DISCLAIMER 9/8/14. NFPA 25, Table A.3.3.7: Identifying & Classifying Deficiencies & Impairments. Instructor

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1 NFPA 25, Table A.3.3.7: Identifying & Classifying Deficiencies & Impairments Presented by Terry Victor To receive credit for this seminar, you must 1) sign in on Sign-In sheet, 2) attend seminar in its entirety, and 3) submit a completed evaluation form. 2 Instructor Terry Victor, National Manager of Sprinkler Business Processes at SimplexGrinnell, has over 40 years of technical experience in the sprinkler industry. He serves on various industry boards and committees including the NICET Fire Protection Advisory Group, and is NICET Level IV certified in Sprinkler System Layout and Special Hazards System Layout. He is a member of several NFPA technical committees including those for NFPA 3, 4, 13, 13D, 13R, 14, 15, 16, 20, 25, 214, 232, and 303. Contact Information: SimplexGrinnell 705 Digital Drive, Suite N / Linthicum, MD / USA / 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 1

2 4 Paper-Lite In an effort to be environmentally responsible and to increase the quality and timeliness of training resources, AFSA is reducing the amount of paper used at our conventions. The handout file for this seminar can be downloaded at: 5 Seminar Description NFPA 25 requires inspections and tests of water based fire protection systems, and provides pass/fail criteria. Based on the results of an inspection or test, systems and/or components could be found to be deficient or even impaired. This session will instruct on the differences between an impairment and the two levels of deficiencies, and will help participants understand how to classify the findings of an inspection or test. Tagging requirements in several states will also be discussed and guidance given on what tag to use for the different levels of deficiencies. Table A will be introduced and referenced during the session. 6 Learning Objectives: Upon completion of this seminar the participant should be able to: Explain the difference between an impairment and a deficiency as applied by NFPA 25; Demonstrate how the results of an inspection or test should be classified; Examine photographic examples of impairments and deficiencies and properly classify them; Defend the classification of an impairment or deficiency using guidance found in NFPA 25 Table A.3.3.7; Apply the tagging requirements from several states to the classifications found in NFPA 25 Table A Explain to a building owner the need for urgency to have certain repairs done based on the severity of the impairment or deficiency. 2

3 NFPA Identifying Deficiencies 7 8 Chapter 1 Administration * This standard does not require the inspector to verify the adequacy of the design of the system. Inspectors are not responsible for design or install errors A The requirement to evaluate the adequacy of the design of the installed system is not a part of the periodic inspection, testing, and maintenance requirements of this standard. However, such evaluation is the responsibility of the property owner or designated representative as indicated in and Responsibility of Property Owner or Designated Representative. The property owner is responsible for compliance 4.1.1* Responsibility for Inspection, Testing, Maintenance, and Impairment. The property owner or designated representative shall be responsible for properly maintaining a waterbased fire protection system. A Any portion or all of the inspection, testing, and maintenance can be permitted to be contracted with an inspection, testing, and maintenance service. 3

4 * Corrections and Repairs. No time frame is given for making repairs * The property owner or designated representative shall correct or repair deficiencies or impairments that are found during the inspection, test, and maintenance required by this standard Corrections and repairs shall be performed by qualified maintenance personnel or a qualified contractor. 11 The building owner must address recalled products A Recalled products should be replaced or remedied. Remedies include entrance into a program for scheduled replacement. Such replacement or remedial product should be installed in accordance with the manufacturer s instructions and the appropriate NFPA installation standards. (continued) 12 Findings discovered during ITM activities should be classified A Needed corrections and repairs should be classified as an impairment, critical deficiency, or noncritical deficiency according to the effect on the fire protection system and the nature of the hazard protected. (continued) 4

5 13 Chapter 3 Definitions * 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. A unit refers to a fire pump, storage tank, or fire main 14 Chapter 3 Definitions Additional guidance is provided on emergency impairments * Emergency Impairment. A condition where a water-based fire protection system or portion thereof is out of order due to an unplanned occurrence, or the impairment is found while performing inspection testing or maintenance activities. A Emergency Impairment. Examples of emergency impairments might include a ruptured pipe, an operated sprinkler, or an interruption of the water supply to the system. 15 Chapter 3 Definitions Preplanned Impairment. A condition where a water-based fire protection system or a portion thereof is out of service due to work planned in advance, such as revisions to the water supply or sprinkler system piping. Time limits are provided before additional steps are needed 5

