Fire & Life Safety--Testing our Limitations
Upon close inspection, there seems to be a philosophical change occurring in the latest 2013 edition of the National Fire Alarm and Signaling Code especially regarding system testing responsibilities. It appears an obvious effort has been made to limit our responsibility to only the equipment we install—specifically, the equipment we have installed under the fire safety control function rules of NFPA 72. The other codes have their dividing lines as well. The Building Code covers the minimum level of protection for the construction of certain commercial buildings based on what that building will be used for and by how many people. The Building Code also references NFPA 72 for the proper location, installation and function of the equipment required. The Fire Code regulates the on-going system maintenance by requiring compliance with NFPA 72’s testing and inspection chapter after the building is completed. A new defining line in NFPA 72 indicates that we must state more exactly, and in writing, what services we are providing the building owner while performing our regular fire alarm tests and inspections.
Q. Has the documentation requirements changed to follow this new concept?
A. Yes. A new rule in section 14.2.10 now requires a “Test Plan.” This documentation will be created for each fire alarm system to “clearly establish the scope of the testing for the fire alarm or signaling system” and requires that this Test Plan be kept with the regular test and inspection records for that system. Another notable change has been introduced that will limit our testing responsibilities. For example, if your system ties in smoke dampers, you will not be testing the operation of the smoke dampers, but will verify the proper signal (usually a relay contact closure) is caused by the fire alarm system that is intended to activate the damper-closing mechanism. Equipment connected to our fire alarm system relays is not within the scope of our responsibility. The same can be said for elevator recall operation. Our responsibility is to provide three (or more) relay contacts are labeled with the physical location of the detectors that are associated with each relay. We will no longer test the recall function of elevator cars. Instead, we will simply verify that our relays are operating when told to do so by the appropriate automatic detectors.
Q. Have the methods used to test these devices changed?
A. No, but the circumstances under which fire alarm devices should be tested has been made clearer. Usually, the best way to determine if an interfaced operation/function has occurred is to watch it take place. Sometimes, there is more to the operation of an emergency safety function—a lot more. If you see a relay change state using a VOM, the fan (for example) in the stairway should start. Maybe you even heard the fan start, but didn’t realize the venting damper didn’t open all the way on the second floor; and after a time, the air pressure built up in the stairwell beyond the limits that allow the exit doors to be easily opened. If we were following rules prior to this 2013 edition, our test report may have indicated that the stairwell pressurization fan functioned properly, but in reality, the safety function did not perform as intended. Another example could be that of magnetic holders installed on hallway doors that are programmed to release the fire doors in the event of a fire alarm. What if we didn’t know that these doors must close and latch? NFPA 80 requires that people testing these doors know their business: “Functional testing of fire door and window assemblies shall be performed by individuals with knowledge and understanding of the operating components of the type of door being subject to testing.” Unless you specifically include in writing, in your “Test Plan” plan, the performance of connected safety systems will not be part of your fire alarm inspection services.
Using the 2013 edition of NFPA 72, the owner must be told, in writing, what equipment and functions are being tested and what are not. Armed with this knowledge, the owner may then hire qualified persons to maintain the other building systems, according to the published standards for each system. Our technicians will no longer give the impression that we have verified that the operation of other safety systems performed properly. Our business is fire and emergency alarm systems. Not locks. Not doors. Not elevators. Not smoke control equipment.
NFPA 72 states that we will provide “testing of the fire alarm or signaling system up to the end point connection to the interfaced system or emergency control function.” After that, NFPA has published other standards that cover their care and feeding. We cannot continue to give the impression that we have tested the performance of other systems when in fact; we have only verified we gave it the proper signal. (See graphic.)
Going one step further
Starting with the 2013 edition, there seems to be another dividing line between persons designing the fire alarm system and those periodically testing it. For example, it is no longer the responsibility of the test and inspection technician to continue to use a decibel meter to measure audibility after the initial acceptance test. The 2013 edition has us only verifying notification appliances as being functional (flashing/sounding, or not). NFPA 72 states that it is no longer the intention of the yearly inspections to verify the suitability of the original design. If the building’s ambient noise has increased by construction or use, then it is the owner’s sole responsibility to determine any side effects on their building’s other safety systems. This is not to say a technician can’t suggest to the owner that additional equipment should be considered for an area housing their new metal stamping operation. They should, but the technician will no longer be responsible for maintaining the performance concept of the original design.
Q. Could these changes be a prelude to NFPA pushing for the adoption of their new commissioning standard?
A. It could be. Although NFPA 3 isn’t a “standard” just yet, this could easily change someday. The way to create a market for their new guide is for NFPA to better separate the testing of fire safety control functions and reference NFPA 3 for any integrated testing rules. For those of you that haven’t heard yet, NFPA 3 is the new “Recommended Practice for Commissioning and Integrated Testing of Fire Protection and Life Safety Systems” and is intended to provide owners of large buildings with end-to-end guidance for testing more involved, combination, life-safety systems and it provides “guidance on documenting and handling of faults, failures, and corrective action for integrated testing.”
Only time will tell if these new provisions were necessary. And as always, until your state updates their Building Code to include the adoption of the 2013 edition of NFPA 72, these changes will not affect your work. But until then, it is wise to stay ahead of the curve when it comes to changes in standards that may directly impact your company’s operations. New T&I contracts, anyone?
