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Author(s): Robert Solomon. Published on November 1, 2018.

In Compliance | NFPA 101

Fire protection system impairments


NFPA 101®, Life Safety Code®, mandates ongoing inspection, testing, and maintenance (ITM) provisions for all systems required in an occupancy, but sometimes things just happen—it’s inevitable that at some point the required fire protection systems in many types of occupancies will be out of service.

It might be a planned outage to conduct preventive maintenance. It could be a system failure or fault that can’t be repaired until the correct replacement components are available. Or it might be the result of an external event such as a natural disaster that causes failure of essential utility services including electrical or water systems. Regardless of the cause, what happens when the automatic sprinkler system isn’t functional or the building fire alarm system isn’t available?

Rather than stipulating a particular set of provisions, NFPA 101 mandates compliance with NFPA 25, Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems. NFPA 25 manages the ITM provisions for water-based fire protection systems with the ultimate goal of maintaining system readiness at a high level of reliability. It utilizes the concept of system “impairments,” including preplanned impairments, events that allow building owners to schedule outages, make arrangements with contractors to complete the work, and, at least in theory, minimize the amount of time a system is out of service. The companion type of impairment, an emergency impairment, is simply one that was not scheduled or planned.

The fundamental provisions from NFPA 25 are centered around a time-based threshold and do not require any special measures from the impairment coordinator until a fire protection system has been out of service for more than 10 hours in a 24-hour period. Measures related to the sprinkler system include evacuation of the building, providing a fire watch, establishing a temporary water supply, and establishing a program to eliminate ignition sources and available fuel. Neither NFPA 25 nor NFPA 101 specify a preferred option, and each particular circumstance or situation determines the best course of action.

Evacuation of the building is perhaps the least desired option for building owners, since the building is meant to be functional for occupants. Unless employees can relocate to a backup facility, that option may not be practical.

Providing a fire watch is often a preferred method, as it provides not only additional surveillance of the overall building but a way for trained personnel to intervene during the incipient fire stage. This option must be acceptable to the authority having jurisdiction (AHJ) and includes a mix of trained personnel with the ability to physically monitor the areas where the system is out of service, as well as the ability to provide fire department notification. NFPA 25 offers additional discussion on those responsibilities.

If the impairment involves only the loss of the external water supply, arranging a temporary hose connection between the hydrant and fire department connection might be the easiest solution. Other water supply sources can include a combination portable tank and pump, or a dedicated fire apparatus at the building site.

Isolating or removing flammable liquids and gases can be difficult to apply to some occupancies because it may result in the shutdown of the fundamental or basic operation of the building, especially if the structure is of an industrial or processing nature.

A parallel set of provisions exists for the fire alarm system components, but there are marked differences. NFPA 72®, National Fire Alarm and Signaling Code®, also utilizes the concept of impairment, which includes the need for a contingency plan for the impacted system. In this case, the service provider is responsible for notifying the AHJ when any system is out of service for more than eight hours. Offsetting or temporary mitigation measures are applied only when required by the AHJ. Similar to NFPA 25, NFPA 72 offers a list of considerations that should be weighed if the building fire alarm system is not functional.

NFPA 101 works to keep building systems and features functional and operational. When system failures occur, the prevailing requirements of the appropriate ITM documents give building owners, facility managers, and AHJs options to consider during the outage.

ROBERT SOLOMON is the director of building and life safety at NFPA.