Issue 91: NFPA 3 & 4 – What’s New?
By Doug Fisher, P.E., FSFPE
NFPA 3,1 Recommended Practice for Commissioning of Fire Protection and Life Safety Systems, and NFPA 4,2 Standard for Integrated Fire Protection and Life Safety System Testing,
were both recently approved by the NFPA Standards Council for
publication as 2015 editions. For both documents, this has been a long
process, but finally the fire protection community has two separate
documents to fill a much needed gap related to fire protection and life
safety systems (FP&LSS).
Before reviewing what's new with these documents, it is important to
talk about how they got to where they are. The concept for developing
an NFPA document on commissioning FP&LSS systems started back in
2005 when the NFPA Standards Council identified the need for more
technical information on commissioning FP&LSS. This resulted in an
NFPA document entitled Commissioning Fire Protection Systems.3
Soon thereafter, NIBS submitted a proposal to NFPA requesting that
NFPA become involved in FP&LSS commissioning as part of the NIBS
total building commissioning project. An NFPA Technical Committee was
formed, and it first met in 2008. The end result was the 2012 edition
of NFPA 3.
Even before the 2012 edition was published, the committee felt that
commissioning and integrated FP&LSS system testing were two distinct
events that should be treated separately from an NFPA standards point
of view. The committee began working on the best way to include the
functions into separate documents, yet allow them to still work together
This allowed the creation of NFPA 3, on commissioning FP&LSS and
NFPA 4, which addressed integrated FP&LSS System Testing. The
question that remained was whether each document should be a recommended
practice, standard or code. Since commissioning (Cx) is (currently)
more of an owner’s concern, the decision was made to continue to move
NFPA 3 forward as a recommended practice. Integrated FP&LSS
testing, however, is an aspect that is not required by any of the
installation standards, although it is necessary to be performed in
order to verify integrated FP&LSS systems perform as intended.
Because of the nature of integrated FP&LSS system testing, the
decision was made to publish NFPA 4 as a standard.
Changes to NFPA 3
Before discussing the changes to NFPA 3, it is essential to understand
what Cx is and what it is not. In the fire protection industry,
commissioning is often used as a buzzword in reference to acceptance
testing of final turnover of the system to the owner. "We commissioned
the sprinkler system” is a common, yet incorrect, phrase. Commissioning
is not acceptance testing, nor is it integrated system testing.
Acceptance testing does not equal commissioning; however,
commissioning can include acceptance testing. Paraphrased,
commissioning is the process of verifying that systems are designed,
installed, functionally tested and capable of being operated and
maintained according to the owner’s operational needs. The key words
are "process” and "owner’s operational needs.” The AHJ is noticeably,
and intentionally, missing as NFPA 3 is written for the owner.
The 2015 edition of NFPA 3 was not a major revision but, rather, a
continuation of the initial efforts to develop concise recommended
practices for commissioning. While there were minor changes throughout
the entire document, two major revision items are:
Elimination of all recommendations for integrated system testing. As
can be assumed by the development of NFPA 4, all references to
integrated system testing were removed from NFPA 3 (old chapter 7) and
moved into NFPA 4. Throughout the document, the text was tweaked to
reference NFPA 4 and how integrated FP&LSS system testing works with
Clarification and expansion of the recommendations for existing
FP&LSS system commissioning, otherwise known as re-commissioning
(Re-Cx) and retro-commissioning (Retro-Cx). The information associated
with Re-Cx and Retro-Cx was increased by a factor of four to respond to
user requests for clarification on what should be performed during Re-Cx
and Retro-Cx. The definition of Re-Cx was revised to clarify that it
only applies to systems that were previously subject to Cx, and its
purpose is to verify the system performance continues to meet the
owner’s project requirements (OPR) and the basis of design (BOD). Re-Cx
should be performed when specified in the Cx plan, or when a change in
the FP&LSS systems affects the operation of such systems.
Specific guidance was then provided to clarify what steps should be
included in the Re-Cx process in order to verify that the system
performance continues to meet the OPR and BOD. The definition of
Retro-Cx was revised to clarify that it only applies to systems that
were not previously subject to Cx. Retro-Cx should be performed when
concerns related to design, installation or operation are identified
through the inspection, testing and maintenance process, or when a
change in the FP&LSS systems affects the operation of such systems.
As with Re-Cx, specific guidance was provided to clarify what steps
should be included in the Retro-Cx process. With Retro-Cx, there may
not be an OPR or BOD available, so the Cx team is responsible for
developing an OPR and BOD based on discussions with the current owner
and an historical review of the project.
Changes to NFPA 4
Some of the key points of NFPA 4 include:
The standard does not address individual system testing or
performance. This is covered by the individual installation standard.
NFPA 4 provides "how” to perform integrated system testing but not
"when.” The frequency of integrated system testing will be noted in the
design documents, Cx plan or applicable codes and standards. This was
such an important topic to the committee that the text was worded to
state "this standard shall not be interpreted (emphasis added)
to require integrated fire protection and life safety systems testing…”
The committee wanted to make sure there was no confusion about this
NFPA 4 establishes the requirement, role and responsibility for an
Integrated Test Agent (ITa). While the owner is responsible to verify
that integrated system testing it performed, the ITa is responsible for
planning, documenting, coordinating and implementing integrated system
testing. If qualified, the role of the ITa can be played by the owner
or the installation contractor.
An integrated system test plan is required to be developed by the
ITa. The test plan is required to include items such as the systems to
be tested, documentation that individual system testing has been
performed, members of the integrated system test team, a functional
matrix for the integrated systems, test scenarios, test schedule and
frequency of periodic integrated system testing.
Provides details on the test methods and scenarios that should be
developed for use in the integrated test plan. This section focuses on
what should be in the test methods, not the actual method itself, as no
two integrated FP&LSS systems may be the same.
NFPA 4 provides requirements for when periodic testing is to occur.
Periodic integrated system testing is only required if some other
charging document requires compliance with NFPA 4. Periodic testing is
required based on the frequency noted in the integrated test plan.
For existing systems that do not have an integrated test plan, NFPA 4
requires that an integrated test plan be developed within five years of
the adoption of the standard (by May 2019). This test plan would
provide the requirements for periodic integrated systems testing. If a
test plan is not developed within that time frame, integrated systems
testing is required to be performed. So, the owner is either required
to develop a test plan that documents when periodic testing will occur
or perform integrated systems testing, which also requires the
development of a test plan.
The Future of NFPA 3 and 4
The next editions of NFPA 3 and 4 are part of the Annual 2017 revision
cycle with the first set of public comments due on July 6, 2015, less
than one year away. There has been much discussion about whether or not
NFPA 3 will remain a recommended practice or if it will become a
standard. At a minimum, both documents will continue to expand to
provide more guidance and clarification for commissioning and integrated
FP&LSS system testing.
Doug Fisher is with Fisher Engineering, Inc.
NFPA 3, Recommended Practice for Commissioning of Fire Protection and Life Safety Systems, National Fire Protection Association, Quincy, MA, 2015.
NFPA 4, Standard for Integrated Fire Protection and Life Safety System Testing, National Fire Protection Association, Quincy, MA, 2015.
Hague, D. Commissioning Fire Protection Systems, National Fire Protection Association, Quincy, MA, 2005.
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