The building owner has decided to test instead of replacing their installed sprinklers at the intervals required in NFPA 25. The qualified personnel of their designated representative has removed 4 or 1%, whichever is greater, of the representative sprinklers in a sample area defined by the building owner and sent them to an approved testing laboratory (e.g. Dyne Fire Protection Labs) for the sprinkler field service test. The laboratory has found one or more of the sprinklers in the sample set to be unacceptable – that is, one or more of the sprinklers in the sample set no longer meets the thermal sensitivity (RTI) and functionality (water way clears) requirements set forth by NFPA 25. How long does the building owner have to address such a failure?
NFPA 25, the Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, states that “where one sprinkler within a representative sample fails to meet the test requirement, all sprinklers within the area represented by that sample shall be replaced”. How long you have to replace those sprinklers depends on whether or not the failure will be deemed a deficiency (critical or noncritical) or an impairment based on the context of the failure and input from the authority having jurisdiction (AHJ). These terms are all formally defined in Chapter 3 of NFPA 25 (with further, explanatory material also found in Annex A) – in general:
- Noncritical deficiency: no impact on system function
- Example: the sprinkler has non-manufacture applied paint, but only on the frame such that the activation, release, and water distribution pattern of that sprinkler would not be affected
- Critical deficiency: system will function but not as well as intended
- Example: the sprinkler has a delayed release
- Impairment: the system will not function at all
- Example: the sprinkler does not activate or release at all
According to Table A.3.3.8 Water-Based Fire Protection System Inspection and Testing Findings in the current, 2023 edition of NFPA 25, sprinkler(s) that fail the laboratory testing could be either an impairment or a critical deficiency depending on the test results, the nature of the hazard, and life safety exposure. “A deficiency that is a critical for one hazard might be an impairment in another” (A.4.1.5). Classification of the failure ultimately requires careful judgment and input from an AHJ.
If the failure is deemed an impairment, that is, the sprinkler would not function at all, it “should be addressed promptly by either immediately correcting the condition or implementing the impairment procedures found in Chapter 15” (A.3.3.8). Specifically, note the following from 15.5.2 in Chapter 15 Impairments of the current, 2023 edition of NFPA 25:
(4) Where a fire protection system is out of service for more than 10 hours in a 24-hour period, the impairment coordinator shall arrange for one of the following:
(a) Evacuation of the building or portion of the building affected by the system out of service
(b) An approved fire watch
(c) Establishment of a temporary water supply
(d) Establishment and implementation of an approved program to eliminate potential ignition sources and limit the amount of fuel available to the fire
If the failure is deemed a critical deficiency, it “should be corrected as soon as practical after considering the nature and severity of the risk” (A.3.3.8) NFPA 25 also states “critical deficiencies need to be corrected in a timely fashion” (A.4.1.5) but, beyond that, no specific timetable is given by the standard. Again, careful judgment and input from an AHJ would be needed.
Please note that, while all of the above has referenced the requirements in NFPA 25, local jurisdictions can also have their own requirements for timely correcting impairments and deficiencies as well – always consider all applicable requirements.
If you have any questions regarding this article, please contact Dyne Fire Protection Labs at firstname.lastname@example.org or (800)632-2304.
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