Using NFPA 3 and NFPA 4 to ensure fire-safe structures

NFPA 3 and NFPA 4 address commissioning and integration of fire protection and life safety systems. It’s critical to review and implement these standards to increase the building’s safety.

By Bruce G. Campbell, FSFPE, JENSEN HUGHES, Baltimore March 28, 2018

Learning objectives:

  • Define NFPA 3 and 4, and how they relate to fire protection engineers.

  • Explain the basis and importance of complying with NFPA 3 and 4.

  • Understand what risks are involved with noncompliance to NFPA 3 and 4.

Within the past 5 years, two documents from the NFPA address the testing and inspection of fire protection and life safety systems, which has become increasingly critical as technology has advanced in the past few decades. Essentially, NFPA 3: Recommended Practice for Commissioning of Fire Protection and Life Safety Systems provides the framework so that all systems are tested and will operate as intended, while NFPA 4: Standard for Integrated Fire Protection and Life Safety System Testing ensures all systems are integrated and will operate cohesively as an overall building fire protection and life safety system.

Prior to the creation of NFPA 3 and NFPA 4, there was extremely limited integration of fire protection and life safety systems. The best tools fire protection engineers had in regards to fire protection safety reporting were fire detection devices and flow/pressure switches reporting to the analog fire alarm panel, and even then, in some cases a flow alarm would also activate notification appliances. To compare the 1980s and today, nearly all fire alarm control panels (FACPs) are digital/processor-based and microprocessor-based using digital signals for communication between the device and the fire alarm panel. These panels now interface with all sorts of fire protection, life safety, and property-protection systems including smoke-control systems, clean agent systems, elevator recall, emergency/standby generators, sprinkler systems, equipment shutdowns, ventilation control, and addressable “smart” smoke/heat detectors. It’s critical that these systems are fully integrated to operate as one seamless system. It would be a disaster if a fire occurs near a stairwell and the door hold-open device fails, which then causes the smoke-control system also to fail.

History of NFPA 3 and NFPA 4

The first edition of NFPA 3, in 2012, represented the NFPA’s first document providing an outline for a systematic approach to ensure that fire protection and life safety systems would function as intended. The 2015 edition of NFPA 3, the current version, is a recommended practice. Unless adopted by the authority having jurisdiction (AHJ), corporation, government agency, etc., the requirements within the document are not mandatory, but are suggestions. One will not see “shall” statements within NFPA 3. NFPA’s Commissioning and Integrated Testing technical committee determined, after a lengthy discussion, that NFPA 3 was not ready for standardization; however, there was an imminent need to create a standard for integrated fire protection and life safety systems, thus NFPA 4 was prepared and approved by the NFPA in 2015.

The intent of NFPA 3 and NFPA 4 is to provide the building owner, the design team, and the various other stakeholders (AHJs, insurance company, fire department) documentation that their facility would be protected as designed and approved. The origin of the document was via a request from the National Institute of Building Sciences (NIBS), which recognized the need to provide a commissioning document for fire protection systems that would be an integral part of the overall facility commissioning documents. The end goal was to include fire protection and life safety systems as an integral part of the overall commissioning documentation. NFPA 3 addresses the administrative and procedural concepts of fire protection and life safety system commissioning and directs users to NFPA 4 for the integrated testing portion of the systems. Neither document provides specific requirements for inspection and testing of specific fire protection or life safety systems. Instead, they establish frameworks for properly identifying, performing and documenting the inspection and testing requirements of other codes and standards, as well as other features specified by the owner and design team.

In addition, they provide guidance in choosing the commissioning team to execute the inspection and testing plans. NFPA 3 also has been configured to provide guidance to the commissioning team members based on their suggested qualifications, roles, and responsibilities.

NFPA 3 provides a roadmap to commission systems from the initial stages (conceptual design) through the occupancy of the facility once the certificate of occupancy has been granted by the AHJ. To this end, many key documents, such as the basis for design, testing criteria, etc., are identified to assist the building owner to successfully install all fire protection and life safety systems.

Another important aspect of NFPA 3 is retro-commissioning and recommissioning of existing buildings. Both activities are critical elements of an overall building fire protection/risk management program. Typically, retro-commissioning of existing systems is to establish a benchmark for the facility’s various systems (and may include more than fire protection and life safety systems). A facility with a well-documented fire protection system can then be recommissioned, which is then compared to the retro-commissioning to determine all deltas. One example could be where a bank of elevators has been updated and not properly provided with an interface to the elevator recall system.

