Use NFPA 3 for new, existing buildings
NFPA 3 defines commissioning and integrated testing of new fire protection and life safety systems in both new and existing buildings.
Commissioning (Cx) of certain building systems has been occurring for some time, stemming from U.S. Green Building Council LEED requirements or other requirements for green or high-performance buildings, to owners wanting their lighting and HVAC to run more efficiently to save on their monthly utility bills. Commissioning of such buildings and systems in the United States has been on the rise in recent years. There also has been a rise in commissioning of fire protection and life safety systems—not for utility savings, but for owners that want to confirm the fire protection and life safety systems are designed and installed to meet the overall project goals, comply with applicable codes, and provide protection to the building occupants, the building, and its contents.
A number of years ago, the National Institute of Building Sciences (NIBS) was pushing for a set of commissioning documents to set national guidelines. During this process NIBS reached out to NFPA regarding the development of a commissioning document that focused on fire protection and life safety systems. NFPA developed this document, which is called NFPA 3: Recommended Practice for Commissioning and Integrated Testing of Fire Protection and Life Safety Systems (2012 edition)
NFPA 3 was the first nationally recognized document addressing commissioning for fire protection and life safety systems and was also the first nationally recognized document addressing integrated testing of fire protection systems. In addition to outlining a standardized approach for commissioning and integrated testing, NFPA 3 also developed standard definitions for the industry, which were desperately needed. Even the term “commissioning” in the fire protection field had very different meanings to different people. Common terminology and meanings are crucial to having people understand and coordinate with each other during commissioning. For example, commissioning was often confused with acceptance testing with the authority having jurisdiction (AHJ), which is very far from the truth. NFPA 3 defines fire protection and life safety commissioning as “a systematic process that provides documented confirmation that fire and life safety systems function according to the intended design criteria set forth in the project documents and satisfy the owner’s operational needs, including compliance with applicable laws, regulations, codes, and standards requiring fire and life safety systems.”
The focus of this article is commissioning and integrated testing of new buildings and new systems. However, NFPA 3 also addresses commissioning of existing systems that have not been commissioned previously (retro-commissioning, RCx) and commissioning of existing systems that have previously been commissioned (re-commissioning, Re-Cx).
NFPA has since published a 2015 edition, but has broken commissioning and integrated testing into two separate documents. NFPA 3 (2015 Edition): Recommended Practice for Commissioning of Fire Protection and Life Safety Systems, and NFPA 4 (2015 Edition): Standard for Integrated Fire Protection and Life Safety System Testing. The 2015 edition of NFPA 4 was upgraded to the level of standard in NFPA because the committee felt there was a need for a rigorous standard on integrated testing of fire protection and life safety systems. Standards have more adoptable and more enforceable language for reference in building and fire codes because they use terminology such as “shall” rather than the term “should” that is found in NFPA recommended practice documents. This article addresses critical facets of both commissioning and integrated testing.
NFPA 3 (both the 2012 and 2015 editions) defines a process for commissioning, but does not specifically detail how to test a particular fire protection or life safety system. Other NFPA standards provide information on how to functionally test specific fire protection and life safety systems, such as NFPA 72: National Fire Alarm and Signaling Code for fire alarm systems.
Roles and responsibilities
The fire commissioning agent (FCxA) implements and leads the commissioning of the fire protection and life safety systems. In the capacity of owner’s representative, the FCxA provides another set of eyes and ears working in the owner’s best interest. Qualified FCxAs have an advanced knowledge of and experience with the installation and operation of the fire protection and life safety system(s) being commissioned.
The integrated testing agent (ITa) implements and leads the integrated testing of the fire protection and life safety systems to verify the proper interface and coordination between various fire protection and life safety systems. Qualified ITas also have an advanced knowledge of and experience with the installation, operation, and interfaces between the various fire protection and life safety systems being connected to each other. For example, fire alarm systems typically have different types of integration with other fire protection and life safety systems, such as sprinkler systems, smoke control systems, elevator controls, fans, card access systems, and emergency generators. The same person can be the FCxA and the ITa for a project, as long as he or she meets the qualifications for both positions.
