INITIAL STATEMENT OF REASONS

CALIFORNIA CODE OF REGULATIONS
TITLE 8: Chapter 4, Subchapter 7, Article 7,
Section 3317(a) of the General Industry Safety Orders; and
TITLE 24: Part 2, Section 512, Table 5-C of the California Building Code
Illumination


PROBLEM ADDRESSED BY PROPOSED ACTION

Section 3317, Illumination, of the General Industry Safety Orders (GISO) references 1973 ANSI standards for office and industrial illumination levels. The 1973 ANSI standards are no longer in print and have been revised in later publications. The proposal will reference current editions of ANSI standards for office and industrial lighting and make similar revisions to the equivalent section in the California Building Code, Title 24.

SPECIFIC PURPOSE AND FACTUAL BASIS OF PROPOSED ACTION

Section 3317. Illumination.
Subsection (a)

Existing subsection (a) provides the requirements for minimum levels of illumination for safety in various working areas shown in Table IL-1. Note 2 of this subsection references ANSI A11.1-1973, Practice for Industrial Lighting and ANSI A132.1-1973, Practice for Office Lighting. These two national consensus standards provide recommended illumination levels for office and industrial lighting. A proposed revision in Note 2 will replace references to the 1973 ANSI standards with references to ANSI/IES RP-7-1991, Practice for Industrial Lighting, and ANSI/IES RP-1-1993, Practice for Office Lighting. Additionally, a minor editorial revision will correct the Title 24, Part 2 reference for Section 3317(a).

The 1973 ANSI standards are no longer published and are difficult to obtain. The proposed revisions are necessary to ensure that current editions of these national consensus standards are readily available and consulted for industrial and/or office recommended illumination levels.

Title 24, Part 2, Section 512, Table 5-C
Note 2 of Table 5-C references 1973 ANSI standards for office and industrial illumination levels. A proposed amendment in Note 2 will replace references to 1973 ANSI standards with references to current editions of the ANSI standards for industrial and office lighting, ANSI/IES RP-7-1991 and ANSI/IES RP-1-1993 respectively. An editorial revision is also proposed to Note 1. The proposed amendments are necessary for the reasons stated above for GISO Section 3317 and for consistency with Section 3317.

DOCUMENTS RELIED UPON

  1. American National Standard Practice for Industrial Lighting, ANSI A11.1-1973.
  2. American National Standard Practice for Industrial Lighting, ANSI/IES RP-7-1991.
  3. American National Standard Practice for Office Lighting, ANSI 132.1 1973.
  4. American National Standard Practice for Office Lighting, ANSI/IES RP-1-1993.

IDENTIFIED ALTERNATIVES THAT WOULD LESSEN ADVERSE ECONOMIC IMPACT ON SMALL BUSINESSES

No adverse impact on small businesses is anticipated from the implementation of the proposed amendments. Therefore, no alternatives which would lessen the impact on small businesses have been identified.

SPECIFIC TECHNOLOGY OR EQUIPMENTM

This proposal will not mandate the use of specific technologies or equipment.

COST ESTIMATES OF PROPOSED ACTION

Costs or Savings to State Agencies
No costs or savings to state agencies will result as a consequence of the proposed modifications.

Impact on Housing Costs
The proposal will not affect housing costs.

Impact on Businesses
The proposal will not result in a significant adverse economic impact on businesses, including the ability of California businesses to compete with businesses in other states. The proposal merely references current editions of the ANSI standards for office and industrial recommended illumination levels.

Cost Impact on Private Persons or Entities
The proposal will not require private persons or entities to incur additional costs in complying with the proposal.

Costs or Savings in Federal Funding to the State
The proposal will not result in costs or savings in federal funding to the state.

Costs or Savings to Local Agencies or School Districts Required to be Reimbursed
No costs to local agencies or school districts are required to be reimbursed. See explanation under "Determination or Mandate."

Other Nondiscretionary Costs or Savings Imposed on Local Agencies
This proposal does not impose nondiscretionary costs or savings on local agencies or school districts.

DETERMINATION OF MANDATE

The Occupational Safety and Health Standards Board has determined that the proposed regulation does not impose a mandate requiring reimbursement by the state pursuant to Part 7 (commencing with Section 17500) of Division 4 of the Government Code because the proposed amendment will not require local agencies or school districts to incur additional costs in complying with the proposal. Furthermore, this regulation does not constitute a "new program or higher level of service of an existing program with the meaning of Section 6 of Article XIII B of the California Constitution."

The California Supreme Court has established that a "program" within the meaning of Section 6 of Article XIII B of the California Constitution is one which carries out the governmental function of providing services to the public, or which, to implement a state policy, imposes unique requirements on local governments and does not apply generally to all residents and entities in the state. (County of Los Angeles v. State of California (1987) 43 Cal.3d 46.)

The proposed regulation does not require local agencies to carry out the governmental function of providing services to the public. Rather, the regulation requires local agencies to take certain steps to ensure the safety and health of their own employees only. Moreover, the proposed regulation does not in any way require local agencies to administer the California Occupational Safety and Health program. (See City of Anaheim v. State of California (1987) 189 Cal.App.3d 1478.)

The proposed regulation does not impose unique requirements on local governments. All employers - state, local and private - will be required to comply with the prescribed standards.

PLAIN ENGLISH STATEMENT

It has been determined that the proposal may affect small business. The express terms of the proposal written in plain English have been prepared by the Board pursuant to Government Code Sections 11342(e) and 11346.2(a)(1) and the informative digest for this proposal constitutes a plain English overview.

ASSESSMENT

The adoption of the proposed amendments to this regulation will neither create nor eliminate jobs in the State of California nor result in the elimination of existing businesses or create or expand businesses in the State of California.

ALTERNATIVES THAT WOULD AFFECT PRIVATE PERSONS

No alternatives considered by the Board would be more effective in carrying out the purpose for which the regulation is proposed or would be as effective and less burdensome to affect private persons than the proposed action.