NFPA 3: Commissioning fire protection systems
NFPA 3, Recommended Practice on Commissioning and Integrated Testing of Fire Protection and Life Safety Systems, is nearly complete after moving through the review process.
By Thomas C. Brown, PE, Rolf Jensen and Assocs. Inc., Baltimore
After years of anticipation and hard work, a new document, NFPA 3, Recommended Practice on Commissioning and Integrated Testing of Fire Protection and Life Safety Systems, has been presented for action at the NFPA Conference and Expo Technical Meeting in Boston on June 14-15, 2011.
The committee responsible for this document is aptly named “The Committee on Commissioning Fire Protection Systems.” The project that gave rise to the committee and its work was approved by the NFPA Standards Council in July 2007. The Standards Council recognized that there was no comprehensive commissioning standard for fire protection features similar to ASHRAE Guideline 1, The HVAC Commissioning Process. The fact that U.S. General Services Administration, NIBS (National Institute of Building Science), and the Building Commissioning Assn. (BCA) have pushed for a comprehensive commissioning process with technical detail shows that there has been a clear gap.
The committee’s scope was defined as having “…primary responsibility for documents that pertain to commissioning activities and tasks for fire and life safety systems. This includes the requirements for planning, organization, coordination, responsibility, implementation, and documentation of commissioning of active and passive systems and features that serve a fire or life safety purpose.”
The process to consensus
NFPA uses a consensus process in all of its standard development activities. Committees are balanced by interest group and include special experts, owners, contractors, insurers, authorities having jurisdiction (AHJ), and so on.
Anyone can make proposals for additions and/or modifications to an NFPA document, and anyone can submit comments on actions taken on a proposal. All proposals and comments are reviewed by the assigned technical committee. The technical committee must then act upon the proposals and comments, and the reasons for those actions are published.
If the technical committee approves a new document, it is forwarded to the NFPA membership for action. Only members of NFPA are permitted to vote on floor actions to adopt or reject new or revised documents.
Options for the appeal of the technical committee’s actions are available to potentially aggrieved parties throughout the process. These options are fully explained on the NFPA website at www.nfpa.org.
Challenges in the process
The first draft of the new NFPA 3 document, titled “Standard for the Commissioning and Integrated Testing of Fire Protection and Life Safety Systems,” was released for public review in spring 2009. As could be expected for any new document, the proposed standard generated a lot of discussion, debate, and controversy. Some of the more significant controversial topics are discussed below.
1. Whether the document should be a “standard” or a “recommended practice”: NFPA defines a standard as: “[a] document, the main text of which contains only mandatory provisions using the word ‘shall’ to indicate requirements, and which is in a form generally suitable for mandatory reference by another standard or code or for adoption in to law. Non-mandatory provisions shall be located in an appendix or annex, footnote, or fine print note and are not to be considered a part of the requirements of a standard.”
NFPA defines a recommended practice as: “[a] document similar in content and structure to code or standard but that contains only non-mandatory provisions using the word ‘should’ to indicate recommendations in the body of the text.”
The technical committee saw much debate over this issue before the first draft was released. Ultimately, it reached consensus to title the document a standard.
The debate was reignited by comments on the draft standard. AHJs were looking for a document that could be readily incorporated into law, which would make system commissioning and integrated systems testing mandatory. Others expressed concern that the document was too new to recognize as a standard; they felt a few years as a recommended practice would allow the opportunity to identify and correct any problems recognized during implementation of the new document.
In April 2010, the committee took action to proceed with releasing a revised document incorporating accepted comments and including “recommended practice” in the title in place of “standard.”
In October 2010, the committee acted on another round of comments. A committee motion also was passed to petition the standards council at its regular meeting in March 2011 to consider splitting the document into two separate documents: a Recommended Practice for Commissioning, and a Standard for Integrated System Testing.
