Martin M. King, State Coordinator, National Fire Sprinkler Association – Wisconsin Chapter
(Appeared in the March 2019 issue of The Dispatcher)
Inspection, testing, and maintenance (ITM) records came up at several meetings recently. The main issue was where the inspection records need to be provided. This is a longtime issue with the owners, tenants, contractors, and Authority Having Jurisdiction (AHJ) because each has its own perspective on the ITM record retention.
ITM of water-based fire protection systems are the responsibility of the property owner or designated representative. This can be found under NFPA 1, Chapter 13 Fire Protection Systems (13.1.5) or NFPA 25, Chapter 4 (4.31). Both state that the documentation shall be kept by the property owner and shall be made available upon request for review by the AHJ. NFPA 25 allows for “delegation of responsibility to the occupant (tenant), management firm, or managing individual through specific provisions in the lease, written use agreement, or management contact.” They assume the same responsibilities for records as the property owner.
Back when I was a fire inspector in the early 1990s (yes, some of you may not have been born,) systems were marked with the ITM paperwork. Our fire department handed out plastic bags to protect the paperwork from water or other damage. However, we were only required to keep records for one year, but there were multiple years of ITM paperwork. Most ITM is now completed electronically for ease of record retention, to forward information back to the company, and to send out invoices and service quotes.
The requirement did not change over time. The wording never changed. The contractor was never required to provide the paperwork at the site. Because they used carbon copies, one was left for the convenience of the owner. That has led many AHJ assuming no ITM was performed if a copy was not conveniently left at the fire sprinkler riser or fire alarm panel. Many states have a requirement but did not place it within the municipal ordinance. They may get what they want, but it is not a requirement. NFPA 25, and many other ITM standards, only require that the owner make it available.
Part of the confusion comes when the AHJ asks the ITM contractor to provide the paperwork directly to them. What they do not realize is if that the ITM contractor works for the property owner but does not assume the role of designated representative, the ITM contract is modified and allows the report to go directly to the AHJ. There are many property owners that do not want their information sent to anyone—only directly to them. This is their right, but you may request the information, which they must provide.
I have mentioned that fire inspectors are more educators rather than enforcement officials. It is assumed everyone reads and understands the fire prevention codes. They do not. We also assume the reasoning behind the idea that the paperwork is left at the riser or property. While this may be a convenience to us, it is probably an inconvenience to the property owner. Educating them on the “why” may help get cooperation.
With the advent of third-party reporting companies such as IROL and Brycer, we see more municipalities moving to use this service to assist with the reporting requirement. This still means that the municipalities need to place this requirement into their ordinance to get compliance, otherwise they are still asking them to voluntarily comply.
Remember, we all play a part in reducing the risk of loss and injury through prevention and mitigation. For more information on how fire sprinklers save lives and property, please contact Marty King at [email protected]. Or, visit the Wisconsin Chapter of the National Fire Sprinkler Association at www.nfsawi.org; the National Fire Sprinkler Association at www.nfsa.org; or the Home Fire Sprinkler Coalition at www.homefiresprinkler.org.