I can't see the lack of test switches or competent staff as being a legally acceptable reason for not complying with recommendations!
You already have a test switch Wiz. It is the circuit breaker at the mains consumer unit. Not the mains switch but each lighting circuit breaker switch or switches.
You have to have a competant person. If you don't have competant staff then you should source a competant person from outside the company.
I think that there are companies around whose sole purpose is to do the user checks on systems.
nearlythere, your'e definitely not quite there with this one!
You missed the point of my post.
Of course, there are ways of testing any emergency lighting system even without a 'test' switch being provided and it doesn't matter if you consider your staff as 'incompetent' to do a test.
However neither of these 'excuses' make it permissable, from a legal sense, to ignore the recommendations. The original post asked if these 'excuses' made it 'permissable' to ignore the current recommendations.
I thought it was pretty obvious, maybe only because I did it for 20 years, that there were third parties, who were competent to do this sort of testing. I didn't think the question was asking if these services were available - however I get your point if you are trying to advise Redone, instead of me!