The first edition of NFPA 25, Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, in 1992, was a collection of inspection, testing, and maintenance (ITM) provisions that helped ensure the successful operation of water-based fire protection systems. NFPA 25 was developed as an extension of existing documents such as NFPA 13A, Recommended Practice for the Inspection, Testing, and Maintenance of Sprinkler Systems, and NFPA 14A, Recommended Practice for the Inspection, Testing, and Maintenance of Standpipe and Hose Systems, which had assisted authorities having jurisdiction and property owners with routine inspections of sprinkler systems and standpipes.
Since then, NFPA 25 has become the main document governing sprinkler systems and related systems, including underground piping, fire pumps, storage tanks, water spray systems, and foam-water sprinkler systems. The application of the standard does not cover deficiencies in the design or installation of the system; the intent of the standard is to confirm that the system components are in good working order and will function properly should a fire event occur. The standard states that the property owner is responsible for obtaining 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. Compliance with the requirements of NFPA 25 is required by NFPA 1, Fire Code; NFPA 101®, Life Safety Code®; the International Fire Code; and insurance companies. Failure to satisfy the requirements of NFPA 25 may be a reason why an insurance company does not pay an insurance claim.
Recently, though, questions have arisen regarding the scope of NFPA 25 and whether the standard is adequate to ensure the successful operation of automatic sprinkler systems. For example, it is not uncommon for obvious design deficiencies, such as unsprinklered areas or obvious spray pattern obstructions, to go unreported to owners despite an inspection by a qualified person. Changes have been proposed to NFPA 25 to address this issue, and committee discussions have taken place on a variety of related topics. Some of those discussions have addressed whether the scope of NFPA 25 should be limited or expanded, whether a separate document detailing the owner’s requirements should be created, if there are any inspection activities that should be added, and whether NFPA 25 is merely a “wear and tear” document.
THE BAD, THE WORSE, AND THE UGLY The intent of NFPA 25 is to confirm that the sprinkler system components are in good working order and will function properly should a fire event occur. Some of the problems the standard is designed to address include, from left, obstructions in sprinkler piping, sprinkler heads that have been painted, and all manner of corrosion problems.
Such fundamental questions called for a more organized method of evaluating the standard. As part of that process, a group including myself, as chair of the NFPA 25 technical committee; Matt Klaus, principal fire protection engineer at NFPA and staff liaison for NFPA 25; NFPA’s Fire Analysis and Research Division; and the Fire Protection Research Foundation (FPRF) is organizing a symposium in December in Chicago that will address a number of these important issues. We expect the event to identify a range of opinions and perspectives on the issues related to NFPA 25, which will then be included as part of the overall public input on the standard. The committee will consider that public input as it enters the revision cycle for the 2017 edition of NFPA 25.
Some of the most important issues related to NFPA 25 have to do with the responsibility of owners. NFPA 25 clearly states that the owner has the ultimate responsibility for the ITM and impairment procedures of all water-based fire protection systems. Those responsibilities include protecting water-filled pipes from freezing; notifying the authority having jurisdiction, fire department, and alarm supervising station prior to testing or shutting down the system; correcting or repairing deficiencies and impairments identified; evaluating how changes in occupancy, processes, and materials used or stored may impact the sprinkler system; and evaluating changes that might impact the performance of the system.
An upcoming NFPA 25 symposium will examine a range of issues related to the standard’s effectiveness
In December, the Fire Protection Research Foundation will sponsor a two-day symposium on sprinkler system performance and NFPA 25, Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems. Participants will explore the responsibilities of owners; the expectations of owners, insurance carriers, and code officials; and the services typically provided as part of an inspection, testing, and maintenance (ITM) contract.
The event will gather stakeholders to discuss these issues and more, as part of an effort to evaluate the effectiveness of NFPA 25 and to improve the performance of automatic sprinkler systems. It is anticipated that the Technical Committee on the Inspection, Testing, and Maintenance of Water-Based Systems will consider the results of the event, along with ongoing public input, in the development of the next edition of NFPA 25.
Even for ITM activities that are clearly within the scope of NFPA 25, there are questions about the relative effectiveness of the standard to produce the mandated ITM activities and of those activities to produce the intended sprinkler reliability conditions. Such gaps in reliability might not be addressable through changes in the standard itself, but they might be addressable through related changes in requirements or in common practice. Alternatively, it would be useful to know if there is a significant gap in sprinkler performance that we do not know how to reduce or eliminate.
As a practice of good fire protection and life safety, what should be done? Some of the questions that will be presented and discussed at the workshop include:
• Should the scope of NFPA 25 be reconsidered?
• Should a new standard on conducting design evaluations be developed?
• Should NFPA 3, Recommended Practice for Commissioning and Integrated Testing of Fire Protection and Life Safety Systems, address a periodic system “recommissioning activity” for some or all occupancies?
• Should these recommissioning events be addressed by the occupancy chapters of NFPA 101®, Life Safety Code®?
