An ambitious new standard, NFPA 3, is being devised as a practical solution to the problems associated with the testing and start-up of fire and life safety protection systems.
NFPA Journal®, May/June 2009
By David Hague, P.E., CFPS
Field acceptance testing of fire protection and life safety systems is a critical step at the end of a construction project, but it’s often conducted in a manner that diminishes its importance. Ask any authority having jurisdiction (AHJ), whether it’s a fire marshal or an insurance company representative, and they’ll tell you that field acceptance testing is often handled poorly. The installing contractors may be unprepared for the acceptance test, the systems may not be complete enough to test and do not function properly, the integrated testing between interconnected systems may not yet have been conducted or even specified—the potential problems can come from any number of sources. The result is systems that do not perform properly and must be tested again, adding time and expense to a project.
To help eliminate this problem, NFPA has developed NFPA 3, Commissioning and Integrated Testing of Fire Protection and Life Safety Systems, a new standard containing a formal commissioning program that takes into account all of these systems. The program also involves all interested parties in the initial project planning, and in monitoring the design and construction of these systems throughout the project. This is intended to provide oversight through better documentation of the building owner’s needs, compliance with the applicable codes, and inspection and testing during construction, resulting in better quality control and systems that pass the acceptance test the first time, every time.
Commissioning, which takes place at the end of a construction project, has traditionally been thought of as the acceptance testing of a building’s systems and equipment. It is often viewed as a painful and poorly performed process that many people dread—painful because the testing occurs with little planning and preparation (and often at the end of a contract when there is little money left for such an activity), and poorly performed because, in many cases, individual contractors are not aware of any integrated testing requirements and are unprepared to perform integrated testing.
NFPA 3 covers the minimum requirements for procedures, methods, and documentation for the commissioning, described as "a systematic process of ensuring that building systems perform according to the design intent and the owner’s operational needs." It also covers the integrated testing of active and passive fire and life safety systems, ranging from fire alarms and emergency communications to elevators and commercial cooking operations.
The purpose of a comprehensive commissioning program is to improve the communication of the building owner’s needs to the design team, then verifying that those needs are met. Commissioning also improves documentation and verification, so that a system is installed in accordance with codes and standards requirements. While commissioning is a process that never really ends, done properly it will deliver improved system documentation, improved operating personnel training, and better inspection, testing, and maintenance programs throughout the life cycle of the system.
The foundation of a standard
In 2005, NFPA produced a book entitled Commissioning of Fire Protection Systems, written by David R. Hague, that provides detailed information on the commissioning process. In 2007, it formed the Technical Committee on Fire and Life Safety Systems Commissioning, which is responsible for documents that pertain to the requirements for planning, organizing, coordinating, implementing, and documenting the commissioning of active and passive fire and life safety systems. The committee does not write acceptance-testing requirements, but it may extract those requirements from the appropriate documents for inclusion in NFPA 3.
Initially, the driving force behind commissioning was ensuring that heating, ventilation, and air-conditioning (HVAC) systems were properly installed. Most building engineers or managers will tell you that an improperly commissioned HVAC system results in increased operating expenses due to energy consumption and in constant service calls from building occupants who complain of being too warm or too cold. While a fire protection system is not the energy consumer that an HVAC system is, it is nevertheless a critical system. When a fire protection system fails, the leading causes include system shut off, lack of maintenance, an inappropriate system for the type of fire, and system component damage. Proper commissioning can test for and identify many of these problems, reducing the likelihood of sprinkler failure.
A building owner should spend more time and money on commissioning because there is a direct benefit in providing a formal commissioning program, in addition to knowing that the system operated during a fire. According to the Whole Building Design Guide (WBDG) Project Management Committee at the National Institute of Building Sciences, building owners can realize a $4 savings over the first five years of occupancy for each $1 invested in commissioning. That’s because a fire protection system that has been properly commissioned requires fewer service calls for repair, resulting in lower operating costs. (For more information on the topic, visit www.wbdg.org/project/buildingcomm.php.)
While construction professionals are already obligated to provide a functioning system with proper documentation and testing, the documentation is frequently handled poorly, despite system standards or codes that require documentation be kept on file for the life of the system. NFPA 3 requires that documentation be kept because its loss complicates the service and repair of the system or components, again increasing costs.
