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.


This article has been peer-reviewed.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.

Figure 1: This illustrates an example of an electric fire pump, controller, and sprinkler risers. All graphics courtesy: JENSEN HUGHES

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.

Figure 2: This example of a complex fire protection system includes a fire pump, sprinkler systems, and deluge systems.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.

Figure 3: An interconnected sprinkler system is paired with a deluge system. 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.

Figure 4: An example of multiple fire alarm control panels and releasing control panels that are all interconnected. 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.

Figure 5: An example of a fire alarm control panel and a clean agent control panel that are interconnected.

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