The implementation of fire-protection standards
Economics vs. risk debate weighs on the implementation of fire-protection standards.
June 12, 2013
Section 1.2.1 of National Fire Protection Association 13, “Standard for the Installation of Sprinkler Systems,” states the purpose of the standard is to “provide a reasonable [emphasis added] degree of protection for life and property from fire through standardization of design, installation and testing requirements for sprinkler systems.”
Reasonable is always related to economics, and our view of what is reasonable is skewed by whether we are spending someone else’s money or our own. When a new edition of the standard is developed, much of the debate around any proposed change revolves around the concept of reasonableness. The reasonableness of the standard or any specific part always is measured against the economic impact and the resulting benefit.
The governance of NFPA’s standard- and code-making process is designed to ensure that reasonableness is a part of every published standard and code. NFPA technical committees are mandated to maintain stakeholder balance among the members. For example, the automatic sprinkler technical committees responsible for NFPA 13 are made up of members representing enforcers (fire/building officials), installers and maintainers (contractors), insurers, manufacturers, users (owners) and special experts. No stakeholder group can hold more than 30% of the seats on any committee. Any change to the standard must be approved by a two-thirds super majority of the committee. The economic impact of any change is always a significant part of the debate.
Sprinkler system design
Recent editions of NFPA 13 have incorporated changes that are a direct reflection of the search for reasonableness. One example is added text in the 2010 edition clarifying the design basis for a sprinkler system.
1.1.2: This standard (NFPA 13) is written with the assumption the sprinkler system shall be designed to protect against a single fire originating within the building.
This text was added in response to the actions of a few fire and building officials who were requiring the water supplies for a sprinkler system to be sufficient to handle multiple fires occurring simultaneously in a building. While it is possible this scenario might occur, the costs incurred to provide this level of protection were deemed to not be worth the lowered risk. Further, corresponding annex material was added to the 2013 edition explaining the standard provides guidance for exterior protection and specific hazards. Where these systems are installed, they are designed for protection of a fire from a single ignition source.
Some changes are much simpler to gain consensus. For example, the 2013 edition of NFPA 13 removed the requirement for pressure gauges to be “listed.” Pressure gauges are now simply required to be “approved,” which means acceptable to the authority having jurisdiction. The committee determined pressure gauges are not essential to the operation of a sprinkler system and therefore the added expense of using listed products was not reasonable.
Other changes are much more contentious. NFPA 13 allows the omission of sprinklers in certain areas, while still considering the building to be fully sprinklered. One such area is bathrooms located in dwelling units less than 55 sq. ft. in area. Dwelling units are defined by NFPA 13 and include units such as hotel and motel rooms, dormitory rooms, apartments, condominiums, sleeping rooms in nursing homes and similar living units. The committee changed this requirement to limit the omission to hotel and motel rooms. The debate on this issue was long and intense and focused on the cost of adding these sprinklers vs. the likelihood of fires occurring in bathrooms and sprinkler failure in other areas of the dwelling unit to control the fire. Consensus finally was reached and the change to the standard was incorporated.
Inspect, test and maintain
The search for reasonableness extends beyond the installation standards. Economics vs. risk are at the heart of the requirements found in NFPA 25, “Standard for the Inspection, Testing and Maintenance of Water-Based Suppression Systems.” The 2014 edition of this standard is in the final stages of development. The frequency and scope of the various inspections and tests are under constant scrutiny and the various stakeholders have definite agendas regarding the standard.
There are a number of committee decisions regarding the 2014 edition being “appealed” to the general membership of NFPA in June at the NFPA conference in Chicago.
An example of determining what is reasonable involves the correction of deficiencies. NFPA 25 mandates the owner or designated representative must correct or repair deficiencies and impairments found during inspections, tests and maintenance required by the standard. However, there are no requirements or guidance regarding the timeliness for making corrections or repairs.
In order to ensure owner compliance in addressing deficiencies, proposals have been submitted over past revision cycles for mandatory reporting by the contractor to the local fire department and specific timelines for correcting or repairing deficiencies. Thus far, the technical committee has rejected placing specific requirements in the standard under the belief enforcement is the job of the local jurisdiction.
Two issues that superbly illustrate the NFPA 25 Committee’s “search for reasonableness” are the frequency of the no-flow test for fire pumps and internal pipe inspections and obstruction investigation.
Prior to the 2011 edition, a no-flow test was required weekly for all fire pumps. This requirement was modified in 2011 to a monthly test for fire pumps equipped with an electric motor driver. This change was quite controversial and the subject of much debate. Many owner representatives felt the benefits of weekly testing did not come close to the cost. On the other hand, many pump manufacturers representatives, service providers and others felt there was no justification for decreasing the frequency.
As a result, the NFPA Research Foundation conducted a study that compared fire pump testing frequencies with pump failure rates. This information was presented to the committee for use during the revision process for the 2014 edition. After much debate and intense task group work, the committee determined a weekly test will be required except where an approved risk analysis is performed showing a different frequency is acceptable.
However, electric motor-driven pumps may be tested monthly except in certain conditions such as pumps serving systems in buildings that have floors beyond the pumping capacity of the fire department, pumps with limited service controllers, vertical turbine pumps and pumps taking suction from water supplies that do not have sufficient pressure to be of material value without the pump.
Chapter 14 of NFPA 25 has been re-titled “Internal Piping Condition and Obstruction Investigation” for the 2014 edition. The requirements for obstruction inspections have been among the most hotly debated over the last several editions of NFPA 25. At the core of this debate is the disagreement among industry interests regarding the extent and severity of the obstruction issue. In fact, some question if current obstruction requirements are a solution in search of a problem — meaning there is a lack of solid evidence showing obstructions to be a significant issue related to system failures.
As a result, the inspection and investigation requirements have ranged from the 2008 edition requiring a two-point inspection every five years for all systems, to a two-point inspection of every other wet system in 2011, to the 2014 edition that will require a five-year inspection unless a risk analysis shows another frequency is acceptable.
These are a few examples of seeking what is reasonable that lie before every NFPA committee. Of course, in the view of many this is the NFPA consensus process at its best with the various stakeholders, each having a valid viewpoint that must be heard and considered, striving to find agreement. It is sometimes most difficult to find consensus and as a result the requirements of NFPA standards will continue to evolve as the reasonableness of the various requirements are identified and agreed upon.
As frustrating and difficult as it sometimes can be, by sticking with the process the industry has standards that truly meet their defined purpose of “ensuring a reasonable degree of protection for life and property from fire.”
Russ Leavitt is the executive chairman of Telgian Corp., He serves as a member of the NFPA Automatic Sprinkler Correlating Committee, is the chair of the Technical Committee on Sprinkler System Discharge Criteria and is a member of the NFPA 25 Technical Committee. Leavitt conducts seminars around the world for NFPA, Fire Smarts and other industry organizations on a variety of fire- and life-safety-related subjec