Slide 1 NFPA 25 The Owner s Manual Roles & Responsibilities Presented by: Bob Caputo Slide 2 Instructor Bob is the Executive Vice President of Compliance Solutions with Telgian Corporation. He is the Chairman of the NFPA 16 technical committee and a member of multiple NFPA committees including NFPA 13, NFPA 3 & 4 and NFPA 25. Bob is a contributor of the NFPA 13, and NFPA 25 handbooks and the NFPA Inspection Manual. A senior member NFPA and AFSA faculties, Bob has written and presented seminars throughout the world on fire protection and life safety systems. He is a regular speaker at NFPA and AFSA s annual conventions and is the author of AFSA s Project Management Tools program. He was named San Diego County Fire Prevention Officer of the Year in 1994 and Fire Protection Contractor Magazine s Person of the Year in 1997. Bob attended the University of Albuquerque, NM and is a US Navy veteran. 2 Slide 3 DISCLAIMER This seminar and its content is not a formal interpretation issued pursuant to NFPA regulations. Any opinion expressed is the personal opinion of the author and presenter and does not necessarily present the official position of the NFPA and its Technical Committees. 3
Slide 4 NFPA 25 Structure Scope, Application and General (Ch 1,2,4) Definitions (Ch 3) Individual System Chapters (Ch 5-12) Valves (Ch 13) Internal Conditions (Ch 14) Impairments (Ch 15) Extracts (Ch 16) 4 Slide 5 Document Scope NFPA 25 establishes the minimum requirements for the periodic inspection, testing, and maintenance of waterbased fire protection systems and the actions to undertake when changes in occupancy, use, process, materials, hazard, or water supply that potentially impact the performance of the water-based system are planned or identified. 5 Slide 6 What is the scope of NFPA 25? Wear and tear driven Inspections are not design evaluations Not a re-commissioning event Management of change is owner driven Impact of permitting process 6
Slide 7 Common Phrases Installed in accordance with generally accepted practice Adequacy of design Assumed to have complied at the time of construction/ modification 1.1.3, 1.1.3.1, & A.4.1.6 7 Slide 8 Wear and Tear vs Design Slide 9 Design Evaluation
Slide 10 Re-Commissioning 10 Slide 11 Management of Change 4.1.6 & 4.1.7 11 Slide 12 Is permitting the answer? 12
Slide 13 Systems Covered 1.1.2 1.1.2 13 Slide 14 NFPA 72 1.1.1 & 1.1.1.1 14 Slide 15 NFPA 13D 1.1.5 15
Slide 16 Board and Care Exception 16.2 16 Slide 17 NFPA 25 Purpose 17 Slide 18 4.1.1.2 Competence NFPA 25 does not cite specific credentials Competent to AHJ Understanding of tasks and system components Check local/state requirements 18
Slide 19 Who is qualified? 3.3.34 Qualified. A competent and capable person or company that has met the requirements and training for a given field acceptable to the AHJ. 19 Slide 20 Roles and Responsibilities Slide 21 Who is involved? The owner The owner s designated representative Tenant Property manager or management firm Inspector/contractor AHJ - fire department personnel Municipal department (water, health, transportation...etc) Insurance Manufacturers 21
Slide 22 Responsibilities Owner Design evaluation Management of change Building conditions Access Tag systems Corrective action Inspector/Contractor Fulfill contractual obligation Conduct tests and inspections Tag systems Corrective action 22 Slide 23 Responsibility of Property Owner 23 Slide 24 Designated Representative Contractual agreement with owner Assumes owner s responsibilities Part or entire ITM program 24
Slide 25 Owner or Designated Representative Overall ITM execution Access to systems/components Freeze protection Notification to AHJ or supervisory agent Corrections repairs Changes in occupancy, use, process, or materials Recalled products Design evaluations Maintain records 25 Slide 26 Owner or Designated Rep Overall ITM Execution 26 Slide 27 Owner or Designated Rep Access 4.1.3 27
Slide 28 Slide 29 Owner or Designated Rep Freeze Protection 4.1.2 29 Slide 30 Owner or Designated Rep Notification to AHJ or Supervisory Agent 4.1.4 30
Slide 31 Owner or Designated Rep Corrections and Repairs 4.1.5 31 Slide 32 Owner or Designated Rep Changes in Occupancy, Use, Process, or Materials 4.1. 6 32 Slide 33 Owner or Designated Rep Recalled Products A.4.1.5 33
Slide 34 Owner or Designated Rep Design Evaluations Slide 35 Owner or Designated Rep Record Retention 4.3 & 4.3.5 4.3 & 4.3.5 35 Slide 36 Records Management 4.3.1.1* Records shall be permitted to be stored and accessed electronically. 36
