Matt Klaus 2017-07-14 02:03:04
HOW A SOLID ITM PROGRAM CAN SAVE LIVES AND REDUCE LIABILITY making sure a building’s inspection, testing and maintenance (ITM) program is efficient involves more than just checking a box. When it comes to fire protection, a properly executed ITM program can be the difference between life and death — both literally and financially. ITM for fire protection is an often-overlooked life cycle activity because the systems are not used by building occupants on a daily basis. Unlike heating, elevators, restroom facilities and the majority of other building systems, it’s usually a good day when fire protection systems are not needed. Since the systems get very little attention from occupants, they often get very little attention from maintenance and budgetary perspectives as well. This can be a huge mistake because these systems not only keep people alive during a fire event, but also help reduce liability. To understand why ITM of these systems is critical, start with the industry standard on fire protection system ITM — The National Fire Protection Association’s standard NFPA 25: The Standard for the Inspection, Testing and Maintenance of Water-based Fire Protection Systems. NFPA 25 is adopted in most of the United States either through fire or building codes. In other instances, NFPA 25 might be enforced by an ownership group or insurance company where there is no legal mandate for an ITM program. ITM PROGRAM MANAGEMENT NFPA 25 can be misunderstood by facility professionals since the titles “property manager” and “facility manager” are not used in the standard. NFPA 25 is considered an “owners document,” meaning it is largely the responsibility of the owner to make sure these activities are happening. It is not the expectation that the fire service or authority having jurisdiction (AHJ) is actively enforcing the standard for each building in their jurisdiction. AHJs, like local fire or building inspectors, simply do not have the manpower to be witnessing inspections and tests for every commercial property. NFPA 25 puts the onus for carrying out these activities on the owner or the owner’s designated representative. The concept of “owner’s representative” is where the facility manager comes into play. When referring to an owner in NFPA 25, the expectation is not that the chief executive officer is down in the fire pump room performing the inspection. More likely, it is an in-house or contracted property manager or facility manager who’s responsible for executing the ITM program. The true owner, or ownership group, of a company will hold the liability and financial responsibilities if there is an issue with the system. However, from an execution perspective, the facility manager is commonly on the front lines. When property or facility management expertise is in-house, the requirements for carrying out ITM activities is part of the organizational structure. When those activities are hired out by a building owner, the transfer of responsibility for the ITM program should be addressed in writing in the contract. If the facility manager is taking over responsibility, that should be clearly stated, and the terms — especially where work like main drain testing and fire pump testing will be further subcontracted — should also be very clearly identified. The contract and terms become critical since it is not the expectation of NFPA 25 to have in-house staff and facility management conduct all the ITM tasks outlined. ITM service providers can be brought in to conduct system tests and perform inspections on a contractual basis. Therefore, the facility manager need not be an expert on fire protection systems, he or she simply needs to know what role is assigned in the standard. This begs the question, what are the NFPA 25 responsibilities of the owner or the facility manager? The responsibilities of the facility manager, if accountability for NFPA 25 compliance is assumed from the owner, are as follows: 1 Overall execution of the ITM program Many facility managers assume that if the fire department isn’t bugging them about ITM documentation, they are in good standing. Due to budgetary constraints and lack of staffing, confirming every activity outlined in NFPA 25 cannot fall on the AHJ. The facility manager must take responsibility for conducting all the ITM activities outlined. The facility manager can write a modified ITM plan or a performance-based plan if NFPA 25 is considered too onerous for the facility, but the plan would need to be approved by the AHJ. 2 Management of change NFPA 25 is a wear-and-tear document, therefore when an outside ITM service provider is hired to carry out an inspection, they are looking for systems or system components that are rusted, leaking, painted or in some other way not able to operate effectively. The outside service provider is not looking for design deficiencies or issues of non-compliance with the original design standard. Identifying inadequate sprinkler spacing, non-sprinkler areas or potential obstructions to sprinkler spray pattern development would not be part of an NFPA 25 inspection. Though these items may be present in a building being inspected, it is not the responsibility of the individual brought in one day a year to identify them. NFPA 25 works from the premise that building systems are “assumed to have complied at the time of construction or latest renovation.” If something has changed in the building (occupancy, use, stored goods, partitioning scheme, etc.), the owner or designated representative is responsible for managing necessary changes to systems based on operational changes. This is a big responsibility and one lost on many facility managers because they assume the outside inspector will provide support in a change management program. 