Designing a commissioning program
To design a commissioning program, a construction project should be divided into four major phases: programming, design, construction, and project closeout. In the programming phase, a design team is assembled that includes the building owner, operating personnel, a construction manager, the AHJ, and a registered design professional (RDP) for each discipline. The owner describes the building’s intended function and retains the services of the RDP, who assumes responsibility for designing components, assemblies, and systems, and for preparing, initiating, and monitoring the commissioning program. The owner also provides funding for all of this work.
During the design phase, a commissioning agent or administrator prepares the commissioning specifications and the overall commissioning program. The output of the design phase includes a commissioning plan tailored to the specific construction project, a basis of design (BOD) document, and the commissioning specification. The BOD describes the critical aspects of the project and includes the building’s description and applicable laws and regulations, such as those of NFPA, the Occupational Safety and Health Administration (OSHA), and the Americans with Disabilities Act (ADA). The document describes the fire or life safety system and states who has design responsibility or who the RDP is.
The BOD also provides the design methodology behind the fire protection system, including building occupant notification and evacuation procedures, and safeguards to be taken during construction. It describes the methods for inspecting, testing, and maintaining the system, including any special considerations with regard to specific aspects of either the performance-based or prescriptive design. The BOD should interpret and clarify codes and standards for the AHJ and the system designer, and should identify any waiver or variance of code requirements through the regulatory process.
Important to the BOD is a detailed testing criteria section that clearly states whether the testing is performance-based, prescriptive, or both. The BOD also specifies testing procedures, including integrated testing with other systems.
Also important is a testing criteria section that describes the equipment and tools required, including specific hardware, and any documentation approvals and notification announcements needed. The BOD is submitted to all AHJs on the project for their approval and becomes part of the project closeout documentation package.
The design phase of a project also includes specific activities, such as obtaining permit applications and the plan review process. The plan review should be completed and a permit to install the system obtained before construction begins. The permit application process varies from jurisdiction to jurisdiction, but it should include such information as the identification and description of the work; a description of land and the building’s use or occupancy, plans, and specifications; the valuation of the proposed work; and the signature of the permittee. The BOD is an important tool in this phase of the project.
The plan review portion of the design phase involves the AHJ, who receives the information and reviews it against a legal standard, such as a building code or installation standard. The AHJ will issue an approval or corrections list and a permit to install the new system. In addition to the commissioning agent, who is an independent third party hired by the building owner, the AHJ may also periodically inspect the installed work. The AHJ also witnesses the acceptance testing and retains copies of all project records for public review.
The construction phase mainly involves the commissioning agent, who inspects material deliveries and rough-in and finish installation, and observes pre-functional and functional testing of systems and equipment. Pre-functional testing is required to verify that systems and components have been installed correctly and are properly integrated with other systems. Verifying this before final acceptance testing is important because of the coordination issues involved in scheduling the final acceptance test. The commissioning agent notifies the construction manager of any deficiencies and initiates and supervises any required corrective action.
The project closeout phase involves much more than acceptance testing and final submittal of system documentation. It can also involve training operating personnel using the project closeout documentation, such as "as-built" drawings and operation and maintenance manuals (O&M), which are excellent training tools. In addition to maintenance information, the O&M should include the BOD, as well as a complete list of equipment; maintenance requirements for each component; all inspection and test reports; recommended spare parts; contact information for each supplier; "as-built" drawings and calculations; and the system warrantee. Depending on the size and complexity of the project, formal classroom training may be needed.
Commissioning is not intended to reinvent the wheel, but simply to provide a means of verifying that tasks are being completed—and completed correctly. While NFPA statistics indicate that sprinklers operate and perform effectively 90 percent of the time, too many systems do not perform as they should for reasons that proper commissioning can prevent. An organized method for designing, installing, documenting, testing, and, most importantly, maintaining a fire or life safety system will improve on an already impressive performance record.
David R. Hague, P.E, CFPS, was principal fire protection engineer at NFPA and helped establish the NFPA 3 project and technical committee. He is currently manager of the Engineering Technical Unit for Liberty Mutual Property in Weston, Massachusetts.