Protecting Fire Protection
Who is responsible for the inspection, testing and maintenance of fire protection systems?
It is time to reevaluate the relevance and effectiveness of the National Fire Protection Association’s (NFPA) Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, NFPA 25. This standard implies that it is the basis for maintaining automatic fire sprinkler systems, a basic and essential fire and life safety system that is required in most buildings by the adopted fire code.
My experiences have taught me that the standard could be effective — if it was enforced and used in its entirety. I use the word “could” because one of the significant fallacies of NFPA 25 is its premise: that all sprinkler systems are designed, installed, tested and inspected correctly when they are installed or remodeled. But they are not!
The images shown in Figure 1 display an example found during a risk management observation. Here the sprinklers and piping were more than 10 feet below the roof where they belong, and supported from the floor. This building had an annual inspection, testing, and maintenance program with a sprinkler contractor who, according to NFPA 25, is not required to look for this type of problem.
There are four options to improve the relevance and effectiveness of this standard:
Change the title to the Standard for Functionality of Water-Based Fire Protection Systems.
Break NFPA 25 into two standards: one for the functionality and limited work performed by fire sprinkler contractors, and the other for inspection, testing and maintenance required to be performed by the owner beyond what contractors provide.
Have sprinkler contractors thoroughly perform inspection, testing and maintenance of these systems without the assumption that they were designed and installed properly.
Improve the communication between the contractor and occupants and owners so that the occupants and owners realize the scope of work the contractor performs and the long list of remaining inspection, testing and maintenance items that are left to the occupants and owners.
The images in Figure 2 show an example of sprinklers that would not operate as intended in a fire condition. The sprinkler on the left is corroded and almost all of the liquid has drained from the glass bulb. The escutcheon for the sprinkler in the center has foam insulation sprayed around it from above (the top of a freezer) which will impact the operation. The sprinkler on the right has the protective strap on and has been painted. This sprinkler had been in service for several years when it was observed.
Again, a sprinkler contractor performing a typical NFPA 25 annual inspection would not be looking for this problem. Their proposal and contract could include an inspection of all of the sprinklers, but typically does not, and isn’t offered as an option. Obviously some sprinklers will be easier to look at than others with sprinklers below 8- or 10-foot ceilings much easier to observe than those in attics or at the roof in a 20-foot tall building. Looking for sprinklers like these is the owner’s, not the contractor’s responsibility. The contractors will not look for this in an annual inspection.
The reality is that this standard barely ensures functionality of the sprinkler system, let alone assuring anyone that the system will perform as required or expected. I realize how broad and brazen that statement is. I also realize that sprinkler systems perform exceptionally well when they are designed, installed, tested, inspected and maintained properly. Even the sprinkler systems that have deficiencies can control fires. However, my experience is that when more than one deficiency is present, the chances of success decrease.
Figure 3 is another example that I frequently see: sprinklers that some contractor (probably the painter) has ‘taped’ to prevent paint from spraying onto the sprinkler. There are at least two potential problems here. One is that the tape can delay the operation of the sprinkler; and two, the taping process can damage the sprinkler operating mechanism (e.g., crack the glass bulb).
The NFPA can provide detailed information on the excellent performance of sprinkler systems; it also provides information on many of the failures, or at least the statistics on the failures. When systems don’t operate as intended (such as in a freeze failure with water damage) or fail in a fire condition, the impact can be large, not just in monetary terms, but also in the disruption to the lives of the owners and occupants. Not to mention the rare, but occasional injury or death (to firefighters or building occupants) that might have been avoided.
Without doubt, this is a complex issue. A recent court case in New Jersey in essence ruled that if a sprinkler system isn’t designed and installed properly, those issues would not be identified or fixed by contractors that are hired to inspect, test and maintain the system in accordance with NFPA 25:
“The trial court granted defendants’ [private fire sprinkler inspection companies] motions for summary judgment, finding that defendants’ inspectors had possessed no duty to report any sprinkler system design flaws to the hotel owner because applicable state regulations did not necessitate any such report.”
An appellate court overturned the summary judgment, but the Supreme Court of New Jersey reversed the appellate court and upheld the trial court ruling.
As I understand it, the sprinkler system in the New Jersey case was installed and a sprinkler (or sprinklers) were not installed in all areas of the building, specifically including a closet below the combustible exit stair involved in the fire. A contractor (or contractors) performed annual inspection, testing and maintenance on the sprinkler system, and never noticed the missing sprinkler or sprinklers. NFPA 25 does not require the contractors to look for missing sprinklers; that is the owner’s responsibility. NFPA 25 is predicated on the assumption that sprinkler systems are designed, installed and inspected properly, all in accordance with NFPA 13, Standard for the Installation of Sprinkler Systems. If the system isn’t correct initially, NFPA 25 has little to do with directly fixing it. Essentially, the inspection, testing and maintenance contractor is not required to look for missing sprinklers or other changes that would affect the sprinkler system in a fire condition.
