Commissioning buildings for fire, life safety
The National Fire Protection Assn. recently adopted NFPA 3, Recommended Practice on Commissioning and Integrated Testing of Fire Protection and Life Safety Systems. The adoption of this document was controversial. Many wanted the document to be a “standard” instead of a “recommended practice.” Standards are more easily adopted into law and provide better enforcement language. Authorities wanted an industry standard so they would be able to enforce integrated system testing.
Others were concerned about mandating the commissioning process to all buildings if the document was made a standard. To resolve this issue, NFPA decided to create NFPA 4, Standard for Integrated Fire Protection and Life Safety System Testing.
This new document is still under development, but once it is complete, NFPA 3 will be revised to deal only with the commissioning process, and NFPA 4 will deal with the integrated systems testing.
The commissioning process focuses on three primary areas that are reviewed in all phases of the construction process.
1. Owner requirements: The purpose of the commissioning process is to deliver a building that meets the owner’s requirements. Therefore, it is imperative that these requirements be clearly defined and monitored for necessary adjustment throughout the process.
2. Commissioning plan: ASHRAE Guideline 1.5-2012 (replaces Guideline 5-1994 (RA-2001), Commissioning Smoke Management Systems, defines this as “The overall document that outlines the organization, scheduling, allocation of resources, documentation, etc. pertaining to the overall commissioning process.”
The level of detail in the commissioning plan changes over the course of the project. The initial predesign phase plan may only define players from a functional perspective with little or no detail on the process.
At the end of the construction process, detailed plans that include specific system and subsystem tests and inspections with associated pass/fail criteria are necessary.
3. Documentation: The third key element is documentation because “if it wasn’t documented, it didn’t happen.”
Testing and inspection in accordance with the commissioning plan must be documented in detail. Any noted deficiencies must be tracked through resolution.
Documentation is also used to communicate the status of the process to the project team.
One early decision that is a key component of the plan is who will be the commissioning authority (CxA).
ASHRAE defines the CxA as “The qualified person, company, or agency that will plan and carry out the overall commissioning process. There are many options as to which party to the commissioning process will be the ‘authority.’ The design professional, contractor, independent commissioning agency, or owner may be the CxA.”
This ASHRAE definition differs notably from the Building Commissioning Assn.’s (BCA) “Essential Attributes of Building Commissioning.” The BCA suggests that the CxA must be independent of the design and construction team.
The general positions on the two sides of this issue are discussed below.
Many times during the commissioning process it is discovered that systems do not meet performance requirements due to errors in the design. If a member of the design team is also the CxA, there is an obvious conflict of interest. Someone representing the design team may compromise the commissioning process to justify the design.
Those that support the use of a design team member argue that no one is more familiar with the design intent and project requirements than the designer. Using someone else for that function could compromise the original intent and ultimately could result in additional expenses for the owner for a perceived duplication of effort.
The possible conflict of interest may be clearer in the case where the contractor is the CxA. It is possible that system performance is impacted by improper installation. Corrections could lead to additional costs to the contractor, construction delays, or other impacts.
It is an easy position to advocate that the CxA should be independent, answering only to the owner. However, this arrangement does lead to some duplicity of effort for the “authority” with both the design team and construction team. It also results in additional owner costs.
Ultimately, the owner must weigh the pros and cons and make the best decision for the project.
What is clear is that, regardless of who leads the team, representatives from design, construction, and ownership must be integral participants in the commissioning process. Commissioning is not a post-construction review of installed systems; it is an integral part of the design and construction process. If fully implemented, commissioning also extends into ongoing building operations. Accordingly, it must be accounted for in project schedules, project resource allocation, and budgets.
Codes and standards
Many owners mandate the building commissioning process through their contract documents. However, no current model codes require total building commissioning. Some elements of the process are, however, mandated by the code.
For years, the model building codes have contained some form of a “Critical Structure Program” for elements of construction that deal with the structural integrity.
Under these programs, specific elements of the construction as defined by the design team (owner requirements) are inspected to code-mandated criteria (commissioning plan). Test results and inspection observations are recorded and filed with the building official (documentation).
More recently, the smoke control special inspector process has been added to the model building codes to assure proper commissioning of smoke control systems. These requirements were originally added to the Uniform Building Code in the mid 1990s. Today, the concept has been added to the International Building Code; NFPA 5000: Building Construction and Safety Code; and NFPA 101: Life Safety Code.
System installation criteria for fire and life safety systems are not detailed in model building codes. The model codes typically adopt by reference, installation standards.
Most of these installation standards contain acceptance testing criteria for systems or portions of systems. Examples include:
- Flush before backfilling
- Inspect restraint
- Complete contractor material and test certificate.
- Complete contractor material and test certificate.
These processes and others like them are an attempt to assure quality. However, the standard forms are not detailed enough for complex buildings to meet the commissioning criteria. Additionally, the processes allow for self-certification by the installing contractor, which is not acceptable under a formal commissioning plan.
