AUTHOR: Jonathan Hart

Deficiencies and Impairments of Sprinkler Systems

NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems provides the criteria for the routine activities that must be conducted to ensure that water-based fire protection systems, such as automatic sprinklers systems, can be relied upon in the event of a fire. These activities range from simple visual confirmation of some things such as valve position or water tank temperature, on a more frequent basis; to performance of much more complex activities such as full flow tests and internal assessments at longer intervals.   There is a very large number of observations or findings during inspection or testing of a sprinkler system that can be out of compliance with the standard. With that said, there is a difference between issues that mean the system will not function in a fire event as opposed to those that do not have much, if any, of an effect on the ability of the system to function in a fire event. While each needs to be corrected, the urgency and priority of the former is clearly ahead of the latter. Here we will discuss how NFPA 25  classifies conditions of noncompliance.  Noncritical deficiency, critical deficiency, impairment Editions prior to the 2011 edition of NFPA 25 presented ITM requirements as pass/fail because no other options for identifying system status was presented in the standard. Since that edition additional definitions have been added and the standard is continuously being refined to clarify these differences with each new revision. The following are definitions form NFPA 25 (2020 edition) related to noncompliant conditions. These conditions can be classified as an impairment or a deficiency with there being two subsets of deficiency.  Noncritical Deficiency: A deficiency that does not have a material effect on the ability of the fire protection system or unit to function in a fire event, but correction is needed to meet the requirements of NFPA 25 or for the proper inspection, testing, and maintenance of the system or unit.  Critical Deficiency: A deficiency that, if not corrected, can have a material effect on the ability of the fire protection system or unit to function as intended in a fire event.  Impairment: A condition where a fire protection system or unit or portion thereof is out of order, and the condition can result in the fire protection system or unit not functioning in a fire event.  Simple but not easy While in theory the definitions allow for easy classification of issues not in compliance with the standard into one of the three levels it is often not cut- and-dried. Where the water supply is not available or has been significantly compromised it can be clearly labeled as an impairment. Where a general information sign is missing it can clearly be classified as a noncritical deficiency. Most things fall somewhere in between these two extremes and requires more of a judgement call. The image below shows a “System Tagging” feature from the NFPA 25, ITM of Water-Based Fire Protection Systems Handbook in which different conditions are evaluated along with key considerations and a tag is applied. This feature demonstrates the variables that come into making a determination. This particular example speaks to painted sprinklers. Check out this blog more information on the specific sprinkler inspection items.  There’s a Table to Help While each situation and condition still needs to be evaluated individually there is a table provided in the annex of NFPA 25 that provides a good starting place for considering how to classify a noncompliant condition. While annex material of NFPA codes and standards is not considered part of the requirements of the document it is included for informational purposes as explanatory material. With that caveat understood it is still an output of the standards development process that is voted on and passed by a consensus of the technical committee responsible for the standard. The image below provides a snapshot of a small portion of the table. It is informational because the specifics of each situation and condition must be considered for the individual situation.   View larger Tagging the System While NFPA 25 does not specifically define a “tagging structure” for identifying levels of deficiencies or impairments, many states have developed a series of color-coded tags that are placed on a system or component to identify the significance of the condition identified. Annex G of NFPA 25 providesauthorities having jurisdiction ( AHJs) with some basic guidance regarding a system status tagging program. Readers should check the requirements for tagging in the jurisdiction they are working. The NFPA 25 guidance suggest four tags to identify the condition.  A color-coded tagging system that mirrors the standard would include the following tags:  Green tag — No deficiencies or impairments found when inspections and tests performed at the required frequency were completed as indicated on the ITM report provided to the owner  Yellow tag — Noncritical deficiencies found and recorded on the ITM report  Orange tag — Critical deficiencies found and recorded on the ITM report  Red tag — Impairments found and recorded on the ITM report (The color-coded tagging program should be kept separate from the impairment tag and other requirements outlined in Chapter 15.)  Additional information to be included on the tag is detailed in Annex G.  Mind the Edition As mentioned earlier, the standard is being continuously refined around this topic. The examples and information provided here are based on the 2020 edition of NFPA 25. While it is not likely that the overall approach outlined here will change small tweaks can certainly be expected from edition to edition. The 2023 edition of the standard will be released later this year and is proposed to have significant revisions to the annex tables and the classification of certain findings as deficiencies or impairments.  Correction or Repair of Deficiencies and Impairments The correction or repair of deficiencies or impairments are one of the responsibilities of the building owner or designated representative. The property owner is responsible for ensuring that deficiencies or impairments are corrected or repaired. Corrective action to remediate deficiencies and impairments must be done in accordance with the applicable design and installation standard. Impairments must be corrected within 10 hours or the building either needs to be evacuates, an approved fire watch established, a temporary water supply be established, or an approved program be established and implemented to eliminate potential sources and limit the amount of potential fuel.  A  number of other steps and policies on dealing with impairments  is detailed in Chapter 15 of NFPA 25. Understanding the differences between impairments, critical deficiencies, and noncritical deficiencies is necessary for properly prioritizing corrective actions.  

