NFPA 25, 2014 Edition Hand Book
The inspections required by NFPA 25 are not intended to reveal installation flaws or code compliance violations. As a result of practical limitations and an effort to keep the cost-benefit ratio of implementing the standard reasonable, the inspections required by NFPA 25 are specifically intended to assess the operating condition of the system, with the goal that the system will function as intended. The installation standards are typically not retroactive; therefore, inspecting a system for compliance to the original installation or design criteria would require extensive research and knowledge. For example, inspecting sprinklers to ensure that they are positioned correctly to meet the requirements related to obstructions would require the inspector to determine which edition of the appropriate installation standard and which associated obstruction rules were in effect and enforced at the time of the original installation. Local authority having jurisdiction (AHJ) amendments and variances would also need to be researched. This research would be complicated by the fact that the obstruction rules for sprinklers have greatly expanded over the last two decades with the continuous introduction of new sprinkler listings and applications. What complicates the task even further is that it is virtually impossible to identify many obstruction deficiencies from the floor, which is where NFPA 25 expects the inspection to be conducted.
Therefore, to manage the cost of inspections while maintaining a reasonable degree of protection, NFPA 25 assumes that the original installation was approved by all applicable AHJs and is still considered acceptable. However, where modifications to the building or its use are contemplated or have been made, such as new or relocated walls or ceilings, changes in occupancy, or the construction of an addition, the owner must comply with the requirements in Chapter 4. NFPA 25 inspections are intended to address the operating condition of a system or system components, not the adequacy of the system design when compared to the applicable design and installation standards.
One of the most common misapplications of NFPA 25 comes from not understanding the document scope completely. NFPA 25 is intended to confirm the functionality of the system components
that are installed, not to make sure that the designer has designed the system correctly and observed the rules of the design and installation standard. This misapplication of scope can often lead to arguments between owners, inspectors, and AHJs when certain conditions are present in a building. In some cases, the owner has the expectation that the hired inspector is not only looking for “wear and tear” items associated with the water-based systems but also giving the system a clean bill of health from a design perspective
as well. The level of effort to produce this clean bill of health is significantly more than what the standard intends and requires an inspector to deliver.
Simply put, if a condition that is found in the field does not comply with the design standard, but the components observed are in good working condition, it would not be considered a deficiency or impairment per NFPA 25.
As outlined in Chapter 1, the scope of NFPA 25 does not require the inspector to evaluate the design and layout of the systems covered in the standard. The standard presupposes that the system, as designed and installed, complies with the applicable standards at the time of construction and at the points where changes were made to the building that would necessitate system modifications. The requirements in 4.1.6 address this concept by identifying that is it
the owner’s responsibility to understand the impact of changes in occupancy, use, process, or material. The requirements in 4.1.6 also state that at the time these changes are made, a hazard
evaluation must be conducted that will either confirm that the system(s) meets the design requirements of the applicable standard as currently installed, or that modifications to the system(s) must be made. In the event that changes are made to the building and this evaluation does not take place, any non-compliant conditions created by the changes are not the responsibility of the inspector to identify.
Case in Point
In some cases, a condition that does not comply with the design standard is relatively easy to identify. It can be identified from the floor level without the need of a lift, ladder, tape measure, or any other equipment. The first photo* shows a sprinkler that is several feet below the ceiling. In this instance, a drop ceiling was removed and the sprinkler was not relocated to within 12 in. (305 mm) of the ceiling as required by NFPA 13, Standard for the Installation of Sprinkler Systems. A similar case would be a sprinkler located too close to a hot air diffuser, as shown in the second photo*. Although the sprinkler shown is too close to the hot air diffuser per the spacing rules of NFPA 13, this is not a deficiency per NFPA 25 and should not be called out in an NFPA 25 inspection report.
That is not to say that inspectors cannot inform building owners that there might be an issue with a system as it relates to a design standard such as NFPA 13. The problem with providing a client with more information, though, is that it can open the inspector to liability. If an inspector is identifying some design deficiencies on an NFPA 25 inspection report, but not all of them, the line can become blurred as to the depth of the review and the inspector’s contractual obligation to the owner. Many owners believe that NFPA 25 requires the inspector to conduct a hazard evaluation, so when an inspector includes a few design deficiencies mixed in with proper NFPA 25 deficiencies, it can further muddy the waters.
Many inspectors feel that they have a moral and ethical obligation, as members of the fire protection and life safety community, to inform their clients of all potential concerns. One way to comply with the requirements of NFPA 25 while still satisfying that moral obligation is to keep two deficiency reports: one dealing with NFPA 25 issues and another that could be called the “good Samaritan” list. The NFPA 25 report would catalog wear-and-tear issues while clearly identifying the scope of NFPA 25. The “good Samaritan” report would list all other items that are beyond the scope of NFPA 25, along with a disclaimer stating that these items are not considered part of an NFPA 25 inspection program. This way, the scope of NFPA 25 is acknowledged, as are any and all problems observed during the inspection.
- Photo’s on page 88 of the 2014 Water-Based Fire Protection Handbook.
Annex B: Forms for Testing, Inspection, and Maintenance – Commentary
Any forms that are used for checking a fire protection system must comply with the reporting requirements of NFPA 25. Note that NFPA 25 does not have a specific form or series of forms that must be used when conducting inspection, testing, and maintenance (ITM) tasks. There is a common misconception that the inspector must fill out “the NFPA 25 form,” but the standard has no forms that are required to be used. This allows the owner and inspector to develop custom forms for their properties based on the systems that are present. There are several electronic reporting systems that are also available. Any system that meets the minimum reporting requirements of the standard can be used.
Where NFPA 25 is the standard adopted as code by the AHJ (the Northwest Territories for example), it is law. The “minimum reporting requirements” means that for a given system, all inspection, testing, and maintenance items identified by NFPA 25 that are relevant to that system must be addressed. As per the Office of the Fire Marshall, NFPA.25 2014 edition is now in effect.