NFPA Journal

With the promotion of NFPA 3, Commissioning of Fire Protection and Life Safety Systems, from a recommended practice to a standard, there has been renewed discussion on the need to “recommission” fire protection systems, specifically sprinkler systems.

There is an assumption that, since NFPA 25, Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, requires an annual inspection of the sprinkler system, recommissioning the system would be unnecessary. While this would seem to be true—that getting a “green tag” or passing NFPA 25 inspection would provide some level of assurance that the system is in good working order—it’s not quite the same as recommissioning the system.

To understand the nuances that differentiate a recommissioning event from an NFPA 25 “clean bill of health,” you need to look at the scope of the activities. The focus of NFPA 25 is for an inspection to consider the operating condition of the system, including a review of all of the components and subsystems that support the sprinkler system to make sure they are in good working order. This includes checking devices to make sure they do not display potentially inhibiting levels of rust, corrosion, paint, or other type of loading. It also requires a review of systems status to make sure valves are in the appropriate position and are being exercised as required to make sure they will work in the event of a fire.

The scope of this inspection does not include a review of the original system design to confirm that it is still appropriate for the hazards present—an individual hired to perform an NFPA 25 inspection is not there to confirm design concepts such as sprinkler spacing or hazard classification, or to check that the right k-factor sprinkler has been selected based on the system demand. All of these items fall under the heading of a “system evaluation,” which is considered outside the scope of an NFPA 25 inspection. NFPA 25 does, however, require building owners or their designated representatives (commonly facility or property managers) to make sure that changes in the buildings do not create situations where the systems in place are no longer effective in protecting the present hazards.

NFPA 25 stops short of providing owners with a program or explicit direction on how they are expected to carry out this requirement. Owners well versed in the world of ITM and change management may have processes and procedures that trigger compliance and safety reviews when certain changes are made to their buildings. Other owners make necessary operational changes, like repartitioning buildings or adding new shelf storage in warehouses, without understanding the potential impact those changes could have on the relationship between their systems and the goods contained in the buildings.

NFPA 3 is structured to assist these owners in providing a framework to ensure that they are not carrying unnecessary liability based on poor change management. NFPA 3 covers the topic of recommissioning as a mechanism to conduct a design evaluation with the result of providing the liability protection owners are looking for. A recommissioning event would likely include a review of the original design, a review of changes made to the building and building operations, and a building survey, all activities that would be considered outside the scope of NFPA 25.

While there is a pervasive argument that these two standards compete with one another and that overlap exists in their scope, in fact these two documents complement each other. Each standard outlines a different breadth and depth of their stated activities, which drives the different costs of the services needed to execute them. Many owners assume that, when their ITM inspection is performed they are also getting confirmation that the design is still adequate—but that assumption is incorrect. For a more accurate and more complete picture, owners should consider periodic recommissioning in accordance with NFPA 3 to supplement their current ITM programs.

MATT KLAUS is NFPA technical services lead for fire protection engineering.