Incorrect 13 install makes inspection moot? 2

[ContractorDave]

Attached is a pic a lot of you have probably seen variations of: obstructions that are built into the building by poor design. I understand the odd pendant light fixture obstruction infraction. But not this. I have seen this time and again, whether it's in kitchens above the cupboards, or in closets. My question is to the inspectors out there (as I know all you FPE's will be suitably aghast already), if you walk into an occupied building and come across multiple instances of this, what is the proper course of action? The system is not installed correctly. Do you A) say sorry you cannot do the inspection? B) Do the inspection and check off the appropriate box indicating obstructions exist and mention it to the owners rep? At what point during the course of an inspection where you come across multiple installation violations do you simply say a proper inspection cannot be done?

Regards
Dave

 

[FFP1]

Hello lightecho.

Your most recent post provides a GREAT example of my overall point regarding this issue. Fire Protection Contractor Inspectors are NOT required to confirm whether or not a water-based fire protection system was installed in accordance with NFPA 13, 13R or 13D. Just imagine the time and research involved if you applied this approach at all of the facilities you inspect. This task and responsibility is placed on the local building inspectors and AHJ fire inspectors for VERY good reasons. The fact that many of these people are not fully trained, not qualified and/or not properly focused on details creates the problem you are trying to resolve.

If the issue falls under one of the criteria outlined in NFPA 25, then my advice is to include the deficiency in your report and discuss clearly with your customer. If the issue does not fall under one of the criteria outlined in NFPA 25, then my advice is to make a decision whether or not you want to help your customer outside of the scope of your contract (assuming you have a written contract for your inspection activities of course!).

I sincerely hope this helps & I support your efforts to pursue what is in the best interest of your customer in this situation.

 

[ContractorDave]

Sigh "light echo" is a holdover from a music audiophile forum I used to haunt... sounds kind of corny here.

So FP, You are saying regardless of what code it was installed to, if it's a 25 deficiency now, you call it as such, discuss it with the owner and call it a day? Last week I was inclined to say it was that black and white, and I believe that NFPA 25 is trying to make it that way as they develop and modify the code through each subsequent update. Unfortunately whilst replying to cdafd I quoted " NFPA 25 5.2.1.2 The minimum clearance required by the installation standard shall be maintained ...." and (s)he through it back at me asking: "which code / edition was it then installed under?"

Where to now?

Regards
Dave

 

[FFP1]

For most instances, I would have to answer YES.

My understanding of the approach taken by NFPA (& the great State of Georgia): In a nutshell, inspections are performed in accordance with NFPA 25 to ensure the systems are fully functional (as originally installed). They have essentially decided that as long as the systems have not been signifcantly altered, the valves are in the correct position, water supplies are reliable & fire pumps are fully functional, FD connections/fire hydrants/standpipes are accessible & functional, water-filled portions are protected from freeze, all alarm components are fully functional and there are no painted/corroded or severely obstructed sprinklers, then the systems will operate as designed leading to prompt notification.........as long as these facts are confirmed by qualified people on an annual basis (do not forget about the weekly/monthly/quarterly inspections by plant/facility employees) the likelihood of minimizing the fire damage is Good.

That is my understanding anyway........the more severe fire exposures and more complicated occupancies should have formal risk management policies including engineering evaluations and other detailed evaluations (we all know this is not the case in many instances, but it is prudent).

The most significant problems arise when the initial system acceptance inspection activities which SHOULD be completed when the systems are originally installed are not compleetd at all or if they are not thoroughly completed by competent people. Significant exposures also exist when systems are not properly inspected by certified & qualified inspectors and/or not properly maintained due to several factors. Anyone who has completed inspections and/or been involved in our industry for several years is well aware of these exposures/problems.

We should all be focused on what is best for our customers, our company and the industry in general. NFPA and the various state laws provide guidance outlining the MINIMUM requirements...........I am not aware of anything that prevents us from provided more than the minimum requirements; this might be an instance where you go over and above the call of duty in the best interest of your customer, your company & the industry. Document what is required and provide solid good advice as needed even if the problem lies outside of the scope of NFPA 25.

Take care!

 

[ContractorDave]

Hmmm Take Care indeed!

Thx for the thoughtful response.

