COVID-19: ITM on Essential Buildings
It would be remiss of us to not address some of the issues that we have before us today. Our nation and world are in a crisis. The COVID-19 virus has halted our world as we know it. Only the “essential services” are allowed to open and running in many states around the country. An important question to answer, for our industry, during this time, is what happens to all the ITM responsibilities and what are the requirements for ITM for “essential services” during this time?
A term that we have heard frequently over the last several weeks is, “essential services.” What does that mean? It’s a great question. The IBC provides some insight into this topic. Chapter 16 of the 2018 IBC focuses on structural design. While that isn’t completely pertinent to our discussion, it does provide an idea of what essential services are from a code perspective. Section 1604.5 requires that all structures be assigned a risk category. The risk category drives the structural requirements, such as seismic, throughout the rest of the chapter. The use of the building determines the risk category. Table 1604.5 assigns the risk category per the use of the building. As the building use is more “essential,” the higher the risk category. The higher the risk category, the more structural considerations. Risk category IV is the highest and, in that category, we find a list of “essential structures.” Those structures are as follows: Emergency Surgery Centers (I-2 Condition 2), Emergency Treatment Facilities (I-2 Condition 2), Police stations and garages (B, F-1), Fire stations and garages (B, F-1), designated emergency shelters (varies), emergency management centers (B), Public water storage facilities (U), Public water pumping facilities for fire suppression (U), Power generating stations for category IV uses (U), Aviation control towers (B), Hangars (S-1), National defense facilities (varies), facilities containing highly toxic materials that exceed the quantities in T307.1(2) of the IFC or materials that pose a threat if released (H).
So, who’s responsibility it is to maintain the sprinkler systems and other life protection systems in a “essential services” building, both active and passive? While the codes and standards don’t speak directly to this type of situation, however, they do provide some guidance. The 2018 IFC states in Section 701.6, that the owner is responsible for maintaining an inventory of all required fire-resistant rated construction. It also states that it is the owner’s responsibility to visually inspect and properly repair, restore, or replace any damaged, altered, breached, or penetrated systems. We are talking about fire wall, fire barriers, penetrations, joint systems, doors and windows. All the passive systems one would normally see in a structure. What about the active systems? Section 901.6 of the 2018 IFC states that active systems (fire detection, alarm systems, water-based fire protection systems, etc.) shall always be maintained in an operative condition. It also says non-required systems shall be inspected, tested and maintained in the same manner or they should be removed. Furthermore, Section 901.6.1 states, that fire protection systems should be inspected, tested and maintained per their appropriate standard, which can be found on T901.6.1. The systems that are relevant to our industry would be mostly governed by NFPA 25. The 2020 NFPA 25 states in Section 4.1.1, the owner is responsible for properly maintaining a water-based fire protection system as well as maintain records in Section 126.96.36.199.
Now that we have the responsibility portion nailed down, let us talk briefly about the ITM requirements. While there are many requirements that govern such systems, we will take broad look at the requirements for such buildings. Most passive systems (fire walls, fire barriers, fire blocking, smoke barriers, smoke partitions, etc.) are required to be inspected and tested annually per Chapter 7 of the 2018 IFC as well as NFPA 1 and NFPA 5000. When considering fire dampers, those requirements are found in NFPA 80 and are required to inspected and testing every 4 years (6 years for hospitals). Smoke damper requirements are found in NFPA 105 and are same as fire dampers. Fire doors and windows are governed by NFPA 80 and are required to be inspected and tested annually.
Alarm systems and fire detection systems and similar systems are all governed by NFPA 72. These requirements are broken down often by component and component type. Reference 2019 NFPA 72 T14.3.1, T188.8.131.52 for more detailed. Most of these components are usually required to be inspected and tested on a semi-annually and annually basis. Smoke detectors are required to inspected and tested annually. Carbon Monoxide detects are governed by NFPA 720 and required to be inspected and tested annually as well.
As well all know, NFPA 25 governs the ITM requirements for water-based fire protection systems. Like NFPA 72 the requirements are broken down by component and component types. Sprinkler system component inspection and testing can range from weekly to quarterly to monthly to yearly. Chapter 5 of NFPA 25 will help sort all these components. Fire pump components are usually required to be inspected and tested annually, however, there are some that are required to be inspected weekly and some monthly. Chapter 8 provides the ITM requirements for fire pumps. Standpipe and hose system is another common system we find in these “essential buildings.” Those system components are most often required to be inspected and tested annually. Keep in mind many other standpipe and hose systems components are required to be inspected and tested more frequently. Check out chapter 6 of NFPA 25 for more information. There are many other water-based fire protection systems out there. All those ITM requirements would be found in NFPA 25 as well.
During this time of uncertainty and concern, it is important to remember that it is very important that we protect those who are on front lines, that are protecting us. We wish all of those suffering a speedy recovery.