The International Building Code (IBC) contains code requirements for special inspection of any smoke control system, which is analogous to commissioning. In IBC terminology the qualified commissioning agent may be referred to as the special inspector. The IBC also contains qualification requirements for special inspection agencies. So in regard to smoke control systems, the qualified FCxA commissioning smoke control is sometimes also referred to as the smoke control special inspector.
Commissioning of fire protection and life safety systems occurs in the design phase of the project as well as during the construction phase, with a comprehensive review and documentation of the commissioning process. Commissioning is not just showing up at the end of the project to test a system to see if it performs properly. For example, the FCxA reviews the design teams’ design documents, attends coordination meetings, reviews shop drawing submittals, reviews installation progress, reviews contractors’ pretest documents, and witnesses the systems perform in accordance with the commissioning plan.
There a number of documents during the commissioning process, but key documents include:
- Owner’s project requirements (OPR): This document should be developed early in the process and outlines the owner expectations and requirements for the project. For example, continuity of operations may be a critical feature of the building for an owner, and as such the OPR may contain goals or requirements, such as redundancies or advanced fire protection system features intended to reduce downtime due to a particular event,
- Basis of design (BOD): The document that outlines the specific criteria, concepts, and design approach for each fire protection and life safety system. This document is not only for the design, installation, and commissioning of the systems, but is also a critical document for the life of the building necessary for future reference and potential modifications to the systems.
- Commissioning plan: The document that indicates the process and specific tests that will be conducted in the field, and how those tests will be conducted for commissioning. In addition to functional testing of the equipment, this typically includes test scenarios and conditions, such as fault conditions or loss of normal power. The commissioning plan is developed and agreed upon early in the process, so that all stakeholders involved are on the same page and have a common understanding of what to expect for testing of the individual fire protection and life safety systems.
- Integrated test plan: The document that indicates the process and specific tests that will be conducted in the field, and how those tests will be conducted for integrated testing. The integrated test scenarios and conditions are intended to verify the proper interface and coordination between various fire protection and life safety systems with the intended outcomes (results), often done as end-to-end testing with no bypasses. This document also allows the various stakeholders involved to be on the same page and have a common understanding of what to expect for testing the interfaces of the fire protection and life safety systems.
- Commissioning (plan) record: This document is a single repository for all items related to commissioning of the fire protection and life safety systems and may include items such as, but not limited to:
- Commissioning plan
- Test scenarios
- Test procedures
- Integrated tests
- Submittal reviews
- Issues log (nonconformance log)
- Test certificates
- Testing documentation
- Approved operations and maintenance manual
- Recommended test frequency of the integrated test.
Stakeholders and Cx phases
The stakeholders for commissioning of fire protection and life safety systems may include:
- Architect and design engineers (A/E)
- Commissioning agent (CxA, if there is one on the project)
- ITa (may be FCxA, if qualified)
- Subcontractor (sub)
- Registered design professional (RDP)
- General contractor (GC).
Ideally, commissioning of fire protection and life safety systems occurs in all of the following phases:
- Pre-design phase (planning stage)
- Design stage
- Construction stage
- Occupancy stage
- Life of the building phase: building renovations, additions, or fire protection/life safety system replacements; and re-commissioning.
Cx and integrated testing example
The following building case study follows commissioning and integrated testing of a stair pressurization system through the various phases, outlines critical steps, and highlights some of the key issues that were identified.
During this phase the OPR were developed and the commissioning plan was started through formation of the commissioning team.
For the stair pressurization system, the commissioning team included a CxA responsible for overall commissioning of the building and the FCxA performing the commissioning of the fire protection and life safety systems. In this particular case, the FCxA reported to the CxA, and the FCxA was also qualified to serve as the ITa.
Key objectives for commissioning during the design phase were:
- Development and approval of the BOD for the various fire protection and life safety systems
- Development and approval of the sequence of operations for these various systems
- Development and approval of the project drawings and calculations
- Update of the commissioning plan
- Development of the integrated testing plan
- Review of the documents for compliance with the OPR and BOD
- Overall coordination and integration of the fire protection and life safety systems, including documentation and progress reports.
