Issue 53: NFPA 3 and NFPA 4 - Separating Commissioning from Integrated Testing
By Cecil Bilbo
Over the last four years, the original NFPA Committee on
Commissioning and Integrated Testing worked hard to create a set of
guidelines that could be useful to building owners and others involved
in creating, using and maintaining the built environment. The result was
NFPA 3,1 which was published earlier this year.
There is a call that all stakeholders become involved in
a process now known as "Total Building Commissioning." As David R.
Hague, previously wrote,2 the word 'commissioning,' which has
been shortened to 'Cx' by those involved, should no longer be said to
be the final acceptance testing of fire protection and life safety
Commissioning should be understood to be "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 and satisfy the owner's operational
needs, including compliance with requirements of any applicable laws,
regulations, codes, and standards requiring fire and life safety
Upon examination, this definition of commissioning
appears to be no different than what is presently done. It appears no
different because it is no different. There are a couple of new items
that the total building commissioning process would demand of the
stakeholders. Primarily, Cx requires that there be an entity named to be
responsible to the owner and act as its agent in documenting the
planning, design, construction, and occupancy of a project. And
secondly, Cx will require that the owner/occupant be trained on the use
and care of the fire protection and life safety systems in the building.
Contracts and specifications are written, systems are
designed and installed, Certificates of Occupancy are granted. There are
some projects and some owners that demand a thorough documentation of
the process. But, they have become less and less in number in today's
world of fast track delivery. Fire protection engineers write
specifications that are specific to a project and are suitable for the
owner's needs. The average building owner has been less and less willing
to pay for the required evaluations and documentation that comes with a
well written project specification and highly documented turnover to
However, considering the built environment and the
building stock from the perspective of sustainability and a life time of
use, this calls for a different approach to having the building's life
documented. As technology moves forward and makes the built environment
more complex, it is necessary to plan further in advance to deliver such
Additionally, the AHJ is demanding field proof of the
adequacy of these complex systems for fire protection and life safety.
As an AHJ responsible for a variety of fire protection and life safety
systems, it can be more than difficult to keep up with technology. It
can be helpful to see systems operate as intended by the designer,
especially as these systems depend on each other to achieve the goals of
the designer and the building owner and to meet the requirements of the
And this is where NFPA 3 enters the scene. The NFPA 3 Technical Committee used ASHRAE Guideline Zero3
as the base for creation of the new NFPA 3. Also implicit in the
committee's scope was a need to address the integrated testing of fire
protection and life safety systems.
There is a new role created in the Cx process. It's the
role of the fire commissioning agent (FCxA). The fire commissioning
agent is appointed by, and a representative of, the owner. As the role
is described, it feels very familiar to most work being performed by
fire protection engineers. And in fact, it is likely that fire
protection engineers or their firms will make up the vast majority of
the fire commissioning agents that will be contracted in the immediate
future. The FCxA will be the individual responsible for delivering all
of the documentation that is required under NFPA 3.
When it came to commissioning, there were some committee
members that thought the rules for this process could be immediately
developed as a standard. That is to say, these rules would be mandated
and have the full force of law. Others on the committee felt that the
process needed to be governed by the commissioning team members and,
most notably, the owner. The latter line of thinking prevailed and the
NFPA 3 document that was originally conceived as a standard has been
released as a recommended practice.
Most committee members agreed that the part of the
committee scope dealing with integrated testing was important enough
that there should be a standard for this part of the commissioning
process. The committee included a chapter on integrated testing in the
new NFPA 3, but they also asked the NFPA standards council to allow for
the creation of a new standard that would set the rules for integrated
testing. The committee had a difficult time even discussing the
frequency at which integrated system testing was needed. However, nearly
every committee member agreed that the need for a set of rules for
integrated testing was a high priority in that currently there is no
single standard that describes this process.
In the time that the NFPA 3 committee was completing
work on the 2012 edition, there was a concern from other NFPA committees
and their members that NFPA 3 would try to dictate rules for testing of
the systems for which the individual system standards held
jurisdiction. The NFPA 3 committee exercised great care in avoiding
rules for individual systems. To facilitate a discussion of this issue,
the NFPA standards council held an "Inspection, Testing and Maintenance
Summit" in May 2011 and invited members of the various system standards
to participate in an airing of concerns. In August 2011, the standards
council approved the development of a new document to be called NFPA 4,
which would address the integrated testing of fire protection systems.
In September 2011, the standards council responded to
requests by various committees that they be allowed to create the
requirements for any systems that are interconnected to the systems over
which they have jurisdiction. The standards council agreed that
creating rules for integrated testing is a very important issue, but
they were very clear in saying that the rules for integrated testing
would be developed under the scope of NFPA 4.
The standards council went on to advise the individual
system standards to focus on the requirements for their systems. The
council advised "... committees to address issues of integrated testing
related to its systems by providing input on the content of NFPA 4
through the submission of proposals and comments and through TC member
representation that is anticipated will be appointed to the NFPA 4
Committee." They further directed the technical committees to
specifically reject proposals and comments that "...address concepts
outside of their scope."
The standards council also disbanded the committee on
commissioning and integrated testing of fire protection and life safety
systems and called for a "reconstitution" of the committee. In an August
2011 memo released immediately after a standards council meeting, they
wrote: "The new NFPA 4, however, calls for a review of the committee
structure of the current TC and a fresh consideration of the interests
and balance appropriate to a technical committee responsible for both
NFPA 3 and NFPA 4. ...Accordingly, the council intends to reconstitute
the TC under a new name and updated committee scope, and it will do so
after conducting a full review of the structure and membership of the TC
to ensure the expertise and the representation of the membership is
appropriate to the expanded tasks before the committee."
Cecil Bilbo is with Parkland College
NFPA 3, Recommended Practice on Commissioning and Integrated Testing
of Fire Protection and Life Safety Systems, National Fire Protection
Association, Quincy, MA, 2012.
"Commissioning: A New Buzz Word?" David R. Hague, Fire Protection Engineering, 4th Quarter 2010.
Guideline 0, "The Commissioning Process," ASHRAE, Atlanta, GA, 2005.
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