3 Access to systems/components The facility manager must provide the ITM service provider with access to all equipment. This includes identifying the locations of specific system components, such as the fire department connection and inspector’s test connection. Service providers may visit hundreds of buildings a year, so they cannot be expected to remember where every component or system valve is located. If they are not able to access a piece of equipment or cannot locate it, they will likely skip that activity and note the reason why on their report. 4 Freeze protection Maintaining temperatures above 40 degrees Fahrenheit (about 4 degrees Celsius) throughout the building, or providing adequate freeze protection, is the responsibility of the facility manager. An ITM service provider may be contracted to perform an annual sprinkler inspection during a warmer month, but cannot be held responsible if the system freezes up a few months later. Where freeze protection is incorporated into system design using dry or pre-action systems (and antifreeze in older systems), the ITM service provider would be responsible for confirming systems and components are functioning, but not if they are necessary due to potential freezing conditions. 5 Notification to AHJ or supervisory agent When testing occurs, the AHJ and/or supervising agent must be notified of system shutdowns and potential for alarm. This is the facility manager’s responsibility, but it is not uncommon for the owner to transfer this responsibility to the service provider. Where there is an expectation the service provider will take on the responsibility, it should be addressed in writing in the service contract. 6 Corrective action The role of the service provider is to identify deficiencies when conducting an inspection. Very few service contracts give the service provider responsibility to take corrective actions as issues are identified. Therefore, once the inspection report is delivered to the facility manager, it is the facility manager’s responsibility to seek the means and methods to correct the issues. If these issues are not corrected and the AHJ becomes aware of them, the service provider has no culpability in the lack of action. 7 Recalled products Recalled products have been a topic of debate by the NFPA 25 technical committee for several cycles. In the 2017 edition, identifying recalled products is not considered a responsibility of the service provider. If the facility is concerned that there are products that are no longer acceptable or have been recalled, they would need to identify the products or have them identified as part of a system evaluation above and beyond what NFPA 25 requires. 8 Maintain records The facility manager is required to retain records for all ITM activities per NFPA 25. The AHJ is not required to retain records, but can come to the owner to look at any report or documentation. While most contractors keep copies of service records, it is not their responsibility to furnish documents for the AHJ should the facility manager not have a copy. TRACKING ADDITIONAL ITM TASKS In addition to assigned responsibilities in NFPA 25, some facility managers choose to carry out physical ITM tasks (or a portion of them) as well. When this happens, it is important the facility manager can clearly delineate which tasks were performed by facility staff versus which ones were contracted out. The role of the ITM service provider When contracted to perform ITM work on a system, the ITM service provider’s job is to execute the contract with the facility manager. This may include conducting tests, performing inspections or performing assigned maintenance activities. Some activities are rather simple (confirming a valve is open or reading a pressure gauge), while others, such as conducting a flow test on a fire pump or assessing the interior condition of the piping network, require significant formal training. Following these activities, the service provider’s job is to communicate findings to the facility manager. NFPA 25 does not require a specific form be filled out, so each service provider may have a different methodology and documentation. The service provider is also required to furnish personal protective equipment for work being done. The role of the AHJ AHJs are assigned a fairly hands-off role in NFPA 25. They are not expected to witness tests or inspections, but are permitted to. They are not asked to retain or review ITM records, but can ask for them when necessary. The major AHJ role in NFPA 25 is making sure impaired systems are brought up to code. Therefore, when a system is “red tagged” or deemed impaired, the AHJ would be notified and would approve an impairment program to assure the safety of building occupants as the system is returned to compliance. CONSIDER THE RISKS AND BENEFITS Fire events can be costly from property loss and life safety perspectives. Where there is no evidence that systems have been properly maintained or tested to confirm operational status, the owner could hold significant liability should a claim be brought against a company. Where ITM is effectively carried out, proper documentation can help illustrate to the courts that an owner has done everything possible to prevent injury or harm to occupants. The ITM arena has become extremely litigious over the last decade and there is frequent debate over which parties took which actions, so proper documentation is critical. The potential for saving the lives of building occupants and the chance to significantly reduce liability are huge benefits to running an efficient and effective ITM program. MATT KLAUS is a principal fire protection engineer at the National Fire Protection Association. He holds a master’s degree in fire protection engineering from Worcester Polytechnic Institute and is a member of the Salamander Honorary Fire Protection Engineering Society.
Published by International Facility Management Association . View All Articles.
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