• Should the provisions in NFPA 1, Fire Code, be supplemented to require inspection reviews that can address the adequacy of a system?
• Should the issues with NFPA 25 remain with the owners and regulatory process as they currently do, in the hope that the problems resolve themselves organically?
A summary report of the symposium will be available from the Fire Protection Research Foundation at nfpa.org/foundation.
Addressing the Performance of Sprinkler Systems: NFPA 25 and Other Strategies
Renaissance Blackstone Chicago Hotel
For information on the symposium, visit nfpa.org/foundation.
Most owners delegate the responsibility for some of the above items to outside contractors. However, the typical contract between the owner and contractor limits the contractor’s responsibilities to only some of the above items. That raises important questions about the standard: Do building owners understand their responsibilities? Do they understand which items are included — and which are not — in the typical ITM service? Should the owner’s responsibilities be addressed in NFPA 25, or should they be addressed in a separate document? What is the enforcement mechanism to ensure that the owner’s responsibilities are being met?
Adequacy of the design and installation
NFPA 25 does not require the person performing routine inspection services to verify the adequacy of the design. It is presumed that the system was properly designed and installed in accordance with NFPA 13, Installation of Sprinkler Systems. As such, following the acceptance test procedures and documentation required by NFPA 13 is critical to the ongoing proper performance of the system. It would be cost prohibitive if the adequacy of the original system design and installation had to be verified at some frequency, such as annually.
For example, if the pipe in a dry-pipe sprinkler system is not installed with the proper pitch towards a drain, water may collect in the system. If the system is installed in an area subject to freezing, the owner will assume that the dry pipe sprinkler system provides adequate protection against freeze conditions in the pipe. The ITM contractor who performs the trip test of the dry pipe valve will assume that the water that entered the system will be properly drained. Combined, these assumptions could result in a failure of the sprinkler system piping if water freezes in the pipe.
In addition, many of the tests required by NFPA 25 involve comparing the current test results with the results of previous tests as well as the initial test results. For example, when a main drain test is performed, the results are compared to tests performed over the past two years as well as the test performed during acceptance of the system. An analysis is required if the test results have decreased by 10 percent or more. The comparison will show if there has been a recent reduction in the water supply for the system.
The results are also compared with those obtained during the acceptance tests for the system. It is anticipated that during the acceptance test the main drain test results are used to confirm the adequacy of the water supply for the system. As such, the ITM contractor is not required to perform any calculations to verify that the water supply is still adequate, only that the water supply is similar to the one that existed during the acceptance test. If the evaluation was not done during acceptance of the system, the water supply for the system may have been inadequate from the beginning without anyone noticing the deficiency.
Again, these scenarios raise important questions about the scope and intent of NFPA 25. Is it reasonable for an owner to assume that, once a system is installed, it has been designed and installed correctly? If not — and considering that NFPA 25 inspection activities do not address such issues — what is the mechanism to address design deficiencies with the system, especially those that are not caught during plan review, installation, and acceptance of the system? Does the person doing the inspection have a duty to notify the owner of any potential deficiencies with the system if they are in plain view? How does the person doing the inspection know if it is a potential deficiency if they were not involved in the design?
Management of change
It’s the owner’s responsibility to manage any changes that may impact the performance of the sprinkler system. Some owners assume that the periodic inspection of the system will address this issue, but typically this may not be the case. ITM forms used by contractors 20 years ago included a question about the adequacy of the system to protect the hazard, but modern-day ITM forms used by most contractors no longer include that question.
How does an owner who may have minimal knowledge about fire sprinkler systems fulfill this responsibility if periodic inspections do not provide this service? In some instances, the regulatory process should result in the proper evaluation. For example, when a tenant fit-out occurs and walls are relocated, the registered design professional involved in the project, along with the building permit process itself, should produce the necessary changes being made to the sprinkler system.
Not all changes involve a registered design professional or a building permit, however. For example, many of the containers in the cosmetics industry are now plastic instead of glass, which changes the commodity classification for the stored product. As a result, the sprinkler system would need to be evaluated based upon a higher commodity classification. Will most owners recognize that such a change in materials requires the sprinkler system to be re-evaluated? What about a hospital, where unused furniture is stored in a room previously used as a patient sleeping room — would hospital management know that the room is no longer a light hazard occupancy as defined by NFPA 13? How should these kinds of changes — changes that can impact the performance of a sprinkler system — be identified, and, more importantly, how should they be corrected?
Sprinkler system failure
Recent fire incident data indicate that the most common cause of sprinkler system failure is a closed or partially closed valve. The current NFPA 25 requirement for monthly inspections of these valves, along with valve supervision requirements contained in most building and fire codes, should be improving the performance of automatic sprinkler systems.