Visual Inspection of Sprinklers

NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems provides the criteria for the routine activities that must be conducted to ensure that water-based fire protection systems, such as automatic sprinklers systems, can be relied upon in the event of a fire. These activities range from simple visual confirmation of some things such as valve position and room or water tank temperature on a more frequent basis, to much more complex activities such as full flow tests and internal assessments at longer intervals.    This blog will focus on the requirements for visual inspection of the sprinklers themselves. Check here for  more information on the different types of sprinklers.   How often? One of the required activities is to perform an annual visual inspection of the sprinklers themselves. An annual frequency is defined as occurring once per year with a minimum of 9 months and a maximum of 15 months between inspections. See this blog more information on NFPA 25 ITM frequencies.   From the floor A key specification in the standard is that these visual inspection of sprinklers are intended to be conducted from the floor level. This means that typically there should be no special equipment needed for these routine inspections such as ladders or lifts. To further support this concept, NFPA 25 clearly states that sprinklers located in concealed spaces such as above suspended ceilings do not require inspection.    All sprinklers? It is often asked if the requirements of NFPA 25 for sprinkler inspections only require a certain percentage of sprinklers to be included as part of the inspection. There is no allowance in the standard that indicates any sprinklers are permitted to be skipped during an inspection, other than those in concealed spaces as referenced above and for those installed in areas that are inaccessible for safety considerations due to process operations, the latter of which must be inspected during each scheduled shut down. The owner or their designated representative is responsible for providing access to sprinklers at the time of the inspection. See this blog for more information the owner’s responsibilities related to ITM. If certain sprinklers cannot be accessed for inspection it is common to note that on inspection reports.   What is being inspected? The following are items that NFPA 25 includes as part of the visual inspection of sprinklers.  Leakage Corrosion detrimental to sprinkler performance Physical damage Loss of fluid in the glass bulb heat-responsive element Loading detrimental to sprinkler performance Paint other than that applied by the sprinkler manufacturer Sprinklers installed in the incorrect orientation Minimum clearance to storage is maintained  The conditions in this list can have a detrimental effect on the performance of sprinklers by adversely impacting water distribution patterns, insulating thermal elements which could delay operation, or otherwise rendering the sprinkler inoperable or ineffectual.   The visual inspection does not include any sort of verification of the design or layout of the sprinkler system. This is true of all of the ITM activities specified by NFPA25. If NFPA 13 needs to be referenced to cite an issue then it is likely outside the scope of inspection activities of NFPA 25. Some inspectors might provide items related to the design of a system if they are noticed as a separate report. It is the responsibility of the owner to have a design evaluation performed if changes have been made.    Leaking Sprinklers that are leaking or that have been damaged must be replaced without testing. Dissolved minerals and other residues in the water can solidify as the sprinkler leaks, hampering the operation of the sprinkler by changing internal clearances or acting like an adhesive, preventing parts from moving as intended. Annex material in NFPA 25 makes a distinction between “spraying or running” water and “dripping” water. The sprinkler could be damaged and might not activate as it is intended to. Either way, this condition would require action because the functionality of the device is in question.   