Too Much of a Good Thing?
The problem of taking NFPA 25 inspections too far
NFPA Journal®, January/February 2013
It’s not uncommon to see “design issues” noted on an inspector’s deficiency report following a review of a sprinkler system as required by NFPA 25, Water-Based Fire Protection Systems. The question is, should “design issues” be noted at all?
While it seems like common sense for inspectors to identify such problems, design deficiencies are not part of the scope of NFPA 25. From an inspection standpoint, NFPA 25 is written as a “wear and tear” document, not a design evaluation standard — a differentiation that often leaves people scratching their heads. While design deficiencies and failures in managing change can create serious life safety concerns and have been attributed to the failure of water-based fire protection systems, it is important to understand where these issues should be documented, and by whom.
Inspections conducted in accordance with NFPA 25 should focus on the functionality of the system or component. The central question in an NFPA 25 inspection is, “Can this component or system function properly in its current state?” The answer to this question can usually be made from the floor level relatively quickly, and includes things like leaking sprinklers, paint on deflectors, and corroded control valves.
By comparison, a design evaluation, or retro-commissioning event (see NFPA 3, Commissioning and Integrated Testing of Fire Protection and Life Safety Systems), is a confirmation that the system was designed and installed in accordance with the appropriate design standard at the time of construction. Here, the central question is, “Was this component or system designed and installed appropriately based on the applicable code or design standard?” Answering this question requires the person conducting the evaluation to have some knowledge of the original system design, the applicable codes and standards, and the design drawings for the property. In this case, each device would have to be thoroughly reviewed. A design evaluation of a typical office building, for instance, would require the inspector to measure all distances between sprinklers, as well as distances to possible obstructions — hundreds of individual measurements.
That’s not to say that inspectors shouldn’t inform building owners that there may be an issue with a system. The problem with providing a client with more information, though, is that it can open the inspector to liability. If an inspector is identifying some design deficiencies on his NFPA 25 inspection report, but not all of them, the line can become blurred as to the depth of the review and the inspector’s contractual obligation to the owner. Many owners believe that NFPA 25 requires the inspector to conduct a design evaluation, so when an inspector provides a few design issues mixed in with proper NFPA 25 deficiencies, it can further muddy the waters.
Many inspectors feel that they have a moral and ethical obligation, as members of the fire protection and life safety community, to inform their clients of all potential concerns. One way to comply with the requirements of NFPA 25 while still satisfying that moral obligation is to keep two deficiency reports: one dealing with NFPA 25 issues and another that could be called the “good Samaritan” list. The NFPA 25 report catalogs wear and tear issues while clearly identifying the scope of NFPA 25. The “good Samaritan” report lists all other items that are beyond the scope of NFPA 25, along with a disclaimer stating that these items are not considered part of an NFPA 25 inspection program. This way the scope of NFPA 25 is clearly acknowledged, as are any and all problems observed during the inspection.
Matt Klaus is a senior fire protection engineer at NFPA and staff liaison on NFPA 13, 13R, 13D.