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Current or Former AHJ Input Requested - NFPA25 Inspection Failure Building Modifications

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jclarkjjc

Specifier/Regulator
May 23, 2013
6
I would appreciate any input regarding the thread discussion below regarding failure of NFPA25 inspections for recent building modifications on a building with an exisiting sprinkler system resulting in a new hazard and lack of fire sprinkler coverage.

Thank you.


jclarkjjc (Specifier/Regulator) 28 May 13 16:23

I agree with you lamuppet, original design is one thing, but when a customer modifies a building and creates a hazard while ignoring the requirements of NFPA 4.1.6 - 4.1.6.1 I believe the system cannot be passed with a life/safety hazard, legal/insurance liability and code violation present.

If the customer can provide documentation of the building modification and FDP approval of the system coverage (or lack thereof) then it is a non-issue and the inspection passes with a recommendation of coverage. If the customer is willfully violating the requirements of NFPA25 chapter 4 then I believe it would be a failure.


lamuppet (Mechanical) 28 May 13 15:15

An NFPA 25 inspection is one thing, but a sprinkler system still have to be in accordance with NFPA 13.

In exemple if a duct is newly installed, and the sprinkler system isn't correct in accordance with NFPA 13 2010 - 8.5.5.3.1, (Obstruction that prevent sprinker discharge from reaching the hazard), the deficiency shall be put in the report and a new sprinkler shall be install under the duct. Or if a wall is taken down, and there's 2 sprinkler now spaced less then 6ft, then it's not in accordance with NFPA 13 2010 - 8.6.3.4.1. (Minimum distance between sprinklers) and, then, this shall be arranged, to make sure that the sprinklers are not spaced with less then 6 ft. Those are important stuff! It's up to you to judge....

In your inspection report, you can put NPFA 13 articles. That's what I do....

My two cents...


jclarkjjc (Specifier/Regulator) 28 May 13 14:14

The approach that the inspection is based on the assumption that the system was installed as designed and approved is understandable; but my question is that if the inspector has knowledge that the building has been modified since the installation of the system by the customer and that a hazard has been created, for example the addition of walls to create office spaces without coverage or the addition of a loading dock canopy without coverage that has combustible material below it is that a failure item if it does not have approval?

Under NFPA25 4.1.6 - 4.1.6.1 if building modifications or other conditions that affects the installation criteria of the system are identified, it is the responsibility of the owner to contact a C.16 licensed contractor, (California) State Fire Marshal or California Board of Professional Engineers to evaluate the adequacy of the installed system. Where the evaluation reveals a deficiency causing a threat to life or property, the owner SHALL make appropriate corrections.

If the owner has modified the building and created a hazard, and has not obtained approval for the modification and creation of the hazard, how can an inspector pass the system if there is knowledge that the owner is violating the requirements of NFPA 4.1.6 - 4.1.6.1?


lamuppet (Mechanical) 25 May 13 15:41


There's the link!!


fireguy519345 (Structural) 24 May 13 11:36

In the Jan/Feb 2013 issue of the NFPA Journal is an article dealing with that subject.


jclarkjjc (Specifier/Regulator) 23 May 13 18:40

Thanks, I'll look up the article. I understand that NFPA25 is not for NFPA13 design installation interpretation but the concern is that this is a new hazard created by the customer that has altered the coverage of the system and given the obvious safety issue in addition to the legal/insurance liabilities it presents to the customer (and to the inspecting firm) how can the system be certified? Both from a professional and moral standpoint...


Sdpaddler50 (Mechanical) 23 May 13 18:26

This was covered in an article in NFPA in the past few months. If i remember correctly, the NFPA engineer essentially said 25 is an ITM document only. IE, making recommendations in regards to sprinkler system design/deficiencies is technically beyond the scope of a 25 based inspection. You may want to google it, and see if you can find it on line. Personally, i think you should note these items in your report perhaps as supplementary commentary because thesee are important things your client should know. I have a feeling others are going to dispute this, and i dont blame them, but that was my general understanding from the article that came from the horse mouth.


jclarkjjc (Specifier/Regulator) 23 May 13 17:54

I have noticed many posts regarding NFPA25 inspections and the debate regarding failing a system based on original design flaws; but my question is if during the NFPA25 inspection process it is noted and confirmed by the building ownership that a new large canopy has been recently installed on a sprinklered building above a loading dock where combustible materials are being stored and there is no sprinkler coverage under the canopy; given the creation of a new hazard can that be listed as a failure on the inspection report?

Same question regarding building modifications such as the addition of offices with no coverage in a sprinklered building or the addition of drop ceilings that block overhead coverage, can these be listed as a failure item if there is no proof of fire department approval of the building modification obstructions to coverage and creation of a hazard?
 
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Not sure of your question

Luckily as an ahj, we do annual inspections, so we try to catch any changes, and have them corrected.

We also require an annual inspection of sprinkler systems.

Some sprinkler companies will write up missing sprinkler coverage, some will not.

To me it seems like a liability if they do not???
 
