Topic: Code Enforcement

Man inspecting and looking at a tablet

Automated and Remote Inspection and Testing of Water-Based Fire Protection Systems

Remote inspections and automated testing were trends that were gaining momentum in codes and standards and field application for several years. Then in the first half of 2020 when the COVID-19 pandemic was in its early stages and strict lockdowns were being enforced, it pushed this trend to progress even faster as many more realized its potential. During this time, the development of a proposed new standard NFPA 915, Standard on Remote Inspections, continued. While the proposed NFPA 915 will be broadly applicable to any inspection or testing allowed by the AHJ, there are already provisions in NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, that allow for inspections and tests to be conducted in an automated manner. Automated inspection and testing can be a very useful option but what steps must be taken to ensure it is equivalent to a person being at the location? If a fire pump demonstrates an abnormal condition during a test what must the response be and how is the condition corrected? Let’s take a look at the requirements in NFPA 25 to allow the use of technology for automated inspection and testing and the criteria to ensure it meets the same objectives as when they are conducted in person. The first thing to address is when and where automated inspection and testing can be utilized. NFPA 25 does not limit the use provided automated inspection equipment can meet the intent of a required visual inspection and automated testing equipment can produce the same action as required by the testing requirements. Beyond that there are a few other criteria specific to when automated inspection and testing is utilized such as where automated tests do not discharge water that at least once every 3 years the discharge must be visually observed. At that point it becomes a cost-benefit analysis for the stakeholders and primarily the building owner. Activities required at greater frequencies might present more of a benefit while those required less frequently might see less of a benefit. Let’s review the requirements specific to automated and remote inspections. To start, automated test devices must be listed for the purpose of the test being conducted if they are subjected to system pressure or are integral to the operation of the system during a fire event. The equipment must be such that its failure does not impair the operation of the system unless that failure can be indicated by a supervisory signal to the fire alarm system. Similarly, any failure of a component or system to pass an automated test must result in an audible supervisory signal and failure of automated inspection and testing equipment must result in a trouble signal. The monitoring and signals required ensure that instances where there are issues with the automated testing or inspection equipment or an unsatisfactory inspection or test result notification will be made and the situation can be remedied. The testing frequencies of NFPA 25 must be maintained regardless of the functionality of automated testing equipment and a record of all inspection and testing must be maintained in accordance with the requirements that apply to all inspection and testing. One of the benefits of automated inspection and testing is that there is not necessarily a need for personnel on site. However, certain circumstances might need to be addressed quickly. This is specified for no-flow testing of fire pumps. This testing is required on a weekly or monthly basis depending on the type of pump and the building it is located in.  The 2020 edition of NFPA 25 requires that when remotely monitored automated testing of the no-flow fire pump test is being performed qualified personnel must be able to respond to an abnormal condition within 5 minutes. In all reality, this means that a qualified person must be located on site. For the proposed 2023 edition which will be approved this summer that timeframe is to be changed to 4 hours. This additional time means that someone does not need to be immediately on site but can respond quickly enough to take the needed corrective action. The use of technologies to perform automated inspections and testing will only grow in future years. As it becomes more widely used, as building owners, service providers, and AHJs gain more experience, and the use expands into other areas of fire protection and life safety with the future publication of NFPA 915, it is very likely that the requirements will continue evolve
Person on a tightrope

A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 5 – Risk Assessments)

NFPA 70E®, Standard for Electrical Safety in the Workplace® Section 110.5(H) requires that a risk assessment procedure be developed as part of an electrical safety program (ESP). NFPA 70E is not a how-to manual for detailing a risk assessment procedure. It is also not appropriate for training an employee how to conduct the assessment. There are hundreds of valid methods of performing risk assessments for the thousands of tasks that could be conducted on the millions of pieces of equipment available. Section 110.5(H) requires a minimum of three things to be addressed and documented before any employee begins a task. The risk assessment procedure must detail the process that will be used to: identify hazards assess risks implement the hierarchy of risk controls Consistency is important when conducting risk assessments. Without it an employee conducting an assessment may tolerate a risk level that is not acceptable, ignore hazards that have been previously recognized, or improperly apply the hierarchy of risk controls. Training an employee to follow NFPA 70E Section 110.5(H) rather than your documented procedure will introduce such unsafe practices. Identify Hazards – NFPA 70E defines an electrical hazard as a dangerous condition such that contact or equipment failure can result in electric shock, arc flash burn, thermal burn, or arc blast injury. The two hazards (shock and arc-flash) currently covered by NFPA 70E are easily recognizable. The potential for an electrical shock typically at starts at 50 volts. An arc-flash burn begins at 1.2 cal/cm2. Contact burns can occur at temperatures as low as 44°C (110°F) if the contact is prolonged and as quick as a second above 80°C (186°F).  There currently is no consensus on what an arc-blast hazard is. NFPA 70E does not specify where any of these hazards exist. It is the role of the ESP to cover how equipment is evaluated to determine if these hazards are present during any task performed on equipment. Assess Risks - Human factors are generally recognized as being among the leading causes of injury and the potential for human error must be addressed in a risk assessment. This takes knowledge not only of the assigned task but also the location of the task, the equipment to be worked on, the tools to be used, competency of the employee assigned, and other issues. Working above a piece of equipment provides an opportunity for items to be dropped into ventilation openings or for an employee to choose to stand on the lower equipment rather than use an appropriate platform. Maybe an employee could confuse a Category I meter for a Category III meter because of a similar design. The risk assessment procedure should address what is to be considered a potential human error when conducting the specific task on the equipment in its installed location. Implement the Hierarchy of Risk Controls - The hierarchy of risk controls must also be addressed. It is beneficial to include a requirement for a risk assessment prior to purchasing or installing equipment to achieve the maximum benefit of the hierarchy. For installed equipment, requiring the assessment to retroactively apply the hierarchy to mitigate risks before the same task is performed again can increase workplace safety. The risk assessment procedure must require that elimination be the first control considered when planning a task. It must address why elimination was not used or required before applying other controls including personal protective equipment (PPE). Not having a documented procedure for conducting risk assessments is dangerous. Acceptable and unacceptable risks will vary. Electrical hazards will not be properly addressed. The use of PPE as the sole means of protecting employees will become commonplace. Inconsistency in risk assessments could put an employee at a higher risk of injury when conducting the same task on different equipment. Make sure a documented risk assessment procedure is part of your ESP and is used for every risk assessment.

