Author(s): Robert Keough, Paul LeBlanc. Published on July 2, 2018.

Managing Magnitude

Hundreds of zones, thousands of devices, millions of square feet: How NFPA 3 and NFPA 4 are becoming valuable tools in the building commissioning process in Macau, home to some of the world's largest assembly occupancies.


For the last 14 years, Jensen Hughes has been involved with the building commissioning process in Macau, a special administrative region on the southern coast of China, across the Zhujiang River estuary from Hong Kong. Macau is home to some of the largest assembly-use buildings in the world, many of them mixed-use casino/resorts, structures that have earned it the nickname of “the Las Vegas of Asia.”

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Additional lessons learned from commissioning megaoccupancies.

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We have been part of the commissioning process for 11 projects in Macau, each with gross areas exceeding one million square feet. The first and smallest project for us was the Sands Macao, which opened in 2004 with approximately 1.7 million square feet. The Sands Macao was the first new casino after the Chinese government ended a four-decade gaming monopoly in 2002 and opened the market to six casino concessions. The success of the Sands Macao was immediate, with its $240 million in construction bonds paid off within nine months. This created a frantic construction boom of megacasino/resorts, the largest of which, the Sands Cotai Central, opened in 2012 with 13.8 million square feet—the equivalent of nearly 240 football fields. The price of construction increased with the size of the facilities, with the Wynn Palace Cotai, which opened in 2016 with approximately 4.8 million square feet, costing $4.2 billion.

As would be expected, the size and complexity of the fire protection and life safety systems in these facilities are proportional to the size of the buildings and can result in increased commissioning challenges. These projects can include over 100 peer-to-peer fire detection and alarm panels with hundreds of auxiliary power supplies monitoring and controlling more than 10,000 devices. Those devices, in turn, are integrated with over 100 sprinkler system zones, alternate suppression systems, elevator controllers, and more than 50 (each) smoke control and access control systems. This does not include the number of generators monitored, shutters and door closers controlled, and a variety of other emergency control functions associated with mega-integrated systems.

This challenge applies to commissioning approaches, too. Locally accepted processes and procedures for system commissioning may not address complete system integration or require the same level of system verification for performance, reliability, and survivability as demanded by NFPA, nor require the same professional qualifications and certifications.

The adopted codes and standards for the built environment define the fire and life safety system requirements. These requirements tend to become more complex with every new code and standard edition and are magnified as the system requirements increase with the size, use, occupant load, intricacy, and associated hazards. Considering that the casino/resort megaprojects being built in Macau include all of these challenges—and with assembly occupant loads in the larger projects comparable to small U.S. cities—the process of commissioning these systems can be daunting.

Our commissioning experience in Macau has led us to develop processes and procedures that parallel those identified in NFPA 3, Commissioning of Fire Protection and Life Safety Systems, and NFPA 4, Integrated Fire Protection and Life Safety System Testing. Jensen Hughes participated in the technical committees responsible for developing those standards, and we shared our experiences from commissioning these types of facilities with the committee. As with all complex integrated processes that involve multiple outcomes that need to be monitored and verified, successful commissioning of a system begins long before any testing actually starts and does not end after the building is occupied. The commissioning and integrated testing of the Macau megaprojects incorporated these concepts through all four phases of the projects: planning, design, construction, and occupancy.

Macau's Cotai strip at night with an array of resort/casinos

BIG, BIGGER, BIGGER STILL Macau's Cotai Strip includes an array of resort/casinos that are among the largest assembly occupancy structures in the world. Photograph: Newscom

Although many regions around the world are seeing a significant increase in the number of large and complex assembly facilities being built, the local codes regulating their development may not have kept pace with their size, complexity, or intended use. When this occurs, it is not uncommon for local jurisdictions to consider the adoption of NFPA codes and standards to supplement or replace local regulations. But the adoption of any new standard can be a challenge when a jurisdiction already has fire and life safety regulations in place that have worked relatively well for smaller, simpler buildings. Those same regulations may not fully address the unique architectural designs or unfamiliar hazards associated in larger, more complex facilities that have significant areas dedicated to high-occupant-load assembly use.