Corrosion detrimental to sprinkler performance Corrosion found on the seat, or built up on the deflector that could affect the spray pattern, or a buildup on the operating elements that could affect the operation can have a detrimental effect on the performance of the sprinkler. Lightly loaded sprinklers or sprinklers having limited corrosion that does not impact the water distribution characteristics can continue to be used if the samples are selected for testing in accordance NFPA 25 based on worst-case conditions and if the samples successfully pass the tests. Surface discoloration that does not impact the performance of the sprinkler should not warrant replacement or testing.     Figure 1: Corroded Sprinkler (Courtesy of Wiginton Fire Systems)   Physical damage Damaged deflectors should not be overlooked, although they can be difficult to detect from floor level. What might appear to be only slight damage to the deflector can have a drastic impact on the distribution of the spray pattern and the density of the water that is delivered.      Figure 2: Damaged Sprinkler Deflector (Courtesy of Wiginton Fire Systems)   Loading detrimental to sprinkler performance Any loading used to require replacement however in recent editions the criteria for sprinkler replacement depend on whether the corrosion or loading is detrimental to sprinkler performance. This introduces a certain level of subjectivity into the inspection of sprinklers and further explains the necessity of those conducting the inspection to be qualified as defined in NFPA 25. Sprinklers that upon inspection show signs that they will not operate correctly are required to be replaced. However, those with light loading can be cleaned with a vacuum or a blast of compressed air.   Figure 3: Close-Up of Loaded Sprinkler (Courtesy of Wiginton Fire Systems)   Paint other than that applied by the sprinkler manufacturer Sprinkler must be free of paint other than that applied by the manufacturer. Painted sprinklers are never permitted to be cleaned and/or reinstalled, because the potential of damaging the assembly is too great. A “light” overspray or loading can be tolerated when a representative sample is tested to verify that the sprinklers will operate as intended   Figure 4: Painted Sprinkler (Courtesy of Josh Elvove)   Sprinklers installed in the incorrect orientation Sprinklers installed in the incorrect orientation such as an upright sprinkler installed in the pendent position will not develop an effective spray pattern. Where this happens, the situation must be corrected by repositioning the branch line, drop, or sprig, or the sprinkler must be replaced. While this is not always easy to tell from floor level, where it is observed it must be corrected.   Figure 5a: Upright Sprinkler Incorrectly Installed in the Pendent Position   Figure 5b: Pendent Sprinkler Incorrectly Installed in the Upright Position   Minimum clearance to storage is maintained Obstructions to sprinkler distribution patterns, such as storage that is too close to sprinkler deflectors, can hamper the effectiveness of sprinklers. Obstructions that are closer than 18 in. (457 mm) below the sprinkler have a greater impact on distribution patterns than do obstructions located further away. These are easy to visually spot as opposed to many of the other obstruction distances specified by NFPA 13 so they are the only ones referenced by NFPA 25.   Figure 6 Typical Obstruction: Storage    There is much more that goes into a complete inspection of a sprinkler system than just the visual inspection of sprinklers. NFPA 25 should be referenced in full as it applies to a specific system. Sprinklers themselves should be visually inspected at an annual frequency for the items listed in this blog. 
Man looking at tablet and working with a piping system

