Using NFPA 3 and 4 to commission fire protection systems

NFPA 3 and 4 provide the process for commissioning and integrated testing of fire protection and life safety systems.
By David J. LeBlanc, PE, FSFPE, JENSEN HUGHES, Boston March 28, 2017

This article is peer-reviewed.Learning Objectives

  • Define how NFPA 3 and NFPA 4 address commissioning and integrated testing for fire and life safety systems.
  • Understand the benefits of commissioning and integrated testing of new and existing systems.
  • Explore the key documents and process involved with commissioning and integrated testing.

Commissioning (Cx) certain building systems has been occurring for years, from U.S. Green Building Council’s LEED requirements to owners requiring that their building’s lighting and HVAC run more efficiently to lower monthly utility bills. Commissioning of such buildings and systems in the United States has been increasing over the past decade. 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.

Developing fire protection, life safety system standards

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 the NFPA regarding the development of a commissioning document that focused on fire protection and life safety systems. NFPA developed a document, titled NFPA 3: Recommended Practice for Commissioning and Integrated Testing of Fire Protection and Life Safety Systems (2012 edition).

Figure 1: Special suppression systems, such as aqueous film-forming foam (AFFF), are sometimes used to deal with unique hazards. This AFFF room contains AFFF tank and AFFF sprinkler-zone risers. All graphics courtesy: JENSEN HUGHES NFPA 3 was the first nationally recognized consensus document addressing commissioning for fire protection and life safety systems. It 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 for having people understand and coordinate with each other during the commissioning process. 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 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.”

Although commissioning and integrated testing of new buildings and new systems will largely be discussed, NFPA 3 also addresses commissioning of existing systems that have not been commissioned previously (retro-commissioning; ReCx) and commissioning of existing systems that have previously been commissioned (recommissioning; RCx).

NFPA has since published a 2015 edition, but has broken commissioning and integrated testing into two separate documents: NFPA 3-2015: Recommended Practice for Commissioning of Fire Protection and Life Safety Systems and NFPA 4-2015: Standard for Integrated Fire Protection and Life Safety System Testing. NFPA 4-2015 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. The 2018 edition of NFPA 3 will also be upgraded to the level of standard. This article addresses critical facets of both commissioning and integrated testing.

NFPA 3 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.

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. A qualified FCxA has 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. A qualified ITa also has an advanced knowledge of and experience with the installation, operation, and interfaces between the various fire protection and life safety systems being interconnected 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 serve as both the FCxA and the ITa for a project, as long as they meet the qualifications for both positions. 

The International Building Code contains code requirements for commissioning of smoke control systems and establishes the need for a qualified commissioning agent for smoke control systems as the smoke control special inspector. Thus, in regards to smoke control systems, the qualified FCxA commissioning smoke control agent 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, via a comprehensive review and documentation of the commissioning process. Commissioning is not just for performing testing at the end of the project to determine if the fire protection systems are performing 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’ performance in accordance with the commissioning test plan.

Figure 2: Buildings are becoming more complex. Oftentimes, performance-based designs are used to meet design challenges, resulting in more complicated fire protection and life safety systems. Key documents for the commissioning process

There are a number of important documents during the commissioning process including:

1. Owner’s project requirements (OPR). This document should be developed early in the process. The OPR 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 that include redundancies or advanced fire protection system features intended to reduce downtime due to a particular defined design basis event.

2. Basis of design (BOD). This is the document that outlines the specific criteria, concepts, and design approach for each fire protection and life safety system. The BOD is not only for the design, installation, and commissioning of the systems, but is also a critical document for the life of the building and is necessary for future reference for potential modifications to the systems.

3. Commissioning plan. The Cx plan is 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 Cx 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 the expectations for testing each of the individual fire protection and life safety systems.

4. Integrated test plan. This document indicates the process and specific tests that will be conducted in the field, and how those tests will be conducted to ensure each individual system is fully integrated into the overall fire protection system. 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). They are often performed as end-to-end testing with no bypasses. As with the Cx plan, this document permits the various stakeholders to be involved so they can be on the same page and have a common understanding of what to expect when testing the interfaces of the fire protection and life safety systems.

5. Commissioning record. This document is a single repository for all items related to commissioning of the fire protection and life safety systems and may include the following:

  • Commissioning plan
  • BOD
  • OPR
  • Test scenarios
  • Test procedures
  • Integrated tests
  • Submittal reviews
  • Checklists
  • Issues log (nonconformance log)
  • Test certificates
  • Testing documentation
  • Approved operations and maintenance manual
  • Recommended test frequency of the integrated test.

