As a fire protection engineer who oversees the proposals to repair fire alarm systems, I often experience communication disconnects between the contractor, owner and authority having jurisdiction (AHJ). These disconnects manifest in the extent of changes each stakeholder requires. Many AHJs require a great deal of work—not originally in the bid—because, as a contractor, you either upgraded the system control panel or replaced a large number of devices during the repair.
Consider the following scenario. In a renovation, the AHJ has approved specific plans to add notification appliances on the floor or area being renovated, and the contractor finds that he or she must replace the fire alarm control unit. The contractor does the right thing and replaces the control under what they would deem a necessary repair. But, it was not originally part of the approved work described in the renovation.
And that’s where the trouble begins. The AHJ arrives, finds the change and states, “Now that you have changed the control unit, you must upgrade the entire system.” Not something you want to hear just before trying to occupy the renovated space.
So is the AHJ right? It depends. I can definitively state that NFPA 72 2013, National Fire Alarm and Signaling Code, does not address the issue. The building code and fire code in your jurisdiction may shed some light on it, so let’s review what they say about the differences between renovations (alterations) and repairs.
The 2012 International Building Code (IBC) states the following in Section 3403.1 about additions and alterations to a building: “Additions to any building or structure shall comply with the requirements of this code for new construction. Alterations to the existing building or structure shall be made to ensure that the existing building or structure together with the addition are no less conforming with the provisions of this code than the existing building or structure was prior to the addition.”
Based on this IBC excerpt, take note that, when renovating a space, the entire refinished space must be code-compliant. Thus, the fire alarm system that serves the entire renovated space must meet the requirements of NFPA 72 2013.
Similarly, when we review the IBC requirements for repairs in Section 3405.1, we also get some valuable help: “Work on non-damaged components that is necessary for the required repair of damaged components shall be considered part of the repair and shall not be subject to the requirements for alterations in this chapter.” The section goes on to say that routine maintenance, ordinary repairs exempt from requiring a permit, and “abatement of wear due to normal service conditions shall not be subject to the requirements for repairs in this section.”
Mark these sections in the IBC in case a discussion arises on what constitutes a repair or a full renovation.
For existing buildings, the AHJ may require compliance with the 2012 International Fire Code (IFC). The IFC 2012 essentially provides similar guidance in Section 102.4: “Any alterations, additions, changes in use or changes in structures required by this code, which are within the scope of the International Building Code, shall be made in accordance therewith.”
However, the IFC 2012 states in Section 907.5.2.3 Exception No. 1 that, “Visible alarm notification appliances are not required in alterations, except where an existing fire alarm system is upgraded or replaced, or a new fire alarm system is installed.” Unfortunately, this section leaves room for interpretation with regard to the issues presented at the beginning of this article. The AHJ could interpret the replacement of the fire alarm control unit as either an upgrade or replacement. Either way, the AHJ may require upgrading the visible notification appliances throughout the building.
The IFC 2012 clearly states in Section 1103.1 that it does not permit “the elimination of fire protection systems or a reduction in the level of fire safety provided in buildings constructed in accordance with previously adopted codes.” And, as long as the AHJ had approved the fire alarm system originally installed in the building at the time of the installation, AHJ had approved the fire alarm system originally installed in the building, the AHJ will normally not require you to replace it or upgrade the components. However, the AHJ may require replacement when the equipment has become obsolete and you can no longer maintain it. Then, failure to upgrade the fire alarm system will affect occupant safety.
In one final example, the unintended consequence of failing to protect smoke detectors during renovation necessitated replacing them because they were too dirty to leave in place. The contractor unsnapped the detector from the base and inserted a replacement, making no wiring changes. However, the AHJ claimed that, by replacing such a large number of devices, the contractor must replace the entire fire alarm system. To bring sanity to this situation, I asked the AHJ, if he happened to replace a similar number of lamps in his house for efficiency reason, would he then replace the electrical service and fixtures. He answered, “No,” and saw the point.
Contractors need to understand whether their work meets the criteria for a “repair” or “renovation.” Understanding all of the codes that apply will keep you from losing valuable profits.