Through our work in Macau we have identified important ground rules for each of the four project phases that can help stakeholders avoid common mistakes related to commissioning. With the trend of building big being embraced around the world, anyone involved in the commissioning process is urged to consider a handful of key practices that can effectively shape expectations and streamline the steps necessary to getting a facility up and running, on time and on budget.


Identify commissioning challenges early

Obtaining and maintaining the attention, focus, and input from the project’s major stakeholders during the planning phase is always a major challenge. This is when critical decisions are made that will assist the project in meeting its budget and schedule, and for achieving optimum system performance during its life cycle.

NFPA 3 defines the planning phase as the period when the fire protection and life safety commissioning team is formed and initial project concepts and owner’s project requirements are developed. Knowing early in the planning phase what your commissioning challenges will be allows the fire commissioning agent to push planning goals to meet system performance objectives while understanding their limitations, with the additional objective of ensuring a minimum level of safety demanded by the adopted codes and standards.

In most casino/resorts, a major portion of the building is dedicated to assembly occupancies that include gaming, theaters, event arenas, convention spaces, conference centers, ballrooms, restaurants, bars, and similar spaces. Planning needs to recognize not only the size but the complexity of the fire and life safety systems. Code and standard requirements found in mega-assembly areas are generally more numerous and restrictive due to the high occupant loads; even the comparatively small Sands Macao has a total gaming area of approximately 229,000 square feet, with a legal occupancy load of over 20,000 in the gaming areas alone. The largest project, the Sands Cotai Central, has a total calculated building occupant load exceeding 176,000.

The planning phase provides the first opportunity to introduce stakeholders to fundamental challenges such as horizontal exits and exit passageways and how they can impact the design of the mechanical, electrical, and plumbing systems, fire protection systems, and building operations. Horizontal exits can impact fire alarm evacuation signaling zones, and sprinkler zones and smoke zones often need to be coordinated with the horizontal exit boundaries. Fire-resistance-rated boundaries need to have combination fire and/or smoke dampers, which require interconnected controls from associated smoke detectors. Horizontal exit openings require standpipes on each side of the wall adjacent to the opening.

Elevator control room for a megaoccupancy building Fire alarm system of a megaoccupancy building

COMPLEX OVERLAP Commissioning and testing challenges for megaoccupancies include extensive elevator controls (top) and fire alarm systems (bottom). Photograph: Jensen Huges

Commissioning can include verifying passive fire protection features, and exit passageways can present design challenges that should also be addressed during the planning phase. Stakeholders should understand that they need to treat an exit passageway as they would a vertical exit enclosure—meaning that system penetrations into and through exit passageways are prohibited unless the system is dedicated to the exit passageway. Designers often look at exit passageways as horizontal shafts or as storage areas due to their increased width, but this is a point that the fire commissioning agent can clarify, preventing unnecessary design changes and saving time and money in the overall process.


Consider alternate means for materials and practices

NFPA 3 defines the design phase as the period when the basis of design is produced, when drawings and calculations, including those for design and fabrication, are produced, and when testing procedures are developed.

It is important to remember that fire and life safety regulations represent, in the most general terms, an acceptable level of safety for the locality. What is required to achieve this level differ significantly depending on the locality, and this applies to statutory design requirements, too. Codes and standards, including those from NFPA, are specific on the manufacturing and performance standards for products that may not be easily found locally or where there is little or no experience with installing the products. Installation experience is often critical to a system’s reliability, performance, and, in the case of fire and life safety systems, survivability.

Our experiences in Macau have shown us that it makes operational sense to accept alternate means and methods related to products, equipment, and construction system components or installation practices if equivalencies can be proven. It is best that this issue be addressed early during the design phase so that all relevant stakeholders become aware of the adopted material standards and listings to give them adequate time to research acceptable equivalencies to submit for approval.

Atrium at the Venetian Macau

IMPACT OF SCALE A public area in the Venetian Macau. As building size grows, experts say, the commissioning and testing processes become correspondingly more complex. Photograph: Getty Images

Stakeholders should be provided with the system test methods before they begin to lay out the systems—though this can result in additional challenges. The pace of the Macau projects is breakneck—the 10.5-million-square-foot Venetian Macau, for example, was designed and constructed in three years, and that was after reclaiming the building site from a mudflat that was mostly underwater—and testing of these alternative materials and methods can easily be overlooked in the rush to get the facility built. The fire commissioning agent needs to be aware of this fact and make all parties aware of these testing needs during both the design and construction phases.