If for whatever reason the installing sprinkler contractor doesn’t sprinkler a room or area or incorrectly sprinklers a room or area, then it won’t be identified and modified. In general, sprinkler contractors do not include an internal peer-review of their design, and my experience is that they don’t include a field inspection of projects. They instead rely upon the plan reviewer and the inspector to make sure they haven’t made any mistakes.
Who are these plan reviewers? If you are reading this article you most likely have encountered plan reviewers and may even be one. Most plan reviewers don’t have the experience or the expertise of the sprinkler system designers. Plan reviewers rarely have the opportunity to attend sprinkler system design classes or extensive plan review classes. They often don’t have the time and support to stay on top of the latest sprinkler system design changes and do not have computer programs to verify hydraulic calculations. There are many qualified and experienced plan reviewers, but most have never designed a sprinkler system or designed the complex sprinkler or fire suppression systems they are reviewing.
So, if the plan reviewer is supposed to catch all of the mistakes a designer makes, but really isn’t trained for that level of competency, how will those design mistakes be caught?
How about the initial inspection of the sprinkler system installation? Who are the fire sprinkler system inspectors? Frequently, their experience and education with the design and installation of fire sprinkler systems is very limited. The inspector is not expected to look in every room and closet, at every sprinkler, and they are not given the time or being paid to perform that level of inspection. Many inspectors are not given the time to review every sprinkler in a building, and they don’t have the opportunity to train themselves to thoroughly inspect the fire suppression systems they are asked to look at.
Although sprinkler contractors perform main drain tests and fire pump tests, frequently they don’t compare those tests to previous years or, in the case of the fire pump, to the certified pump test. Unsatisfactory results (e.g., where water supplies have deteriorated) need to be communicated and explained to the owner and occupant. Furthermore, they need to be told that additional testing is required. This communication is often left to a tag on the riser, recorded readings on the inspection report, and nothing more is said to educate or inform the owner and occupant.
Figure 4 is an example where the fire pump test header is incorrectly labeled as a fire department connection. This was approximately 20 years old and the owner had never been told it was incorrect. Fortunately, they did not experience a fire, and the fire department did not find out the hard way that it wasn’t a connection for their use in an emergency. How does this happen?
A few months ago I looked at a residential fire sprinkler system in Florida where a sprinkler had operated in a closet, and there wasn’t a fire. I called the city fire inspector to discuss the project and attempted to obtain sprinkler system drawings. The inspector informed me that the occupants would not be in that building if the sprinkler system wasn’t in accordance with NFPA 13R, Standard for the Installation of Sprinkler Systems in Low-Rise Residential Occupancies, because they thoroughly review and inspect the systems. In the living room of this condominium unit there was a sprinkler missing; it had never been installed. It was immediately obvious to me that the other sprinklers in the area were more than 10 feet off the walls, and in fact they were 14 feet off the adjacent walls. Even with extended coverage sprinklers, the sprinkler could not be more than 10 feet off walls. In this case, they weren’t extended coverage sprinklers, so they couldn’t be more than 7 feet, 6 inches off the walls. Unfortunately, I see this all the time in my plan reviews and after losses in my inspections.
If the sprinkler system is not designed, installed and inspected in accordance with the appropriate standards, who will find problems before it is too late? NFPA 25 has been watered down to place all of the responsibility on the owner of the building: 4.1.1 Responsibility for Inspection, Testing, Maintenance, and Impairment, the property owner or designated representative shall be responsible for properly maintaining a water-based fire protection system.
It also relieves the inspection contractor of any responsibility to look for design, installation or occupancy change issues:
1.1.3* This standard addresses the operating condition of fire protection systems as well as impairment handling and reporting and applies to fire protection systems that have been properly installed in accordance with general accepted practice.
126.96.36.199* This standard does not require the inspector to verify the adequacy of the design of the system.
A.188.8.131.52 The requirement to evaluate the adequacy of the design of the installed system is not a part of the periodic inspection, testing, and maintenance requirements of this standard. However, such evaluation is the responsibility of the property owner or designated representative as indicated in 4.1.6 and 4.1.7.
Realistically, what building owner knows enough about their sprinkler system to do anything more than call a sprinkler contractor for annual inspection, testing and maintenance or for remodeling? See Figure 1 for an example. Do they really know that they have to look for occupancy changes (or what that means) or missing sprinklers, drain hidden low point drains, drain obvious low point drains (many without signs indicating they are drains), perform internal pipe inspections, test dry type sprinklers after ten years, test fast-response sprinklers after twenty year, and so on? No, often they do not!
The only expert that generally sets foot in a building and looks at a sprinkler system on any regular basis is the sprinkler contractor. Why and how then is it the owner’s responsibility to know what they should look for, what they should do, when they should do it, and so on? Taking it further, suppose that at the time of the certificate of occupancy the original building owner was given instructions and a copy of NFPA 25, as is appropriate and required. Are they going to read it? And if they do, will they understand it? Will they know where it is when they sell the building and give it to the new owners? NFPA 25 does not require the contractor to inform the owner that they need to comply with NFPA 25, nor does it require the contractor to give a copy of NFPA 25 to the owner. So, how does the owner, or the second owner, or the new management group get that information?