Responsibilities of the Building Owner for Fire Sprinkler System Inspection Testing and Maintenance

NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems provides the criteria for the routine activities that must be conducted to ensure that water-based fire protection systems, such as automatic sprinklers systems, can be relied upon in the event of a fire. These activities range from simple visual confirmation of some things such as valve position or room or water tank temperature on a more frequent basis to much more complex activities such as full flow tests and internal assessments at longer intervals.  NFPA 25 also includes responsibilities for inspection, testing, and maintenance (ITM) of water-based fire protection systems that specifically fall to the owner or their designated representative. This information is essential for building owners and their designated representatives to know and understand. A designated representative can include the occupant, management firm, or managing individual through specific provisions in the lease, written use agreement, or management contract. Wherever this blog mentions the responsibilities of the owner it also applies to the owner’s designated representative where applicable. This information is also valuable for all ITM service providers to have a good understanding of these requirements to improve communication with their customers. The following details some of the items listed as the responsibility of the owner or designated representative. Chapter 4 of NFPA 25 should be reviewed for a complete listing of these.  Overall ITM program The owner or designated representative is responsible for the overall ITM of system(s) in their building. They must ensure that these activities are completed within the specified frequencies. While often the performance of these activities are contracted with a service provider, the ultimate responsibility for ITM falls on the building owner. We could just stop here since it covers most everything, but there are other specific requirements that the building owner must be responsible for.  Impairment procedures Impairments to a system can be either planned or unplanned. There needs to be a plan in place for either situation. The owner is responsible for this. Chapter 15 of NFPA 25 includes the requirements for what must be included in an impairment program.  Minimizing water damage Anytime water is released, consideration must be given to where that water may ultimately end up. This is not only the responsibility of the person performing the ITM, but it must also involve the owner. The owner or designated representative, such as maintenance personnel, is often more familiar with the condition of the plumbing system or the drainage characteristics of the surrounding area.  Freeze protection The owner is responsible for ensuring that all areas of the building containing water-filled piping that does not have another means of freeze protection shall be maintained at a minimum temperature of 40°F (4°C).  Providing ready access The owner must provide ready access to components of the systems that require inspection, testing, and maintenance. This is intended to address the all-too-common practice of placing objects — such as file cabinets or stock — in front of sprinkler risers and other control equipment. This requirement is not limited to the interior of the building. Exterior components of the system must be kept accessible as well.  Notification of systems shutdown or testing The property owner is responsible for notifying the authority having jurisdiction (AHJ), the fire department, if required, and the alarm-receiving facility before testing or shutting down a system or its supply.  Testing a system without proper notification might—and often does—result in a false alarm. False alarms must be avoided since they remove emergency services personnel from service at a time when their services might be needed for an actual emergency. At the conclusion of such tests, the alarm-receiving facility should be notified that any alarms received from that point on are not test-generated and should be responded to appropriately.  Correction and repairs The property owner is responsible for ensuring that deficiencies or impairments are corrected or repaired. Corrective action to remediate deficiencies and impairments must be done in accordance with the applicable design and installation standard. Understanding the differences between impairments, critical deficiencies, and noncritical deficiencies can be helpful in prioritizing corrective actions.  Change management The evaluation shall consider factors that include, but are not limited to, the following:   Occupancy changes such as converting office or production space into warehousing  Process or material changes such as metal stamping to molded plastics Building revisions such as relocated walls, added mezzanines, and ceilings added below sprinklers Removal of heating systems in spaces with piping subject to freezing Changes to the storage method, arrangement, height, or commodities Changes in water supplies   Records management Records must be made for all ITM activities undertaken on a system and its components. The property owner is responsible for maintaining these records which can be hard copy or stored and accessed electronically. The records must be made available for the AHJ upon request. Some jurisdictions require the submittal of ITM records to the AHJ while others will check for them while the building is due an inspection or at another time they determine.   Closing  While a substantial percentage of fire protection systems have their ITM work contracted to a service provider there are still many responsibilities placed on the building owner. Those building owners that understand what these responsibilities are and where they come from can see improved communications with their service providers and a more complete picture of what is needed to maintain fire protection systems. This knowledge can lead to more robust ITM programs and contribute to ensuring a safe environment for people in the building and an added layer of protection for the property. 
Man inspecting and looking at a tablet

