NFPA 25 Revisited
My September 2013 column reported the changes in the 2014 edition of NFPA 25. I also discussed an issue that did not have a big impact in terms of changes to the standard but generated a lot of discussion: The scope of NFPA 25. Specifically, I discussed to what extent fire protection system inspectors are capable of identifying system deficiencies that go beyond the expectations of NFPA 25.
These are system deficiencies related to changes in occupancy or hazard that would require a design evaluation. Water-based system inspection companies, in general, do not use engineers or sprinkler designers to conduct inspections of fire sprinkler systems. As such, the technician performing the work may not understand detailed requirements of NFPA 13 (or 14, 20, etc.), and may not be able to evaluate whether or not the original system design intent is still being achieved.
Traditionally, NFPA 25 has tried to avoid giving the inspector these types of responsibilities, and placed the burden for identifying and correcting these items with the owner (see paragraphs 4.1.6 and 4.1.7 of NFPA 25). The problem is the owner is also not capable of making these evaluations and, more importantly, is not able to identify whether or not a problem exists. The classic example is in storage occupancies where the hazard has changed because the storage arrangement, height, or commodity class has changed. Furthermore, many system owners have an expectation that compliance with NFPA 25 means the system is OK, and will put the fire out.
I would hazard to guess that many Authorities Having Jurisdiction (AHJ) also have this same expectation from NFPA 25 compliance and the “qualified” fire protection contractors documenting the compliance. Both owners and AHJs may be unaware that the system may have deficiencies not intended to be identified by a NFPA 25 inspection.
To deal with this issue, the NFPA Fire Protection Research Foundation sponsored a workshop in Chicago in December 2013 called “Addressing the Performance of Sprinkler Systems: NFPA 25 and Other Strategies.” The full report can be found at www.nfpa.org/research. The workshop brought a number of industry experts together to brainstorm the issue. A total of 55 persons attended, 15 of which were NFPA 25 Committee personnel. The report described the key issue in the following excerpt on page 10 :
“It is explicitly stated in Chapter 4 of the standard (NFPA 25) that the property owner is responsible to obtain an evaluation of the fire protection systems before any changes are made related to occupancy, use, process, or materials and that this evaluation is not considered part of the normal ITM required by the standard. However, this approach has been questioned due to the belief of many experts that it is not uncommon for obvious design deficiencies, such as unsprinklered areas or obvious spray pattern obstructions, to go unreported to owners despite the presence of a life safety professional conducting an inspection. This is not to say that the inspector must be the individual to call out these design deficiencies, but rather, it highlights a gap in the standard where post-occupancy design evaluations may be needed. Many owners and Authorities Having Jurisdiction (AHJ) assume that the ITM service provider is providing a full design evaluation while the service provider is delivering only wear and tear inspection.”
Much of the reason for the gap stems from misunderstanding surrounding the scope of NFPA 25 which in paragraph 1.1 states:
“This document establishes the minimum requirements for the periodic inspection, testing and maintenance of water-based fire protection systems and the actions to undertake when changes in occupancy, use, process, materials, hazard, or water supply that potentially impact the performance of the water-based system are planned or identified.”
NFPA 25 does a fine job with the first 20 words of that sentence, but gives the remainder of that sentence limited attention.
One major conclusion of the report was that, “Overall there was general consensus that NFPA 25 should remain a wear and tear document and that it is for the most part OK in its current state.”
Now in my view, if AHJ’s are mandating compliance with NFPA 25 and owners are required to fork out good money to a qualified fire protection contractor to gain proof of this compliance then that qualified fire protection contractor should be able to identify some basic deficiencies beyond a “wear and tear” evaluation. A trained monkey can identify a closed valve, perform a two-inch drain test, and flow the inspector’s test and, quite possibly, do it at a lower cost. At a minimum, the contractor should be able to identify basic conditions, not related to wear and tear, where sprinkler peformance may be compromised —nonsprinklered areas, obstructions to sprinkler discharge and pattern development, and major changes in hazard.
Another view, which surfaced during the workshop, is that perhaps NFPA 25 should go in the other direction, towards greater simplification. This view appears to be borne out by Marty Ahrens, NFPA Fire Analysis and Research Division, in his workshop presentation on sprinkler system performance. His presentation was based on the Dr. John R. Hall’s June 2013 report “Sprinkler Performance in US Fire.” Ahrens indicated that sprinklers operated effectively 87 percent of the time. Of the remaining 13 percent, sprinklers failed to operate 9 percent of the time and sprinklers operated ineffectively in 4 percent of the incidents. Of the 9 percent where sprinklers failed to operate, system-shut off (e.g. closed valve) was responsible for 64 percent of the incidents. Of the 4 percent where sprinklers operated ineffectively, 44 percent involved cases where water did not reach the fire (e.g. nonsprinklered areas and obstructions).
It seems there is much to be gained, in terms of sprinkler system performance, by focusing inspections on identifying and correcting these deficiencies. In many jurisdictions, the personnel performing inspections are qualified by nature of being employed by a licensed fire protection contractor. It seems to me that if the standard moves in the direction of simplification, then AHJs should consider providing the means for the owner or their designated representative to easily become qualified, so they may self-inspect their systems. NFPA 25 appears to permit that.
I certainly do not have all the answers to address this gap in coverage in the area of design evaluation. But, I believe the solution should be provided in NFPA 25, or at least start with NFPA 25. As suggested in the workshop, NFPA 25 could contain provisions that assist the inspector with identifying conditions requiring a design evaluation. One idea from the workshop, that I liked, was to provide standard checklist items or interview questions in NFPA 25, which could help bring conditions warranting a design evaluation to the attention of the inspector and owner.
This discussion and the workshop tended to focus on sprinkler systems. Other water-based systems covered by NFPA 25 may need a different treatment particularly the more complicated systems.
Certainly, it is the owner’s responsibility to make sure their water-based fire protection system is modified, as needed, to address changes in the hazard. The fire protection industry and its regulators need to help the owner determine when a design evaluation is needed. One thing that should not be incorporated into any standard is a requirement to perform a design evaluation of a water-based fire protection system on a routine frequency, regardless of whether or not a need for the evaluation is determined.
Hey, I could make a few bucks on that, so on second thought … Solutions involved with heaping more responsibility (and cost) on system owners and maintaining low expectations of inspectors are not needed.
Samuel S. Dannaway, PE, is a registered fire protection engineer and mechanical engineer with bachelor’s and master’s degrees from the University of Maryland Department of Fire Protection Engineering. He is past president and a Fellow of the Society of Fire Protection Engineers. He is president of S. S. Dannaway Associates Inc., a 15-person fire protection engineering firm with offices in Honolulu and Guam. He can be reached via email at SDannaway@ssdafire.com.