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Louisiana AFAA Quarterly Meeting State Fire Marshal Questions March 22, 2013

This document contains a list of questions and answers from the Louisiana Department of Public Safety and Corrections Office of State Fire Marshal regarding fire alarm systems, suppression systems, and building safety codes.

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Louisiana AFAA Quarterly Meeting State Fire Marshal Questions March 22, 2013

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  1. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Louisiana AFAA Quarterly Meeting State Fire Marshal Questions March 22, 2013

  2. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Question 1 a. NFPA 33, Par. 9.1.2 (2011) states “the fire alarm & fire protection system shall be supervised in accordance with NFPA 72." Are required suppression systems required to be monitored off premise (remote station) if the building has a fire alarm system, that is not a required fire alarm system? If the fire alarm system is required, then the suppression system is required to be monitored. If the fire alarm system is not required, then it may not be required to be monitored.

  3. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Question 1 b. Same question, but the building fire alarm system IS required? See answer a.

  4. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Question 1 c. If so, how far back would buildings be grandfathered? If a system is an approved installation and no work is being done to the system, the system would need to comply to the code edition it was built under. If repairs to the system exceed the minimum amount stated it LRS 40 1574, then it would have to be brought up to current code.

  5. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Question 1 d. Is the OSFM interpretation that all paint booth suppression systems are to be monitored off premise, even if it is a fusible link system only? See answer a.

  6. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Question 1 e. There are many many dry chemical paint booths installed without control panels. If answer to “a” is yes, when did this requirement go into effect? Our office reviews a lot of dry chemical paint booths suppression systems. We don’t recall seeing any submittal without a control panel.

  7. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY LRS 40 1574. Construction or repair of structures C. If within any twelve month period, alterations or repairs costing in excess of fifty percent of the then physical value of the building are made to an existing building, such building shall be made to conform to the requirements of the code for new construction. Per LAC 55:V.Chapter 30, a suppression system may be installed as a non-required/non-conforming or non-required system. “Non-Conforming—a system or component of a system which does not comply with applicable NFPA codes or standards. Non-Required—a system or component of a system which is not required by the applicable occupancy chapter of NFPA 101 (Life Safety Code).”

  8. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY If a system is determined to be non-required, then it is up to the owner to determine if they want to an install non-required/non-conforming or non-required system. It seems like this would be up to their insurer. NFPA 17 states the following: 5.7.4 Connection to the Alarm System. The extinguishing system shall be connected to the fire alarm system, if provided, in accordance with the requirements of NFPA 72, National Fire Alarm Code, so that the actuation of the dry chemical system will sound the fire alarm as well as provide the function of the extinguishing system.

  9. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Question 2 Current IBC & NFPA 13 use wording indicate required suppression systems be monitored off premise. Would this include clean agent suppression systems also, if no fire alarm system is present? See answer to question 1. Can you cite a specific code section? IBC 904.3.5 states the following IBC 904.3.5 Monitoring. Where a building fire alarm system is installed, automatic fire-extinguishing systems shall be monitored by the building fire alarm system in accordance with NFPA 72.

  10. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Automatic fire-extinguishing systems need not be electrically supervised unless the building is equipped with a fire alarm system. This section recognizes the fact that a fire alarm system is not required in all buildings. However, because most alternative fire-extinguishing systems require the space to be evacuated before the system is discharged, they are equipped with evacuation alarms. Interconnection of the fire extinguishing system evacuation alarm with the building evacuation alarm results in an increased level of hazard notification for the occupants in addition to the electrical supervision of the fire-extinguishing system. NFPA 101 states 9.7.1.4 Automatic sprinkler systems installed to make use of an alternative permitted by this Code shall be considered required systems and shall meet the provisions of this Code that apply to required systems. So if the suppression system (including clean agent systems) is required and the fire alarm system is required to be monitored, then the suppression system is required to be monitored.

  11. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Question 3 Would non-required clean agent suppression system have to be monitored as well? No.

