NFPA updates their codes and standards on three-year cycles, including NFPA 72, the National Fire Alarm and Signaling Code. Although the 2010 Edition has been on the streets less than two years and practically no state or municipality has adopted it, the period for submission of changes to it for the 2013 edition has already expired and we are now into the proposal Comment period. That is where you come in. Anyone can comment on proposals and you don't have to be an NFPA member. As professionals in the fire alarm industry we have the privilege and responsibility every three years to participate in this process in order to oversee the proposed changes to NFPA 72.
Many proposals are submitted by those without real-world experience, including some engineers, government employees, insurance underwriters, sprinkler contractors, manufacturer's reps and hospitality industry representatives. The vast majority of these submissions are well meaning although a few are there merely to further their industry's agenda. Therefore, when you read these proposals you have to ask yourself two things: "Is this proposed rule addressing a real problem/issue that will make things better/safer if adopted?" And: "How can this proposal, if adopted, come back to bite me in the butt?" This column looks at a few proposals that may compel you to submit a comment either for or against the changes they will elicit.
The first proposal is one that small/local alarm companies may like, but larger/nationals may not. This proposal, if passed, would eliminate the word "testing" from the requirements for "Central Station Service." The requirements for monitoring by a UL-listed central station and installation and service by a UL-listed prime contractor, as well as providing "runner service" would remain. Removing the word "testing" would not eliminate the requirement for testing, just change who may provide the testing. The submitter of the proposal stated that "by allowing test and inspections to be provided by an independent third party who is not involved in the service or maintenance of the system, true third party verification could be provided." He makes a good argument (in part).
"A listed central station that provides all of the services in any configuration allowed by the previous sections ([1-]) but allows the Building Owner to directly contract for inspection and testing services to an independent third party that meets the requirements similar to section 10.18.2.4 which has verified the compliant installation of the system and provided documentation of such to the prime contractor directly."
This change, if adopted, would allow any qualified company (not just the ones that have paid thousands to become 'Listed') to contract with the property owner to provide the regular testing required by NFPA 72 and the Fire Codes. The submitter's justification states that the owner is under "restriction of free trade" if the code requires them to be tied into a single listed provider for all the required central station services. Will the codes allow the small alarm company to compete with the larger companies and provide "true third party verification?" How do you feel? Maybe strongly enough to submit a comment.
These next two examples, I predict, are ones where both large and small alarm companies may find more drawbacks than intended benefits. The first proposal wants fire alarm system plans submitted for approval to include: "Type and quantity of conductors and conduit (if used) for each circuit." The "type and quantity of conductors" has been around for quite some time but not as long as the conduit requirement. Another new twist here is the requirement to show the dimensions of the conduit. Shouldn't conduit be evaluated at the end of the job instead of limiting the installation before it begins? If conduit sizing is needed, will the wire fill capacity of junction and work boxes be next? Will listing the conduit dimension on the plans cause problems if the conduit contains additional conductors for other low-voltage systems? What if the conduit was re-sized on the job to accommodate other conductors, or smaller conduit was installed when the circuit changed routes? Will this cause the inspector to question the change either way? Or, even worse, would the AHJ require new plans be submitted for approval? What if conduit was eliminated in the final installation? Currently, plan reviewers do not have to worry about every small detail so that the installation technique can be left up to the licensed installer/electrician. Do you think this proposal has merit? Certainly in specifications for bids, but this requirement is probably not necessary or desirable for every single fire alarm system installation.
Now consider this other proposal which would require that plans show the "Location of all supply and return air diffusers (where automatic detection is used)." Is there a problem that will be fixed if the air supply or return-air registers were required to be shown on the plans? Do you think this is a practical idea? What if the grill is directional, would this also need to be indicated on the plans? What if the HVAC contractor makes a change to the diffuser's location or direction? Will you still pass your inspection or will another review be "needed?" Where does the code end, and industry practice begin? The rules in NFPA 72 now require that you do not install smoke detectors in the air stream of these air supply diffusers and otherwise locate detectors where they would not be adversely affected by air currents created by HVAC systems. Requiring HVAC-installed devices to be indicated on a fire alarm plan opens the door for plan reviewers to guess what effect they might have. The way it is now, too many plan reviewers erroneously believe that there is an actual rule requiring a "three foot" separation, between these devices and smoke detectors. A solution without a problem; or overdue?
Here are some other examples of proposals that may seem confusing. For example, a new proposal states: (18.104.22.168.3)
"Voltage drop calculations for strobes shall be provided in a lump-sum/end-of-line method."
I guess if using this method of calculating wire gauge has been proven to increase the level of occupant safety then I would have to agree that this method "shall" be used. However, this cannot possibly be the case, because another proposal negates this and states that if you don't use the first method, then you "shall" do it another way: (22.214.171.124.4.) "Voltage drop calculations for strobes prepared using point-to-point method shall allow for a 1 volt safety margin."
So which is it? Shouldn't the rule say you can calculate voltage drop using one of two methods and then list these two as the A and B choices?
If these examples have stirred you to submit comments, here are the NFPA dates you should be aware of: Comment Closing Date: 8/30/11; ROC (Report on Comments) Published and Posted: 2/24/12; (NITMAM) Notice of Intent to Make a Motion Closing Date: 4/6/12 (NFPA wants to know if you're going to take up voting time at the Association Meeting.); Association Meeting [for NFPA Members (at least 90 days prior)] to vote on documents with Amended Motions: 6/4-7/12; appeal closing date regarding Association Meeting Documents: 6/27/12 (your absolute last chance to change their minds.)
Many of the proposed changes are relevant and necessary. Several will correct issues you've had to deal with for years. Some proposed changes you may find confusing and attempt to 'fix' things that don't need fixing, or are counter productive. That's why it is important the general public submit comments on the proposals submitted by others. If you aren't part of the solution, you are part of the problem. You can download the proposals to NFPA 72 from their Web site, www.nfpa.org, as well as the required Comment Form. This is OUR industry, let our collective voices be heard.
Greg Kessinger is SD&I's longtime resident fire expert and regular contributor to the magazine. Reach him at firstname.lastname@example.org.