Q: We are looking for guidance now that the language of “If a fire watch is required, fire/smoke detection or alarm system outage” has become a point of conversation with our local and state Fire Marshals. We can’t seem to get a straightforward answer from them as to when exactly we need to implement a fire watch. For large projects, we will definitely be bringing in a contractor to install upright heads. Our question is related to the small, 1-2 day projects that may only have 1-2 heads without a ceiling barrier, making them non-compliant. Would this scenario, in your eyes, require a fire watch assuming no upright head installation? We struggle with the feasibility of both situations: implementing a continuous fire watch and also bringing in a contractor for just a couple of heads for one or two days.
A: Let’s take our guidance from section 220.127.116.11 of the 2012 Life Safety Code, which says where a required fire alarm system is out of service for more than 4 hours in a 24 hour period, then an approved fire watch must be conducted. Now, if we go to the Annex section A.18.104.22.168 it says the term ‘out of service’ is intended to imply a significant portion of the fire alarm system is not in operation, such as an entire initiating device circuit, signaling line circuit, or notification appliance circuit. It is not the intent to require a fire watch for a single non-operating device or appliance.
Now, I know that is for fire alarm systems and your question was specific towards sprinkler impairments, but the problem is beginning with the 2012 LSC, the LSC discontinued to have a standard on sprinkler system impairments, but in turn referenced NFPA 25-2011. So, we go to section 15.5.2 (4) through (6) for guidance. This section basically says whenever the sprinkler system is out of service for more than 10 hours in a 24 hour period, then you do a fire watch, contact the fire department, and notify the insurance carrier and the state AHJ. But in this case, the Annex section does not offer any explanatory information as what constitutes ‘out of service’ like the Annex section in the LSC does for fir alarm systems.
So, this means the AHJ gets to decide what ‘out of service’ means. I know that CMS and the accreditation organizations interpret it to mean a circuit or zone has to be out of service before a fire watch is required, and a single device impaired does not warrant a fire watch. But in your case, you’ve asked your state AHJ to explain their position and so far they have not.
I suggest you decide for yourself, since your AHJ refuses to make a decision. Write a policy that states a single device out of service does not warrant a fire watch, but rather a zone or circuit that is impaired does, and reference Annex section A.22.214.171.124 of the 2012 LSC as a guidance.
If the AHJ won’t help you by informing you what they expect, then you do the next best thing and decide for yourself based on referenced standards.