Stakeholders

The stakeholders for commissioning of fire protection and life safety systems may include:

  • Owner
  • Architect and design engineers
  • Commissioning (CxA, if there is one on the project)
  • FCxA
  • ITa (may be FCxA, if qualified)
  • Subcontractors
  • Registered design professional
  • General contractor
  • AHJ
  • Insurance carrier(s).

Phases of commissioning and integrated testing

Ideally, commissioning of fire protection and life safety systems is involved in the following phases:

  1. Predesign phase (planning)
  2. Design phase
  3. Construction phase
  4. Occupancy phase
  5. Life of the building—building renovations, additions, or fire protection/life safety system replacements/enhancements.

Pre-design phase: During this phase, the OPR is developed and the commissioning plan is started through formation of the commissioning team by the building owner.

Design phase: Key objectives for commissioning during the design phase are:

  • 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
  • Continuing updates to 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.

The early establishment of the commissioning and integrated test plans allows for proper planning by all parties involved. A common misunderstanding during the design phase is the need for comprehensive test scenarios (e.g., fire during a power outage). Testing is much more involved than running one test under normal, ideal conditions. 

Construction phase: Key objectives for commissioning during the construction phase are:

  • Review of shop drawings and equipment submittals for conformance to the OPR, BOD, and the construction documents
  • Field inspections to verify that approved equipment, materials, and wiring is being installed and protected in the field at the approved locations
  • The witnessing of component testing of equipment to ensure it is properly functioning per the approved submittals
  • Witness performance testing of the fire protection and life safety systems 
  • Documentation of the process of commissioning of the fire protection and life safety systems including completed checklists, issues log, resolution of identified issues, and testing forms.  Remember, if it is not formally documented, then it did not happen.

Occupancy phase: Key objectives for commissioning during the occupancy phase are:

  • Final close-out of documentation delivered to the owner
  • Proper training of facility staff on all the systems and how they are integrated
  • 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 activities and a schedule for each system
  • Copy of the commissioning record delivered to the owner
  • Ongoing inspection, maintenance, and testing of the fire protection and life safety systems as required per NFPA that is or should be required by 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.

Figure 3: This photo shows atrium smoke control exhaust fan belts. To meet the redundant belt requirement of 1.5 times, a total of 6 belts are provided for this atrium smoke control exhaust fan.Benefits of commissioning and integrated testing

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 must be reliable and spring into action at a moment’s notice to perform their desired function. Commissioning and integrated testing provides owners with added confidence via a third party that the fire protection and life safety systems are designed and installed properly.

Another benefit of the commissioning process and having an FCxA during the construction phase is that the most appropriate industry standards are followed. For example, it is generally agreed that an installing contractor needs to perform their own pretest to debug the system and to verify that it performs as intended. The installing contractor then needs to certify that their installation fully functions to the specific NFPA standard for that system prior to any tests with the engineer of record or the local authorities. Due to tight construction schedules and the pressing desire for higher profits by contractors, this critical step is often skipped because no FCxA is used. This often results in the inefficient witnessing of the testing for the engineer of record and the local authorities. In some cases, this can result in the system not being properly tested, which then can result in a system or program having issues or deficiencies that remain as part of the “approved system” in an occupied building. 

The commissioning process verifies that the proper steps are being followed and that these systems work properly under various conditions/scenarios prior to new buildings obtaining their certificate of occupancy (CO) and being occupied. The FCxA expects the contractor pretest documentation and NFPA installation certificates as part of the CO process. By following these steps, it verifies that the owner receives what they paid for and is delivered building fire protection and life safety systems that are performing properly when the new building is occupied.

A properly commissioned system has been debugged, coordinated, tested, and documented so that all features of the overall system perform seamlessly. This typically permits the final acceptance test with the local building and fire departments much easier since the systems function as designed/intended. Many owners and local jurisdictions see the direct correlation between a properly commissioned fire protection and life safety system and 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 allowing a building to be opened and occupied on schedule. The commissioning and integrated testing process helps to prevent such delays and allow owners to occupy buildings on time, because the process helps reduce and eliminate many last-minute issues at the completion of the project.

Commissioning and integrated testing of fire protection and life safety systems is on the rise as buildings are becoming more complex and the benefits (cost savings) of the commissioning and integrated testing process are realized. To help deal with tough design challenges, performance-based approaches are now being used by design teams for these new buildings, which many times result in more complex fire protection and life safety systems.

Building owners benefit from commissioning and integrated testing of these fire protection and life safety systems because of the confirmation that the design objectives were satisfied, which result in 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. In the near future, the use of NFPA 3 and NFPA 4 will clearly increase as these standards are referenced and incorporated into other NFPA documents, building codes, and fire codes.


David J. LeBlanc is the vice president at JENSEN HUGHES. LeBlanc has more than 25 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.

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