NFPA 4 is a standard, thus the criteria within the standard includes “shall” versus the “should” statements found in NFPA 3. NFPA 4 is intended to address the testing of the performance of the interconnections between multiple fire protection and life safety systems. As with NFPA 3, NFPA 4 defines the roles and responsibilities of the integration testing agents.

Glossary of terms

Like most codes and standards, NFPA 3 and 4 have many terms that most folks, including fire protection engineers, aren’t always familiar with. The following are key terms and definitions that are critical to understand.

  • Commissioning (Cx): A systematic process that provides documented confirmation that building 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.
  • Commissioning authority (CxA): The qualified person, company, or agency that plans, coordinates, and oversees the entire commissioning process.
  • Commissioning plan: The document prepared for each project that identifies the processes and procedures necessary for a successful commissioning process.
  • Commissioning record: The complete set of commissioning documentation for the project that is turned over to the owner at the end of the construction phase.
  • Fire and life safety commissioning (FCx): 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 as well as satisfy the owner’s operational needs, including compliance with any applicable laws, regulations, codes, and standards requiring fire and life safety systems.
  • Fire commissioning agent (FCxA): A person or entity identified by the owner who leads, plans, schedules, documents, or coordinates the fire protection and life safety commissioning team and implements the commissioning process and integrated testing of fire and life safety systems.
  • Integrated testing agent (ITa): A person or entity identified by the owner, who, plans, schedules, documents, coordinates, and implements the integrated testing of the fire protection and life safety systems and their associated subsystems.
  • Re-commissioning (Re-Cx): The process of verifying the performance of existing fire protection and life safety systems that have been previously commissioned to ensure that the systems continue to operate according to the design intent or current operating needs.
  • Registered design professional (RDP): In commissioning, an individual who is registered or licensed to practice their respective design profession as defined by the statutory requirements of the professional registration laws of the jurisdiction in which the project is to be constructed, or other profession with qualifications or credentials acceptable to the jurisdiction in which the project is to be constructed.
  • Retro-commissioning (RCx): The process of commissioning existing fire and life safety systems that were not commissioned when originally installed.

Key criteria within NFPA 3

The following are NFPA 3’s key requirements that are most important to a successful and compliant commissioning effort.

Chapter 4 of NFPA 3 provides suggested qualifications for all team members. For brevity, there are various qualifications for personnel involved with commissioning; knowledgeable (in their respective position), experienced, objective, unbiased, and able to read and interpret drawings and specifications. Each state, and in many instances local jurisdictions, will have licensing, registration, or certification requirements for each role within the commissioning or testing team. It is then up to each individual to verify the requirements to ensure their license, registration, or certification is aligned with local requirements. The local AHJ can accept personnel who are not licensed, registered, or have certain certifications, although this is not a common practice.

Chapter 5 of NFPA 3 defines the various stages of the overall commissioning effort. The first stage is the planning phase, where the fire protection and life safety commissioning team is established and is expected to perform the following:

  • Develop the initial owner’s project requirements (OPR), which documents the owner’s vision for the planned facility’s requirements and expectations. Typically, the OPR is prepared with input from fire protection professionals and generally fire protection engineers, code authorities, the local fire department, and insurance representatives.

  • Select the FCxA who can be part of the design team, part of the corporate staff, or an independent third party.

  • Identify the commissioning scope that is based on the OPR. For the commissioning scope, all fire protection and life safety systems and their interfaces should be identified. Identifying the fire protection and life safety systems is based largely on the regulatory code analysis.

  • Create the first draft of the commissioning plan, based on criteria in Chapter 5 of NFPA 3.

  • Perform the initial regulatory code analysis.

  • Initiate the commissioning plan as appropriate.

Before, during, or after the fire protection and life safety commissioning team is selected, the team can include, but is not limited to, the following members:

  • Owner

  • Commissioning authority

  • FCxA

  • Installation contractor(s)

  • Manufacturers’ representatives

  • RDP(s)

  • Construction manager/general contractor

  • Owner’s technical support personnel

  • Facility manager and/or operations personnel

  • Insurance representative

  • Special experts

  • AHJ

  • ITa.

