Don’t Call it A Deficiency; It’s Been Here For Years

Understanding NFPA 25 Sprinkler Deficiencies 

By Vincent Powers
ITM Specialist, National Fire Sprinkler Association

 NFPA 25 Deficiencies: What Contractors Should (and Shouldn’t) Report

Contractors performing inspections, testing, and maintenance (ITM) on water-based fire protection systems have a huge responsibility: ensuring systems are ready to protect lives and property. But there’s a persistent gray area in our field that causes a lot of confusion—and it’s not about what’s in the system, but how we document what we find.

How often have you seen a building cited for being “out of compliance” just because a required test wasn’t completed, like a 5-year internal pipe inspection or a 3-year full-flow test? While those tests are required, how we report them matters.

Let’s clear the air. In this blog post, we’ll break down:

• What qualifies as a deficiency under NFPA 25
• What contractors should report
• What they shouldn’t report as deficiencies
• And how to stay professional, accurate, and compliant

So, What are NFPA 25 Sprinkler Deficiencies?

The term “deficiency” was officially introduced in the 2008 edition of NFPA 25. But it’s changed a few times since then to make it better.

Here’s how it evolved:

• 2008: A component isn’t within its design limits
• 2011: A system or part is damaged or inoperable but not totally shut down
• 2014 to now: A condition that could negatively affect system performance—but still not an impairment

Why does this matter? Before “deficiency” was defined, every problem got lumped in as an impairment—which often meant AHJs treated everything like a full system shutdown. That’s overkill, and it created a lot of friction. The updated terminology helps everyone understand the difference between something that needs attention and something that’s seriously compromised.

Let’s Talk About the Table: Table A.3.3.8

If you’re a field technician or contractor, chances are you’ve heard of Table A.3.3.8. You’ll find it in Annex A of NFPA 25. It’s not enforceable—but it’s an incredibly useful guide.

It was first introduced in 2011 to help contractors and AHJs classify issues into three categories:

• Non-Critical Deficiency
• Critical Deficiency
• Impairment

And here’s the key: a single issue can fall into different categories based on occupancy or risk.

Example:

• A painted sprinkler in a data center (high hazard)? Could be an impairment.
• That same painted sprinkler in a metal shop? Maybe just a critical deficiency.

The 2023 edition of NFPA 25 even shows multiple classifications for a single condition—like deterioration of a water supply—depending on the situation. That’s where experience and training come into play.

But remember: Annex A is explanatory or additional information. Unless your state or local code formally adopts it, it’s a guide—not a rulebook.

Table A.3.3.8, NFPA 25, 2023 edition

Note there is nothing regarding recalled sprinklers in the table

What Should Contractors Report?

Here’s where things often go sideways.

Say a building didn’t get its 5-year internal pipe inspection. Should you cite that as a deficiency?

No. That’s not a deficiency—it’s a code compliance issue. Only the Authority Having Jurisdiction (AHJ) can enforce that.

Here’s what you can and should report as deficiencies:

✅ Corroded valves
✅ Missing escutcheons
✅ Non-functional flow switches
✅ Damaged or painted sprinklers

These are all physical conditions that directly affect system performance. That’s squarely in the contractor’s lane.

What You Shouldn’t Report as Deficiencies

Some of the most common missteps happen when contractors overstep their role.

Here are things that should not be listed as deficiencies:

🚫 Missed 5-year or 3-year tests
🚫 Recalled sprinklers not yet replaced
🚫 Lack of completing ITM within NFPA 25

These aren’t system conditions—they’re owner responsibilities. According to NFPA 25 Section 4.1.1, the building owner (or owner’s representative) is responsible for ensuring all required testing is completed—not the contractor.

Contractors are informers, not enforcers.

You’re there to report what’s wrong, not enforce compliance.

The Right Way to Document NFPA 25 Sprinkler Deficiencies

Here’s a new slogan I am pushing:

“If it’s not in the table, you’re not able.”

That means if an issue isn’t covered in the deficiency tables (like Table A.3.3.8), and it doesn’t fit the standard’s definition of a deficiency, don’t call it one. Report it as an observation instead.

This keeps your report accurate, defensible, and professional—and it keeps you out of hot water with the AHJ, building owners, and potential legal disputes.

This mindset protects you, supports the building owner, and keeps everyone aligned with the intent of NFPA 25. Misclassifying an issue as a deficiency when it’s not can lead to unnecessary conflict—or worse, a law suit.

Instead, make clear observations. Keep your reports clean. And focus on facts, not assumptions.

Final Thoughts on NFPA 25 Sprinkler Deficiencies

NFPA 25 is a powerful tool. But like any tool, it only works if it’s used properly.

✔ Know what counts as a deficiency
✔ Use the table as a guide—not gospel
✔ Report conditions, not compliance gaps
✔ Let the AHJ do the enforcing
✔ And always, document with clarity and care

By staying in your lane and focusing on the actual condition of the system, you’ll not only do your job right—you’ll also help build a more credible, consistent, and trusted fire protection industry.

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