COVID-19, Construction Practices, and Inspection, Testing, and Maintenance
NFSA has reached out to our members and compiled the summary below of current practices being implemented in response to the COVID-19 pandemic. As with most national emergencies, we are seeing various actions and reactions across the country. We have areas of the country with offices and construction sites that remain open with additional precautions. At the same time, we have areas that have shut down offices, construction sites, and manufacturing facilities. All these different situations are impacting our industry, and we are observing that measures taken in one area are likely to be taken in another, primarily fueled by government action.
The NFSA mission to protect lives and property from fire remains a priority even in the face of the current COVID-19 pandemic. Building, fire and life safety codes allow tradeoffs for some fire protection measures, such as fire-rated walls, door closers, and smoke dampers in buildings having automatic fire sprinkler systems installed throughout. Buildings having complete sprinkler protection are permitted to have increased height and area versus comparable non-sprinklered buildings. The occupants in some buildings (residential, institutional, healthcare, etc.) with fire sprinkler systems are dependent upon functioning and operating systems as part of egress or defend in place life safety objectives. The same building, fire and life safety codes that the installation of fire sprinkler systems in structures require the same systems to be inspected, tested, and maintained (ITM) per NFPA 25, the Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems.
Model building, fire and life safety codes are adopted by federal, state, and local jurisdictions. The requirement for ITM for all buildings with sprinkler systems through NFPA 25 are found in the following building, fire and life safety code sections:
- International Building Code (IBC): 903.5
- International Fire Code (IFC): 903.5
- International Property Maintenance Code (IPMC): 704.1.3
- NFPA 1, Fire Code: 22.214.171.124
- NFPA 101, Life Safety Code: 9.11.1
In order to ensure the NFSA mission of gaining widespread acceptance of the sprinkler concept, we support continued inspection, testing, and maintenance of fire protection systems. NFSA’s position is that fire protection systems must remain in working order to protect lives and property as part of a comprehensive community risk reduction program which requires ITM activities to continue. NFSA believes ITM work can be accomplished during the COVID-19 pandemic with proper scheduling, planning, and precautions.
Scheduling. The minimum required frequency scheduling of ITM should not be compromised. For example, NFPA 25, sets the minimum frequency schedule for fire sprinkler systems. NFSA’s position is the minimum code required scheduling of ITM shall remain in effect. Owners should work with members to ensure the minimum code required schedules are maintained. Impairments must be addressed immediately as outlined in the Impairments Chapter 15 of NFPA 25.
Planning. NFSA recommends owners and members work collaboratively to prioritize and plan ITM activities with other building operations including the challenges associated with the COVID-19 pandemic. ITM for some occupancies, including hospitals, is heightened as changes are made to facilitate increased usage or infection control practices. Some health system surge capacity plans may seek to convert existing occupancies into temporary critical care facilities. Occupancies currently with reduced activities including schools, dormitories, and offices present opportunities to accelerate ITM activities. With some coordination, ITM inspections may be accomplished shortly after a facility has been cleaned and prior to it being reoccupied.
Precautions. Members should work with owners to identify potential infectious disease risks on each site during ITM activities and develop a safety plan for their employees. Implementing imposed social distancing requirements as well as washing hands and following other COVID-19 recommendations and directives is essential to ensure success. Members should also review and enhance their infection control plans including awareness, training, and use of personal protective equipment in addition to the standard personal protection equipment (PPE).
Below are some of the practices and precautions being used and implemented across jobsites throughout the U.S. While most of these practices are not directly related to ITM they impact NFSA members:
- Review and adjust project schedules to allow for social distancing, including staggered work scheduling and extra shifts to physically separate employees working on site.
- Develop a written virus response policy with provisions to inform employees and for enforcement.
- Require anyone entering a work site to complete a health survey prior to entry.
- Conduct job site safety briefings remotely, and do not report to construction trailers.
- Provide facilities and procedures for proper disposal and removal of used cleaning supplies and personal protective equipment.
- Eliminate the use of coffee trucks, lunch trucks, and centralized gathering or eating areas.
- Advise employees to bring their own food, drink, and utensils.
- Encourage employees to change and wash clothing when they get home or to use on site facilities, if available.
- Prepare additional contingency plans for potential reduction in work force, limited materials/supplies, or the need to suspend a job site for cleaning.
- Develop a plan for maintaining job sites safely and security during any shut down periods. Such plans include fire safety and exposure safeguarding elements.
- Work with owners and facility managers to ensure essential ITM work is continued, systems remain in service, and impairments continue to be addressed immediately.
- Work with building and fire officials to schedule plan reviews, permitting, and field inspections.
- Review and comply with OSHA requirements for employers to prevent employee exposure to the virus including PPE standards requiring gloves, goggles or safety glasses, face protection, and respiratory protection.
The CDC has not made specific recommendations for the construction industry regarding COVID exposures. However, the published best practices include:
- Monitor and follow WHO/CDC/OSHA recommendations.
- Monitor federal, state, and local government recommendations.
- Practice social distancing as recommended by the CDC by maintaining a six-foot distance, not shaking hands, restricting gatherings to ten people or less, covering mouth and nose when sneezing or coughing, and avoiding touching your face.
- Stay home if you are sick.
- Provide a process to recognize and remove sick employees.
- Provide facilities for and encourage frequent hand washing and sanitizing.
- Encourage employees to work from home where possible.
- Provide additional resources and technology to assist remote employees.
- Cancel in person meetings, and shift meetings to online.
- Only allow essential employees in the office and on job sites.
- Eliminate visitors.
- Eliminate unnecessary travel.
- Make provisions for additional cleaning including restrooms, equipment, tools, and commonly touched areas.
NFSA believes that proper scheduling, planning, and precautions can ensure ITM and fire protection installation activities to continue as required by code to ensure fire protection systems save lives and property during the COVID-19 pandemic as they have for the past century.