Louisiana Automatic Fire Alarm Association – Quarterly Meeting 1/15/10 Question & Answer Session

1. LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND CORRECTIONSOFFICE OF STATE FIRE MARSHAL, CODE ENFORCEMENT AND BUILDING SAFETY Louisiana Automatic Fire Alarm Association – Quarterly Meeting 1/15/10 Question & Answer Session

2. Question 1Does a security system control panel have to be listed for “fire” if the owner wants to connect alarm and trouble signals from a non-required clean agent suppression system for off premise monitoring? The building does not have a fire alarm system. Where a security system is used to supervise non-required fire alarm devices, or subsystems, a monitoring panel listed for 'fire' is not required.

3. Question 2Regarding Duct DetectorsA. Are HVAC Duct Detectors interfaced to fire alarm control panels, required to be “yellow tagged,” if they do not shut the AHU down per requirement of 90A? YES, yellow tag the system and follow the notification procedures to the fire marshal if not repaired within 60 days.

4. Question 2 (cont.)Regarding Duct DetectorsB. Are they required to be “red tagged” if they do not shut units down and do not sent alarm or supervisory signals to the building fire alarm panel? If your firm's policy is such you can red tag the system; however, the yellow tag and 60 day time period for repair would be acceptable.

5. Question 2 (cont.)Regarding Duct DetectorsNFPA-90A does not regard HVAC Duct Detectors as “Life Saving” devices – so are these devices under the jurisdiction of the State Fire’s Marshal? Yes.

6. Question 3I understand that Fire Marshal Field Deputies are issuing “tickets” similar to the state police!1. I don’t recall ever seeing a memo - though, it was discussed/proposed at a previous LA-AFAA meeting?2. Who has the authority to issue these tickets?3. Is there a published fine schedule or is the field deputy the person solely responsible for placing a dollar value on the alleged offense?4. How does a company receiving such a “ticket” appeal?5. How/where is the fine paid?6. How many days after issuance is the payment due? Only the Licensing Section is using the ticket. This is in lieu of sending a formal Notice of Violation letter out for violations. All rights to appeal and due process are the same as the letter and are printed on the ticket.

7. Question 4Churches are exempt from Visual Notification per Memorandum July 8 1997 from Jerry Jones. He states that even “DAY CARE CENTERS” if church owed are exempted from the requirement. Is this memorandum still “Applicable”? The memo is still in effect and can be found on our website. Furthermore, the ADA specifically provides the exception under Section 36.102(e) of the Federal Register 28 CFR Part 36, which states that "religious entities" are exempt from the requirements of title III of the Americans with Disabilities Act. The exception being, where the facility is operated for use by the general public, and not limited to the members of the religious entity.

8. Question 4 (cont.) NFPA provides no guidance on what areas of a building are required to be visually notified. These location requirements are derived from the ADA, so that all 'public' and 'common use' areas receive visual notification. Where the facility is exempt from the ADA requirement to provide visuals, then no guidance for their location is available, and we allow omission of those devices. The bottom-line is the only criteria for any occupancy classification is that it be owned and operated by the religious institution to be exempted for compliance from ADA-AG.

9. Question 5If a project is “Assembly” under 300 and Voice is not required, but engineer indicates he still wants to just install a “Fire System” with Voice, will this be acceptable to your office? Yes.

10. Question 6Can the FIRE ALARM contractor provide contacts to other sub-contractors for systems requiring them to “RELEASE” their system upon activation of Fire Alarm, without having to submit the short form? Note the contacts are “Existing” in the FACU. No work can be performed or connection be made to the fire alarm system, except by an appropriately licensed fire alarm contractor. The relay between fire other fire protection systems and the fire alarm system is a listed fire alarm device, and must be connected by the licensed fire alarm contractor on both sides of the relay.

11. Question 7NFPA 72 (2002) Paragraph 10.4.3.4 states: Restorable fixed temperature spot type heat detectors shall be tested in accordance with 10.4.3.4.1 through 10.4.3.4.3.A. Does the Louisiana State Fire Marshal’s Office recognize & accept this method of testing? Yes.

12. Question 7 (cont.)B. Many building owners “bid” inspections on an annual basis. If the owner has no previous test records to substantiate previous partial testing, then is the contractor to test all 300 – 400 heat detectors in order to “green tag” the panel? If the owner can not provide the appropriate documentation of required testing (per the appropriate edition of NFPA 72) and you do not perform such at the time of inspection, then the yellow tag should be used.

13. Question 7 (cont.)C. Can the contractor “green tag” and punch “certification” if only a partial quantity of heat detectors are tested as per paragraph 10.4.3.4? Only certify the system if it meets the requirement as set forth in the testing chapter of the appropriate edition of the NFPA 72.

