Greg Kessinger is SD&I’s fire alarm and codes expert and a regular contributor. Email him your fire & life safety questions at email@example.com.
Q. Are there still more blank chapters in NFPA 72, the National Fire Alarm & Signaling Code, than existed in the 2010 edition?
A. The NFPA 72 Committee decided to add 15 blank chapters to the code in 2010 and reserved them for future use. They reasoned that it would allow new chapters to be added to the standard without having to renumber existing chapters, making the code more “user friendly.” There are now 14 blank chapters in the 2013 edition being “reserved” for future content. Why? You may ask, considering the abundance of numbers after Chapter number 11—you know, like 12 and up.
The ‘Household’ chapter originally was its own standard. It was combined into NFPA 72 many years ago as Chapter 2 when there were a total of seven chapters. ‘Household’ was moved to the last chapter in the 1996 edition and became Chapter 8 when a new chapter was created for “Public Fire Alarm Reporting Systems.” Up until the 2010 edition, every time a new chapter was created, it was inserted numerically ahead of the ‘Household’ chapter which caused all chapters after the new one to be renumbered, but ‘Household,’ then Chapter 11, was kept as the last chapter in the book. Someone at NFPA thought that this renumbering of the chapters was confusing the users of NFPA 72 (yes, they thought renumbering chapters every three years was the confusing part). That is why the “Reserved” chapter system was implemented. It was explained that by using the “Reserved” chapter numbering system, existing numbered chapters could remain the same throughout future editions of the standard. So, in the 2010 edition of NFPA 72, the ‘Household’ rules (by now renamed “Single- and Multiple-Station Alarms and Household Fire Alarm Systems”), were moved one last time, to become Chapter 29. One of the blank “Reserved” chapters of NFPA 72 was used in the 2013 edition, Chapter 7, and titled, ‘Documentation.’ This meant ‘Household’ wasn’t required to move again in the 2013 edition and it can still be found at the back of the book, with one foot out the door.
Q. Are these new chapters being created as a result of new rules?
A. For the most part, no. At first glance, it seems so, since NFPA still marks existing rules as “new” by placing a black vertical line in the margin, even when these rules have only been moved from another chapter. Chapter 7’s contents were primarily created from existing material taken from other chapters. The new ‘Documentation’ chapter was created by culling existing information from several of the other chapters and also from the Annex.
Annex material is not adopted by state building and fire codes as part of the standard. Annex material is provided for clarification of the rules of the standard and sometimes illustrates the intent of the chapter’s text. Remember that NFPA 72 is not a code, but a second-tier standard, referenced by a state or jurisdiction’s adopted code—most often, the IBC/IFC. To keep from presenting material that may conflict with the existing mandatory requirements of already adopted building and fire codes, each section of the Documentation chapter had to be made optional, or conditional. This is why sections of the new ‘rules’ in the documentation chapter begin with some version of: “Where required by governing laws, codes, or standards, or other parts of this Code, the requirements of this chapter, or portions thereof, shall apply.” (Also see 1.2.4 and A.1.2.4)
Q. Is a special documentation cabinet required to be used?
A. Yes, a cabinet labeled “System Record Documents” must be used with new commercial fire alarm systems to house all the required software, documentation, calculations, forms, manuals and reports. Section 126.96.36.199 states: “With every new system, a documentation cabinet shall be installed at the system control unit or at another approved location at the protected premises.” The cabinet’s contents must be accessible only to those authorized to review or maintain them. This means it will be in a secure area or have a locking door.
Q. Were the Record of Completion and other forms removed from NFPA 72?
A. Not removed, just moved. The forms have been relocated to this new Chapter 7 and the sample blank forms/checklists now span 27 pages. Providing an exact reproduction of the “record of completion” form shown in NFPA 72 has never been required. NFPA said they have clarified that misconception with the new language in Section 188.8.131.52 which states that you are to use “Figure 184.108.40.206(a) through 7.8.2(f)” or just the “elements of Figure 220.127.116.11(a) through 7.8.2(f) applicable to the installed system.” This is still open to local misinterpretation. The Annex states that “It is the intent of this section to permit using forms other than Figure 7.8.2(a) through Figure 7.8.2(f) as long as they convey the same information.” However, any local inspector can take it exactly as stated (use the Figure or applicable parts of the Figure) and is under no obligation to use the Annex material where it states that you can create and use your own Figure.
The fact is, and always has been, any document you provide that is acceptable to the local code official which contains the applicable information for the system installed, is compliant. It is a shame the Figure (Form) was moved from the “Fundamentals” chapter to the “Documentation” chapter instead of being moved to the Annex where it would be more obvious that the exact Figure (or parts of that Figure) isn’t required; and that NFPA 72’s Figure of a blank Form is not copyrighted material in spite of that declaration at the bottom of each page! Same thing goes for the Test and Inspection form shown in NFPA 72; the applicable information is required, not the duplicated Form as it appears in NFPA 72. Strictly speaking, all sample forms should be located in the Annex section of NFPA 72 and the required information identified and enumerated in the text of Chapter 7.
In future columns, I will present detailed information regarding the brand new paperwork and reports you will have to provide the local code officials and to your customers when your jurisdiction adopts the 2013 edition of NFPA 72.
Greg Kessinger is SD&I’s longtime resident fire alarm and codes expert and a regular contributor. Reach him at firstname.lastname@example.org.