However, because the motion to petition the standards council to split the document was so late in the document processing cycle, it had no bearing on what is to be acted upon in June at the NFPA Conference and Expo. The standards council did review the proposal to split the new document into two separate documents for future cycles. After review and consideration, the council decided to solicit public comments on the need for two separate documents, and will review public comments and take additional action at its meeting in August 2011. Nevertheless, for now, the standard will remain one document.
2. Technical requirements: Another extensively debated issue involved which technical committee is responsible for developing the acceptance testing requirements for individual fire protection systems and/or features.
All of the individual fire protection system technical committees, e.g., NFPA 13, Automatic Sprinkler Systems; and NFPA 72, The National Fire Alarm and Signaling Code, have historically developed their own requirements for system acceptance testing, ongoing test requirements, and maintenance requirements.
While developing those technical requirements is not within the commissioning committee’s scope, developing standards related to documentation is.
Many of the fire protection system technical committees filed comments on the proposed commissioning standard, questioning whether the NFPA 3 technical committee was operating outside of its scope and trying to mandate requirements that fall under the authority of the existing individual system standards.
NFPA sponsored the Inspection, Testing, and Maintenance Summit in May 2010, in part to address the questions and concerns raised during the NFPA 3 approval process, and also to help define the role of the NFPA 3 technical committee in correlating the inspection, testing, and maintenance requirements into criteria for integrated system testing.
3. Integrated system testing: The concept of integrated system testing itself was debated at length. Fire protection systems typically are interconnected with other
building components to ensure that the building is in a safe condition during an emergency. The systems under consideration could include elevators, air handling equipment, security systems, architectural barriers, and so on.
According to the recommended practice stated in NFPA 3 Section 1.3.3, proposed 2012 edition, integrated testing should verify and document the following:
- Performance in accordance with applicable codes and standards
- Conformance with BOD (basis of design) and OPR (owner’s project requirements)
- Sequence of operation
- Installation in accordance with manufacturers’ published instructions
- Accuracy of diagrams of system interconnections and device location prior to final acceptance.
Most committee members accepted the fact that it is reasonable and appropriate to conduct integrated system testing during initial building acceptance. There was considerable debate about if, and how often, integrated system testing needs to be performed during the building’s lifecycle.
Service and maintenance contractors were concerned about being responsible for interconnected systems that were outside their scope of expertise and becoming their responsibility for maintenance. Questions such as, “What happens if something breaks?” are easy concerns to identify.
Owners and building users were concerned about the cost of regular integrated system testing. The test could require representatives from the fire alarm service, sprinkler service, fire pump service, elevator maintenance companies, and others. There is obviously a cost associated with assembling all of the appropriate technical personnel and the coordination of this group. The owner would also need someone (referred to in the standard as the “integrated testing agent”) familiar with the operation of the integrated systems to identify if they all worked properly during testing.
In addition to the cost, testing also presents significant potential for interruption to building occupants or tenants.
After much debate, the proposed document allows for the development of a specific NFPA-approved plan for ongoing integrated testing. If there is no approved plan, the default required period for testing is every five years.
The proposed document, NFPA 3, Recommended Practice on Commissioning and Integrated Testing of Fire Protection and Life Safety Systems, will be adopted without the need for a floor vote by the members of NFPA in June 2011. It is expected to be published as the 2012 edition unless a notice of intent to make a motion (NITMAM) is filed with NFPA in accordance with its timing rules.
If a NITMAM is filed, the merits of the motion will be debated on the floor of the NFPA technical membership meeting and the outcome determined. The final decision to issue the document rests with the NFPA standards council, which may choose to hear appeals filed following the action at the NFPA meeting in June.
Regardless of what happens, this document is a testament to the NFPA’s consensus standards process and a tribute to all who worked diligently to create it.
Brown is president of Rolf Jensen and Assocs. Inc. He has expertise in the design and commissioning of complex fire protection systems, and he sits on numerous NFPA committees including those responsible for NFPA 3, 13, and 72.