6 16 Impairments when found require immediate action per Chapter 15 A Impairments are the highest priority problem found during inspection, testing, and maintenance and should be corrected as soon as possible. The fire protection system cannot provide an adequate response to a fire, and implementation of impairment procedures outlined in Chapter 15 is required until the impairment is corrected. (continued) 17 Chapter 3 Definitions Knowledge of how systems operate is needed 3.3.7* Deficiency. For the purposes of inspection, testing, and maintenance of water-based fire protection systems, a condition that 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 Critical Deficiency. A deficiency that, if not corrected, can have a material effect on the ability of the fire protection system or unit to function as intended in a fire event. 18 Sometimes judgment must be used when classifying findings A Critical deficiencies need to be corrected in a timely fashion. The fire protection system is still capable of performing, but its performance can be impacted and the implementation of impairment procedures might not be needed. However, special consideration must be given to the hazard in the determination of the classification. A deficiency that is critical for one hazard might be an impairment in another. (continued) 6

7 19 Chapter 3 Definitions Correction is still needed for these deficiencies 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. 20 A Noncritical deficiencies do not affect the performance of the fire protection system but should be corrected in a reasonable time period so that the system can be properly inspected, tested, and maintained. (continued) Correcting before the next inspection improves efficiency 21 The annex is providing the basis for the judgment calls A Assembly occupancies, health care facilities, prisons, high rise buildings, other occupancies where the life safety exposure is significant, or facilities that cannot be evacuated in a timely manner require special consideration. As an example, a nonfunctioning waterflow alarm might be considered a critical deficiency in a storage warehouse but an impairment in a hospital. (continued) 7

8 22 The annex is providing the basis for the judgment calls A High hazard occupancies where early response to a fire is critical also require special consideration. A small number of painted sprinklers could be considered an impairment for a system protecting a high hazard occupancy but might be considered a critical deficiency in a metal working shop. (continued) 23 A Classifications of needed corrections and repairs are shown in Table A The annex of Chapter 4 sends the user to Table A Chapter 3 Definitions A Deficiency. The annex of Chapter 3 also sends the user to Table A Table A provides examples for classifying conditions needing repair or correction that are identified during the inspection, testing, and maintenance of water-based suppression systems.... The table is not all-inclusive but is included to provide guidance in responding to these conditions.... It should be noted that many jurisdictions have requirements for the timely correction of impairments and/or deficiencies. 8

9 25 Non-critical Deficiency? Critical Deficiency? Impairment? Evaluation? Are you ready to play the NFPA 25 Classification Game? See screen for picture slides and Table A Water-Based Fire Protection System Inspection and Testing Findings 30 Refer to Table A Pgs NFPA 25, 2014 Ed. The TC is trying to remove as much subjectivity as possible from the classification process Table A Water-Based Fire Protection System Inspection and Testing Findings 31 Refer to Table A Pgs NFPA 25, 2014 Ed. Conditions of sprinklers are the findings that are the most difficult to classify 9

10 Table A Water-Based Fire Protection System Inspection and Testing Findings 32 Refer to Table A Pgs NFPA 25, 2014 Ed. For the first time, NFPA 25 addresses missing coverplates and escutcheons Table A Water-Based Fire Protection System Inspection and Testing Findings 33 Refer to Table A Pgs NFPA 25, 2014 Ed. The table differentiates between a leaking pipe that s spraying or dripping Table A Water-Based Fire Protection System Inspection and Testing Findings 34 Refer to Table A Pgs NFPA 25, 2014 Ed. Water storage tank inspections could reveal an impairment 10

11 Table A Water-Based Fire Protection System Inspection and Testing Findings 35 Refer to Table A Pgs NFPA 25, 2014 Ed. The only impairment for a hose valve is if the threads aren t compatible Questions 54 NFPA ? Tagging Best Practices 33 11

12 NFPA Public Input 165 Statement of Problem and Substantiation for Public Input This Public Input seeks to add a new annex section (Annex G) that would suggest a standardized format for System Status Tagging. As NFPA 25 does not currently contain recommendations on system tagging, individual jurisdictions have adopted their own tagging procedures and there is no consistency between jurisdictions. There are many different status tagging systems in use today around the country. Some jurisdictions are using two color tags while other are using three or four color tags. The proposed Annex G will suggest a standardized tagging procedure to promote a consistent method. 56 NFPA Public Input 165 Statement of Problem and Substantiation for Public Input 57 This proposed method would consist of a General ITM Tag (White Tag) and three types of color-coded system status tags, indicating the presence, or lack of deficiencies. A green "compliance" tag indicates a system found to be compliant with NFPA 25. A yellow "deficiency" tag would indicate a system found to have deficiencies as defined by section of NFPA 25. A red "impairment" tag would indicate a system found to have impairments as defined by section of NFPA (PI 165) ITM Tag. Whenever an inspection, test, or maintenance is performed, a white ITM tag should be securely attached to the main control valve of each system. Photo Byron Blake White tag to indicate an inspection and/or test was made 12