Regards
Dave

 

[NJ1]

Ok lets look at the big picture here. As a NICET level III Inspector I will tell you the following. NFPA 25 does not addresses NFPA 13D to begin with. Also NFPA 25 states that specific guidance for clearance and obstruction is found in NFPA 13. With that said, your service technician/inspector must be qualified to note such items on site. In relation to that picture it will be noted on my report since it is an obstruction and or lack of clearance regardless of what modifications where done to the building. The problem is that most contractors limit their inspectors to just NFPA 25 items. That means they are not fully clear on what the NFPA requirements are.

 

[FFP1]

I am responding to the recent post submitted by NJ1 for clarity:

NFPA 25 does address NFPA 13D...........NFPA 25 states the following: "1.1.3 This standard shall not apply to sprinkler systems designed and installed in accordance with NFPA 13D, Standard for the Installation of Sprinkler Systems in One- and Two- Family Dwellings and Manufactured Homes."

In reference to your comment regarding clearance & obstruction issues; I understand where there is room for some confusion based strictly on the 1998 & 2002 versions of NFPA 25. The excerpt you are referring to states the following: "5.2.1.2* Unacceptable obstructions to spray patterns shall be corrected." & "A.5.2.1.2 Obstructions to spray patterns include continuous or noncontinuous obstructions less than or equal to 457 mm (18 in.) below the sprinkler deflector that prevent the pattern from fully developing. Obstructions that prevent sprinkler discharge from reaching the hazard include continuous or noncontinuous obstructions that interrupt the water discharge in a horizontal plane more than 457 mm (18 in.) below the sprinkler deflector in a manner to limit the distribution from reaching the protected hazard. Specific guidance for clearance and obstructions is found in NFPA 13, Standard for the Installation of Sprinkler Systems, and specific sprinkler listings." This text has been replaced in the 2008 version to provide clarity.

NFPA 25 (2008 version) helps to clear some of the confusion with the following: "5.2.1.2* The minimum clearance required by the installation standard shall be maintained below all sprinklers. Stock, furnishings, or equipment closer to the sprinkler than the clearance rules allow shall be corrected." The 2008 Appendix provides the clarity we all need to understand the overall intent of NFPA 25: "A.5.2.1.2 NFPA 13, Standard for the Installation of Sprinkler Systems, allows stock furnishings and equipment to be as close as 18 in. (457 mm) to standard spray sprinklers or as close as 36 in. (914 mm) to other types of sprinklers such as ESFR and large drop sprinklers. Objects against walls are permitted to ignore the minimum spacing rules as long as the sprinkler is not directly above the object. Other obstruction rules are impractical to enforce under this standard. However, if obstructions that might cause a concern are present, the owner is advised to have an engineering evaluation performed."

There are exactly zero additional references in NFPA 25 regarding "sprinkler spray pattern obstruction issues"; the remaining obstruction references in NFPA 25 refer to possible obstruction to water flow inside the water-based systems or obstrusted discharge nozzles for water mist, foam & deluge systems which are tested in a different manner than standard spray sprinklers.

NFPA 25 clearly requires confirmation that the 18in. and 36 in. clearance requirements are inspected/addressed, but the detailed "sprinkler obstruction" requirements outlined in NFPA 13 are actually outside of the scope of NFPA 25. This does not mean we should ignore obvious problems..........as I have stated above (previous posts) we all should do what is best for our customers and the general public, but from a legal standpoint, there is no requirement for fire protection sprinkler inspectors to evaluate or document the various "sprinkler obstruction" issues outlined in NFPA 13. These issues should be identified & resolved during the initial sprinkler system acceptance testing performed and/or required by the AHJ.

 

[ContractorDave]

Thank you FPP1, I enjoy your detailed posts.

All these responses though and no one has addressed what I was inquiring about in the initial post, so perhaps I'll ask again and pose the question more broadly, when a system is incorrectly installed, where do you simply say that such is the case and an inspection to NFPA would be irrelevant? I'm sure that each situation is unique as in the example I initially posed, but do you 'Red Flag' the system if you find 20 obstruction issues as opposed to 2 or simply write it up as obstructions exist? What if you look in the crawlspace of a building (like I recently did) and find a copper system, all 1" pipe with the pipe laid low and 12" x 1/2" risers / candle sticks with SSP in the upright position installed less than 6' apart and more the 22" from the floor above? Do you go running for the woods? Do you 'Red Flag' it? It sure is hard to write up in NFPA 25 isn't it?