Allow for phased system testing and control group testing

The construction phase is defined in NFPA 4 as “the phase during which the systems and materials are fabricated and installed, tested, and accepted.”

NFPA 4 requires end-to-end system testing: that is, a test from the first input of the first system to the last output of the last system. The purpose of the end-to-end test is to observe the response of the applicable system components rather than to measure the performance of the overall system. The standard allows control group testing to meet the goal of integrated system testing, which is to “demonstrate that the final integrated system installation complies with the specific design objectives for the project and applicable codes and standards.”

A common challenge among our Macau projects is the integrated commissioning of the fire detection and signaling system, which is the common integration hub for the majority of fire protection systems. Besides providing fire detection, it is common for the system to monitor and control a wide variety of associated systems, including sprinkler and alternate fire suppression systems, smoke control, access control, HVAC, elevators, escalators, background music, lighting, and others. Megaoccupancies make it impractical and virtually impossible to test every aspect and function of the system concurrently; the fire alarm system for the Venetian Macau, which includes the Parisian and the Plaza Macao, has over 25,000 addressable fire alarm points, and every possible variable cannot realistically be accounted for in integrated testing.

Although it may not be necessary to witness the performance-associated function every time the initiating device is activated, NFPA 72®, National Fire Alarm and Signaling Code®, requires the verification of “emergency control function interface device activation” during initial, reacceptance, and periodic testing. The challenge is to accomplish this in an extremely large integrated system with interconnected systems and functions that will not be ready for testing at the same time. For example, in a high-rise with a control group of over 100 smoke detectors that will recall an elevator when individually activated, it is not necessary to recall the elevator over 100 times when testing those individual smoke detectors. This is where a control group test can come into play—it is acceptable to develop testing scenarios that verify the activation of all relevant fire detection control devices related to elevator recall when the initiating devices within the control group are activated, provided the scenario includes the actual recall of the elevator during the testing of at least one initiating device in the control group.

Our testing approach is to verify the function, such as elevator recall, with the activation of the first and last device within the initiating control group. The first device ensures that the actual emergency control function performs as intended, which can be rectified if the function does not perform as intended while the other initiating devices are tested. We can then confirm that the emergency control function performs correctly upon the activation of the last device, providing final commissioning verification.

Although this approach provides assurances of an interfaced system function, it is seldom possible to obtain the same level of assurance when multiple systems with different functions are activated from the same initiating devices within the control group. Consider the elevator recall function; due to construction scheduling on a large-scale project, it may be necessary to finalize the integrated relationship between the fire detection system and elevator recall before the smoke control functions are ready for testing, even though both may be activated from common initiating devices. Although you can use the same “first and last” testing methods for the smoke control system used previously for elevator recall, the activation of some of the smoke detectors related to the smoke control testing will also activate the now-functioning elevator recall.

This is a common dilemma associated with the project schedules of large systems, where an initiating device will belong to multiple control groups that activate different functions that are not or cannot be completed and ready for testing at the same time. Being aware of these challenges when developing the commissioning plan and integrated test procedures allows the commissioning team to make provisions to temporarily disable the interconnection to functions not applicable to the specific integration test.

Even so, all stakeholders need to accept a common feature of commissioning large and complex fire detection and signaling systems, which is that the process is rarely a one-and-done proposition—numerous initiating devices will be interfaced to multiple emergency control functions that will not be completed and ready for testing at the same time. Even when those functions are ready at the same time, the size and complexity of the system may make it impractical to verify the performance of all the functions concurrently, which will require redundant activation of the same device. Test what you can, document and track the results, and continue until system performance is verified as meeting design goals.


Revisit problems until you get it right. Prepare for ongoing inspection, testing, and maintenance of the fire and life safety systems over the life of the building.

As commissioning and integrated testing agents on multiple Macau projects, we have observed that there is often a need to revisit issues to make sure system requirements are properly addressed, even if challenges typically addressed in the construction phase extend into the occupancy phase.

Although projects in Macau are required to submit the various required documentation, it often becomes apparent during the latter phases of commissioning that the documentation does not address all challenges comprehensively. This can be due in part to project stakeholders’ lack of experience with the adopted codes and to the local design and construction culture. Most stakeholders are not familiar with the relevant codes and standards, especially how these requirements can impact a project’s architectural features, intent, and functions.

