by person requirement.

Ceiling Void Hazards: Asbestos, Services, and Restricted Access

Cable routing for emergency lighting systems requires entry into ceiling voids in most commercial projects. Ceiling voids present a distinct set of hazards:

• Asbestos-containing materials (ACMs) — Any building constructed or refurbished before 2000 may contain ACMs in the ceiling void — including pipe lagging, thermal insulation boards, cement panels above suspended ceilings, and sprayed coatings on structural steel. Your RAMS must confirm that:
  • An asbestos management survey or refurbishment survey covering the ceiling void has been obtained
  • The register has been reviewed for the specific areas where cable will be routed
  • If ACMs are present, they have been assessed and either removed, encapsulated, or confirmed as suitable for working adjacent to without disturbance
  • If the ACM status of the ceiling void is unknown, work cannot begin until a survey is completed
• Hidden services — Ceiling voids contain electrical cables, data cables, sprinkler pipework, HVAC ductwork, and gas pipework. Your RAMS must specify how services drawings will be obtained and reviewed before cable routing begins, and how cable routes will be planned to avoid conflict with existing services.
• Restricted working space and postural hazards — Working in a ceiling void with limited headroom creates musculoskeletal hazards from sustained awkward postures. Your RAMS should set a maximum continuous period for ceiling void working and specify the rotation of operatives.
• Falls from access equipment — Entry into ceiling voids typically requires working from a ladder or podium step to reach the access hatch. Your RAMS must apply the work at height hierarchy for this access.

BS 5266 Testing and Certification Requirements

Emergency lighting systems must be tested and commissioned before handover. BS 5266-1 specifies the tests that must be conducted and the records that must be produced. Your RAMS must describe the testing methodology and confirm the record format:

• Functional test — Each luminaire and central battery circuit must be tested to confirm that it illuminates on simulated mains failure. Your method statement must describe how the test will be conducted (typically by interrupting the mains supply to the circuit) and how the result will be recorded.
• Duration test — The full discharge duration test (typically 3 hours for maintained or non-maintained systems) must be conducted after the system has been fully charged. This test must confirm that every luminaire continues to operate for the full specified duration without relamping or battery replacement.
• Emergency exit sign illumination — Where emergency exit signs are part of the installation, their illuminance levels must be verified against BS 5266-1 requirements.
• Completion certificate — A completion certificate signed by a competent person must be provided to the duty holder. Your RAMS should specify the format (BS 5266-1 Annex B provides a model form) and confirm that it will be submitted to the principal contractor as part of project close-out.

For projects on higher-risk buildings under the Building Safety Act 2022, all test records become part of the Golden Thread and must be retained and handed over to the Accountable Person.

What Your Risk Assessment Must Say

• Live working assessment: per-phase statement (dead or live), justification for any live phase, controls for each live phase
• Isolation and lock-off procedure: multi-lock hasp use, AVI verification sequence
• Asbestos: survey obtained, register reviewed, ACM status confirmed for all ceiling void areas
• Services drawings: obtained and reviewed before cable routing begins
• Ceiling void postural controls: maximum continuous periods, operative rotation
• Working at height for ceiling void access: access equipment, PASMA/IPAF requirements
• Testing methodology: functional test, duration test, illuminance check for signs
• Completion certificate: format, signatory, submission process
• Golden Thread requirements for HRB projects

Frequently Asked Questions

What happens if the asbestos survey has not been completed before we need to start cable pulling?

You cannot legally enter ceiling voids in a pre-2000 building without confirming the asbestos status. If the survey has not been completed, raise this immediately with the principal contractor and do not begin ceiling void work. The principal contractor has a duty under the Control of Asbestos Regulations 2012 to ensure that pre-construction information includes information about asbestos. If the survey is missing, this is a failure of the principal contractor's duty — not your problem to solve by proceeding without it.

Can we conduct the 3-hour duration test while other trades are still working on site?

The duration test requires simulated mains failure across the circuits being tested, which will interrupt the mains supply to those circuits (and potentially adjacent circuits). This must be coordinated with the principal contractor and notified to all trades working in the affected areas, who must be prepared to lose power to their tools during the test period. The test should be scheduled during a period when the disruption can be managed — typically at the end of the working day or on a weekend.

Is a separate RAMS needed for emergency lighting in each area of a large building?

Not necessarily — a single RAMS is sufficient if the hazard profile is consistent throughout. However, if some areas present significantly different conditions (for example, a live trading floor where the live working risk is substantially elevated compared to unoccupied floors), include area-specific sections within the single RAMS document rather than producing separate documents for each floor.