For the stair pressurization system, the FCxA was able to highlight a number of items that were not identified or addressed by the RDP for the stair pressurization system. These were items that the FCxA was looking for as part of the review and field inspection/testing performed during the construction phase. Several of the stair pressurization requirements that were not identified in the design documents were:
- The UL UUKL listing of the controls equipment for the stair pressurization system
- The service factor of the stair pressurization fan motor of 1.15 and the fan having 1.5 times the required number of belts
- The 2-hour fire resistive requirement for the power and control wiring of the smoke control equipment
- All smoke control wiring being required to be in continuous raceway
- The locally adopted requirement for having a blue LED light on the smoke control panel for the stair pressurization fan duct smoke detection.
During the design phase, these items were easily identified by the FCxA and incorporated by the design team into their documents. These changes were minor to incorporate during the normal design phase process, but allowed for more coordinated design documents and more accurate bidding by the GC and its subcontractors. The review, coordination, and resolution of these issues during the design phase was better for the owner, design team, RDP, subcontractors, and GC than the alternative of expensive field changes during construction that could also have an impact on the overall construction schedule.
The development and distribution of the stair pressurization commissioning and integrated testing plan during the design phase allowed the owner, design team, and the GC to have a better understanding of the system requirements, what the commissioning steps would be, what documents to expect, what test scenarios would be run, and what contractor pretests, commissioning tests, and AHJ tests were needed. Through this document, a higher degree of coordination of contractor manpower and the project schedule was possible.
This early establishment of commissioning plans allows for proper planning. One of the common misunderstandings is the need for comprehensive test scenarios. Testing is much more involved than running one test under normal, ideal conditions. Some of the comprehensive test scenarios for the stair pressurization systems included:
- Automatic activation under normal operation
- Automatic activation under fault conditions
- Manual activation of the smoke control panel under normal operation
- Manual activation of the smoke control panel under fault conditions
- Manual override at the smoke control panel of the automatic stair pressurization activation
- Confirmation of positive monitoring of fan status, damper status, and power status
- Performance measurements of the fans, pressure differentials, and door opening forces
- Performance of the stair pressurization system time requirements both for individual components to reach their desired state and the positive monitoring time of those components
- Full load test (integrated test) without bypasses, and including sprinkler activation, fire pump activation, fire alarm notification sounding, stair pressurization activation, off-site fire alarm signaling, loss of normal building power, and activation of the emergency generators.
Key objectives for commissioning during the construction phase were:
- Review shop drawings and equipment submittals for conformance to the OPR, BOD, and the construction documents.
- Witness stair pressurization duct leakage test from the certified air balancer and review certified air balance duct leakage test report.
- Conduct field inspections to verify approved equipment and wiring being installed and protected in the field at the approved locations.
- Witness component testing of the equipment properly functioning per the approved submittals.
- Witness performance testing of the fire protection and life safety systems. Stair pressurization system performance testing include pressure differentials, fan performance, door opening forces, and timing of the various system components.
- Document the process of commissioning the fire protection and life safety systems, including completed checklists, issues log, resolution of issues identified, and testing forms. Remember, if it is not documented, then it did not happen.
For the stair pressurization system, the FCxA was able to highlight a number of items, such as the need to pressure test the stair pressurization ductwork in segments. Since the stair pressurization duct could not be concealed until after acceptable results from the duct leakage test, this had an impact on the ability of the GC to push the project ahead of schedule.
During the performance testing of the stair pressurization system, the measured pressure differentials were lower than designed/expected. The FCxA was able to help identify a number of areas within the stair where penetrations needed to be sealed with UL listed fire penetration assemblies, including, ironically enough, the stair vent, as well as a missing exterior landing for the stair discharge door to the exterior. Once the penetrations were appropriately sealed and the exterior landing was completed, the tighter construction of the stair was able to meet the designed/anticipated pressure differentials.
The full load test scenario (integrated test) of the stair pressurization system on emergency power with the fire alarm system activated, fire pump running, and stair pressurization system running identified a problem with a breaker which was not previously seen during some of the other tests because they had lower partial loads on the emergency power system. This repair was able to be readily fixed. If this test was not conducted and in the future a real emergency happened, the system could have failed at a time when it was needed the most.
A majority of fire protection and life safety systems remain in the background of a building until an emergency occurs in the building, at which time they are called into action. The fire protection and life safety systems need to be reliable and spring into action at a moment’s notice to perform their desired function.