Buildings, systems, and their related components have become much more complicated. These systems are more interconnected to achieve fire and life safety goals than they were in the past. The technology and flexibility of modern systems have created more opportunities for undetected human error.
The shift to performance-based designs brings with it a responsibility to confirm and maintain building performance. This is our responsibility as engineers with a public duty to design and build safe structures.
ASHRAE Guideline 0, The Commissioning Process, divides the process into phases that include predesign, design, construction, occupancy, and operation.
The primary objectives during the predesign phase are to select the CxA and to develop:
- The owner’s project requirements
- Scope and budget for the commissioning process
- An initial commissioning plan.
Fire protection and life safety requirements are rarely the driving force in the owner’s project requirements. As the project requirements dealing with items such as schedule and budget, user requirements, security requirements, and so on, are refined by the design team with the owner, the fire protection engineer must then determine appropriate fire protection requirements. Those requirements will probably include active fire protection systems such as:
- Fire pumps
- Fire alarms
- Smoke control systems.
The requirements will also include passive features such as
- Fire rated walls and doors
- Fire and fire/smoke dampers
- Egress systems
- Structural fireproofing.
During the definition of scope and budget for the commissioning process, potential areas of overlap between team members need to be identified and clarified.
It seems obvious that sprinklers, standpipes, fire pumps, and fire alarms fall under the scope of the fire protection engineer. Who is responsible for other systems and features is not as clear. For example: Should the mechanical engineer or the fire protection engineer be responsible for the smoke management systems? The mechanical engineer will likely have a better understanding of the operation of the air handling equipment, especially if it is also used for environmental air. However, the fire protection engineer will have a better understanding of how that mechanical equipment fits into the overall fire and life safety plan for the building. For example, the fire protection engineer will know which architectural boundaries must be in place for proper system operations during an emergency, which doors and/or dampers must be simultaneously controlled to create appropriate boundary conditions, and what impact system operation has on egress door opening force requirements and whether it is acceptable.
An appropriate division of responsibility in this case may be that the mechanical engineer is responsible for proper air handling unit operation and the fire protection engineer is responsible for system control and overall system performance, including preparing the rational analysis required for these systems.
Another typical area of overlap is building emergency power. Power distribution issues normally are the responsibility of the electrical engineer. However, emergency power is critical to many areas of fire and life safety such as emergency lighting levels and proper operation of equipment, like fire pumps, in an emergency.
It may be appropriate for the fire protection engineer to be responsible for correct emergency lighting levels and the proper operation of the transfer switch, which is integral to the fire pump controller. The electrical engineer would be responsible for commissioning all other portions of emergency power generation and distribution.
Scope overlap can occur as it relates to passive fire protection features. Who should be responsible for the commissioning process on structural steel fireproofing: the architect, the structural engineer, or the fire protection engineer? How about proper construction of fire-rated separations or proper hardware on rated doors and/or egress doors?
The overlap areas cited are common; however, this is not intended to be a comprehensive list. Each project will be different. The correct solution will also vary for each project based on factors that could include complexity, schedule, money, staff resources, commissioning team members’ competencies, and others.
The process directs that the scope and fee for the commissioning process be determined in this phase. That cannot be correctly done without going through this review.
There is one more critical scope clarification item that should be done in this phase. The fire protection and life safety features of the building are the most highly regulated piece of the construction process. The authority having jurisdiction (AHJ), usually either the fire marshal or the building official, will require documentation of completion of the fire and life safety features. He may also require that he witness the tests.
The fire protection engineer should be designated as the liaison with the AHJ as it relates to commissioning issues. The AHJ is not concerned if the building meets the owner’s criteria. He is only concerned that it meets a minimum standard of safety for use by the public.
The AHJ should view the fire protection engineer as his trusted advocate on the project team. That cannot happen if there are multiple points of interface to the project team.
If the AHJ requires that he witness system tests, scope and fee documents should reflect the costs associated with a complete successful pretest prior to testing with the AHJ.
Complex integrated fire and life safety systems often do not function correctly the first time, due to equipment failure, programming errors, or misunderstanding of the project design documents. Allowing the AHJ to witness a failing test can diminish his confidence in the project team and may prompt a higher level of scrutiny, which could ultimately delay the occupancy. The common excuse that we do not have time to pretest should never be acceptable.
At the conclusion of the predesign phase, the fire protection requirements for the project should be identified and documented. The scope of work and budget for fire protection commissioning should be defined and integrated into an initial commissioning plan.
Key objectives during the design process include:
- Verify that basis of design reports are consistent with owner requirements
- Update the commissioning plan to include construction and post-construction issues
- Develop construction checklists
- Define training requirements.
The fire protection engineer should be involved in either the preparation or review of the basis of design report for all active fire protection systems, including smoke management systems. In addition, he should design or review passive issues such as height and area compliance, construction type, approach to mixed uses, fire resistance assembly ratings, and egress.