  12. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Question 4 NFPA 72, Par. 23.11.10 (2013) and previous editions require suppression system releasing panels to be monitored at the building fire alarm system for alarm, supervisory, and trouble signals. Many systems are installed without this feature. Also see NFPA 72, Par. 17.13 (2013), could reviewers post a statement to the effect on fire alarm & fire suppression system review letters, so all parties; POR, installer, OSFM inspector can be aware of this requirement. A cautionary comment will be added to all suppression system review stating the 2008 code section.

  13. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY 2008 edition

  14. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY 2013 edition

  15. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Question 5 NFPA 2001, Par. 4.3.3.5.1 (2012), states that a “discharge pressure switch shall be required where mechanical actuation is possible.” It appears that the OSFM is not enforcing this requirement in review letters and final acceptance. NFPA 2001, Par. 4.3.3.5.1 (2012), states that “the discharge pressure switch shall provide an alarm initiating signal to the releasing panel. “ This also is not being enforced on suppression systems. Both requirements have been in the code for sometime OSFM enforcement would insure a “level playing field” when contractors quote suppression systems. This note per NFPA 2001 2008 edition will be added to all future reviews as a cautionary comment.

  16. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Question 6 NFPA 2001, Par. 5.3.6.2 (2012), many owners do not allow the ventilation system to be shut down due to potential unwanted alarms. However, this can be done after 2nd alarm, during the time delay period when a discharge is imminent. This paragraph requires ducts & areas above suspended ceilings to be protected (part of total hazard volume) and requires detectors and nozzles in this area. It appears this requirement is not being enforced. Can your reviewers add this cautionary statement to clean agent suppression system letter? Even if initial shop drawings indicate air handling equipment shut down; it’s very often revised in the field.

  17. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY A cautionary comment will be added to all clean agent system reviews stating the 2008 code section.

  18. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Question 7 NFPA 72, Par. 26.6.2 (2013), state that “nothing in this paragraph 26 shall be interpreted as prohibiting the use of listed equipment using alternate communications methods that provide a level of reliability & supervision consistent with the requirements of chapter ten.” This statement is also in the 2010 NFPA 72. a. Does this paragraph require cross listing of components used in off premise monitoring? “72:10.3.1 Equipment shall be installed in conformity with this Code shall be listed for the purpose for which it is used.”

  19. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY b. Seems like the current interpretation by the OSFM increases cost & may prevent many non-required off premise monitoring systems from being installed? Please give an example of when this has happen. If the fire alarm system is not required to be monitored and it is submitted as a “Non-required Fire Alarm Exemption Request” then this office will not regulate the configuration of the technology for off site monitoring and therefore not prevent such installations.

  20. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY c. Many members of the Louisiana AFAA have confirmed that they feel a memo and Seminar should be presented by the OSFM Plan Review Section, so that this requirement can be clarified and receive input from Industry. Could your office present such a Seminar (2 hours) in conjunction with our June Meeting? Lets discuss.

  21. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Question 8 NFPA 13, Par. 6.9.4.2 (2013) states, “sprinkler water flow systems that are not part of a required protective signaling system shall not be required to be supervised, and shall be installed per NFPA 70, article 760 - this is confusing. Doesn’t IBC require all sprinkler systems to be supervised? The code section 13:6.9.4.2 states that if a sprinklered system is not required to be supervised, the water flow alarm system is to be installed per NFPA 70. NFPA 13 does not mandate supervision, this is done by NFPA 101 or the IBC. Since the IBC requires all sprinkler systems to be supervised, this NFPA code is mute.

  22. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Are non-required sprinkler systems required to be supervised per NFPA? No, if they are submitted as non-required/non-conforming.

  23. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Question 9 NFPA 17 (Par. 5.7.2 (2009) (Supervision), states in 5.7.2.1 that supervision of electronically or pneumatically operated automatic systems (dry chemical), be provided unless specifically waived by the authority having jurisdiction. Also see paragraph 5.7.4, concerning “connection to the alarm system” Is Par. 5.7.2.1 requiring off premise notification? “9.6 System Supervision. 9.6.1 Where electrical power is required to operate the fixed automatic fire-extinguishing system, the system shall be monitored by a supervisory alarm and provided with a reserve power supply. 9.6.2 Where fixed automatic fire-extinguishing systems include automatic mechanical detection and actuation as a backup detection system, electrical power monitoring and a reserve power supply is not required.”