For the Macau projects, the owners and architects initially adopted alternate codes and standards because they allowed large and open assembly spaces that were not permitted under local regulations. The local building and fire departments accepted this approach because the new regulations were comprehensive and addressed the unique architectural concepts and hazards found in casino/resort megaprojects. But the overall impact on a project’s architecture and systems is seldom understood or appreciated until the new requirements are enforced—and that can sometimes require multiple attempts before an acceptable level of system performance is achieved.

Overhead photo of a UFC fight

STAGE & RING Spaces such as theaters and arenas, common in large casino/resort facilities, can pose additional commissioning and testing challenges. Photograph: Getty Images

Macau is familiar with smoke exhaust systems, for example, but their performance objectives were limited in comparison to smoke control systems as defined by NFPA. The introduction of smoke control as a life safety system with engineered performance objectives to provide a tenable environment for exit access was a fairly new concept to authorities in Macau. As a complex life safety system, smoke control has multiple integrated functions that commonly include fire detection, sprinkler control, and air handling systems that require extensive positive-status monitoring by the smoke control system during both its passive and active states. The complexity of this integration was a new concept to most stakeholders and required comprehensive education and coordination throughout all phases of the commissioning process to ensure successful system performance.

Additionally, the occupancy phase needs to include the establishment of a system inspection, testing, and maintenance process for the life of the building. Even though system commissioning and testing methods are closely related to the system’s maintenance requirements, specific maintenance guidelines are not comprehensively addressed by all codes and standards.

NFPA 3 and NFPA 4, by contrast, thoroughly define commissioning needs that should be used by code developers and manufacturers to further integrate their requirements and products into the overall design development and eventual maintenance of these systems. Consider fire detection and signaling systems, for example. Both the building- and system-related codes have expanded the design development requirements over the years to address system performance and installation needs, but the enhanced design requirements do not require comprehensive justification of the system layout in relation to the eventual need to test and maintain the system. The reliability and performance of large systems would benefit from a rational analysis that addresses circuit layouts, grouping of emergency control functions, evacuation signaling zones, and other integrated functions with the goal of developing a maintenance plan that limits the disruption of building operations during scheduled testing.

GOING FORWARD, these types of tools and practices will be instrumental for managing commissioning and testing as megaoccupancies become more popular around the world. We will likely need to amend some of the tools we have and develop new ones. Codes and standards developers, for example, need to recognize that as system complexity increases, simplified system controls are needed to disable and reinstate system functions by area, group, or type for testing. Present regulations require limited system controls for emergency operations and resetting, but there are few system control mandates related to testing and maintenance.

Positive-status field monitoring capabilities dedicated to testing and maintenance could significantly improve the effectiveness of the process. The ability to obtain positive feedback from a fire alarm interface device—that it received an actuation message without activating its associated control function during testing—would greatly simplify testing methods and the amount of time devoted to testing. Fire commissioning agents could activate a large group of initiating devices associated with a common elevator, damper, or notification zone without disrupting building operations with repeated tests. Providing inherent visual and audible status monitoring of notification devices could allow testing of thousands of devices within seconds, instead of disrupting operational functions for hours or days during testing.

It is understood that manufacturers may be reluctant to develop capabilities that improve testing ease and efficiency, since the improvements may decrease their maintenance revenue. But if code authorities continue to relate safety to available fire protection system performance, then they should also recognize that the reliability of a system’s performance is directly related to its testing and maintenance. A code’s mandates related to maintenance should have the same weight as those related to the system’s performance.

Ultimate success depends on thorough design reviews, inspections, and maintenance, not just documenting system testing. It must always be remembered that the ultimate goal is not for the system to pass an acceptance test, but rather to survive actual emergency conditions while meeting required performance demands. This can only be achieved if the system is available and performs as designed—the definition of reliable.

ROBERT KEOUGH, P.E., FSFPE, SET, is sr. vice president, Pacific Rim Operations, for Jensen Hughes. DAVID LEBLANC, P.E., FSFPE, is a vice president and commissioning service lead for Jensen Hughes. Top Photograph: Getty Images