RP-46: Unveiling the IES Turbulent Journey of Circadian Entrainment

Screen Shot of RP 46

While RP-46, Supporting the Physiological and Behavioral Effects of Lighting in Interior Daytime Environments, could have been the most important RP written in the past few decades, bad management, secrecy, turf fights, and politics have turned the RP into a convoluted mess, likely only meaningful to the consultants who will earn tens of thousands interpreting its intent.

This article, conceived after consulting members of the IES Light and Human Health committee, IES staff,  those who provided feedback during the peer review process, and the ANSI public comment process, reveals significant and alarming issues. While there are many concerns, perhaps the most important is the fact that there are three different metrics for circadian entrainment, but the Light and Human Health Committee painstakingly advocated for only one.

The Key Players

  • George C. Brainard, Ph.D.: Chair, IES Light & Health Committee; Director, Thomas Jefferson’s Light Research Center; Consultant; Expert Witness
  • Steven Lockley, Ph.D.: Vice-Chair, IES Light & Health Committee; Associate Professor of Medicine, part-time, Harvard Medical Center; Advisor, Midwest Lighting Institute; Consultant; Expert Witness.
  • Brian Liebel: Former IES Standards Chair; Advisor, Midwest Lighting Institute; Consultant
  • Mariana Figueiro, Ph.D: Former member IES Light & Health Committee; Founder of Mt. Sinai’s Light & Health Research Center

The dispute, wrongly, centers on metrics for quantifying light. The complexities and detailed calculations of the Melanopic EDI (MEDI) and Circadian Stimulus (CS) metrics can be found in the December 2022 issue of designing lighting (dl) magazine. To put things in simple laymen terms, the authors of both metrics agree on the importance of delivering light to the eye to provide brighter days and darker nights. And both metrics show relatively greater efficacy for white-light spectra dominated by short-wavelengths, which some call “blue enriched.” But this is a marketing term with no accepted definition other than, perhaps, its association with 6500 K. The authors of the MEDI metric posit that by receiving “blue enriched lumens” in the morning, users can attain the same alertness level and potential health benefit as from the CS model but with slightly different watts, depending upon the spectrum.  But the amount of light used to deliver circadian-effective light is only part of the energy story. Energy is the product of watts and the duration of operation (and only the CS metric addresses both).

Fundamentally, however, there is little point arguing about metrics. Ultimately, it’s the application that matters. For example, the researchers and authors of the CS metric argue that moving the source closer to the user can dramatically reduce energy use while still providing circadian-effective light. This is what matters in the built environment.  In fact, the slight benefit of 6500 K “blue enriched lumens” over a “warm” 3500 K lumens is completely negated by simply moving the source 30% closer to the user. This perspective is important if, in a home application, one would rather eat breakfast under a warm source than under a “blue lumen” source.

I have read RP46, and it stands as the most peculiar RP I have ever encountered. A review of the 50-page document reveals confusing language and an apparent rush to publish, despite 8 years of work committee effort.

The document is a tangled confusion, with the committee’s decision to exclusively endorse MEDI and disregard CS entirely. Perhaps in a slight gesture towards fairness, the RP does outline some of MEDI’s research drawbacks, though this only adds to the confusion as the document appears to be at odds with itself. It would have been more prudent to detail all three metrics in both technical and layman’s terms, since all three can produce the desired result.

The Committee

The problem with this RP begins with the Light & Human Health committee itself and the problems continue throughout the process, including the so-called ANSI public review. 

Former chair of the committee, Mariana Figueiro, of the Light & Health Research Center at Mount Sinai, is one of the researchers who developed the CS metric.  She has shown, and continues to show, through her peer reviewed publications, the utility and performance of the CS metric in the field. In 2008, after leading the publication of IES TM 18-8, she turned the chair of the committee over to George C. Brainard. It seems that Dr. Brainard, Dr. Steven Lockley, the Vice-Chair, and the former IES Director of Standards and Research, Brian Liebel, favor the Melanopic EDI (MEDI) method. I believe that the trio of leaders align themselves with the MEDI camp, and are anti-CS.  This configuration has, from the outset, introduced an inherent conflict.  My view is that Dr. Figueiro and other experts simply wanted the committee to have an objective discussion of metrics, but the committee leadership did not accept Dr. Figueiro’s offer to write a more balanced section of the RP. She was assigned by the Chair to work on the references, which is really a clerical task, and not one of respect for a global expert on this subject, as exemplified by her numerous R01 grants from NIH and her longstanding commitment to the IES as a committee member. 

We spoke to IES staff a few times about balance on the committee and were told that it does meet the ANSI definition, although we did not see a producer (manufacturer) represented.