Figure 5 is an example of improper original design and installation. I found it a couple of years ago in northern Minnesota after it froze and broke in a hotel, sending the guests out of the hotel during the Christmas holiday week. The water-filled CPVC was designed and installed to be in the unconditioned attic and to be above the blown-in insulation. That is not a good design where the normal temperatures are below freezing for many months and the temperature that day was near 0 F. Unfortunately, I have examples of this in residential as well as commercial occupancies.
Recently contractors have started eliminating the required trip testing of dry systems to minimize their exposure for water in dry systems that don’t get properly drained, and then freezes and causes water damage a few months later. Or, leads to corrosion that years later causes a freeze failure, pinhole leaks, or a blockage in a sprinkler system in a fire condition. If NFPA 25 is supposed to ensure the functionality or operation of a sprinkler system, but the inspection, testing, and maintenance contractor is not performing the required trip testing of the dry pipe valve, that does not ensure functionality or operability.
There are many examples of the inspection, testing and maintenance contractor performing the full trip test of dry pipe systems in October, November, December and January in northern plains states where they can freeze in any of those months, and often freeze for all of those months. That is neither responsible or a good practice by the expert: the sprinkler contractor. NFPA 25 states:
184.108.40.206.2* Each dry pipe valve shall be trip-tested annually during warm weather.
220.127.116.11.2* Auxiliary drains in dry pipe sprinkler systems shall be drained after each operation of the system, before the onset of freezing weather conditions, and thereafter as needed.
When water enters a dry system or a sprinkler contractor puts water in a dry system in the fall or winter, and then the sprinkler contractor 1) drains the system; 2) partially drains the system; or 3) doesn’t drain the system, the occupants or the owners don’t know that they have to 1) drain it themselves to get the water or the residual water out; 2) hire someone to come back and drain it; 3) blow it out with the air compressor to get all of the water out; and 4) continue until all of the moisture or water is gone. Most occupants and owners would not know how to do that work.
Additionally, water or moisture in steel pipe dry systems causes corrosion. Figure 6 is an example of corrosion in a dry system, which was not brought to the owner’s attention by the contractor working on the system. A fire watch and obstruction investigation in accordance with NFPA 25 should have immediately been undertaken, but the contractor did not inform the owner of the corrosion or the requirement to investigate.
If the sprinkler system subsequently freezes and breaks, it causes water damage, takes the fire sprinkler system out of service and displaces some or many of the occupants. The expert that performed the repairs or that put the water in and didn’t specifically, clearly and thoroughly tell the operator of the building that it could and will freeze if he or she doesn’t drain it frequently, or that operator needs to do it, often points to NFPA 25 and claims it is the owner’s responsibility.
I’ve read and heard that communication is the key to reducing any misunderstanding of the contractor’s and the owner’s roles in the inspection, testing and maintenance of fire sprinkler systems. So who isn’t communicating? The owner doesn’t know the questions to ask and most don’t have the expertise to do anything about the inspection, testing and maintenance even if they did have the answers.
It’s clear to me that we need the sprinkler contractors and their associations to educate the owners they work for, as well as provide and explain the requirements from NFPA 25. The contractors need to be clear that “A” through “Z” are required (and we know in some facilities that list is shorter and in some it is much longer than that), and that the owner needs to perform “A” through “W” while the contractor will be performing “X, Y and Z” only.
In some states and in some communities, the Authority Having Jurisdiction (AHJ), usually the fire service, is tasked with overseeing the implementation of NFPA 25. However, this is not true everywhere, and there are many fire protection systems in service in out-of-state areas where virtually no AHJ has either the authority or the funding to set foot in the buildings. How can and why should the AHJ be responsible for educating the occupants, owners or managers when the sprinkler contractor is being paid to perform the tasks in their proposal relative to NFPA 25?
I believe the solution does revolve around communication, but the communication must be from the contractors and their associations to the occupants, owners and managers. And it must be more than handing them a warranty letter and a photocopy of NFPA 25 when the original installation is completed.
The contractors can take our industry, their bottom-line and the fire safety of our buildings a big step forward by offering educational information to every one of their clients, on an annual basis, as they perform the inspection, testing and maintenance that they are contracted to perform. They can improve fire safety and communications by offering their clients copies of NFPA 25, and pointing out the tables within the standard indicating all of the work the owner still needs to perform.
If this becomes the norm, we will have significantly strengthened the relevance and effectiveness of NFPA 25. And that’s good for everyone.
Scott A. Futrell, PE, FSFPE, CFPS, SET, CFEI, is a fire protection consultant with Futrell Fire Consult & Design Inc., in Osseo, Minn. and has more than 40 years’ experience designing, specifying and investigating fire protection systems. He is a fellow in the Society of Fire Protection Engineers, co-author of “Designers Guide to Automatic Sprinkler Systems”, and can be reached by email at: email@example.com, or visit ffcdi.com.