An Informal Interpretation by the AFSA:
Inspection Forms and NFPA 13 Deficiencies:
“We perform NFPA 25 inspections per the scope agreements with our clients. The reports are forwarded to the local jurisdiction for review. The jurisdiction has complained that the inspection forms are lacking information and details. We are being requested by a local jurisdiction to use different forms and also include additional information such as NFPA 13 deficiencies to our sprinkler inspection reports by referencing Florida’s 69A-46.041 Inspection Requirements for Fire Protection Systems. Is this the intent of NFPA 25?”
We have reviewed NFPA 25, 2011 edition as the applicable standard. Our informal interpretation is that NFPA 25 does not require that NFPA 13 deficiencies be found or noted during an inspection of a fire sprinkler system or that specific forms have to be used.
The intent of NFPA 25 is only to address maintenance issues with an overall objective of ensuring that the system is mechanically operational. When an inspection is conducted in accordance with NFPA 25, it is assumed that the installation met the minimum requirements of the installation standard when it was installed. As stated in Section 1.1.3 “This standard addresses the operating condition of fire protection systems as well as impairment handling and reporting and applies to fire protection systems that have been properly installed in accordance with generally accepted practice.” The NFPA 25 handbook commentary explains that the intent of the standard is to require inspection, testing, and maintenance of all water-based fire protection system regardless of the quality of the design and installation. The intent of the scope statement is to relieve the inspector of the burden of continually re-verifying the design and installation of the system. The scope statement basically means that the function of the inspector is to look for signs of normal wear and tear or aging of the system and components, not to re-verify acceptance criteria. Thus adding a section to the report that the system is correct for the occupancy or hazards may expose you to liability issues as the company completing NFPA 25 inspections. However, when NFPA 13 deficiencies exists and are known, it may be prudent for an inspector to inform the owner by separate correspondence. Noting these items separately shows due diligence and may ease concerns of liability for the inspecting contractor. The problem with this is noted in the handbook commentary that the inspector performing the work is not necessarily trained to make this evaluation, nor is it cost effective for such an evaluation to take place each year. The owner and the local jurisdiction should be aware that NFPA 25 does not require NFPA 13 deficiencies to be remedied when found. It only requires that the system be capable of operating properly.
Regarding the jurisdiction’s comment on Florida’s 69A-46.041 Inspection Requirements for Fire Protection Systems, they appear to take issue with the inspection form submitted along with the lack of detail. Number 7 of that document indicates that the contractor or his or her permitted Water-Based Fire Protection Inspector shall complete in detail the inspection reports as required in NFPA 25, as adopted in Rule Chapter 69A-3, F.A.C., that outlines all points of the inspection, test, and maintenance as required by the applicable NFPA standards. A copy of the inspection report shall be provided to the owner at the completion of each inspection performed. Number 8 indicates that the inspection report shall include a detailed explanation of every deficiency, and indicate if the inspection is a weekly, monthly, quarterly or annual inspection. The inspection report shall include the name of the permitted Water-Based Fire Protection Inspector, the inspector permit number, the inspector’s signature, the date and time of the inspection, and the signature of the owner or the owner’s representative. Since NFPA 25 nor the Florida rules give specifics, it is focused just on NFPA 25 requirements, not potential NFPA 13 issues. NFPA 25 does not require any specific forms or minimum information that is to be included on report forms. This is at the discretion of the contractor or owner. Section 4.4 does reference records that shall be made and maintained. The annex A.4.4.3 references sample forms in Section B.2. These forms are not required to be used, especially with the increasing use of handheld inspection reporting software available by several vendors.