Q. Why is there now a document chapter in the 2013 edition of NFPA 72? Wasn’t there enough paperwork already? Maybe NFPA hasn’t heard of the Small Business Paperwork Relief Act (SBPRA).
A. We are in “the service industry” — that is, we provide a service for our commercial customers that they either cannot or do not want to perform themselves. Building owners are the ones who must comply; and they must have the paperwork indicating they are in compliance with building as well as the fire code.
In the past, the codes required that only some of the many rules had to be verified; today the code is saying “show me everything has been done” — with the proper paperwork. Rules prohibiting the removal and tampering with code-mandated equipment was always part of the code. What was slower to follow were the rules that required ongoing services to be documented.
When a building is first opened, it gets a lot of attention from the city/state and everyone agrees to meet to verify compliance at an Acceptance Test. The performance of the ongoing tests and inspections is more difficult to verify. By putting the responsibility back on the building owner, the proof of compliance is now required to be produced whether the fire inspector asks for it or not.
Let’s hope that by having the owner submit an affidavit to the fire department stating that the fire alarm system is being tested and maintained in compliance will help the local inspectors to keep on top of enforcing existing rules requiring fire alarm testing and supervising station monitoring. This code-required written affidavit that commercial fire alarm customers must annually provide to their fire code official identifies the party responsible for the inspection/testing. This affidavit must list the responsibilities and qualifications of the parties doing the work and be signed by a representative of the service provider. Alarm companies can help their customers keep in compliance with this requirement, NEW to the 2010 edition of the code, by providing signed letters for them to submit. NFPA 72 states in the Annex “The building owner or his designated representative, if qualified, may perform this work.” But this declaration, signed by the building owner, is still required.
Since multiple service providers are allowed, there is still room for employees to perform some of the simpler and more frequent visual inspections, but have the alarm company perform all the functional tests. While the affidavit requires a list of qualifications for those doing the work, the code also provides that you may one day have to prove you are qualified when asked to do so: “10.5.3.5, Evidence of qualifications shall be provided to the authority having jurisdiction upon request.”
There is also a new rule for those programming fire and emergency warning systems. 10.5.3.4 Programming states: “Personnel programming a system shall be certified by the system manufacturer.” This clearly indicates that a certification, issued by each control panel manufacturer, is now required for those who perform software changes to fire systems. Also note that being “licensed by the state of local authority” does not exempt those performing the programming from this additional certification.
When you stop and think of all the different panel manufacturers (and all the different models) of power boosters, voice evacuation, cellular communicators, network communicators etc. you install and test, the vast list of programming certificates you must now maintain may surprise you. You probably still have time until your state adopts the 2013 edition to collect your certificates, but that unknown amount of time is running out, so be smart and don’t procrastinate. Your ability to produce the required documentation along with a proposal for a customer’s on-going T&I work, may make your bid that much more professional and attractive to a prospective client.
Greg Kessinger is SD&I's resident fire alarm and codes expert and a regular contributor. Reach him at [email protected].