By the way, what is this Red Flag stuff? It's not addressed in 25 either. (I've read about it in some of these posts as something that appears to be done on occasion in the states).

Regards
Dave

P.S. Looking at the big picture, 13D wasn't an issue here.

 

[FFP1]

Georgia State Law requires Green, Yellow and Red inspection tags; the color placed on the system after an inspection depends on the status or reliability of the water-based fire protection system (based on number and severity of the non-compliance issues). Many of the USA states require this approach.

In the USA impairment tags (as referenced in NFPA 25) are typically red (thus Red Tag or Red Flag).

 

[NJ1]

I am totaly clear with your comment FPP1. I appreciate your opinion. First of all what I meant is that NFPA 25 does not cover 13D systems.
Also obstruction to spray patters in NFPA 13 not only covers 18" and 36" clearance but also covers clearance to spray patterns as shown on NFPA 25-2002 Exibit 5.4 page 68.
Meaning 4" inches or less of any object that can cause lack of spray pattern.
As an expert opinion advisor for the NJ Fire Safety Division
these items are so neglected do to lack of cross reference between NFPA 25 and NFPA 13. Field inspectors need to understand that is not what the business owner wants to write in the report but what is required. Most people think these issues are outside the scope of NFPA 25.

 

[ContractorDave]

NJ1

For someone new to these posts you would do well to be less condescending. FPP1 is fully aware of what is required by the 'field' inspector (as opposed to some other?). There have been many debates and many great opinions posited here on this forum regarding the relationship between 13 and 25. I for one have learned a lot from FPP1, SD2, cdafd and the likes. This is a wonderful resource with many like minded people all interested in the codes and how they apply to the client and his buildings. I turn 50 this year. On September 11th no less. I've been in this particular trade for over 25 years, but when Travis or stookey or FPP1 show up on a particular thread I know I'm likely to learn something.

Regards
Dave

 

[NJ1]

I guess I have nothing else to say since lightecho have better support from Travis, Stookey and FFPI. I just thought I could help since I am license in 5 States for all purpouse fire protection. Is allways good to have people like me around to learn from arguments, discussions,etc.

 

[FFP1]

My intentions are good and I truly want to help everyone understand this issue.

NJ1: Just so you understand my level of expertise, I have obtained NICET Level III Automatic Sprinkler System Layout & I am also a registered FPE (Professional Engineer with a specialty in Fire Protection). I own a fire protection company and we are primarily focused on inspection services and engineering consulting. I am fairly knowledgeable in my realm of the industry, however, I also realize no one person knows everything required by NFPA due to the wide scope and shear volume of the NFPA standards. I learn new tidbits of information on a regular basis and this forum is a wonderful avenue to learn about NFPA standards, the fire protection industry and the common issues we all encounter each and every day.

NJ1 made two statements with his 2/10 blog entry which are true: "obstruction to spray patterns in NFPA 13 not only covers 18" and 36" clearance but also covers clearance to spray patterns" & "Most people think these issues are outside the scope of NFPA 25"...........the "most people" he references are correct in this instance. I sincerely hope NJ1 will conduct some detailed research and eventually realize the fact that not all of the NFPA 13 requirements are included in the inspection routine required by NFPA 25. Confirmation of the 18 in. & 36 in. clearance requirements are included in NFPA 25; however, the other obstruction to spray pattern requirements outlined in NFPA 13 are NOT included in NFPA 25 for good reason (this was not an oversight by the NFPA committee).

 

[NJ1]

FFP1 for our information I just confirmed with Jim Lake about the clearance requirements and his answered was that all obstructions to spray patterns are to be addressed as per NFPA 13. All Obstructions to spray patterns are to be address when performing a NFPA 25 Inspection. Including but not limited to 18 " and 36" clearance. It addresses obstructions such as sprinkler near light fixtures, walls, etc.

 

[ContractorDave]

Hmmm Interesting NJ1. Was this an e-mail exchange and if so, with the good graces of Mr. Lake, could you share that with us?

