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NFPA 3 and NFPA 4 - Separating Commissioning from Integrated Testing
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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 systems.


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 systems."1


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 the owner.


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 documentation.


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 applicable regulations.


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

  1. NFPA 3, Recommended Practice on Commissioning and Integrated Testing of Fire Protection and Life Safety Systems, National Fire Protection Association, Quincy, MA, 2012.
  2. "Commissioning: A New Buzz Word?" David R. Hague, Fire Protection Engineering, 4th Quarter 2010.
  3. Guideline 0, "The Commissioning Process," ASHRAE, Atlanta, GA, 2005.

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