Slide 37 Shared ITM Responsibilities A.4.1.1 Any portion or all of the inspection, testing, and maintenance can be permitted to be contracted with an inspection, testing, and maintenance service. 37 Slide 38 Owner vs. Inspector Inspecting valve positions Gauge readings Maintaining clearances Main drain test Fire pump flow test Trip testing 38 Slide 39 Inspector Get qualified Execute your contractual obligations Understand the scope of NFPA 25 Identify field issues Communicate with the owner Understand safety protocol 39
Slide 40 Inspector Execute Contract with Owner 4.1.1.3 40 Slide 41 Inspector Understand Scope of NFPA 25 ITM Work Inspections from the floor Not a design evaluation Not looking at concealed spaces Wear and tear Contract can go above and beyond NFPA 25 41 Slide 42 Inspector Get Qualified
Slide 43 Inspector Identify Deficiencies and Impairments Slide 44 Inspector Communicate Issues to Owner 44 Slide 45 Inspector Safety Equipment 4.9 & 5.2.1.1.5 45
Slide 46 AHJ Fire Department Approve personnel conducting ITM tasks Approve alternate ITM frequencies/ approaches Request records as necessary Approve impairment plans System tagging 46 Slide 47 AHJ Approve Personnel Conducting ITM Tasks 47 Slide 48 AHJ Approve Alternate ITM Frequencies or Approaches 4.7 48
Slide 49 AHJ Request Records 49 Slide 50 AHJ System Impairment Chapter 15 50 Slide 51 AHJ System Tagging 15.3 51
Slide 52 Other AHJs Water purveyor Transportation agency (road and transit tunnels) Building department Health and safety agencies Insurance representative 52 Slide 53 Insurance Representative Considered an AHJ by definition Use NFPA 25 for assessing risk Many municipalities have no AHJ Fills the role of the fire department 53 Slide 54 ITM vs. Design Evaluation NFPA 25 scope Based on roles and responsibilities Liability Contractual obligation Good fire protection 54
Slide 55 Ask Yourself the Questions Is this in the scope of NFPA 25? Is it broken or was it designed incorrectly? What is my role? What are my responsibilities? What am I looking at? Is it something that I am responsible for? 55 Slide 56 Slide 57 57
Slide 58 Slide 59 59 Slide 60
Slide 61 5.2.1.4 & 5.2.1.5 61 Slide 62 When Should Design Evaluations Occur? Change in hazard, use, occupancy Change is building layout Change in goods stored or storage arrangement Modifications to heating systems that impact water-based systems 62 Slide 63 How do I conduct a design/hazard evaluation? No mandated approach Annex E of 2014 Edition (Annex F in 2011) Retro-commissioning or recommissioning per NFPA 3 63
Slide 64 Addressing Changes in Hazard A.4.1.7 See Annex E for an example of a hazard evaluation form. A hazard evaluation is not part of a system inspection. Annex E Approval of corrections by AHJ 64 Slide 65 Annex E Hazard Evaluation Form Associated with owner s responsibilities for changes of hazard Changes in building occupancy, use or process, or material used or stored create the need for evaluation of the installed fire protection systems. This form is intended to identify and evaluate such changes and should be completed only by an individual properly qualified in the area of system design. 65 Slide 66
Slide 67 Identifying Design Issues as Part of ITM Inspection Understand contractual obligation Understand your liability Discuss the depth/breadth of scope of work 67 Slide 68 Identifying Design Issues as Part of ITM Inspection Good fire protection Side B of inspection form Separate good Samaritan report Ethics rule for licensure Legal disclaimer 68 Slide 69 Deficiencies and Impairments Chapter 3 definitions Annex Table A.3.3.7 Subjectivity Will the system/ component function? Tagging A.3.3.7 69
Slide 70 Tagging Not specifically addressed in NFPA 25 Jurisdictional requirements vary Method for tracking deficiencies AHJ s enforcement of existing system 15.3 70 Slide 71 Impairment 3.3.21* Impairment. A condition where a fire protection system or unit or portion thereof is out of order, and the condition can result in the fire protection system or unit not functioning in a fire event. 71 Slide 72 Deficiency 3.3.7* Deficiency. For the purposes of inspection, testing, and maintenance of water-based fire protection systems, a condition which will or has the potential to adversely impact the performance of a system or portion thereof, but does not rise to the level of an impairment. 72
Slide 73 Critical vs. Non-Critical 3.3.7.1 Critical Deficiency. A deficiency that, if not corrected, can have material effect on the ability of the fire protection system or unit to function as intended in a fire event. 3.3.7.2 Noncritical Deficiency. A deficiency that does not have a material effect on the ability of the fire protection system or unit to function in a fire event, but correction is needed to meet the requirements of this standard or for the proper inspection, testing, and maintenance of the system or unit. 73 Slide 74 74 Slide 75 75
Slide 76 76 Slide 77 77 Slide 78 CONCLUSION Questions & Answers 78