Building and fire codes require fire protection systems as part of the overall package of fire protection measures intended to provide a reasonable level of safety in building. In some cases, the codes may permit reductions in other requirements based upon the presence of one or more fire protection systems. For example, US codes typically allow decreased fire resistance ratings, increased travel distances, and the use of different interior finish materials when the building is protected with an automatic sprinkler system.
Fire protection systems are also provided as a means of meeting other fire safety goals established by the owner such as: property protection, continuity of operations, and preservation of cultural resources. Fire protection systems may also be provided or the type of system is chosen to protect the environment. Insurance carriers may also require fire protection systems to reduce their risk
of loss should an unwanted fire occur.
Therefore, it is critical that such systems be properly designed, installed, and maintained. Codes and standards require that owners properly inspect, test, and maintain any fire protection system. Standards, such as NFPA 25 and NFPA 72, have been developed to identify the activities and frequencies that such activities are to be performed. Building owners and contractors typically use these standards as the basis of their preventive maintenance programs. The purpose of this article is to focus on current issues associated with the preventive maintenance, commonly referred to as inspection, testing, and maintenance (ITM), of fire protection systems.
The primary intent of proper documentation of one’s ITM program is to provide a means by which a regulator can verify that the systems are being maintained as required by codes and standards. However, it should also be recognized that the documentation is one of the first things that an investigator will request after an incident. Documentation will typically help one side of any litigation that might occur after the incident. Here are some examples:
- A contractor failed to document that a hydrostatic test was performed on an automatic sprinkler system which leaked and resulted in a substantial loss of property in a hospital. Any argument that the system was properly installed was weakened by the lack of proper documentation.
- A contractor did not document the specific activities performed while testing a fire alarm system. Later that same day a fire occurred and plaintiffs alleged that the detection system failed to properly detect the fire. The plaintiff further alleged that problems with the detection system should have been identified earlier in the day by the contractor, a claim that was difficult to refute without proper documentation.
There are many instances in which the contractor providing the ITM service properly documents the activities performed and the owner fails to fulfill their responsibilities. Too often the documentation identifies problems that need to be addressed but the owner fails to follow-through to correct the deficiencies. A concern expressed by several ITM contractors who serve on the NFPA Technical Committee responsible for NFPA 25 is the frequency in which the same deficiency is repeatedly found and documented. A procedure should be in place by which the owner properly notes the deficiencies found and implements the appropriate remediation actions.
One way to facilitate this is to customize the ITM documents for a particular facility. Recognizing the benefit of this practice, recently we have had several clients request that we develop customized forms for their use. For example, even the simple task of periodically recording system pressures can be enhanced when the form used includes a range of pressures that one might expect to find. When a pressure is observed outside the “normal range”, it becomes very apparent that some action is required to at least investigate the situation.
Codes and standards that regulate ITM allow the owner to delegate the performance of the activities to a contractor. The contract between the owner and the contractor are critical in making sure that all appropriate activities are being performed and ultimately may determine fault or responsibility if an activity is not performed properly. Without such documentation, certain critical activities may not be performed. Some examples of problems are:
- The adequacy of the system is not evaluated. For example, a contract may require that an annual flow test of a fire pump be performed. The contractor performs the test and provides the owner with the data collected. In this scenario, who is responsible to compare the data to previous test data and to the water supply to ensure that the fire pump performance is adequate? Remembering that the codes and standards assign the ultimate responsibility to the owner, failure to properly document the responsibility results in the owner being responsible.
- A building management company prepared a contract that specifically identified the party responsible to perform specific tasks required by NFPA 25. Unfortunately, the building management company retained the responsibility to perform periodic inspections and tests of the system control valves, including a specific reference to the underground gate valve. When a water leak occurred in the supply pipe to the system riser, the underground gate valve was found to be defective and unable to be closed. The delay in shutting off the water supply to the system resulted in additional water damage. Even though that valve is typically outside the scope of NFPA 25, the building management company was held partially responsible for the additional water damage based upon the contract language.
Evaluating the test data may not be a simple task and should be performed by qualified individuals. An example of where this was not done properly involved a fire in a retail store that was protected with an automatic sprinkler system. Due to an underground gate valve being essentially closed, the sprinkler system failed to control the fire. During the investigation it was determined that the installing contractor misrepresented the data points for the main drain test that was allegedly performed during the acceptance testing of the system. A third party engineering firm certified that the test results and that the test was performed as required by NFPA 13. However, the pressures recorded on the form were essentially impossible to obtain at that particular site. A proper main drain test, with correct pressures recorded, would have identified that the underground gate valve was essentially closed. Unfortunately this mistake was compounded by several contractors subsequently failing to perform a main drain test on a periodic basis.
Are Existing Standards Minimum Requirements?
One of the concerns expressed with the existing standards is that the activities to be performed have expanded to a point where they exceed what some consider to be a minimum standard. This may be compounded by the fact that most standards apply to all installations of such systems, regardless of the hazard of the occupancy. As the use of fire protection systems have expanded beyond high risk occupancies, should there be different levels of ITM requirements based upon the level of risk being protected?
One way in which some standards currently address these differences are by allowing a performance based option to determine the activities and frequencies at which such activities should be performed. Unfortunately, the lack of adequate data restricts the use of an ITM program based upon a risk analysis. In some cases the data may exist but it is not collected in a manner in which it can be used by those wishing to perform a risk analysis. Performance based options also require approval by the regulatory authorities which can provide an additional barrier to using the option, especially with insufficient data. For many building owners, it becomes easier to simply accept the prescriptive solution.
In the past, insurance carriers would typically perform detailed audits of the protected properties. Fire officials had adequate resources to evaluate whether the fire protection systems in a building have been properly maintained. However, many insurance carriers and fire officials are reporting reduced resources and therefore the inability to provide the oversight that has been provided in the past. Without such oversight, it becomes more critical that owners make the effort to ensure that their systems are being properly maintained. It should also be noted that despite the reduced oversight provided by insurance carriers, some insurance policies contain a clause that reduces or eliminates their financial responsibility if the systems are not properly maintained.
In order for fire protection systems to be reliable, it is critical that owners assume the responsibility for proper inspection, testing, and maintenance of their fire protection systems. Where the responsibility is shared or delegated, it is important that the division of responsibilities be properly defined. Those that are performing ITM services, whether a contractor in in-house personnel, need to make sure that the activities are properly performed and documented. When deficiencies are identified, the responsible party needs to make sure that they are corrected in a timely manner. Lastly, all of us involved should strive to provide the data necessary so that our standards can be technically based and that alternative programs can be implemented, where appropriate.
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