The Journey to Compliance
How does a fire inspector navigate the journey through NFPA 1 Fire Code in order to have inspection, testing and maintenance (ITM) compliance of fire sprinklers and standpipe systems? It is often misunderstood which document we enforce and how to get to those requirements for fire protection systems. In states using NFPA 1 Fire Code and NFPA 101 Life Safety Code, such as Maryland, these codes become the governing documents for address fire protection systems in existing buildings.
The journey begins in NFPA 1, Chapter 13, Fire Protection Systems. The very first Section, 13.1 General, gives the authority having jurisdiction (AHJ) the ability to require construction documents for review, approval and permit prior to the installation, rehabilitation or modification. This is a simple section allowing the AHJ to verify new work being done but doesn’t necessarily address the ITM component we seek.
13.1.1 The AHJ shall have the authority to require that construction documents for all fire protection systems be submitted for review and approval and a permit be issued prior to the installation, rehabilitation or modification. Further, the AHJ shall have the authority to require that full acceptance tests of the systems be performed in the AHJ’s presence prior to final system certification.
While the specifics for the ITM requirements are in Chapter 13, they are found individually under the ITM requirements for each type of system.
Standpipes are in Section 13.2 Standpipe Systems and specific ITM requirements can be found in Section 13.2.3 Inspection, Testing and Maintenance. This section contains three simple requirements.
- Section 126.96.36.199 requires the standpipe system to be maintained to provide at least the same level of performance and protection as it was designed.
- Section 188.8.131.52 Requires the owner of the system to be responsible for maintaining the system in good working order.
- Section 184.108.40.206 states that the system shall be inspected, tested and maintained in accordance to NFPA 25 Standard for the Inspection, Testing and Maintenance of Water-Based Fire Protection Systems.
Fire sprinklers, on the other hand, are found later in the chapter under Section 13.3.3. It only has two requirements spelling out the same three basic requirements we found for standpipe systems.
- Section 220.127.116.11 requires the fire sprinkler system to be maintained to provide at least the same level of performance and protection as it was designed, but also adds in the requirement for the owner to maintain it in good working order.
- Section 18.104.22.168 states that the system shall be inspected, tested and maintained in accordance to NFPA 25 Standard for the Inspection, Testing and Maintenance of Water-Based Fire Protection Systems.
NFPA 101 in turn becomes our source for occupant specific requirements and provides us similar clarification on where to find guidance on specific ITM requirements. This is found in Chapter 9 Building Service and Fire Protection Equipment.
9.11.1 Maintenance and Testing. All automatic sprinklers and standpipe systems required by this code shall be inspected, tested, and maintained in accordance with NFPA 25.
So, where does that leave fire inspectors? It specifically reiterates that the system ITM is the clear responsibility of the system owner and that the systems must be in working order. While NFPA 25 gives us the specific ITM guidance, our authority comes clearly from NFPA 1 and NFPA 101. In turn enforcement must be cited from those documents and any action taken, must be issued directly to the owner.
NFPA 25 Standard for the Inspection, Testing and Maintenance of Water-Based Fire Protection Systems, is also very clear on the ownership of the systems and who the responsible party is for ITM. This can be found in Chapter 4, General Requirements. It clearly places all responsibility on the system owner and adds the term designated representative. NFPA 25 also adds responsibility for the correction of any impairments.
Section 4.1.1 Responsibility for Inspection, Testing, Maintenance and Impairments. The property owner or designated representative shall be responsible for properly maintaining a water-based fire protection system.
NFPA 25 therefore becomes the owners document for ITM, spelling out what they need to do and when they need to do it. It also spells out the scope of the document very clearly in the beginning of the document.
Section 1.1 Scope. This document establishes the minimum requirements for the testing, inspection, and maintenance of water-based fire protection system and the actions to undertake when changes in occupancy, use process, materials, hazard, or water supply that potentially impacts the performance of the water-based system are planned or identified.
It also clearly states the purpose of the document which is critical for the owners understanding. This section simply requires minimal inspections intended to provide a reasonable degree of life safety.
Section 1.2.1 The purpose of this document is to provide requirements that ensure a reasonable degree of protection for life and property from fire though minimum inspections, testing and maintenance methods for water-based protection systems.
The most misunderstood use of NFPA 25 is the application of items not included within the standard. NFPA 25 inspections can only include that which is contained within the standard and is not the document used in this case for enforcement. It is simply the owners guide to ITM, spelling out what they need to do and the reference document for fire inspectors to understand what the owners should be completing to be NFPA 25 compliant.
Section 22.214.171.124 Where a designated representative has received the authority for inspecting, testing, maintenance, and the management of impairments, the designated representative shall comply with the requirements identified for the property owner or designated representative throughout this standard.
NFPA 25 does not allow the NFPA 25 inspection to address or verify the design of systems. It is merely meant to assure us that we have a basic degree of safety.
Section 126.96.36.199 This standard does not require the inspector to verify the adequacy of the design of the system.
The journey of enforcement begins and ends in NFPA 1 and NFPA 101 with any action coming from these documents. While NFPA 25 and other documents referenced by our adopted codes and standards are used on this journey as reference documents, any actions must come from our governing codes and standards.