Use NFPA 3 to coordinate fire and life safety projects

NFPA 3 takes a contemporary approach to construction and focuses on commissioning the fire and life safety systems throughout a project, rather than at the end.
By Corey L. Wallace, SET, PE, Southland Industries, Las Vegas March 25, 2013

Southland Industries installs fire protection systems at a data center project in northern Virginia. Courtesy: Southland IndustriesWhen NFPA released the 2012 edition of NFPA 3: Recommended Practice on Commissioning and Integrated Testing of Fire Protection and Life Safety Systems, a much-needed comprehensive commissioning document for the fire protection industry was made available. Without the use of NFPA 3 as a guideline, projects with complex system arrangements and testing requirements risk portions of their interface being overlooked by both the design team and the installation contractors.

Such complexities of the fire and life safety system interactions are often the reason for scope gap, causing stakeholders to remain unaware of issues until the project is near completion—a course of action that can generate chaos when the contractor is attempting to turn over the project to the owner and meet the scheduled project deadline. Rather than waiting until the end of the project to begin coordination of testing procedures, projects should use preplanned and fully coordinated fire and life safety commissioning plans.

Most codes are vague or even silent on the coordination of the various trades and disciplines, especially as it pertains to integrated system testing and confirming that the fire protection systems function as intended by the owner and design team. These codes do an excellent job of covering individual sub-system testing requirements but can often lead to conflicts between the testing requirements of the integrated system.

Failing to coordinate fire and life safety commissioning activities can raise the following questions:

  • How does the double interlock pre-action system operate with the fire alarm system during testing, and will both systems be ready for testing at the same time?
  • What is an acceptable test result specific to the project with complex requirements?
  • How does the clean-agent gaseous suppression system operate with the fire alarm system?
  • How is the integrity test for the room with gaseous suppression conducted?
  • How does the smoke control system react to the fire sprinkler system flow switch, and what type of annunciation is chosen?
  • Is the flow switch on the standpipe system to generate a supervisory or alarm signal?
  • Where does drainage occur when testing fire sprinkler systems?
  • What disruptions occur after occupancy during future testing, and how has this been coordinated?
  • What are the proper metrics for current and future testing of the systems?
  • At what stage of construction will the testing occur, and does the schedule support this goal?

Existing methods and tools

Jurisdictions such as Las Vegas, Los Angeles, and New York City, as well as the U.S. government have vast experience with large and/or complex facilities. Similar jurisdictions regularly use the fire and life safety report option to address unique scenarios. The purpose of the fire and life safety report is to designate one person or organization responsible for illustrating how the different fire protection features interrelate to provide the appropriate level of protection for the facility. In addition, the report is intended to address any aspects of the fire protection strategy that are unique to the facility or that may contradict base code requirements. The ultimate goal is to gather consensus from the authority having jurisdiction (AHJ) and the design professionals prior to the construction phase because doing so allows the overall design concepts of each discipline to operate cohesively. However, the missing step is gathering these same important pieces of the puzzle and incorporating them throughout the construction phase, commissioning phase, and the entire lifecycle of the building.

Many large projects require the development, documentation, and implementation of testing procedures. Reports generated during this activity provide the owner and maintenance entity with testing requirements that are unique to the property. Specific codes are addressed, but so are requirements that fall in a grey area not truly addressed by codes. Often this testing document is developed in isolation from the other disciplines, which can cause the testing procedure to become an afterthought. Instead, a commissioning plan established early in the project scope development can be tracked to anticipate and resolve conflicts before they occur.

Documents such as the Unified Facilities Criteria 3-600-01 used by the U.S. Dept. of Defense and the General Services Administration (GSA) P100 document clearly recognize the need for a fire protection engineer and a fire and life safety report to align all aspects of fire protection on a project. The P100 document takes an additional step in section 7.17 by directly addressing “Commissioning Fire Protection and Life Safety Systems” through the use of the GSA Building Commissioning Guide. The GSA commissioning guide requires much of the same documentation prescribed by NFPA 3. However, the NFPA 3 document provides a detailed guide to meet the requirements of a comprehensive and well-planned commissioning scheme for various jurisdictions, rather than just those of the GSA. Furthermore, the NFPA 3 document sets basic requirements, standardizing the appearance of the report. For these reasons, the development of this document by the NFPA will be more readily adopted by local authorities and provide more flexibility for project specifics.

Information in NFPA 3

The 2012 edition of NFPA 3 was approved as an American National Standard and became effective Aug. 31, 2011. The document was developed to provide a systematic approach to confirming that the fire protection and life safety systems operate as desired by the owner and design professionals. It can also be used in conjunction with other documents to create a complete building commissioning plan. The formal scope of NFPA 3 is as follows:

“1.1 Scope. This recommended practice provides the recommended procedures, methods, and documentation for commissioning and integrated testing of active and passive fire protection and life safety systems and their interconnections with other building systems.”

Definitions critical to understanding the NFPA 3 document include the following.

1. The AHJ is the entity responsible for enforcing the requirements of codes and standards and makes the final determination on system compliance to these documents.

