One of the most often-asked questions I receive is “Where in the National Fire Alarm and Signaling Systems Code will I find the section that states the entire existing fire alarm system must be upgraded when the fire alarm control unit (FACU) is replaced?”
First, NFPA 72 is an installation standard and does not contain such a requirement.
However, many jurisdictions will want the total system upgrade for several reasons, including getting more reliable equipment (new) installed, or maybe wanting additional coverage for detection and notification appliances. Nine times out of ten, the existing system is noncompliant with current code requirements. It is a good bet that the existing notification appliances design does not meet the code requirements. If the system is 10–15 years old, it’s another good bet that the smoke detection devices and the software controlling them are not compatible with the new FACU, and it’s questionable whether they will work with that FACU as required. If you have nothing in writing from the new FACU’s manufacturer regarding compatibility of the existing smoke detection devices, you are on thin ice from a liability point of view.
One other caution: If you decide to replace the existing system, do not sell a one-for-one replacement of all existing devices and notification appliances. If the original design did not meet the code, then it stands to reason that it will still not meet the code when you install new equipment in the same locations. The authority having jurisdiction (AHJ) approving the original installation is not a reason to do a one-for-one replacement.
If NFPA 72 does not contain guidance or requirements that apply to this issue, where do you look for help? A good start is the International Fire Code (IFC).
Let’s look at some of the 2018 IFC sections that you can use as guidance and for discussions with your customer.
Relative to the compatibility question raised above, Section 104.7.1 states that “Materials, equipment and devices shall not be reused or reinstalled unless such elements have been reconditioned, tested and placed in good and proper working condition and approved.”
In the context of all codes and standards, when the word “approved” is used, it means approved by the AHJ, or in the case of the IFC, by the fire code official.
NFPA 72-2019 Section 22.214.171.124.2 requires that the compatible software or firmware versions be documented at the initial acceptance test and at any reacceptance tests. In addition, the Annex statement for this section states that “Compatibility between systems will be documented in one or the other (or both) of the manufacturer’s installation documents for the compatible products and controlled by the listings agencies.”
If you plan to make any changes or repairs to the fire alarm system, Section 105.1.5 of the 2018 IFC requires you to notify the fire official for any “repairs [which] include addition to, alteration of, replacement or relocation … [of a] fire alarm system or other work affecting fire protection or life safety.”
The IFC also requires in Section 901.4 that all fire protection systems be maintained in accordance with the original installation standards for the system. Additionally, the IFC requires that in any building where alteration or remodeling takes place, all required systems must be extended, altered or augmented as necessary to maintain and continue protection where the building is altered or remodeled. All codes, including the IFC, require that any alterations to any existing fire protection system is done in accordance with applicable standards as referenced by that code and as adopted by the jurisdiction.
Many fire alarm system manufacturers try to ensure that their systems are forward- and backward-compatible, so all existing field devices are 100% compatible with their new FACUs. Even if you are given this assurance, you are still required to 100% test the operation of all devices after you have installed and upgraded the system. This includes all addressable relays and control modules that are connected. You should understand that once you have altered the fire alarm system, you “own it” from a liability perspective and the owner also assumes that, as altered, their entire system is now code-compliant and 100% operational.
The bottom line is that even if you only change the FACU, you now “own,” or will be liable for, the whole fire alarm system and you automatically vouch for its code compliance and operational effectiveness. Be aware of these issues and communicate with the AHJ before making changes to the fire alarm system.