Issues that impact fire department operations also require design or review, such as vehicle access, hydrant locations, fire department connection locations, fire control room location, and ladder truck reach.
During the design phase the fire protection engineer should pay special attention to integrated emergency operation of multiple systems. Common pitfalls include lack of coordination among sprinkler, fire alarm, and HVAC zones and with appropriate architectural boundaries. Some common errors include specification of duct smoke detectors by the mechanical designer that are incompatible with the fire alarm specified, conflicting number and location of sprinkler flow and tamper switches, and duplications and/or gaps in control and monitoring points between the fire alarm and building automation systems. Although these are normal design document coordination items, if they are not reviewed from a commissioning perspective, they may lead to later problems.
The fire protection engineer should be involved in the development of construction checklists for fire protection systems in accordance with the scope divisions agreed upon in the predesign phase. Several layers of checklists may be necessary for a system. As an example, to properly commission a stair pressurization system, the mechanical equipment (fans and dampers, injection points) must be verified, the integrity of the shaft enclosure must be verified, and door hardware and door forces must be verified. All of those steps must occur before the system can be fully commissioned.
Checklists developed at this stage of the project may require further refinement during the construction phase with information from the shop drawings. These checklists will be used to define the contractor’s responsibility under the contract documents and to continue the development of the commissioning plan.
The construction phase is the most labor-intensive phase for the fire protection engineer involved in the commissioning process. Key elements during this phase include:
- Review of shop drawings for fire protection systems for conformance with owner requirements
- Review of ongoing construction for conformance with owner project requirements
- Regular meetings with all parties associated with the commissioning of fire protection systems
- Revision of construction checklists to include detailed project specific information
- Verification testing of performance
- Coordination with the AHJ.
The contractor shop drawings need to be thoroughly reviewed for conformance with the project requirements. The drawings must be reviewed for coordination between trades. For example, in a fully sprinklered building with a smoke control system, the sprinkler, fire alarm, mechanical, and building automation system (BAS) shop drawings must all be reviewed and compared to confirm a common understanding of system performance and points of interface.
The shop drawing review process for fire protection systems happens in projects that do not go through the full building commissioning process. Sometimes that review is left to the AHJ, but often it is done by the project design team. However, it is very important that the fire protection engineer on the commissioning team review these documents. He will have the best understanding of the integrated operation of the systems. (The fire protection engineer on the design team can also be on the commissioning team.)
A thorough understanding of the systems at a shop drawing level is needed to generate the detailed performance checklists for the commissioning process.
Regular reviews of ongoing construction will help to prevent later corrections to improper construction. Establishing a good working relationship with appropriate trade contractors will make this process easier and mutually beneficial. While trade contractors may not appreciate someone looking over their shoulders, they do not want to redo substandard work.
All parties involved in the commissioning of the fire protection systems should meet regularly. The frequency of these meetings may vary based upon the complexity of the construction, the project schedule, and other factors. The first meeting should be scheduled early in the construction process.
At these meetings, all of the following should be discussed as it relates to each trade and each system:
- Status of the work
- Pending issues required for clarification to contractors
- Review of the status of previously identified deficiencies.
Checklists should be revised by either the trade contractors or the fire protection engineer to incorporate specific shop drawing details.
Components, subsystems, and systems must be tested for conformance with the project requirements. The verification test procedures should be fully documented before the tests. They should include test scenarios, required test and measurement equipment, contractors required to participate, and any other pertinent information.
During the construction process, the fire protection engineer must manage the interface with the AHJ. The AHJ should be kept up to date on the status of the work. There should be a clear mutual understanding of the AHJ’s expectations. The AHJ should not be scheduled to witness verification testing until a successful pretest has been completed.
Occupancy and operations phase
Depending on the scope of the project and the status of completion of owner requirements at occupancy, the fire protection engineer may or may not be involved in this phase. However, several activities must be completed.
Proper levels of training to building staff must be confirmed. There are numerous cases of large dollar losses from water damage due to sprinkler activation, which resulted from no one knowing how to shut down the system. This is one example of the potential negative results from lack of proper training.
Complete as-built documentation and operations and maintenance manuals should be turned over to the building operations staff. This as-built documentation should include periodic testing or maintenance requirements whether required by proper operation, owner requirements, or code requirements.
Initial operations problems may develop; they need to be investigated and resolved. Examples include nuisance alarms, pump cycling, and equipment adjustment issues.
Work continues on the development of a comprehensive industry total building commissioning process. As the development process continues, buildings must still be completed and occupied. Fire protection and life safety features are the most common reasons for delay in building occupancy. Proper commissioning of the fire and life safety features will ensure an on-time, quality product.
Thomas Brown is executive vice president at Rolf Jensen & Assocs. His expertise is in the design, installation, and commissioning of fire protection systems in complex commercial buildings. He has also spent a great deal of time reviewing post-incident failures of fire protection systems. He serves on numerous NFPA committees on fire protection systems.