The Impact on Report Compliance
The requirements in the 2017 edition of NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, regarding documentation make digital inspection, testing, and maintenance (ITM) abilities increasingly attractive and useful to industry leaders. This is especially true as more jurisdictions adopt electronic report submission services to help streamline fire prevention reports and code enforcement processes.
Let’s take a look at each of the record-keeping requirements in section 4.3 of the 2017 edition of NFPA 25 from the reference point of a company using digital technology to document the results from inspecting, testing, and maintaining water-based fire protection systems.
Sub-section 4.3.1 Records are required for the system and its components. This harmonizes with section 4.6.1, which requires testing of all components and systems. It’s not enough to write down that “(1) Wet pipe system was inspected and tested. Everything passed.” The property owner or designated representative needs to see that the components making up that system are itemized and accounted for during testing. If a component failed, it needs to be individually documented. This also helps the service contractor when quoting service and returning to the site for repairs. This need is even more critical if you’re working in the highly regulated healthcare setting. Whether using a checklist-type form or a report with a device-type-specific listing, digitally inputting this information expedites the ITM process for the service contractor, keeps costs down for the property owner, and provides the level of detail implied in this section.
Sub-section 4.3.1 also requires that the report be made available upon request to the Authority Having Jurisdiction (AHJ). Rather than scanning a multi-page report and emailing it or, slower still, mailing a hard copy, emailing or submitting a report via a web-based service in digital format to the AHJ with a couple of clicks or taps is far more efficient. Additionally, providing the AHJ with the ability to scan a QR code at the actual site and access the report on a phone or tablet instantaneously creates even more significant efficiency advantages for stakeholders. The service contractor’s labor and time in providing documentation is reduced, the property owner’s responsibility to the AHJ is quickly fulfilled, and the AHJ’s wait time in receiving the report for review, especially where there are deficiencies, decreases substantially.
Sub-section 220.127.116.11 This section recognizes the increased usage of digital reporting in our industry by permitting records to be stored and accessed electronically. Digital reporting makes it significantly easier for the property owner to comply with the requirements that follow.
Sub-section 4.3.2 Here we find the minimum required features for the report. At first glance, it might appear light on details. However, annex B.4 clarifies the expectation for documentation by providing a list of recommended information for every report. While NFPA 25 stops short of mandating any specific format, it does provide excellent guidance. New to the 2017 edition, annex B.4 outlines what should be standard content – regardless of the form or report you choose. As one scans through this brief, informative material, it becomes clear how advantageous it is for the service contractor to enter this content digitally. This makes it easier for the inspector to enter the data and expedite delivery to the end-user.
Sub-section 4.3.3 The property owner has the responsibility to maintain records. Digitally documenting inspection records translates to easier storage, retrieval, and delivery options for the owner, saving time and facilitating the relationship with the AHJ when a request is made for the report. This also solves logistical challenges for facility management companies or building owners with multiple properties. Let’s say a large multi-national industrial manufacturer operates numerous plants across North America, but the employees at the corporate headquarters are conducting an audit. The auditors can now rely on a single, centralized online repository of all the required reporting. They’re no longer reliant on each of the facilities to provide hard copies or scanned images of the required documentation, and they have the necessary visibility across operations to identify potential liability issues quickly and easily.
Section 4.3.4 With digital reporting also comes the ability to store related data in the same manner. For example, related data would consist of acceptance tests, data sheets, hydraulic calculations, certificates, and as-builts – all of which are required to be retained for the life of the system. Over the course of many years and many property owners, having this data stored digitally benefits all parties when historical data needs to be quickly accessible for reference during a compliance inquiry or survey.
Section 4.3.5 The “Records” section ends with the requirement for a retention period for documentation, which is currently one year after the next ITM activity. If adhering to the International Fire Code requirements for record keeping, the retention period is not less than three years, and could be longer if specified in another section of that code or in another referenced standard. Regardless of the retention period your local AHJ requires, digital documentation of ITM reports indefinitely allows for safe storage of the data.
Hard-copy documentation is still valid and recognized by all major inspection, testing, and maintenance-related codes and standards. However, those same codes and standards permit electronic alternatives, recognizing a growing awareness of the advantages that digital reporting provides. Paper reporting, which for decades has been the industry standard, is expensive to produce and maintain, highlighting the green, cost-saving benefits to going paperless. Along with 24/7 access and ease of dissemination to stakeholders, the advantages of digital ITM processes are clearly seen in the time and money saved, risk and liability reduced, and highly prized gain of report-compliant reassurance that every sprinkler contractor wants and needs.
IMPORTANT NOTICE: This article and its content are not a Formal Interpretation issued pursuant to NFPA Regulations. Any opinion expressed is the personal opinion of the author and presenter and does not necessarily present the official position of the NFPA and its Technical Committee.
ABOUT THE AUTHOR: Joe Scibetta has more than a decade of experience in the field as a certified inspector and more than a decade serving as codes & standards manager for BuildingReports. In addition to providing product insight and training related to the application of fire and life safety codes and standards, Scibetta is an active member of numerous industry associations and serves on technical committees for AFAA, NFPA, and NFSA. For more information on BuildingReports, visit buildingreports.com.