A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 4 – Lockout)

Does your electrical safety program (ESP) lockout program require that employees follow NFPA 70E®, Standard for Electrical Safety in the Workplace® Article 120? That ESP does not comply with NFPA 70E and employees are being improperly trained if it does. NFPA 70E requires that a lockout program be established and procedures to be developed. It provides requirements that must be addressed but does not provide a procedure for any specific equipment lockout. A lockout program in the ESP must comply with the minimum NFPA 70E requirements even if it refers to an employer’s lockout program. NFPA 70E cannot detail the requirements referenced in Article 120. It is not typical for every employee to have the same experience or training. Does the documented procedure cater to the least experienced or a higher level? The lockout procedure must be applicable to the experience and training of the employee and the conditions in the workplace. It is probable that different lockout conditions are encountered at various locations in the workplace. A mechanical lockout procedure might be different than an electrical one. It is possible for a basic lockout procedure to be developed and a standardized procedure mitigates the potential for human error. A specific lockout procedure could be necessary for a given piece of equipment which in turn requires additional training. Equipment installed before the NEC requirement for a permanent locking means could require additional locking mechanisms which alter the basic procedure. The program must address the use of simple and complex lockout procedures. An ESP could permit a contractor to use their own lockout procedure or contractors could be trained on the facility lockout program. Whose program will be followed and who is responsible for training employees affected by a different lockout procedure? If contractor procedures are permitted, an employee must be assigned to review those procedures to determine that safety standards of the facility are being met. Without a review, it is possible that the contractor does not have one, or that their program is less stringent than the facility’s lockout program. There could be situations when multiple contractors from various trades are affected further complicating the lockout procedure to be used and the training required.  Remember that the lockout process is only one necessary step in establishing an electrically safe work condition. A well-developed lockout program is not as simple as it appears. A generic lockout procedure could address most equipment. A detailed lockout procedure might be necessary to fill in the gaps when using it on specific equipment. Affected people might include facility employees as well as contract employees. Sections 110.5(M)(3) and (M)(4) require a documented annual audit of the lockout program and procedures including witnessing their use in the field.  The ESP must address more issues than this blog points out. Make sure your lockout program and its procedures cover all the bases.