Key objectives for commissioning during the occupancy phase were:
- Final close-out documentation delivered to owner
- Proper training of facility staff on the systems
- Final as-built documents delivered to owner
- Copy of current site-specific software of the systems to owner as a backup
- Copy of the test and inspection records delivered to owner
- Copy of warranty information delivered to owner
- Copy of recommended or required inspection, testing, and maintenance delivered to owner
- Copy of the commissioning record delivered to owner
- Ongoing inspection, maintenance, and testing of the fire protection and life safety systems as required per NFPA and virtually every local jurisdiction for the life of the building
- Identification of the required periodic integrated test frequency by the ITa
- Ongoing periodic integrated test frequency for the life of the building.
It is crucial that the owners receive and maintain these documents, as these documents will be referred to and/or modified for the life of the building. Proper documentation allows for easier, more efficient, and less costly maintenance, inspection, and testing of the fire protection and life safety systems.
Over the life of a building, each building will most likely experience at least some of the following: additions, renovations, change of use, or system replacements. Key objectives for commissioning and integrated testing during the life of the building phase are:
- Determination if the project work requires commissioning or integrated testing
- Determination if the project work requires recommissioning or integrated testing.
The scope and extent of the project work has a large impact on the owner’s decision as to whether commissioning, re-commissioning, or integrated testing of fire protection and life safety systems is needed.
Benefits of commissioning
Another benefit of the commissioning process and having an FCxA during the construction phase is that better industry standards are followed. For example, it is generally agreed that a subcontractor should perform its own pretest to debug the system and verify it performs as intended, and for the installing contractor to certify its installation to the specific NFPA standard for that system prior to any tests with the RDP or the AHJ. Due to tight construction schedules and the contractor’s desire for higher profits, sometimes the contractor skips this critical step, when no FCxA is used, to see how much it can reduce the amount of time and effort necessary to test the system. This often means more inefficient witness testing by the RDP, the AHJ, and in some cases, the system was not being properly tested, resulting in a system or program that has issues or deficiencies that remain as part of the “approved system” in an occupied building.
The commissioning process helps assure the proper steps are being followed and that these systems work properly under various conditions/scenarios prior to these new buildings obtaining a certificate of occupancy and becoming occupied. The FCxA is expecting the contractor pretest documentation and NFPA installation certificates. Following these steps helps the owner receive what it paid for and have the building fire protection and life safety systems working properly when people move into and occupy the new building.
Comprehensive commissioning testing sometimes uncovers deficiencies that may otherwise go undetected. For example, on one project the full-load emergency generator test scenario for a smoke control system clearly uncovered the fact that several key dampers were inadvertently wired to normal power rather than to the emergency power that was required. Rewiring the dedicated circuit to the emergency power distribution panel corrected the installing contractor’s oversight.
A properly commissioned system has been debugged, coordinated, tested, and documented. This typically makes the final acceptance test with the local building and fire departments much easier because the systems function as designed/intended. Many owners and local jurisdictions can see the direct correlation between a properly commissioned fire protection and life safety system, the reduction or elimination of their punch list items, and retests of those systems with the local building and/or fire departments.
Fire protection and life safety systems are most often the final systems to be tested as part of the certificate of occupancy process, and as such they are also often the cause of costly delays in getting a building opened and occupied on time. The commissioning and integrated testing process helps to prevent such delays and occupy buildings on time, since the process helps reduce and eliminate many last-minute issues at the completion of the project.
Commissioning and integrated testing of new fire protection and life safety systems is on the rise because buildings are getting more complex and the benefits of the commissioning and integrated testing process are realized. To deal with tough design challenges, performance-based approaches are more often being used by design teams for these new buildings, which many times results in more complex fire protection and life safety systems. The systems, buildings, and building owners benefit from commissioning and integrated testing of these fire protection and life safety systems to confirm that the design objectives are being satisfied to provide a safe and code-compliant building. NFPA 3 (and now NFPA 4) provide nationally recognized processes for such commissioning and integrated testing of fire protection and life safety systems.
David J. LeBlanc is a senior vice president with Rolf Jensen & Associates (RJA), which recently merged with Hughes Associates. LeBlanc has more than 20 years of experience in fire protection and is an expert in smoke control and commissioning. He is on the technical committee responsible for NFPA 3 and NFPA 4, which outlines commissioning and integration of fire and life safety process.