According to the guidelines set out in the IES Technical Committee manual, a chair’s appointment usually continues upon the conclusion of a one-year term. The SC will contemplate extending this for an additional year, but only if the chair has not already served more than three such terms. When making this decision, the SC should take into account documented proof of the chair’s leadership abilities, punctuality in reporting, and adherence to meeting deadlines for the responsibilities associated with the TC chair’s duties. If a chair has already fulfilled three one-year terms, the SC might still consider an additional partial term if the purpose is to facilitate the selection of a new chair. It’s noteworthy that the present Chair and Vice Chair have maintained these roles for an astounding 14 years!

At the public portion of the Board Meeting of the 2023 IES Annual Conference, Brienne Musselman, the Director of Education and Standards stated that it was difficult working with some of the chairs who had been in their position for a long time and that it was difficult to get them to always follow the correct process. She did not refer to any specific committee in her comments.

Writing of the Document

As best as we can determine, it took eight years for the committee to write the RP, with many months—and perhaps years—with no formal full meetings at all.

The former Director of Standards and Research for IES, advocated that the committee should ballot the document before discussion ensued. In short, when the subcommittee that wrote the draft RP finally presented the document to the entire committee, the committee was not given the opportunity to discuss it before a formal committee ballot.  As a result, members voted for the document with the expectation that a discussion would take place and when it came time to discuss the details, an odd thing occurred.  The Chair told the group that discussion would be limited to specific comments, not the draft as a whole. More interestingly, only the nay votes were to be discussed by the entire committee. Discussion for comments that received a yay vote were not allowed.  This is one of several bizarre questionable practices that went into the writing of the document. IES may explain this away as standard procedure, but I believe a full committee should have the opportunity to discuss the full document.  Again, the committee spent 8 years, but towards the end, the process was drastically hurried, leaving some committee members frustrated with the process and the final outcome.

Conflicts of Interest

Before and during the process of writing the document, the Chair and Vice Chair have served as expert witnesses in legal cases.  One person on the committee and the former Director of Standards and Research at the IES are associated with an entity that promotes the “blue-enriched” lumen. Some on the committee believed some members could benefit financially if the RP promoted the “blue-enriched” lumen. 

At the 2022 IES Annual Conference, I asked Chairman Brainard if he had any conflicts of interest and he explained that he could not discuss anything about the committee as he was bound by an NDA.  I reminded him that I had seen a non-committee document where he listed conflicts of interest and he responded, “You, Randy, as Past President, of all people should know that I am bound by confidentiality and cannot discuss anything from the committee.” 

Conflicts of interest are not inherently negative, but their acknowledgment is essential. It is unclear whether the committee chair and members are obligated to disclose conflicts of interest, as we could not determine if this is a requirement under IES or ANSI rules.  Such disclosure is commonly viewed as a sensible obligation, regardless of formal regulations.

While I do not know whether any committee members stand to benefit financially by promoting one metric over another, this issue should have been addressed and discussed. To our knowledge, the potential conflicts of interest were not a topic of conversation prior to any balloting of the Recommended Practice (RP), and this omission raises questions about the transparency and integrity of the process.

What do the I and R in DEIR stand for?

While the Illuminating Engineering Society (IES) is widely recognized for its commitment to Diversity, Equity, Inclusion, and Respect (DEIR), recent events within the Light & Human Health (L&HH) committee have cast doubt on the sincerity of these principles, specifically regarding the “I” for Inclusion and the “R” for Respect. 

Dr. Mariana Figueiro’s exclusion from contributing to significant work within the committee highlights a shortfall in the true commitment to inclusiveness. Furthermore, incidents where Dr. Figueiro was ignored, ridiculed, and disrespectfully referred to as “Hail Mariana” by the leadership demonstrate a blatant failure in treating her with the respect she has earned and deserved, leading to her eventual resignation from the committee.  No one should, in this day and age, be treated that way.

These events are particularly concerning as they present a stark contradiction to the public position of DEIR by the IES. It calls into question the consistency and integrity of the Society’s entire approach to these principles. The situation underscores a broader issue within IES’s leadership in the areas of Diversity, Equity, Inclusion, and Respect. It brings to the areas where the Society must improve, particularly in fostering a genuine sense of inclusiveness and nurturing respect within its committees. 

Public Review

Regarding the ANSI public review process, the committee seems to have simply gone through the motions. Of the 138 comments that we reviewed from different people, four were accepted by the committee and one of those was to correct a typo.

One potential commenter explained they were told by IES Staff that there was no vote for ANSI Public Review; comments were received and collated and sent to the respective committee who reviews the comments and provides responses. There is no burden to accept any comments from Public Review; the only requirement is to provide responses.  After much back and forth over having to pay $25 to offer feedback, the reviewer paid the money and explained to me, “The whole process made me think that my feedback was not really looked after nor actually wanted.” 

A few commenters were told that their comments would be resolved in the Annex, and they were assured that the Annex would address CS. The problem is that no one, outside of the committee, has seen the Annex and it is not publicly reviewed. 