Special experts are not specifically identified in NFPA 3. In high-hazard facilities, however, select special experts are vital to assist the personnel who are associated with the project. For example, if a facility is to have a 3-D (additive) printer, specific details are required for the material to be printed to determine if classified electrical equipment, pressure-relief walls, fire barriers, argon or nitrogen inerting, etc. are required. Without an expert’s input, there could be significant impacts to the project if certain key fire protection or life safety components are not identified early in the project.

The size and complexity of the project will dictate the size and makeup of the commissioning team. As the project moves forward, the owner can add or subtract team members with the FCxA’s input. The owner is responsible for the commissioning and the commissioning team, and can designate a person as the owner’s representative. The designation should be in writing and documented in the plan.

Chapter 5 also describes the responsibilities of the members of the commissioning team. These responsibilities are found in Section 5.2 of NFPA 3.

The commissioning plan should be revised through all phases of the project to ensure it is accurate and prepares the team for the required testing.

Section specifies that the commissioning plan should include the following information:

  • Commissioning scope and overview of the project

  • General project information

  • Fire protection and life safety commissioning team members, roles, and responsibilities

  • General communication plan and protocol

  • Commissioning process tasks and activities through all phases

  • Commissioning schedule

  • Commissioning process documentation and deliverables

  • Testing procedures, including integrated testing

  • Recommended training

  • Establish an integrated testing frequency, as applicable.

The report should clearly document the objectives of the fire protection and life safety systems so that, in the future, the purpose of each system is clear. The OPR should be based on these objectives, and the commissioning plan becomes a natural extension of the OPR.

The following annex material is to be included within the report to comply with Section

  • Owner’s project requirements

  • Basis of design

  • Commissioning specifications

  • Design review

  • Construction submittal review

  • Issues log(s)

  • Construction checklists

  • Site visit and commissioning meeting minutes

  • Systems manual review

  • Training

  • Integrated testing procedures (from NFPA 4)

  • Warranty review

  • Test data reports

  • Sequence of operation

  • Operations and maintenance manuals

  • Vendor(s) emergency contacts.

According to NFPA 3, the previously mentioned annex topics need be incorporated in the commissioning report. It’s unusual for any of the subject areas to not be included. Other annex material can/should be included, such as a spare parts list, resumes of the commissioning team members, any special studies (e.g., explosible dust laboratory results), photographs, videos, etc.

During the design of the fire protection and life safety systems, several key activities should be performed and documented in the commissioning plan, such as sequence(s) of operation, the commissioning schedule, and construction checklists. Other key information is also found in Section 5.3 of NFPA 3. The basis of design should be included in the commissioning report. This information must include the basis for the selection of various fire protection systems, such as clean agent in lieu of automatic sprinklers, and the basis for the hydraulic density of the automatic sprinkler system (especially critical in a warehouse, big-box store, etc.). If a waiver has been requested and approved by the AHJ, this information should be included as well. If alternative means and methods are used, then the basis for this approach needs to be included.

The inspection, testing, and maintenance requirements for various systems is commonly forgotten during the design phase, which is necessary to efficiently test the systems. It’s critical to think ahead to ensure that the various systems can be properly maintained and tested in the future. For example, take the test header for fire pumps. The design should consider the best location for this header to facilitate flow testing of the fire pumps. Another example is access to fire dampers. NFPA 80: Standard for Fire Doors and Other Opening Protectives and NFPA 105: Standard for Smoke Door Assemblies and Other Opening Protectives require access doors to enable the testing and inspection of fire and smoke dampers, however, the location of these doors needs to be easily reached. The damper shouldn’t be designed in a location where dangerous elevated work is required or special equipment is needed. Other examples are smoke detection placed on very high ceilings in atriums and shopping malls and detectors placed in ducts inside prisons. None of these detectors are easy to test, and they require extensive administration controls to complete the testing in a safe manner.

Just prior to construction, the commissioning plan should be reviewed and updated as required. Ideally, the plan should have been revised on an ongoing basis.

During the construction and prior to occupancy, the fire protection and life safety systems must be tested in accordance with the approved commissioning report. This integrated testing should include, but not be limited to:

  • Conformance to the approved drawings and specifications. If there are disconnects, the drawings and documents will need to be revised and the documentation of the approval for these changes included in the final report.

  • Compliance with the manufacturers’ published instructions.