13 59 (PI 165) Green Tag. If, following inspections and/or tests, the system is found to be compliant with this standard, a green compliance tag should be attached along with the white ITM tag. Photo Byron Blake Green tag for system with no deficiencies 60 (PI 165) Yellow Tag. If, following inspections and/or tests, the system is found to have deficiencies as defined in section 3.3.7, a yellow deficiency tag should be attached along with the white ITM tag. Photo Byron Blake Yellow tag for system with one or more deficiencies 61 (PI 165) Impairment Tag. If, following inspections and/or tests, the system is found to have impairments as defined in section , a red impairment tag should be attached along with the white ITM tag. Photo Byron Blake Red tag for an impaired system, plus tag required by Chapter 15 13

14 New York City NYC Tagging Guide 62 Texas Insurance Code Chapter Inspection, Test and Maintenance Service (ITM) Tag. (a) After a new installation or a scheduled inspection, testing and maintenance (ITM) service, all portions of an ITM tag must be completed in detail, indicating the ITM service was performed according to the adopted standards, and the tag must be attached to the respective riser of each system. (b) After any ITM service, the inspector must complete and attach an ITM tag, and if impairments are found, the inspector must attach the appropriate yellow or red tag in accordance with the procedures in this subchapter. (c) A new ITM tag must be attached each time an inspection, testing and maintenance service is performed. (f) ITM tags must be light blue in color, Texas Insurance Code, Chapter 34, Subchapter G, Fire Sprinkler Rules Photo Byron Blake The ITM tag is to be LIGHT BLUE in color and is to be provided any time ITM is performed 14

15 Texas Insurance Code Chapter Yellow Tags. 65 (a) If a fire protection sprinkler system is found to be noncompliant with applicable NFPA standards, is not being tested or maintained according to adopted standards, or found to contain equipment that has been recalled by the manufacturer, but the noncompliance or recalled equipment does not constitute an emergency impairment, a completed yellow tag must be attached to the respective riser of each system to permit convenient inspection, to not hamper the system's actuation or operation, and also to indicate that corrective action is necessary. 66 Texas Insurance Code, Chapter 34, Subchapter G, Fire Sprinkler Rules Photo Byron Blake The language on the YELLOW TAG is problematic in part because it is used for other purposes that just NFPA 25 inspections and tests Texas Insurance Code Chapter Red Tags. 67 (a) If a fire protection sprinkler system has an impairment which constitutes an emergency impairment, as defined in the adopted edition of NFPA 25, the service person or inspector shall complete and attach a red tag to the respective riser of each system to indicate corrective action is necessary. 15

16 68 Texas Insurance Code, Chapter 34, Subchapter G, Fire Sprinkler Rules Photo Byron Blake The RED TAG is very straight forward, applying only to emergency impairments Florida Administrative Code - Fire Protection System Contractors and Systems 69 69A Inspection Requirements for. (2) Each system that has been inspected, tested, or maintained by a fire protection contractor, or his or her permitted Water- Based Fire Protection Inspector, shall have a record tag of durable and weather resistant material placed on the riser. (3) Inspection Tags. (a) After inspection and testing, an inspection tag shall be completed indicating all work that has been done,... A new inspection tag shall be attached to the system riser each time an inspection and test service is performed. Florida Administrative Code - Fire Protection System Contractors and Systems 70 69A Inspection Requirements for. (4) Compliance and Noncompliance Tag. (a) If a fire protection system is found to be in compliance with the applicable NFPA standards, a GREEN Compliance Tag shall be attached to either the main riser or main control valve in such a manner as to be plainly visible and not more than 60 inches above the finished floor. The two color tag system and the in Florida defeats the purpose of a visual indication of system status, especially when repairs are made 16

17 Florida Administrative Code - Fire Protection System Contractors and Systems 71 69A Inspection Requirements for. (4) Compliance and Noncompliance Tag. (b) If a fire protection system is found to have deficiencies and is not in compliance with the applicable NFPA standards, a completed RED Noncompliance Tag shall be attached to the main control valve of the system to indicate that corrective action is necessary. If the system is operational but not in compliance with the applicable NFPA standards, the building owner or authorized representative and occupant shall be notified by copy of the NFPA 25 inspection report within 30 days of the inspection. If the system is not operational, the contractor or inspector shall notify the building owner or authorized representative, the occupant, and the authority having jurisdiction within 24 hours of the time of the inspection. Questions 72 CONCLUSION 51 Questions & Answers Evaluations: Paper or Mobile Device Attendee ID#: 5-digit number located on your badge Paper: SEMINAR ID# Mobile Device: Use Guidebook App to submit evaluation, or QR Scan application on your mobile device to scan the QR code (below right) before leaving. To receive credit for this seminar, make sure you ve signed the Sign-In sheet and completed a course evaluation (paper or mobile device). SEMINAR ID# Handouts: 17

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