  24. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY So it does not appear it is requiring off premise notification, unless of course there is a required fire alarm system. Then this supervision would have to be tied to the fire alarm system. The IBC says if a fire alarm system is installed it need to be monitored. b. NFPA seems to use the term “supervision” in a variety of places. Doesn’t seem to have a definition in NFPA standards - is there one? Supervision is not specifically defined by NFPA. Many codes or standards use the word supervision Per 5.7.4, only requires connection to a fire alarm system, if provided. This goes back to if the fire alarm is required or not. If the fire alarm system is not required, then it is not required to be monitored.

  25. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY These two paragraphs seem to conflict with each other – can you clarify and state requirements of your office?

  26. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Required sprinklered systems are required to be supervised and monitored by an approved supervising station Required fire alarm systems per IBC 907.6.5 shall be monitored by an approved supervising station per NFPA 72 Required suppressions system (kitchen hood, clean agent, paint booth, etc.) are required to be supervised and monitored by an approved supervising station if the building has a required fire alarm system. Non-required sprinkler systems if installed as non-required/non-conforming can be installed without off site monitoring Non-required fire alarm systems if installed as non-required/non-conforming can be installed without off site monitoring Non-required suppression systems if installed as non-required/non-conforming can be installed without off site monitoring

  27. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY 10. I would like clarification on modifications and upgrades. I had a customer that had a high rise building and wanted to add horns and strobes. Anyway when I spoke to the Fire Marshal’s Office I was told to look at ADA and it states whenever a fire alarm system is upgraded the building fire alarm had to be brought up to meet ADA. Naturally the client said no thanks to adding to his system due to the mandate of bringing the entire system up to ADA compliance. A modification is a minor change involving 10 or less fire alarm devices to an existing alarm system and is not addressed in the ADA. An upgrade is the addition of audible/visual devices which leads to the replacement of the existing fire alarm control panel. If the proposed horn/strobes can be supported by the existing panel without panel replacement, then this would be considered a modification typically.

  28. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY 11. If there is a project with two separate architectural review letters are they looked at as one or two projects? The professional of record wants two separate submittals, since each project is fewer than 10 devices it would require two exemption request forms. If they are submitted together it would be over ten devices. What is your recommendation? Each architectural review is tied to a physical address. Likewise the fire alarm submittal, exemption or full submittal is tied back to that physical address.

  29. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY 12. As in two above one project has a professional of record and one is being done by the owner. a. Does the professional of record have to sign both? No. b. What if he refused? See answer above.

  30. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY 13. We are having problems with schools getting the architectural review letters when adding and relocating temporary buildings. If there something in writing we could show them instead of submitting and being rejected because there is no architectural review letter? “RS 40:1574. Construction or repair of structures A. No structure, watercraft, or movable shall be constructed until building plans and specifications therefor have been submitted to and reviewed by the fire marshal and appear to him to satisfactorily comply with the laws, rules, regulations, and codes of the state. B. No repair, remodeling, or addition shall be made to any structure, watercraft, or movable affecting the exits, stairs, seating arrangement, fire protection, or other details of construction covered by this Part until plans and specifications therefor have been submitted to and reviewed by the fire marshal and appear to him to satisfactorily comply with the laws, rules, regulations, and codes of the state.”

  31. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY 14. Most water flow switches have two switches inside. Can one be used to power an outdoor 120VAC bell and the other used for the fire alarm connection? Even though the low and high voltage would enter the box in through own conduit, is this still permissible? Per Mark Joiner: After reading his question it appears they are using a Power-limited fire alarm circuit. If this is true they must follow the guidelines of NEC 760.136. If they are a Non-Power-limited fire alarm circuit then they must follow NEC 760.48. Many times they use a low voltage relay in a junction box located at the bell location. They run the control voltage(12-24 V) from the flow switch to the relay and break the 110 volt circuit through it for the bell. The relays come with a built in "barrier" separating the low and higher voltages.

  32. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONS OFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY 15. We are having more situations where the customer is replacing their own batteries on required and non-required fire alarm systems. They are also starting to replace field devices. What is your recommended procedure for this type of situation? Submit a complaint on these situations because a license is required to perform any of the work listed above.

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