Lighting systems are essential to the safety, energy efficiency and functionality of any building. Replacing luminaires in an existing structure may seem straightforward, but it requires adherence to a range of electrical and building codes to ensure safety, compliance and long-term performance. The following case study highlights a luminaire replacement project where important code requirements were initially overlooked, leading to unexpected challenges.

Background

The project involved replacing outdated fluorescent luminaires with modern LED fixtures in a midsized commercial office building constructed in the 1980s. The building’s lighting system had become inefficient, contributing to high energy bills and poor illumination quality. The owner aimed to upgrade the lighting system to improve energy efficiency, enhance lighting quality and reduce maintenance costs.

The scope of work included replacing all luminaires in the office building and its associated warehouse. The existing branch circuits were deemed sufficient for the energy-­efficient LED luminaires being installed. Given this, the electrical contractor bid the project as a simple design-build contract, involving a one-for-one replacement with minimal rework of the existing electrical system.

Code compliance issues

During the project’s initial phase, the contractor scheduled an inspection for the new luminaires. The inspector, who also served as the building inspector for the jurisdiction, identified several overlooked compliance issues.

The jurisdiction adopted the 2023 edition of the National Electrical Code and the 2021 editions of the ICC I-Codes, including the International Existing Building Code (IEBC) and the International Energy Conservation Code (IECC). While the inspector found the wiring compliant with the NEC, additional requirements from the IEBC and IECC triggered significant concerns.

Alteration classification

The IBC defines an “alteration” as “any construction, retrofit or renovation to an existing structure other than repair or addition. Also, a change in a building, electrical, gas, mechanical or plumbing system that involves an extension, addition or change to the arrangement, type or purpose of the original installation.” 

The inspector emphasized that replacing all luminaires in the building met the criteria specified in Chapter 6 of the IEBC for a Level 1 alteration:

• It includes the removal and replacement of the covering of existing materials, elements, equipment or fixtures using new materials, elements or fixtures that serve the same purpose.

Chapter 7 of the IEBC covers Level 1 alteration requirements.

Emergency lighting plan: 

• Section 704.1 of the IEBC requires that Level 1 alterations maintain the existing level of safety for means of egress.
• The inspector requested an emergency lighting plan to confirm that the new luminaires provided adequate illumination levels for emergency egress, as outlined in Chapter 7 of the IEBC.

Energy conservation requirements: 

• Section 708 of the IEBC required compliance with the IECC for this project.
• According to Section 503.5 of the IECC, new lighting systems must conform to sections 405 and 408, which mandate:
  • Lighting controls: Automated controls to achieve energy conservation
  • Functional testing: Documented testing of lighting controls to ensure proper operation
  • The exception to Section 503.5, which applies if less than 10% of luminaires are replaced, did not apply to this project due to its scale.
    

Effect of noncompliance

The inspector’s findings significantly affected the project, as the contractor was required to provide the following for compliance.

• Emergency lighting: Fortunately, the building’s emergency lighting was powered by an existing generator and dedicated circuits, maintaining the required level of safety for egress lighting. Minimal adjustments were necessary to address this issue.
• Energy conservation compliance: Updating lighting controls to meet modern energy conservation requirements posed a greater challenge. The project scope had not accounted for the labor and materials needed to install automated controls and perform functional testing, leading to substantial cost increases. These additional expenses strained the relationship between the building owner and the contractor. The owner questioned the contractor’s expertise and contested the additional costs, as the initial bid and contract had guaranteed a code-compliant installation.

Conclusion

Replacing luminaires in an existing building requires more than simply swapping out fixtures. It involves careful planning, adherence to multiple codes and consideration of safety and energy efficiency requirements. This project highlights how overlooking building codes can lead to unexpected costs and a strained relationship with clients. 

Owl.Studio. / stock.adobe.com