Thank you for the reply cdafd, the question was to gain clarification that if during the course of a NFPA25 sprinkler system inspection it is determined that the owner of a building has made recent modifications to a sprinklered building and created a hazard of no fire sprinkler coverage, and that owner is in violation of NFPA25 4.1.6 - 4.1.6.1 by not obtaining approval for the modification and the hazard created, is that cause to fail the system during the inspection?

The reasoning is that although during the NFPA25 inspection we are to assume the system was originally accepted as installed, the building modification was performed after the original system installation, has created a life/safety hazard and the owner is willfully violating the requirement of NFPA25 4.1.6 - 4.1.6.1 therefore the system cannot be passed due to the obvious violation and modification to the system coverage ability.

There have been differing opinions on this subject so looking for additional feedback and input from current and former AHJ's.
 
I think there needs to be a change to 25 , not sure if one has ever been proposed to address this issue

To me it is only common sense , you pay someone to inspect your system, looks like you would want to know about problems
 

Ok here is my 00.02$

If I was the company doing the ITM, I will make darn sure that I have everything well document via a memo or some sort of letter to owner in conjunction with the owner section of the inspection form . Now the NFPA 25( 2011 edition) para 4.1.6 address changes in hazard.

4.1.6.1 Where changes in the occupancy, hazard, water supply, storage commodity, storage arrangement, building modification, or other condition that affects the installation criteria of the system are identified, the property owner or designated representative shall promptly take steps to evaluate the adequacy of the installed system in order to protect the building or hazard in question.

4.1.6.2 Where the evaluation reveals that the installed system is inadequate to protect the building or hazard in question, the property owner or designated representative shall make the required corrections.

So the person (s) performing the inspections has the de duties to notify the owner via the form and explain the in the owner's section of the report. see figure A4.3.1 NFPA 25. That he must sign.

Lou

 
We conduct inspections and note deficiencies based on the code that was current when the system was installed. The first time we inspect a site we take it at face value. Some older places have multiple (often connected) buildings with a sprinklers in one and not the other, or maybe it's an egress system. We describe this in our report and move on. However when it's obvious that new rooms have been added in a protected building without moving/adding heads, that goes on the "recommended improvements" letter that I add to the inspection.
As a private contractor who's been hired by a site owner to provide assurance that their sprinklers will put out fires when called to, we report our findings and work with them to address immediate dangers. More mundane issues go further down the list.
Here's a recent conundrum we came up against-
We've serviced a very large medical center for many years. It's a concrete building built in 1974, with huge service areas/HVAC rooms, etc. all over the building. We did our round of annual inspections and gave them the report with recommendations as always. There are a few issues that have been on the list for years, some because getting a head where it needs to go is nigh on impossible, and some other things. There's always something to do there...
Anyway, a couple weeks later I get a call from the facilities manager screaming at me asking how I could have missed the electrical rooms.
Me- "Excuse me?"
him- "The electrical rooms don't have heads. The NEW state fire marshal came through and said they all need heads."
me- "Those rooms don't require heads."
him- "Well, he says we have to have them in there. How come we never knew that? It wasn't in your report."
me- "Why would we note it? They've never had heads. They're dedicated electrical rooms with two hour walls." I even dug out the book and cited the current code that allows omitting those heads.
him- "He has some other code saying we need heads in there. California something-or-other (his words)" We're in Oregon, just to be clear.

So, despite NFPA 13(2010) saying otherwise, we put heads in about a dozen electrical rooms. It made us look bad in the eyes of a valuable client for a while. I wrote a letter in stating our position on the matter, and it helped some to assuage them. We still had to scramble to get them done.
What do you do about something like that?


Alex Traw
Rainbow Fire Sprinklers
Albany, Oregon
 
love opposing codes, but not really opposing

Did you happen to set down and talk to the fire marshal? I understand nfpa 101, nfpa 13 and whatever fire code adopted.

been there enough times. but most codes say the more stringent applies
 
One problem is trade-offs. One of our clients was found to be out of compliance, the building should have had a sprinkler system (A Occupancy, a church) The FM and BO decided a fire alarm would notify occupants, so the building could be evacuated. Other requirements are fire doors, exit signs,
and new exterior stairs. In 10 years, who will remember the trade-offs? In 10 years, my company will be gone. Will the B/O still have the paperwork? Will the Church? Will the Pastor still be around?

Or a new combustible handi-cap ramp is added that required 5 heads for protection. Oregon allows 4 or 5 heads to be added w/o calculating the sprinkler demand. Then a pre-built building is added. It is far enough from the original building so flame extension is not important. But the handi-cap ramp is extended to the new building. The B/O wants sprinklers added. It is only 3 heads, so again, calcs are not done. Now we have 8 dry heads that have been added. Can we run 8 heads on 1.25" pipe? I know the heads have been added, but does the company that added the last heads know there may not be enough water to supply the 8 heads? Or does the company that does the inspection know?

Does anyone have a good write-up about possible non-compliant piping or additions they would like to share?
 
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