We all know that fire alarm systems that are tested and maintained on a regular basis are more reliable. According to NFPA 72, National Fire Alarm and Signaling Code, the owner is responsible for inspections, testing and maintenance as well as any alterations or additions to the fire alarm system.
However, as of 2013, a new paragraph (220.127.116.11) now states that, if the owner is not the occupant, they can delegate the responsibility “to the occupant, management firm, or managing individual through specific provisions in the lease, written use agreement, or management contract.” It is important to have a written statement indicating who will be the responsible party. Just because the owner or occupant is responsible, depending on state laws, they may or may not be able to perform any of the work on their fire alarm system. Even if they can, is that a good idea?
NFPA 72, 10.5.3, states that inspection personnel must be qualified. This section was rewritten in 2013 and is now expanded into inspector qualifications, testing personnel qualifications and service personnel qualifications. Not only that, but the code is more definitive on the topic by stating these people must be qualified and experienced in the inspection, testing and maintenance of systems addressed within the scope of this code. In the past, the code was silent about who could test interfaced equipment. Now it is clearer that the requirements in Chapter 14 of NFPA 72 only apply to fire alarm or emergency communications equipment. In A.18.104.22.168, NFPA 72 states, “NFPA 72 does not require testing of an emergency control function, such as elevator recall, but does require testing of the emergency control function interface device, such as the relay powered by the fire alarm or signaling system.” It also adds, “Testing of the emergency control functions themselves is outside of the scope of NFPA 72.”
NFPA 72, A.14.2.10 states, “The boundary of the fire alarm or signaling system extends up to and includes the emergency control function interface device.”
So, what does this mean? NFPA 72 does not specifically state who has to test equipment. The intent has always been that whoever is doing the testing must be qualified. So, for many fire alarm systems, multiple contractors will be involved in the testing. The downside is that integrated equipment may not be tested at the same time. For example, fire alarm service personnel may test a circuit up to a waterflow switch but not actually flow the water. That is acceptable based on the above information. Ideally, the sprinkler service personnel will be there to run water at the same time, but that may not always be the case. The same principle would apply to air handler systems, dampers and elevators.
This is because testing of the integrated systems is covered in NFPA 3, Recommended Practice for Commissioning and Integrated Testing of Fire Protection and Life Safety Equipment. This fall, those requirements will be in NFPA 4, a new standard that will cover the testing of integrated systems, while NFPA 3 will remain a recommended practice and focus on commissioning. Keep in mind that NFPA 4 will still have to be adopted by a jurisdiction before it becomes required. NFPA 3 addresses this position, stating, “Even though the fire alarm or signaling system initiating device might activate the smoke control system, the actual testing of the dampers and fan operation would be as required by the smoke control design and not part of the fire alarm or signaling system.”
Let’s go back to that owner who is responsible for testing fire protection equipment. In most cases, the owner will have no idea that multiple contractors will be needed to test their individual equipment, so, in many cases, it is very likely equipment, or the interface between equipment, will not be tested properly or at all. It is our responsibility as industry professionals to educate the owners, as well as the authorities having jurisdiction, to ensure they understand the consequences of improper, or a lack of, testing.
As a fire alarm contractor, ensure you clearly indicate in your inspection and testing contracts what exactly you are and are not going to be testing.
Even though the code states the owner or occupant is responsible, we industry professionals will be held accountable, or at least partly accountable, if systems fail due to a lack of testing and there is a fire incident. The legal system will argue that, as professionals, it is our responsibility to inform the owners of these requirements.