2. The owner’s program of requirements (OPR), also known as the program of requirements (POR), is the owner’s vision of the facility. The owner’s expectations and needs are placed in this document to assist the design professionals in developing the proper product. This document is also used in the project bid phase to normalize what each bidder provides as a solution.

3. The basis of design (BOD) is the abstract or consolidated narrative used to describe how the design professionals’ design will meet the owner’s project requirements.

4. The fire commissioning agent (FCA) is a person or entity identified by the owner to lead the fire protection and life safety team in the commissioning process. This person plans, schedules, documents, and coordinates the various efforts with the assistance of design professionals and construction team members. The FCA should have the ability to provide an objective review of the project commissioning process.

5. The registered design professional (RDP) is an individual registered or licensed to practice a particular design profession as defined by the laws or statutes in the jurisdiction of the construction. The jurisdiction may also recognize other qualifications or credentials determined acceptable.

6. A fire protection system is equipment, a collection of devices, or a combination of items that detect fire (or a by-product such as smoke) and activate an alarm or suppresses the fire, or control the fire and its by-products.

7. Life safety systems enhance or facilitate evacuation or other actions to keep occupants safe. These actions could include smoke control or fire segregation within a compartment.

8. Integrated systems are a combination of systems operating as a unit to meet a fire protection objective.

9. Interconnected systems have components or devices connected to achieve a fire protection objective.

It is important to note that NFPA 3 focuses on four main phases. Chapter 5 indicates that these phases should include, but are not limited to, the planning phase, design phase, construction phase, and occupancy phase. Each phase requires specific components to be executed for a successful project outcome.

At BRAC-133, Alexandria's Mark Center, the new location for the Washington Headquarters Service, Southland Industries designed, installed, and commissioned the fire and life safety systems. Courtesy: Southland IndustriesThe planning phase focuses on the project objectives and the owner-driven program requirements. The commissioning agent is selected and the scope for this agent is solidified. The commissioning plan will remain preliminary due to the early stage of the project design development. Laws, rules, regulations, and policies should be identified and verified during this phase. If the project will occur during the release of a new code edition (e.g., International Building Code), the applicable code should be verified to eliminate any design uncertainties. Then, the fire and life safety commissioning team should be selected. The contract may not have been awarded during the planning phase, but the required roles for the team can be assigned and included in the bid documents. This level of planning will reduce the opportunity for scope gap and project responsibilities.

Upon reaching the design phase, the design team should be selected and the design contract awarded. The makeup of this design team will be different for a design-build contract versus a plan and specification contract, but the overall process will remain the same. The BOD will be developed to convey the design team’s method of meeting the owner’s requirements. The BOD narrative should paint a clear picture of the future design prior to the investment of a full design. This process will help initiate dialogue between the design team and resolve any potential conflicts due to miscommunication. If integrated systems exist, concepts such as sequence of operation and the impact of these interactions should be analyzed.

The testing criteria should focused more on the actual design needs than the conceptual ideas. As the design phase progresses, equipment will be selected and operation and maintenance manual requirements will be incorporated. The training requirements for operational personnel can also be determined in this phase. Finally, the design should take into consideration and allow for the proper testing of these fire protection systems. These considerations could be as simple as including an additional control valve for isolating a section of the fire sprinkler system or as complex as revising the active and passive zones for a smoke control system.

Next, the commissioning activities of the construction phase will back-check compliance with the owner’s requirements, BOD, shop drawings, and design team requirements. The construction phase will confirm if the previous commissioning schedule is still valid or if adjustments are needed. During this phase, documentation of testing, revised testing procedures, and completion of testing will be performed. Systems will be inspected and tested according to the applicable code or standard and in compliance with the overall commissioning plan requirements. The owner or operation personnel may also be trained during this phase. After completion of installation and acceptance testing, closeout documents should be provided to the owner as required by the commissioning plan and the contractual obligations of the project.

In the past, the occupancy phase has generally not been considered a part of the commissioning phase in fire and life safety systems. However, NFPA 3 takes a different approach to this concept. This phase will document completed and outstanding acceptance testing and inspections. Tests due to changes during the construction phase will be performed and recorded here, as will seasonal tests such as stair pressurization. Training may also occur in this phase. All testing and inspections records, warranties, recommended preventive actions, and lists of required maintenance should be provided during this phase.

Planning phase

The planning phase includes development by the owner’s design professionals to address the needs of the facility. These needs comprise the useable area requirements, basic area configurations, required minimum and maximum room dimensions, area uses, anticipated occupant characteristics, and other high-level user needs. The code analysis was performed by the owner’s design professionals prior to the mechanical and fire suppression contractor’s involvement. The applicable codes to be met as well as any other requirements in excess of the minimum code were previously identified. The need for a commissioning plan was determined with specific details of each system delegated to the design-build team—similar to a deferred submittal. The design-build team was awarded the project based on factors such as qualifications, overall value, and justification of how the owner’s needs would be met through a preliminary BOD document.

