Throwing light on OSHA’s illumination requirements

The OSHA General Industry standards don’t specify minimum light levels for most work areas. However, OSHA can issue citations if inadequate lighting puts employees at risk.

In 2016, OSHA cited an employer for exposing employees to hazards in areas without adequate lighting. Specifically, OSHA claimed that employees worked around and between moving equipment and trucks with insufficient light, and in some cases no light. OSHA cited the General Duty Clause and referenced ANSI/IESNA RP-7-01, Recommended Practice for Lighting Industrial Facilities.

A handful of General Industry regulations mention lighting, but they don’t always provide a specific level of illumination. For example, 1910.37 requires that exit routes be “adequately lighted so that an employee with normal vision can see along the exit route.”

Similarly, the forklift standard at 1910.178 says that if general lighting is less than 2 lumens per square foot, then forklifts must have directional lights.

Construction standard guidance

OSHA does list minimum lighting levels in the Construction standard at 1926.56. Although it does not apply in General Industry, it does offer good guidelines. That standard requires at least five foot-candles for indoor areas such as warehouses, hallways, and exit routes.

More light is needed in shop areas, workrooms, and indoor toilets, where the standard requires at least 10 foot-candles. And for offices or first-aid stations, the Construction standard requires at least 30 foot-candles.

Illuminating perspective

To put things in perspective, small night lights for residential use provide 15 to 20 lumens. The forklift standard mentions 2 lumens, which is only a fraction of the light from a night light. In other words, its pretty dark.

A foot-candle is equal to 10.76 lumens. Therefore, five foot-candles would be about 54 lumens, which is more than most night lights, but well under the 450 lumens produced by a 40-watt incandescent bulb.

Although employers could obtain meters to measure light levels, if you can see normally, you probably have enough light. And if the light level is questionable, you probably need more light, even if a meter showed levels above the recommended minimum.

Lighting problems

Insufficient light can increase the risk of injury because employees are unable to clearly see hazards. In work areas, dim light can cause eye strain or even headaches. But too much light can also cause problems like glare from reflective surfaces.

Employers should also consider the distribution of light and the relative illumination levels. For example, a work area should be brighter than the surrounding area; otherwise, the work area seems dim by comparison. Using task lighting can help with this.

Directional lights can throw illumination a good distance, and can be useful outdoors, but they can also create dark zones outside the illuminated area. This can cause safety issues because workers in the dark zone might not be visible to others. It can also cause security issues, since criminals could hide or lurk in the shadows.

Lighting should be sufficient to see normally, but not so bright that it causes glare or squinting. Since the eyes need time to adjust between higher and lower light levels, illumination should be properly distributed and consistent, without excessively bright or dark zones. Good lighting is essential for safety, security, and for avoiding OSHA citations.

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