Update on Commissioning: The Latest on NFPA 3

I have written a couple of articles about NFPA 4, Standard for Integrated Fire Protection and Life Safety System Testing, in the past. The last one in December was about getting it referenced in the model codes to make its adoption more feasible and increase its use by enforcement agencies.

This is an update on NFPA 3. In the 2018 edition, this document was changed from a Recommended Practice to the Standard for Commissioning of Fire Protection and Life Safety Systems. In my opinion, this is significant because commissioning, individual system testing and integrated system testing is conducted many different ways; some better than others. This is usually dependent on the quality of the installer (we all know the low bidder is not necessarily the most qualified) and the quality of the authority having jurisdiction (AHJ). We know, due to budget restraints, AHJs don’t always get the training they need. This standard provides requirements for commissioning all of the fire protection and life safety systems in the building, including passive fire protection features such as fire ratings and extinguishers. Used in conjunction with NFPA 4, this verifies all of the systems work properly together, and there is a paper trail to verify that everything was completed.

The opening language in NFPA 3 states this document outlines “a systematic approach to provide documentation confirmation that fire protection and life safety systems function as intended by the owner and the design team.” It also tells us that this document came about at the request of the National Institute of Building Sciences (NIBS) to be part of a package of commissioning documents for the entire building.

A significant change in language was made during this last cycle to use enforceable language for requirements and moving unenforceable language and recommendations to the annex. This document includes requirements for both new and existing facilities. The next step will be to get NFPA 3 recognized in the model codes to make it enforceable. Even then, it is important to remember that this is essentially a user’s document to help ensure the owner gets what they paid for, that everything was installed per the design requirements and everything meets code. Other than documenting that individual system tests were conducted, they are not part of the requirements for integrated testing or commissioning.

Until requirements are adopted, commissioning remains an option for the owner. The intent is to perform the initial commissioning for new construction. NFPA 3 also contains language for recommissioning for existing fire protection and life safety systems that were previously commissioned to verify everything still meets the owner’s project requirements and basis of design. You will see that abbreviations are very commonly used in NFPA 3. At the insistence of some committee members, both the acronyms and full wording are provided when first used. Retrocommissioning also is defined and used for existing fire protection and life safety systems that were not previously commissioned. This document defines both commissioning agent (CxA) and fire commissioning agent (FCxA). It is possible it could be the same person or entity for both, or they could be separate.

With only six pages of requirements, NFPA 3 is not a lengthy document. As in all NFPA documents, chapters 1, 2 and 3 are the same (Administration, Referenced Publications and Definitions). Chapter 4 is the general requirements, Chapter 5 is on commissioning requirements, and Chapter 6 is on commission of existing systems.

Annex A provides recommendations and explains the requirements of the standard. There is a very detailed list of both active and passive fire protection and life safety systems that should be included in the commissioning process in A.1.3.3. It is worth reviewing. Other annexes include Annex B on qualifications, Annex C on responsibilities, Annex D on a sample basis of design narrative report, and Annex E provides sample forms such as Sequence of Operation Test Form, a Basis of Design form, Equipment Scope and Responsible Parties form, a Project Schedule form, among many others that are useful for the commissioning process. This provides a lot of useful information.

Overall, it is my belief that having NFPA 3 for commissioning and NFPA 4 for integrated system testing will improve the quality of fire protection and life safety systems. There are some who feel these are not necessary and this will only drive up the cost of construction. As systems get more complex and integrated, it is important to make sure these systems are tested and documented by qualified entities for proper operation. It may cost owners a little more today, but I believe it will save them money over the life of the system.

About the Author
Tom Hammerberg

Thomas P. Hammerberg

Life Safety Columnist

Thomas P. Hammerberg, SET, CFPS is president of Hammerberg & Associates Inc. Retired from the Automatic Fire Alarm Association (AFAA) after 23 years, he represents the AFAA on the NFPA 72 Technical Correlating Committee and Protected Premises...

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