By Samuel S. Dannaway, PE,
President, S.S. Dannaway Associates, Inc., Honolulu
A regular feature of this column is to look at the changes in codes and standards affecting our profession. This month, let us look at what is new in the next edition of NFPA 25, Inspection, Testing and Maintenance (ITM) of Water-Based Fire Protection Systems.
The NFPA Standards Council recently issued the 2014 edition, which will be available for purchase within a few months. The 2014 edition incorporates the requirements for Antifreeze Systems previously issued as a Tentative Interim Amendment to the 2011 edition of NFPA 25.
Here are some of the significant changes. Note that paragraph numbering used here is subject to change when the final document is published:
• 18.104.22.168 Sprinkler Replacement. This provision requires that when an installed sprinkler is removed, for any reason, it shall not be reinstalled. This matches the requirement in NFPA 13.
• A.22.214.171.124.6 Concealed Spaces Not Requiring Inspection. NFPA 25 currently does not require the inspection of sprinklers, pipe and fittings in concealed spaces. The annex note is revised to clarify that the no-inspection-requirement applies even in the case of lay-in ceilings or where access panels or hatches are provided.
• New Chapter 16 Special Requirements from Other NFPA Documents. In the 2011 edition, the document scope was revised to clarify that NFPA 25 did not apply to NFPA 13D sprinkler systems. The primary concern was to avoid burdening homeowners with mandatory ITM requirements that could affect decisions to sprinkler homes and create an enforcement issue for AHJ’s. This new chapter is intended for systems required by other NFPA documents that may have special ITM requirements different from NFPA 25. NFPA 13D sprinkler systems installed in Small Residential Board and Care Occupancies, as a requirement of NFPA 101, are the first resident of this chapter.
• 8.3.1 Testing Frequency (Fire Pumps). In the previous edition, the frequency for running electric motor driven fire pumps was changed from weekly to monthly. This was done primarily as a result of information provided by the NFPA Fire Protection Research Foundation. You can view the report, Fire Pump Field Data Collection and Analysis, at: www.nfpa.org/research/fire-protection-research-foundation. The issue was revisited this cycle. As a result, the frequency was changed back to weekly for certain types of electric motor driven fire pumps. Specifically, the frequencies will be weekly for electric motor driven fire pumps serving high rise buildings, vertical turbine fire pumps, electric motor driven fire pumps with limited service controllers, and fire pumps taking suction from ground level tanks or a water source that does not provide sufficient pressure to be of material value without the pump. It was decided that these pumps represent a higher risk and therefore need more frequent attention. Other electric motor driven pumps remain at a monthly test interval. There has been no change to diesel engine driven fire pumps, which remain at a weekly test interval.
• 3.6.4 Definition of a Sprinkler System. The definition was changed to coincide with NFPA 13. The portion of the definition describing a sprinkler system as having, “a water supply source, a water control valve, a waterflow alarm, and a drain,” has significant impact. Any portion of a sprinkler system that has a floor control valve is now considered a separate system. The next bullet point will demonstrate the impact of this new definition.
• 14.2 Assessment of Internal Condition. The requirements for internal inspection of sprinkler piping were modified. The phrase “internal inspection” is now referred to as an “internal assessment.” A proposal that included elimination of the mandatory 5-year inspection frequency failed to get through the committee. The internal assessment must be performed on each sprinkler system. As noted above, if each sprinklered floor of a building has a floor control valve, the system on that floor is by the definition a separate sprinkler system. A sprinklered 40-story building would have 40 sprinkler systems and would require internal assessment on each floor.
• The requirements for ITM of water mist systems are now under the purview of NFPA 25. Rather than simply extracting the ITM material from NFPA 750, the NFPA 25 technical committee is now responsible for establishing ITM criteria for water mist systems.
• 126.96.36.199.1 Valve Status Test. There is a new requirement to conduct a “valve status test” whenever a control valve is returned to service after being closed for any reason. The intent is to insure that the valve is open.
• 188.8.131.52.8 and 184.108.40.206.9 Escutcheons and Cover Plates. Escutcheons and cover plates for recessed, flush and concealed sprinklers shall be replaced if found missing during the inspection. Escutcheons and cover plates for other sprinklers need not be replaced. The distinction made here is that in the case of recessed, flush, and concealed sprinklers, escutcheons and cover plates they can affect the operation of the sprinkler and may actually be part of the listing for the sprinkler, and therefore require correction.
• 220.127.116.11 Diesel Fuel Testing. There is a new requirement for diesel fuel to be tested annually. Fuel determined to be nonconforming shall be reconditioned or replaced, the tank shall be cleaned, and filters shall be replaced.
• 4.1.4 Correction and Repairs. In my view, this may be the most significant change to NFPA 25. Previously, there was no time limit on correction deficiencies. Annex language used phrases like “as soon as possible,” “timely fashion” and “reasonable time period.” The proposals to provide definite time limits originally rejected by the technical committee were presented as Certified Amending Motions to the Standards Council, and passed. NFPA 25 now incorporates time limits for each type of deficiency. Critical deficiencies must be corrected within 30 days. Non-critical deficiencies must be corrected within 90 days.
One issue that did not have a big impact in terms of code changes but that is now receiving a lot of attention relates to the scope of NFPA 25. Specifically, to what extent should inspectors be capable of identifying system deficiencies that fall go beyond normal inspection? These are system deficiencies related to hazard analysis or 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.
NFPA 25 has tried to avoid giving the inspector these types of responsibilities and places the burden for identifying and correcting these items with the owner. The problem is the owner also is 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 may have changed. Furthermore, as noted by William Koffel, PE, in a presentation at the NFPA Conference in Chicago, many system owners have an expectation that compliance with NFPA 25 means their system is OK and will put the fire out. They are unaware that there may be deficiencies not intended to be identified by a NFPA 25 inspection and deficiencies not related to change of use or design that may burn a building down.
NFPA 25 staff liaison Matt Klaus is very aware of this issue and indicated that the NFPA may hold a workshop with owners and technicians to develop a way to deal with what amounts to a significant gap in the measures needed to assure that, once installed, water-based fire protection systems can do their job. Possible solutions could include such things as reliance on the permitting process to catch changes in the hazard, improved enforcement by AHJ’s, educating owners on the scope of NFPA 25 and having owners increase the scope (and cost) of inspection services to include design evaluation. Also, there may be a role for the retro-commissioning process as described in NFPA 3. Stay tuned.
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.