Regards
Dave

 

[NJ1]

I will try to copy and paste somehow. By the way I am not trying to be smarter than anyone here is just my expert side is the Inspection, Testing and Maintenance.
As an expert opinion advisor I have helped the Attorney General to win cases against contractors in NJ because of this.

 

[FFP1]

Wow..........they need to add a new chapter or a clear statement in NFPA 25 to clearly state the requirement if this is really what is expected by the NFPA committee and thus required by state law in the numerous states which have adopted NFPA 25 as the minimum state law.

I am a little skeptical. Where does this line of thinking stop? Which of the remaining NFPA 13 requirements are we responsible to evaluate even when there is no reference outlining the requirement in NFPA 25 (I am sure we all agree all of the NFPA 13 requirements are important)? Are we all required to confirm sprinkler systems are adequate for all occupancies and various storage heights during the annual inspection routine (i.e. engineering evaluations every year by NFPA 25 inspectors)? Are we required to confirm all sprinkler spacing is in accordance with NFPA 13 (remember the maximum spacing requirements are different depending on the sprinkler and the given occupancy.........so the inspectors would have to confirm the combination of sprinkler, available water pressure, sprinkler spacing and occupancy classification meets NFPA 13 for each area of the facility every year as well)? Are we required to confirm all of the hanger spacing & various types of hangers are adequate for the given loads? Are we required to confirm the proper fastners were used for the given structures? I could keep going, but you all get my point.

I absolutely must mention the fact that many of the NFPA 13 requirements differ depending on the year/version.........do we all use the version currently adopted by the given state or do we apply the version based on the year the system was installed; which version do we all use??? I conduct inspections at one facility which has 58 systems; there are probably 5 or 6 different NFPA 13 versions which were used when the various systems were installed. Either approach creates a significant problem; think about it.

OR.......does NFPA 25 essentially require these two basic concepts:

1. Confirm the system components are still fully functional and in good condition AS INSTALLED and accepted by the AHJ.

2. Document any significant changes which have taken place since the last inspection (or since the system was originally installed/accepted by the AHJ) which might justify further evaluation to ensure all of the important NFPA 13 requirements are met.

I will agree that inspectors are required to document when significant occupancy changes have taken place which might warrant a visit from the AHJ or a detailed engineering evaluation to ensure all of the NFPA 13 requirements are met, but I still have a difficult time believing (based on the actual text in NFPA 25) that inspectors are required to evaluate requirements from NFPA 13 in instances where NFPA 25 does not specifically state the function must be included in the annual inspection routine!

If you ask me whether or not the obstructions outlined in NFPA 13 should be evaluated by inspectors who are representing the AHJ (i.e. State employed Fire Inspectors & Fire Department Inspectors), then I would answer: Absolutely YES. However, I simply do not think Fire Protection Contractor Inspectors are required to evaluate sprinkler obstructions (except for the 18 in. & 36 in. clearance) when they perform the annual inspection requirements outlined by NFPA 25.

I could wrong (it would not be the first time by the way), but if NJ1 is correct, NFPA 25 needs some clearly stated revisions which outline what is actually required during the NFPA 25 inspection routine!!

Great Topic!

NJ1: It would be great if you could convince Jim Lake to post a clear and detailed statement regarding this subject. Did he mention if there are any plans to clearly state this requirement in the next version of NFPA 25? Thanks!

 

[SprinklerDesigner2]

"Are we all required to confirm sprinkler systems are adequate for all occupancies and various storage heights during the annual inspection routine (i.e. engineering evaluations every year by NFPA 25 inspectors)? Are we required to confirm all sprinkler spacing is in accordance with NFPA 13 (remember the maximum spacing requirements are different depending on the sprinkler and the given occupancy.........so the inspectors would have to confirm the combination of sprinkler, available water pressure, sprinkler spacing and occupancy classification meets NFPA 13 for each area of the facility every year as well)? Are we required to confirm all of the hanger spacing & various types of hangers are adequate for the given loads? Are we required to confirm the proper fastners were used for the given structures? I could keep going, but you all get my point."

We could all make a book out of it but unless someone can show me differently the answer has to be no.

The oldest system I've inspected was installed in 1912 the year before the Titanic sank. We replaced all the old sprinklers but other than that what could we do? How could anyone say what was required 100 years ago? It's pipe schedule, 3/4" pipe at the end of branch lines on a staggered system what was the water supply requirements back then or was any 400 head sprinkler system good to go by tying into any 8" city water main?