The problem here is that the standard is only looking at one part of the sprinkler failure issue. In fact, there are numerous other failure modes for sprinklers under both fire and non-fire conditions, which can include pipe and fitting failures due to water trapped in a dry-pipe sprinkler system, or a wet-pipe system in an area which is no longer properly heated; and fittings or hangers that fail during an annual flow test of a fire pump. Other failure modes include fires originating in spaces that are not protected with an automatic sprinkler system, even though the building is; insufficient water supply to control the fire; and water damage due to a sprinkler operating, the result of physical damage to the sprinkler due to contact or to a unit heater being installed after the sprinkler system was installed — damage that may go unnoticed during routine ITM activity.
Beyond NFPA 25
Some argue that examples like these illustrate that a proper preventive maintenance program for a water-based fire protection system places too much responsibility on the owner. One way to address these issues would be to perform re-evaluations of existing systems at some frequency to verify that the responsibilities assigned to owners by NFPA 25 are being met.
If system re-evaluations are necessary, should a document such as NFPA 1, Fire Code, mandate such re-evaluations, or should owners implement them when they decide they are appropriate? The need for re-evaluations, referred to as recommissioning, is an issue currently being considered for a new standard, NFPA 4, Integrated Fire Protection and Life Safety System Testing. However, if NFPA 4 were to contain a requirement for recommissioning, it would only apply to integrated fire protection systems. Some observers argue that other parties, such as fire officials or insurance company representatives, can provide the necessary oversight by conducting more thorough inspections and surveys.
The question of how much responsibility is too much will certainly be part of the discussion at the upcoming symposium, and beyond. It’s just one of many questions that we need to address as part of our assessment of NFPA 25 and whether the standard is fulfilling its intended purpose. Regardless of what our evaluation produces, we are confident that the process will result in a stronger standard for ITM procedures for water-based sprinkler systems.
Bill Koffel is president of Koffel Associates and chair of the NFPA 25 technical committee.
|IN OTHER SPRINKLERS NEWS ...
NFPA 13 technical committees responds to concerns over material incompatibility and leaks.
Widely used in residential sprinkler systems, nonmetallic piping has received unwanted attention in recent years due to a series of incidents involving leaks. The culprit is not the piping material itself but rather a fracturing of the pipe when exposed to certain substances commonly used in sprinkler system installations.
“This issue is replacing the use of antifreeze in sprinkler systems as the big focus for the NFPA sprinkler committees,” says Matt Klaus, NFPA’s principal fire protection engineer and staff liaison for NFPA 13, Installation of Sprinkler Systems, and NFPA 13D, Installation of Sprinkler Systems in One- and Two-Family Dwellings and Manufactured Homes. (Read more on NFPA’s response to the antifreeze issue at nfpa.org/antifreeze.)
Here’s the problem: Sprinkler installers lubricate metallic piping with cutting oils while threading the pipe. When metallic pipes are connected to combination sprinkler systems that also utilize nonmetallic pipe, the trapped oils come in contact with the nonmetallic pipe via water flow. In some instances, this interaction can cause chemical stress fractures in the nonmetallic pipe and produce leaks. Not all cutting oils will cause these fractures, however, which is why it is critical to ensure that all products used as part of the installation process are compatible with the pipe and fitting materials.
Cutting oils aren’t the only substances that may cause problems. Corrosion inhibitors, which coat a steel pipe’s interior and prevent rust and microbiologically influenced corrosion, also flow through plastic pipe, causing its chemical composition to break down in some cases.
“Part of the problem is that codes and standards have not historically addressed who is responsible for determining if products are compatible with each other,” says Klaus. “This leaves the owner, the authority having jurisdiction, the contractor, and manufacturers all looking at each other for answers.”
Addressing this issue, the Sprinkler System Installation Criteria Technical Committee approved provisions in the 2013 edition of NFPA 13 requiring that corrosion inhibitors and lubricating oils used in combination systems undergo a compatibility check with nonmetallic piping. Based on the standard’s requirements, Underwriters Laboratories (UL) is developing a new testing standard for thermoplastic piping that addresses this compatibility requirement. UL working groups are currently drafting criteria for the new standard and plan to evaluate a “candidate test protocol” at multiple test facilities in the future, says Kerry Bell, UL’s principal engineer for fire sprinkler and pump equipment.
Meanwhile, a new NFPA task group formed last year at the request of the Technical Correlating Committee on Automatic Sprinkler Systems and comprised of various sprinkler committee members has proposed new language for the 2016 edition of NFPA 13 and 13R, Installation of Sprinkler Systems in Low-Rise Residential Occupancies, that would require corrosion inhibitors and cutting oils to be used in accordance with their listing or the manufacturer’s published information about the product’s compatibility. The task group is also making sure provisions related to material compatibility are consistent in the 2016 edition of NFPA 13 and NFPA 13R.
“The task group has worked hard to come up with an approach to this issue that provides the direction that all of the interested parties have been looking for,” says Klaus. This revised approach for the 2016 edition was approved by the technical committees at the recent First Draft Meetings for NFPA 13 and 13R and is currently in the formal committee balloting process.
— Fred Durso, Jr.