Another commenter explained, ”I did not accept their explanations nor their simplistic treatment of my substantive comments…they continued to assert that I had simply ‘misunderstood’.”

While I don’t dispute that IES followed the exact letter of the ANSI law, it appears they did not follow the spirit of the ANSI process.  

The UL Approach

IES Position Paper on UL

In 2019, Underwriters Laboratories (UL) released a draft version of UL DG 24480,  “Recommended Practice and Design Guideline for Promoting Circadian Entrainment with Light for Day-Active People.” At that time, the IES took the uncommon step of issuing a Position Paper, warning the industry about UL 24480. Specifically, IES stated, “It is important to note that UL Design Guideline 24480 is not a consensus (ANSI) document.” 

In marked contrast to the IES process, the UL Design Guideline listed all three metrics without favoring one over the other. Conversations with Mark Rea and a representative of UL, clarified that the process followed the ANSI Essential Requirements, including adherence to principles of due process, openness, lack of dominance, balance, public comment, and consensus vote. Moreover, the UL committee responded to each comment they received in their two (not just one) public review opportunities, accepting many and providing in-depth reasons, technically and scientific sound reasons for dismissing others. Although IES asserts that their document technically adhered to the ANSI standard procedure, it seems that the UL document may have undergone a more rigorous, comprehensive and open peer review process than IES RP. 

The approach taken by UL reflects a detailed examination and careful consideration of various perspectives, showcasing an apparent commitment to inclusivity and integrity in the development of the Design Guideline. Based on my interviews thus far, the same cannot be said for the Light and Human Health Committee.

Confidentiality Concerns 

A veil of secrecy appears to surround the process behind the RP-46 document, with some committee members unwilling to speak openly about their involvement citing a non-disclosure agreement. Concerns about the handling of confidential information and potential biases within the committee have come to light. We are told that NDA’s are standard IES practice for committees.  While that may be true, this committee would have been better served by being less secretive.

Front Cover of RP 46 that says not for publication

Some committee members have shown hesitancy in discussing the document with me, others have either provided only partial insights or declined to comment entirely.  When I purchased the document from IES, which was an extremely complex process, I was told by IES Staff that I could not share any specific details of the document. This report could have been more complete, if I could have cited specific lines of gobbledygook in the RP. 

I approached Chairman Brainard at the 2022 IES Annual Conference, Vice chair Lockley through email, and former IES Standards Chair Brian Liebel at a IES event in Orlando.  All three refused to comment.  

One source told me that someone from the Midwest Lighting Institute, publicly stated that Figueiro was delaying the document’s publication due to 40 objections. It is interesting to note that this person is not a member of the LHH committee. According to the Midwest Lighting Institute’s website, both Dr.  Lockley and Liebel are on the advisory council of the Midwest Lighting Institute.

The Big Picture

The issues related to RP-46’s confidentiality may signal deeper structural problems within the Society.  I would think members of the committee would welcome informal conversations throughout the process.  This, combined with the document’s controversial content, could have lasting effects on its acceptance and implementation within the industry.

Continued scrutiny of the relationships between committee members and outside entities should lead to calls for greater transparency and accountability within the process.

What’s Next?

We are told that at least one member of the IES Board of Directors recommended the RP be downgraded as an LP (Lighting Practice), to our knowledge that suggestion has been rejected.

One reviewer suggested having a 12th-grade English teacher grade the document for clarity. Another reviewer remarked that it seemed like a collection of random text. A third reviewer said all 50 pages could be summed up in one paragraph, “Daylighting is good and use it as much as you can. If you can’t use daylighting use blue-enriched light in the morning, but not in the afternoon and by the way, don’t use CS as your metric.”

Another reviewer stated, “IES is more interested in circling the wagons than taking points on board and being introspective about where they can and should improve, especially when presented with flaws.”

We have also been informed that the committee intends to conduct a new internal ballot for RP-46. My aspiration is that it faces rejection. Should the RP reach the IES Board of Directors, I hope the Board will reject it as well. The IES should take steps to restructure the committee, ensuring that a comprehensive range of perspectives is heard and considered. And the RP SHOULD BE RE-WRITTEN in LAYMEN’s terms so it can be implemented. Recently, the emphasis has been on timeliness. There may be some sort of looming deadline that I am not aware of, perhaps from ANSI. Regardless, the primary focus now should shift towards the quality of the undertaking rather than hastening its completion.

A well-written, objective RP for Circadian entrainment can be a boon for our industry creating demand for luminaire manufacturers control manufacturers, lighting designers, and installers.  All trades would gain.  As it stands now, the people who will benefit the most may be consultants paid to explain it to the industry. 

Developing….

Editor’s Note:  The LHRC writes a column six times per year for designing lighting (dl) magazine, which is owned by the EdisonReport. In addition, the NLB and the Light & Health Research Center co-produce a quarterly series, “Let’s Talk about Light & Health.” Randy Reid is the moderator of that discussion.