One of the contract documents requires that the commissioning agent be separate, both by contract and employment, from the design team. The intent of this requirement is to meet NFPA 3 section 4.2.1.1.3 and provide an objective and unbiased point of view on how the systems operate and work together. The commissioning team includes the following:

  • The owner’s project manager
  • Operating personnel representatives
  • Owner technical experts
  • The design-build construction contractor and subcontractors/engineers (design professionals)
  • Commissioning agent
  • Architect
  • Life safety engineer.

The design-build contractor and the design-build subcontractor concept reduced the amount of stakeholders by not having an engineer and contractor from separate organizations. The process also combined elements from the design phase into the construction phase and vice versa.

Design phase

Southland Industries project foreman James Clayton (left) and journeyman Bill Witt tighten the gaskets on a check valve before flowing the two 4500 gpm fire pumps. Courtesy: Southland IndustriesThe design phase includes developing and revising the initial BOD, specifications, drawings, calculations, and coordination between disciplines; and coordinating the interaction of testing procedures. There will be a total of six submissions during the design phase. These submissions ensure that the owner’s needs are captured and revised as necessary. Throughout this process, the commissioning schedule and commissioning criteria will be revised to meet the design changes prompted by the review process. Sequence of operations and performance objectives are identified in this process. The owner’s expectations are fully vetted to assist in meeting all stakeholders’ expectations. The presence of all stakeholders allows the cause-and-effect relationship to be determined and rectified more efficiently.

One example of the changes to the commissioning plan and the overall design is a potential modification based on building area use and configuration revisions. If the systems are altered to accommodate the new needs of the space, so would the testing requirements and durations of the testing. An area specified for storage has a tentative reconfiguration and possible ceiling height increase of 2 ft. The desired change could potentially increase the fire sprinkler system demand, causing the secondary water storage tank size to increase from 63,000 gal to 180,000 gal. This change could also affect the required ratings of the fire pump.

The importance of NFPA 3 is to capture the domino effect by such a change. A larger fire pump requires a larger amount of water to be discharged on-site during testing. The design team would have to investigate the site drainage and verify if it could accommodate the additional drainage demands. The larger electric fire pump would also require additional horsepower. The design team would have to determine if the current emergency generator could handle this larger load and whether testing criteria should be modified based on this new information.

The high-value data center requires several double interlock pre-action systems. Clean agent systems are to be used. The interaction between both of these systems, the fire alarm panels, and other fire protection devices is being considered in the commissioning plan. The system matrix is provided to clarify sequence as well as complete testing development.

Construction phase

The fire suppression systems engineering and shop drawings are one combined plan. This method eliminates the concern of acceptable and compliant materials being used. The shop drawings and sequence of operations are revisited for coordination. Field installation personnel and the commissioning agent make sure that any changes adhere to the approved drawings and specifications. Training programs for all of the systems are in development. As the design becomes more concrete, so will the testing requirements. These requirements will then be incorporated into the formal commissioning plan.

Occupancy phase

The documented fire protection commissioning plan will be used to ensure the building is ready for turnover to the building occupants. The plan will address the required testing and inspections as well as cover all required training, documentation, emergency contact information, as-built documents, warranties, operations and maintenance procedures, periodic testing requirements, and system limitations.

The commissioning plan’s most beneficial use will be to provide the owner with a consolidated document of the overall life safety performance and testing requirements for future use. Changes are often desired and/or required after the initial contractor and design team has completed their scope of work. This is also true if the building owner and end users change. Future modifications can be made without being destructive to the fire protection method or testing requirement initially coordinated.

NFPA 3 takes a more contemporary approach to construction and focuses on commissioning the fire and life safety systems at the beginning and throughout a project, rather than at the end. This method allows the design and construction to stay in line with the goals of system performance. Practices recommended in NFPA 3 are powerful tools in project development, project management, construction, and closeout. Following the steps provided in the document can greatly reduce the frustrations of a well-constructed project lacking coordination of the commissioning and testing phase. The document provides a uniform approach; the NFPA formalized guide has the potential to improve project outcome for all involved in the commissioning of the required fire and life safety systems.

NFPA 3 guides data center design

This example illustrates how a fire protection engineer may use the NFPA 3 document to develop the fire suppression portion of the plan and how it may assist in the overall project commissioning. A design-build, U.S. Green Building Council LEED-certified data center project with supporting administrative buildings contractually required a commissioning plan. Because the NFPA 3 document was not formally released until after the project requirements were developed, many of the project’s fire suppression procedures will not follow the exact order of the recommended practices, though the overall goals remain the same.

The project required design of the following fire protection systems: fire service entrance, secondary fire water storage tank, fire pump, wet and double-interlock pre-action sprinkler systems, and clean agent fire suppression systems. Using several registered design professionals, the mechanical and fire suppression contractor served as the engineers of record on the project. Meanwhile, two additional fire protection engineers on the design team included the fire alarm/mass notification designer and the fire and life safety consultant. Successfully implementing the required fire protection systems is vital to the high-value data center (which is considered such, based on the type of data being stored), requiring survivability of the data in the event of a fire, natural disaster, or any other occurrence. 


Corey L. Wallace is associate principal engineer at Southland Industries. He is a licensed fire protection engineer with expertise in fire protection systems design. Wallace has more than 11 years of design and management experience as a consultant as well as a contractor.