14. Question 8In a lot of review letters, it states “CAUTION”: Detectors should not be located within “3” feet of an air diffuser or return air opening, per NFPA72:A.5.7.4.1. This paragraph does not seem to indicate this wording.Where is the “3 foot rule” coming from? Does it have something to do with the amount of “CFM” from the register with regards to most detectors? The 2002 edition of NFPA 72: Annex .5.7.4.1 "Detectors should not be located in a direct airflow or closer than 1 m (3 ft) from an air supply diffuser or return air opening. Supply or return sources larger than those commonly found in residential and small commercial establishments can require greater clearance to smoke detectors. Similarly, smoke detectors should be located farther away from high velocity air supplies."

15. Question 8 (cont.) We cannot specifically enforce the Annex, because the language is descriptive, and only provides recommendations regarding the code requirements, but our office has chosen to cite this language for basic compliance. Where a device can be documented to have a listing that would allow alternate placement it will be allowed, upon submittal of the documentation by the fire alarm contractor and acceptance of the documentation by the reviewer.

16. Question 9Paragraph 10.6 records of NFPA 72 Required permanent records, acceptance tests, etc to be provided to the building owner. Paragraph 10.6.1.3 requires the owner to maintain these records for the life of the system.A. Does the SFM Inspector request such records upon entry of a facility? 75% of all building owners cannot find or typically provide any original drawings, as builtdrawings, or previous inspection reports. No assuming you are referring to existing buildings. Buildings get sold, leased out to new business owners, etc… Therefore this would be impossible to enforce on an routine inspection.

17. Question 9 (cont.)B. Does the field inspector have a check list to verify observation of such items, plus Fire Marshal Installation Tag, power supply source breaker number, etc? Seems like very few contractors provide all of this for the completed installation. 1) No. 2) Yes, the inspector does check for the Fire Marshal Installation Sticker, and power supply source breaker.

18. Question 10NFPA 72, paragraph 10.4.3 (Testing Frequency) has an 18 month exception for certain conditions (i.e. process operations, energized, electrical equipment, excessive height, etc…).A. Does the contractor “yellow tag” the panel if initiating devices are not tested in accordance with this exception?B. If the answer is yes, then what happens 60 days later, if the devices are not tested and still within the 18 month period? How do we handle the potential “red tag”? Only place the yellow tag on the system if the inspection occurs after the 18 month time period expires. If a yellow tag is placed on the system, send in the notification form as required by the rules. The inspection section can work with the owner to establish the exact time that these additional tests will occur.

19. Question 10 (cont.)C. Can the contractor “green tag” the panel, and reference this exception on the back of the tag and inspection forms? Only green tag the system if the system complies with all inspection requirements set forth in NFPA 72, i.e., you can green tag the system if the 18 month time period has not expired.

20. Question 11Will the State Fire Marshal approve a pre-action sprinkler system where the end user has wired anormally closed relay contact controlled by a programmable logic controller (PLC) to place the fire system in a “test” mode? (i.e., when test mode is activated, the fire panel is in trouble, but thesystem can only be released by manual activation at the pre-action sprinkler valve.) The thermal detectors release air and allow water to enter a closed-head pre-action sprinkler system. It is unclear whether the questioner meant to indicate that the system detection was bypassed under normal operations by the relay / PLC connection, or whether this rigging was used only when the system was being tested.

21. Question 11 (cont.) First, the 'end user' is not allowed to modify the system unless they hold an appropriate fire protection license from this office. Second, Such a device would not normally be allowed to intervene in the listed system control or operation, unless it was a component of the listed system itself. “13:7.3.1.2 The automatic water control valve shall be provided with hydraulic, pneumatic, or mechanical manual means for operation that is independent of detection devices and of the sprinklers.”

22. Question 11 (cont.) The device would not be allowed to modify, obstruct or interfere with the required, minimum operations of the suppression system and its control and initiating devices. “13:7.3.2.1 Pre-action systems shall be one of the following types: (1) A single interlock system, which admits water to sprinkler piping upon operation of detection devices. (2) A non-interlock system, which admits water to sprinkler piping upon operation of detection devices or automatic sprinklers. (3) A double interlock system, which admits water to sprinkler piping upon operation of both detection devices and automatic sprinklers.”

23. Question 12A. When will your office adopt a later version of NFPA 101 (Life Safety Code)? The staff attorney will file in the state register before January 20, 2010. It will become effective six months later on July 1, 2010.

24. Question 12 (cont.)B. Is there any consideration being given to adopt the International Fire Code in lieu ofNFPA 101? This office has no plans to adopt the IFC.