Impairment Procedures for Sprinkler Systems That are Out of Order

NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, provides the criteria for the routine activities that must be conducted to ensure that water-based fire protection systems can be relied upon in the event of a fire. These activities range from simple visual confirmation of some things such as valve position and room temperature on a more frequent basis, to much more complex activities such as full flow tests and internal assessments at longer intervals.  All of these activities are intended to keep sprinkler systems in working order. But what about when a system needs to be shutoff for repair or maintenance? What about when a water main is broken, a frozen pipe has burst, a fire pump has failed, or another major issue has been found during inspection or testing? At that point, the building contains a compromised sprinkler system and is no longer protected at the level that is expected while the system is in service. In NFPA 25, the term for a system that is out of order, is impairment, regardless of whether or not it was planned (see Deficiencies and Impairments of Sprinkler Systems). Impairments need to be addressed and resolved as quickly as possible in order to provide the expected level of protection for life and property. If the impairment is prolonged, additional measures need to be taken in consideration of life and property protection. Planning ahead Chapter 15 of NFPA 25 is dedicated to addressing the requirements that include the measures to be taken to ensure that increased risks are minimized, and the duration of the impairment is limited. A key provision here is that the property owner or designated representative must assign an impairment coordinator to comply with the requirements of the chapter (see Responsibilities of the Building Owner for Fire Sprinkler System Inspection Testing and Maintenance). The impairment coordinator should have a detailed plan, ahead of time for how they will handle both preplanned and emergency impairments and meet the requirements detailed below. Any preplanned impairments need to be authorized by this individual prior to removing the system from service. Tag Impairment System A tag must be used to indicate that a system, or part of the system, has been removed from service. The tag must be posted at each fire department connection and the system control valve, and other locations required by the authority having jurisdiction, indicating which system, or part, has been removed from service. Anyone who is shutting down a system should use tagging procedures even if the owner does not. Tags can also be itemized in a list to facilitate proper restoration of the system to working order. As tags are retrieved, they can also be used for verification that a valve or system has been restored to service. Impairment program While the system is out of service, NFPA 25 provides details on impairment programs and what they should cover: Determination of the extent and expected duration of the impairment Inspection of the area or buildings involved and determination of increased risks Submission of recommendations to mitigate any increased risks Notification of the fire department Notification of the insurance carrier, alarm company, property owner, and other authorities having jurisdiction Notification of supervisors in the areas affected Implementation of a tag impairment system Prolonged impairments In addition to these steps, what may be the most important or impactful provision is arranging for one or more of the following measures when the fire protection system is out of service for more than 10 hours in a 24-hour period: Evacuation of the building or portion of the building affected by the system out of service Implementation of an approved fire watch program Establishment of a temporary water supply Establishment and implementation of an approved program to eliminate potential ignition sources and limit the amount of fuel available to a fire Restoring systems to service When repair work has been completed and the system is restored to service, the following items need to be confirmed: Any necessary inspections and tests have been conducted Supervisors have been advised that protection is restored The fire department has been advised that protection is restored The insurance carrier, alarm company, property owner, and other authorities having jurisdiction are notified that protection is restored The impairment tag(s) are removed While we certainly hope that fire sprinkler systems can be maintained in continuous service there are times where planned service, maintenance activities or unexpected circumstances cause the system to be out of service. Assigning an impairment coordinator, planning ahead, and understanding Chapter 15 of NFPA 25 will help to minimize the risk posed while the system is impaired.

2021 “Ecosystem Year in Review Report” Highlights Successes and Tragedies and Resources Needed to Help Improve Global Community Safety

Fire and life safety deaths, injuries, and losses may be unexpected, but they do not happen by chance, according to the newly published 2021 Ecosystem Year in Review report by the NFPA Fire & Life Safety Policy Institute. The year 2021, says the report, was one of modest improvements and tragic setbacks that included massive wildfires, a fatal collapse of an elevated subway rail, and a hospital fire that all highlight how gaps in our global fire and life safety system can lead to tragedies. These and other examples illustrated in the seven-page report are the product of weaknesses in a community’s Fire & Life Safety Ecosystem, a framework NFPA developed in 2018 that identifies the components that must work together to minimize risk and help prevent loss, injuries, and death from fire, life, electrical, and other hazards. A lack of attention to any one of these elements results in greater risks and can create a significant safety threat. If just one element breaks down, people can be hurt. The Ecosystem is a key to understanding how decisions made over time can either exacerbate or control threats to safety. There are many steps to improving safety and more work to be done. But the key to reducing losses in the years to come is starting now to make these changes. Download the report to learn more. This year, the report is also available in Spanish and for the first time since the report’s inception, fire and life safety advocates can read the report in Arabic. Find additional resources and information about the Fire & Life Safety Ecosystem on our webpage.  

NFPA Electrical Inspection Membership: Building the Future One Connection at a Time

NFPA’s commitment to electrical safety has not wavered since our founding in 1896. Over the last 125 years, we have supported many different stakeholder groups (architects, contractors, designers, engineers, first responders, and inspectors, to name a few!), each with a unique role and different objectives, but all with the shared bond of a commitment to the elimination of death, injury, property, and economic loss due to fire, electrical, and other related hazards. Over the last several years, we heard a message loud and clear—the unique and independent voice of the electrical inspection community was being lost in a chorus of other sounds.  So we formed our Electrical Inspection Section, a member benefit available only to qualified individuals, in order to create a community for like-minded professionals to support each other in keeping communities safer through efficient and effective enforcement programs.We built the community so people could share ideas, network, help each other, and support the development and use of codes and standards.Today we are more committed than ever to supporting the electrical inspection community directly—so that NFPA can better understand the unique and diverse needs of a unique and diverse group of stakeholders, and we can work together in support of improved community safety through code compliance. A critical first step in connecting more directly is building a program to formalize these relationships, and so I’m thrilled to be able to talk about our new offering, the Electrical Inspection Membership.  This offer enables qualified electrical inspection professionals to enjoy a number of member benefits, including:  An introductory annual price of $99 A print copy of the 2023 edition of NEC as soon as it is available Access to NEC Changes Online Training (2017 and 2020 editions now; 2023 when available) Automatic enrollment in the Electrical Inspectors Member Section, including exclusive access to members-only content Access to expert 1-on-1 help with technical questions about NFPA codes and standards Subscription to NFPA Journal® with news and analysis of emerging issues Voting privileges after 180 days of membership We hope you’re as excited as we are to start building an engaged community so that we can drive compliance through collaboration and make the world a safer place! For more information and to apply, visit our page of resources for electrical inspection professionals
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