  • Compliance with applicable codes and standards (which should be well-documented in the commissioning report).

  • Review of material and equipment submittals for proper ratings for use; e.g., the proper fire doors in the fire barriers.

  • Coordination of all contractors’ submittal drawings, sequences of operation (based on NFPA 4), and procedures.

  • Prior to occupancy, the verification of successful individual system testing. The inspection document needs to be reviewed for completeness and accuracy.

Key criteria within NFPA 4

Chapter 4 of NFPA 4 requires the establishment of an integrated system test team, similar to NFPA 3’s requirement for a commissioning team. At a minimum, the team is required to include the integrated testing agent and the installation, testing, or maintenance personnel for each of the various fire protection and life safety systems as well as any other systems that might be interfaced (e.g., electrical, ventilation/mechanical, computing systems, public-address, etc.). The testing team must have a working knowledge of the integration between all systems for which the testing is being performed (e.g., activation of the smoke-control system upon sprinkler-flow notification). It adds more value to have an independent third party as part of the testing team in addition to those specified in NFPA 3. This person is there to ensure all integrated testing complies with the codes, standards, and original design intent and expectations of the AHJ, insurance providers, and owner. This includes not only the inspection, testing, and maintenance itself, but also the supporting documentation that demonstrates acceptable completion. The third-party engineer represents the owner and is present to protect the owner.

The test plan (Section 4.5) is required to include, but not be limited to, the following:

  • Written verification that the integrated system and its individual systems have been installed in accordance with the approved design documents.

  • Listing of the individual systems to be tested.

  • The scope and purpose of each system to be tested.

  • Documentation of the individual systems as required by the applicable codes and standards.

  • The integrated test team and additional entities required to be in attendance.

  • Equipment required for testing; calibration shall be up to date (not beyond 1 year) and performed by an independent testing laboratory.

  • Comprehensive functional matrix describing all system inputs and associated output functions and purposes.

  • List of all necessary drawings including riser diagrams and control diagrams.

  • The extent of systems to be tested under the direction of the ITa.

  • The test schedule of all individual systems.

  • Periodic integrated system testing frequency.

Integrated testing in accordance with NFPA 4 is not just performed when the building is new, but also is required to be reperformed at a frequency set forth by the commissioning plan or integrated test plan. Integrated testing is also addressed at some level in other NFPA standards including NFPA 72: National Fire Alarm and Signaling Code and NFPA 96: Standard for Ventilation Control and Fire Protection of Commercial Cooking Operations.

During the preparation of NFPA 4, the committee struggled with including an actual frequency in Section 6.2.1. After a lengthy discussion, the committee felt that it was best to permit the AHJs to make that determination. In many cases, a 5-year frequency seems appropriate. A set frequency is not viable since integrated systems range from simple to very complex. Additionally, the retest frequency needs to consider the number of changes to the system; e.g., additional equipment added, repairs to systems, etc.

Integrated system testing needs to be performed when any of the following occurs (Section 6.4):

  • New fire protection or life safety systems are installed and integrated into existing fire protection and life safety systems.

  • Existing fire protection or life safety systems are modified to become part of an integrated system.

  • Changes are made to site-specific software for an individual system that is part of an integrated system. Engineering judgement is required for this item. One aspect to consider is where device identifications are being modified.

The following documentation is required (Section 7.2) to record the integrated testing in accordance with the test plan:

  • The final test report shall summarize the results of the integrated testing.

  • The test report shall include a narrative or matrix describing each test and the response of the integrated system and individual systems.

  • A description of the status of each individual system for each test.

  • The approval basis for systems where their operation was simulated or where a device’s state change was initiated.

  • A statement that all input and output functions of the integrated system have been tested and operate as intended.

  • A list of all system faults and failures discovered during the testing via the issues log.

  • The issues log shall list each finding and the issue resolution. Where corrective action reports are prepared, they shall be included as well.

Bruce G. Campbell is vice president, Department of Energy services, at JENSEN HUGHES. Campbell has been a fire protection engineer for more than 40 years, during most of which he has been involved with heavy industry. He is chair and principal member of NFPA 241: Standard for Safeguarding Construction, Alteration, and Demolition Operations, immediate past chair and principal member of NFPA 80 and 105, principal member of NFPA 80, and an alternate (former principal) member of NFPA 3 and 4.