Sprinkler System Inspections, Testing, and Maintenance Frequencies Explained

NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems provides the criteria for the routine activities that must be conducted to ensure that water-based fire protection systems, such as automatic sprinklers systems, can be relied upon in the event of a fire. These activities range from simple visual confirmation of some things such as valve position or room or water tank temperature on a more frequent basis to much more complex activities such as full flow tests and internal assessments at longer intervals. Not only does NFPA 25 specify the activities that must be performed, but it also specifies the frequency at which they need to happen. The frequency can describe both the minimum and maximum time between events. These are given in terms of daily, weekly, monthly, quarterly, semiannual, annual, three years, and five years. But what exactly do each of those terms mean and what kind of flexibility is built into those frequencies to allow for different circumstances? The answer to this is of tremendous value whether you are the building owner or facility manager trying to determine how your systems can comply or if you are an ITM service provider communicating with customers about the criteria for compliance. The following table identifies how the frequencies are defined in NFPA 25. As can be seen in looking at these definitions, there is some flexibility given in different ways. The more frequent activities need to happen within the calendar day, week, or month respectively and do not always need to be done at the same exact time in the given interval. The longer duration frequencies start to give more flexibility but also introduce the concept of minimum times that must elapse between the activity being performed in addition to specifying the maximum amount of time that can elapse. For example, inspection and/or testing could occur on December 31st and again on January 1st. For monthly frequency activities this would be acceptable, but it would not satisfy separate inspections or tests for those activities with longer durations including those with an annual frequency because that is based on elapsed time with minimum and maximum criteria rather than just on the calendar year. We’ll look to cover ITM requirements in more depth and get into some specific activities and frequencies in the future. What pain points do you see around following the frequency requirements or explaining them to different stakeholders? What would you like to see us cover in greater detail? Let us know in the comments! Important Notice: Any opinion expressed in this blog is the personal opinion of the author and does not necessarily represent the official position of NFPA or its Technical Committees. In addition, this piece is neither intended, nor should it be relied upon, to provide professional consultation or services.
A building

Fire Sprinkler Considerations for Podium Construction

Podium, or pedestal, construction is a popular construction method that typically includes multiple stories of light wood framing over a single- or multiple-story podium of another, more fire-resistant, construction style which will often include retail or commercial space as well as parking levels. Often this is seen as Type V construction over Type I construction. This approach is used across the country and is most often utilized where the upper stories are residential occupancies. While there are certainly a number of fire protection and life safety issues to be addressed in these building types, for the purpose of this discussion we’ll focus specifically on the application of sprinkler protection for this construction type and particularly around where the use of NFPA 13R, Standard for the Installation of Sprinkler Systems in Low-Rise Residential Occupancies, is permitted in lieu of NFPA 13, Standard for the Installation of Sprinkler Systems.  What’s the difference between NFPA 13 and 13R? Assuming sprinkler protection is required; which for most buildings constructed in this manner building size, height, and occupancy will typically require it; a key decision point is determining if NFPA 13 is needed or if NFPA 13R can be used. The primary philosophical difference between the two is that NFPA 13 has a dual purpose of property protection and life safety while NFPA 13R has the purpose of providing life safety. The video below explains some of this difference.     While the difference might seem subtle there can be a great deal of savings based on the allowances of NFPA 13R. A major perceived benefit in using 13R can be the omission of sprinklers in areas that NFPA 13 requires sprinklers including small closets, concealed spaces, and attic spaces. These attic sprinklers are where a lot of complexity can come in since they will often require a dry system, or at least some other form of freeze protection, resulting in increased up-front costs and more long-term testing and maintenance considerations. NFPA 13R systems can also result in decreased water demands and therefore result in smaller pipe diameters. A very good analysis of the differences between NFPA 13, NFPA 13R, and NFPA 13D, Standard for the Installation of Sprinkler Systems in One- and Two-Family Dwellings and Manufactured Homes can be found here.  Where can NFPA 13R be used in podium construction? The podium portion of the building will need to be protected by an NFPA 13 sprinkler system. Where 3-hour separation is provided at the top of the podium as required by building codes, the upper residential portion can then be evaluated as whether it is within the scope of NFPA 13R. This includes residential occupancies that are up to and including 4 stories in height and located in buildings not exceeding 60 ft (18 m) in height above grade. If it falls within this criteria, then NFPA 13R can be utilized for the protection. While the maximum building height above grade is fixed based on the definition of height above grade, the stories themselves can be counted from the 3-hour horizontal separation. The figure below demonstrates the differences in this criteria. It is important to note that the 2021 edition of the International Building Code limits the allowance of NFPA 13R where the limitation is four stories above grade plane. This is a significant change that impacts the application of the standard. A more in-depth analysis on this can be found here.  Still a design decision Even if 13R is permitted, nothing would prohibit the use of NFPA 13 to provide added property protection required by that standard. In fact, there are building code trade-offs that can only be used with NFPA 13 systems; and the ability to take advantage of those is not available when NFPA 13R is used. Even where that is not the case, there are cost benefits but it is important to understand the goals of NFPA 13R. While a fire in a living space should be controlled as it would be with a NFPA 13 system, a fire originating in a concealed space or in an unsprinklered attic can result in the loss of the building. If all occupants are able to safely evacuate, the system has done its job even if the building is a complete loss, whereas an NFPA 13 system should be able to protect the occupants and provide property protection.

