When approving the installation of a fire protection or life safety system to verify compliance in accordance with governing laws, regulations, codes and standards, many of us use the term “commissioning” interchangeably with the term “acceptance testing.”

However, since 2012 the term “commissioning” has taken on an entirely different meaning with the publication of the first edition of NFPA 3, now known as the Standard for Commissioning of Fire Protection and Life Safety Systems. The commissioning process documents a story about the systems installed in your building. Following this same approach, here is the “plot” that plumbing engineers and contractors need to know about commissioning in accordance with NFPA 3:


What is commissioning?

Commissioning is a highly administrative process. The goal of commissioning is not to simply receive the Certificate of Occupancy, or “C of O” as it is commonly referred to in the field once passing an acceptance test. Rather, commissioning works to ensure the owner is receiving what he or she paid for.

NFPA 3 defines commissioning as a “systematic process that provides documented confirmation that building systems function according to the intended design criteria set forth in the project documents and satisfy the owner’s operational needs, including compliance with governing laws, regulations, codes, and standards.” It’s important to note that “documented confirmation” refers to what was intended on a project vs. what was actually delivered. Throughout the construction process, there are so many changes made on the fly that it is difficult for teams and owners to keep track of all of them. Commissioning provides the owner with all the documentation at their fingertips, keeping them informed of the systems installed in their facility, and delivering quality control and quality assurance most owners are seeking.

The next time you hear someone state they are “commissioning” a system, confirm if the intent is commissioning or acceptance testing. Although this is a simple concept, the term can be viewed differently by many people in the same industry.


Who is involved?

The fire protection and life safety commissioning team includes all the people typically involved in a construction project: owner, installation contractors, manufacturers representatives, registered design professionals, construction manager/general contractor, insurance representative, owner’s technical support personnel, facility manager or operations personnel, third-party test entity, and the authority having jurisdiction (AHJ).

The only person added to this list when commissioning in accordance with NFPA 3 is the fire-commissioning agent. This individual or entity is identified by the owner and is essentially the quarterback of the team. This position is responsible for leading, planning, scheduling, documenting and coordinating the fire protection and life safety system commissioning team.

The person or entity responsible for carrying out these activities needs to have an advanced understanding of the installation, operation, and maintenance of all fire protection and life safety systems to be installed in the subject facility. The fire commissioning agent is the eyes and ears of the owner, but is not expected to be on the jobsite every day, as that would be very expensive. For large projects, such as the new World Trade Center, a commissioning authority is the qualified person, company or agency that plans, coordinates and oversees the entire commissioning process. The commissioning authority works with the owner and the respective field commissioning agents (HVAC systems, fire protection and life safety systems, etc.).


When can it start?

Commissioning begins when an owner wants to start constructing a building or where required by your AHJ.

Not working on new construction? Commissioning can be applied to existing buildings, too! Think of Grand Central Station in New York City. This facility was constructed in the 1870s, certainly before NFPA 3 was first published in 2012. “Retro-commissioning” is the term utilized for existing fire protection and life safety systems that were not previously subject to commissioning in accordance with NFPA 3. The retro-commissioning process can be more time- consuming due to the highly forensic task of finding original documentation necessary to verify system performance, and verifying the operations meet the original design intent, current owner requirements, and applicable laws, regulations, codes and standards.

What would initiate retro-commissioning? A code, law or regulation (basically the AHJ) could initiate the retro-commissioning process. A contract document provided by the owner could require retro-commissioning on a facility they are thinking of buying. A prime example would be in the purchase and sale agreement where the owner may hire a consultant to perform a “due-diligence report,” which would document the systems installed in the facility, and report whether or not they are code compliant. Insurance representatives also may want to perform a retro-commissioning study to determine risk categories.

Re-commissioning is the term utilized in the standard for existing fire protection and life safety systems that have been subject to commissioning in accordance with NFPA 3. This process should be easier than retro-commissioning because if the building has gone through this process once, the documentation should be readily available to verify that the system performance continues to meet the owner’s needs. Re-commissioning would occur where specified in the commissioning plan, or upon a change of the fire protection and life safety system that impacts the operation of those systems.

How does the commissioning process play out? There are four phases outlined in NFPA 3 to complete the commissioning process. The planning phase kicks off the process by establishing the fire protection and life safety commissioning team and developing initial project concepts as well as the owner’s project requirements and Basis of Design document.

The people included on the fire protection and life safety commissioning team are scalable. Depending on the size and complexity of the project, the commissioning team could be as little as the owner and one person fulfilling the role as the fire protection and life safety commissioning agent, or several hundred people if we go back to the example of the new World Trade Center complex.

What does ‘owner’s project requirements’ mean? The owner’s project requirements is the documentation that contains the owner’s vision for the planned facility, integrated requirements, expectation for how the facility will be used and operated, as well as benchmarks and criteria for performance. Sometimes owners want a system or design that is not required by a building code or goes above and beyond the minimum requirements. For example, at NFPA headquarters if the fire alarm sounds in the conference center, all the computer and TV monitors automatically shut off to remove distractions and be proactive in the evacuation process. This is not a requirement by any code or standard, but rather a method NFPA preferred to have installed in our conference center. The more information provided on the current/future use of the space, the better off the owner and those involved in the commissioning process will be.

What is the Basis of Design? The Basis of Design document works to document why decisions were made the way they were. This document contains the concepts and decisions used to meet the owner’s project requirements, and the requirements of governing laws, codes, regulations and standards.

The design phase is where the documentation is produced, and drawings as well as calculations are provided and testing procedures are developed.

The construction phase is the period in which system and materials are installed, tested and accepted.

The occupancy phase is the time where training and periodic inspection, testing, and maintenance are scheduled and performed.

This process does not end when the facility is constructed, but continues throughout the building’s lifecycle.


Why is NFPA 3 needed?

NFPA 3 was developed as a recommended practice and evolved into a standard. It provides a quality control process that holds each of the stakeholders accountable through required documentation of team member qualifications and fire commissioning agent activities.