The Basics of NFPA 25 Record Keeping
Most fire sprinkler contractors will retain fire sprinkler inspection, testing, and maintenance reports (ITM), but what does NFPA 25, The Standard for Inspection Testing and Maintenance of Water-Based Fire Protection Systems, require?
Tour Section 4.3
Let us take quick tour of Section 4.3 to discover what the standard requires. First, understand that Chapter 4 of the standard is the General Requirements chapter. Many inspectors think that they cannot cite any Section of Chapter 4, but that is not true, only Section 4.1 cannot be cited. Section 4.3 is the records section and states records shall be maintained by the property owner. What records shall be maintained? Records for all inspections, tests, and maintenance of the system and its components shall be maintained. However, that really does not tell us much. For, instance, how long do records have to maintained? That depends on the type of record.
Section 4.3.4 states that as-built, hydraulic calculations and acceptance test records shall be maintained for the life of the system. This also includes manufacturer’s data sheets. Many times, data sheets are in the O&M manuals, but how often can the as-built and acceptance tests be found? Section 13.2.1 also states that all manufacturers’ literature shall be made available for specific instructions for ITM of valves and associated equipment.
This is technically a deficiency within NFPA 25 when this documentation is not available. This information is some of the most important to be retained for several reasons. For this blog, it covers the ITM reasons. NFPA 25 is essentially a comparison document. The intent is to compare how the system performs today as to how it did the day it was installed, such as a 3-year full flow of a dry pipe system. It is impossible to do this without the acceptance test results. There is one other place this information should be found, and that is on the general information sign.
ITM Record Information
What information needs to be on the ITM records? According to NFPA 25 Section 4.3.2 the following is required.
- The procedure performed (e.g., Inspection, test, or maintenance).
- The organization performing the activity.
- The frequency of the activity.
- The results including the date of the activity.
- The name and contact information of the qualified person or owner for the activity completed.
There are no annex comments for this section so as with many NFPA documents, it is open to interpretation. An example could be the results. Does this mean that the inspector must document every device tested or just deficiencies found? Maybe, but it is not clear. These records shall be made available to the authority having jurisdiction (AHJ) upon request. This is not the responsibility of the sprinkler contractor. It is the responsibility of the owner, since the reports are their property.
The records must be retained for one year after the next ITM of that type. If a daily inspection program were started on January 1 of 2019 there would be 365 daily reports for the first year and must be retained for one year after. That means the daily records for 2019 and 2020 would be retained and the record for January 1, 2019 could be discarded on January 1, 2021. This holds true for all frequencies including 3-year and 5-year ITM requirements.