Hazardous Materials Identification

There are boundless amounts of hazardous materials that present increased risks to people exposed to them, whether building occupants, people in nearby structures, or first responders. These materials vary greatly in their composition and physical states. The risks, or hazards, associated with these materials are even more varied and must be assessed for a particular material in the state and manner in which it will be stored or handled. With such a wide range of materials and hazards there is also great diversity in construction requirements, fire protection systems, handling and operations, and response tactics associated with these materials. Here we will focus on the system of markings that provides a general idea of how hazardous materials need to be identified. What is a Hazardous Material? Before discussing the specifics of hazardous materials identification, it can be beneficial to know what is considered a hazardous material. Hazardous materials are defined in NFPA codes and standards as chemicals or substances that are classified as a physical hazard or a health hazard. Physical hazard materials are those classified as an explosive, flammable cryogen, flammable gas, flammable solid, ignitible liquid, organic peroxide, oxidizer, oxidizing cryogen, pyrophoric, unstable (reactive), or water-reactive material. Health hazard materials are those classified as a toxic, highly toxic, or corrosive material. How do hazardous materials need to be identified? NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response, specifies the identification requirements for these materials. NFPA 704 applies when another Federal, state or local regulation or code requires its use. NFPA 704 does not specify when a container, tank or facility must be labeled rather it specifies how to label when another code, standard or an AHJ (Authority Having Jurisdiction, such as the local fire department) requires such labeling. The standard applies to industrial, commercial, and institutional facilities that manufacture, process, use, or store hazardous materials. It does not apply to transportation, use by the general public, and a few other specific uses. The purpose of the standard is to provide a simple, readily recognized, and easily understood system of markings that provides a general idea of the hazards of a material and the severity of the hazards as they relate to emergency response. The identification system specified in NFPA 704 is intended to enable first responders to easily decide whether to evacuate the area or to commence emergency control procedures and to also provide information to assist in selecting firefighting tactics and emergency procedures. The NFPA 704 hazard identification system is characterized by a diamond which is more precisely defined as a “square-on-point” shape. It identifies the degree of severity of the health, flammability, and instability hazards. Hazard severity is indicated by a numerical rating that ranges from zero (0) indicating a minimal hazard, to four (4) indicating a severe hazard. The hazards are arranged spatially such that health hazards are indicated in the nine o’clock position, flammability at the twelve o’clock position, and instability at the three o’clock position. The six o’clock position on the symbol represents special hazards and has a white background; it is not always filled. W Water reactivity (avoid the use of water) OX Oxidizer SA Simple asphyxiant (nitrogen, helium, neon, krypton, or xenon)   As an example, the following would be used for propane gas which has a moderate health hazard, a severe flammability hazard, is normally stable, and does not require any special labeling. Another example is for liquid oxygen which can present a serious health hazard under emergency conditions, is not flammable, is stable, and is an oxidizer.\       Where do signs need to be located? The placard is meant to provide quick hazard information for emergency responders. It should be visible in case of an emergency where the responders are likely to enter. If there are numerous areas where the responders could enter the facility, there should be numerous placards. The placement and quantity should be decided using a facility’s best judgment coupled with the advice from your AHJ. At a minimum the placard should be posted on the two exterior walls of a facility or building, each access to a room or area, or each principal means of access to an exterior storage area. Other Considerations As mentioned at the start of this discussion there are many additional considerations regarding hazardous materials. Even within this topic of identification there is a lot more to it than what has been simplified in this blog. Check out this collection of NFPA 704 frequently asked questions for more information. Beyond that there are construction, maximum allowable quantities, fire protection system, and worker exposure requirements just to name a few. Additionally, each of these will vary based on the nature of the material(s) being stored or used. If you want more detail on identification or any of the other topics around hazardous materials, let us know in the comments.
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