As I pointed out previously at one time systems were not limited by square footage covered but the number of sprinklers on a system which was 400. That is where the 52,000 sq. ft. comes from... 400 sprinklers x 130 sq. ft. = 52,000 sq. ft.. Not sure when this disappeared but I think it was the 40's or early 50's.

I've got a federal government warehouse built in the 40's used to store rubber tires 15' high that has a Extra Hazard pipe schedule system I was told rubber tire storage is what it was built for and it has always been used for that. Is this wrong? I don't think it is but you tell me.

As far as verifying calculations and water supplies I don't think we want to go there unless you are ready to present your customer an invoice for $20,000.

With few exceptions the great majority of 25 inspectors are not capable, don't have the equipment, experience or knowledge.

The oldest fire pump I've inspected is natural gas fired. Is it wrong? What did the standard say in 1924? Was there even a standard?

"We are here to inspect the system we must assume was installed correctly for mechanical operation." Sounds like a total cop out but what else is there?

 

[ContractorDave]

Great points FPP1 and SD2

I too am skeptical and I believe the intention of the NFPA with the 25 standard is to limit the need to refer to 13 for ITM purposes. But of course since one is the child of the other, as SD2 points out, there is this can of worms:

"" ..."We are here to inspect the system we must assume was installed correctly for mechanical operation." Sounds like a total cop out but what else is there?... ""

Worse yet, there will inevitably be times when you "know" this to be false. And with that statement we come full circle back to the original intent or question that started this thread: where do you draw the line and just walk away, or do you call it a deficiency and carry on? (Remember that the pic I offered is an installation deficiency 1st, and then a likely obstruction issue after the fact).

Regards
Dave

 

[ContractorDave]

Perhaps there is a better way to frame my question, or a better example to use:

You are doing an inspection on a fire pump and you notice that someone has, in a retrofit, decided to put a backflow preventer, replete with butterfly valves, directly on the suction side of the pump (replacing the now seemingly redundant OS&Y)- do you:
(a) walk away from it because the system isn't installed correctly,
(b) write it up as a deficiency,
(c) write in your report as a recommendation that this is contrary to NFPA 20 installation requirements and probably compromises the system,
(d) say nothing in your report but verbally inform the owner of the problem,
(e) do nothing and carry on with the inspection of the rest of the system which is correctly installed?

Regards
Dave

 

[FFP1]

Lightecho has offered a superb example.

I would complete the NFPA 25 inspection components as usual. I would also have a clear and concise discussion with the customer/owner to inform him/her that the fire pump house alteration could potentially be a problem and that the specific issue or potential issues are not a direct violation outlined in NFPA 25; therefore, we will not list this potential problem as a deficiency. We are required to document this change/alteration on the NFPA 25 inspection form and we recommend a proper evaluation by the AHJ or a certfied consultant (i.e. FPE or qualified sprinkler contractor) to ensure/confirm in writing whether or not the change/alteration is acceptable or not based on all of the applicable NFPA standards and other pertinent state laws.

Excerpt from NFPA 25 (2002): "4.1.6 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 owner or occupant shall promptly take steps, such as contacting a qualified contractor, consultant, or engineer, to evaluate the adequacy of the installed system in order to protect the building or hazard in question."

"5.4.3* Installation and Acceptance Testing. Where maintenance or repair requires the replacement of sprinkler system components affecting more than 20 sprinklers, those components shall be installed and tested in accordance with NFPA 13, Standard for the Installation of Sprinkler Systems."

This is the approach which I have instructed my employees to implement in these instances.............I wonder how other companies/inspectors would handle this situation. Please provide a response for the benefit of the blog participants if you have an opinion.

By the way.............the butterfly valves within 50 ft. of the suction side (rather than OS&Y valves) of the fire pump is not the only potential issue. I have found several instances where a BFP unit was installed after the fact which created either negative suction between the 100%-150% flow rates or reduced the available water supply so much that the "new" water supply was inadequate for some of the more demanding sprinkler systems at the facility. The fixed pressure loss and the residual friction loss associated with some BFP units can be very detrimental to fire protection systems!