Duct Detectors

Q: With regard to testing duct detectors in a hospital, I understand that on an annual basis the automatic shutdown of the AHU’s must be verified when duct detectors are activated. I am unclear if there is also an annual requirement to verify damper (pneumatic and/or electric type but excluding fused links) operation at the same time. Also, is there a requirement to test smoke dampers annually?

A: No… there is not. Even though NFPA 72-2010 does require confirmation of all interface relays tested on an annual basis, and does imply that actuation of the dampers are required, NFPA 72-2010 cannot regulate the testing of fire or smoke dampers. Only NFPA 80-2010 and NFPA 105-2010 can regulate testing requirements for fire and smoke dampers respectfully.

You still have to test the interface relays (modules) on an annual basis, but you are not required to confirm that the smoke dampers did close on an annual basis.

But be aware, that some surveyors may require that you do confirm the smoke dampers closed on an annual interface relay test… That would be an incorrect interpretation on their part, and you may want to point out that NFPA 4 was created (in part) to eliminate these conflicting cross-testing requirements.

Fire Alarm Notification Devices in the OR

Q: Can you explain the fire alarm notification appliance location requirements as it pertains to the operating room? I seem to recall that there’s no requirement to have them in an operating room and, in fact, that it is generally more desirable to NOT have them since they may act as a distraction to the surgical team members. We are a two-hospital system with one of the hospitals having strobe only devices in each operating room and the other hospital having no A/V devices in their operating rooms.

A: Since hospitals are a patient relocation or partial evacuation facility, the private mode of alarm notification is allowed to help avoid a panic situation.  In private mode, the intent of notification (speakers, chimes, strobes, etc.) is to alert personnel responsible for taking action when the fire alarm system activates.  In other words, only key, responding personnel need to hear or see the audio/visual device or receive notification that an alarm has activated (corridors, nurse stations, engineering & back of the house areas, etc.).

These personnel aren’t normally found in operating rooms so there is no requirement to have notification devices in those areas. Even though we all know that surgeon distraction is a very good reason to not have them in operating rooms, NFPA 101 Life Safety Code developers try to stay away from potentially subjective exceptions when they can. Private mode notification is allowed so they don’t need to make a specific exception in this case.

However, there is an exception provided for critical care areas like NICU to use just visual devices. The reason for the difference between your two hospitals is probably that designers often forget or are unaware of private mode notification as an option for these types of facilities.  99% of the time they apply public mode notification that you see in most buildings.  Additionally, they have to consider ADA requirements and for some, it’s just too much time & effort to apply exceptions, so they just paint with a broad brush.

No one minds at the time so it goes forward.  If you’d like to eliminate strobes in the operating rooms, run it by the local fire department’s fire prevention officer, citing your concerns and using private mode notification as justification.  If he’s OK with it, you’ll need to update your system drawings and ensure the wiring is reconfigured correctly, so there’s some expense to doing it. [NOTE: Gene Rowe from Affiliated Fire Systems contributed to this reply.]

Batteries in the Fire Alarm System

Q: We have a difference of opinion in our organization that I hope you can settle for us. I believe the sealed lead-acid batteries in our fire alarm system are supposed to be tested per the requirements of NFPA 72 (Charger Test and Discharge Test annually and Load Voltage Test Semiannually). However, another point of view is that, since they’re a stored emergency power supply, they’re supposed to be tested the same as our Emergency Lights (30-seconds a month and 90 minutes annually). We want to be sure we’re in compliance, but we’ve reached the point where we’re turning in circles trying to figure out what we’re supposed to comply with. What are your thoughts on this question?

A: Based on NFPA 110-2010, section 3.3.5.1, the definition of a stored emergency power supply system is a system consisting of a UPS or a motor generator, powered by a stored electrical energy source, together with a transfer switch designed to monitor preferred and alternate load power source and provide desired switching of the load, and all necessary control equipment to make the system functional. That does not sound like batteries for a fire alarm system.

The Life Safety Code is the document that governs whenever there is a conflict or a disagreement. Section 19.3.4.1 of the 2012 LSC requires compliance with section 9.6 in regards with the fire alarm system. Section 9.6.1.3 says the fire alarm system must be installed, tested and maintained in accordance with NFPA 72. Table 14.4.5 of NFPA 72-2010 says sealed lead acid batteries used on fire alarm systems must have a charger test and a discharge test conducted annually, and a load voltage test conducted semi-annually. This eliminates any thought that the batteries must be tested monthly.

The requirement to test battery powered emergency lights on a monthly basis is found in section 7.9.3.1.1 of the 2012 LSC, and this applies to emergency lighting systems… Not fire alarm systems. In this situation, you are clearly correct. Tell the others they owe you an ice cream cone for being right.

Coded Words for Fire

Q: Our EP manager was discussing removing the code words like Code pink for a missing infant to missing child and the conversation about code red for fire came up. Someone in the conversation said there is a NFPA code requirement that “Code Red” must be in code form instead of saying “Fire”. I have not heard of this and haven not search yet. I wondered what your take is on this. Our FA system is programmed for voice that states “Code Red” and then the location.

A: Well… that ‘someone’ is actually correct… sort of.

Section 19.7.1.7 of the 2012 Life Safety Code actually does say “When drills are conducted between 9:00 pm and 6:00 am a coded announcement shall be permitted to be used instead of audible alarms.” So this section of the LSC does reference a code-word should be used to identify fire, such as ‘Code Red’.

But that requirement for a coded word for fire is only found in section 19.7.1.7 and is limited to a fire drill conducted without audible alarms between 9:00 pm and 6:00 am. Therefore, since the Life Safety Code does not prohibit it, the conclusion is you would be permitted to say ‘Fire’ instead of ‘Code Red’ when the fire alarm system is activated.

But is that in your best interest to do so? I am aware that there is a trend across the country to eliminate coded words for certain emergency announcements. Many coded words (i.e. ‘Code Pink’) are not used universally in all hospitals, and since healthcare staff is rather transient, the movement is to have announcements identify the actual emergency rather than using coded words. But the original intent in using ‘Code Red’ is to alert staff of a fire condition, yet not alarm visitors and patients un-necessarily, thereby causing a panic.

If it were my hospital, I would be an advocate to allow ‘Code Red’ to remain, but eliminating other coded words should be considered.

Smoke Detector Disabled

Q: If a smoke detecting device is disabled for a breathing treatment (often for several days), what sort of fire watch, notification or signage is necessary?

A: None. Fire watches are not for a single device taken out of service, or for a single device found to be impaired. According to section A.9.6.1.6 of the 2012 LSC, it is not the intent of the Life Safety Code to require notification of the AHJ or evacuation (or fire watch) for the portion of the building affected for a single nonoperative device or appliance.

Also, section 9.6.1.6 of the 2012 LSC says where a required fire alarm system (not a single device) is out of service for 4 or more hours in a 24-hour period then an approved fire watch should be conducted. If this smoke detector is located in a healthcare occupancy, there may be a good chance that it is not a required device. Many designers add smoke detectors throughout hospitals where the LSC does not actually require them. In my opinion, you would need to have a branch or circuit disabled on a fire alarm system before a fire watch is required.

Strange Observations – MHO Rod

Continuing in a series of strange things that I have seen while consulting at hospitals…

We already talked about this issue on ‘Strange Observations – Part 20’ posted April 5, 2018, but it’s worth revisiting.

You cannot have home-made components installed on the fire alarm system. The threaded rod is not UL listed for this purpose.

 

NOTE: I’ve received some skepticism on the validity of saying the door release equipment is part of the fire alarm system. I base my position on section 21.8 of NFPA 72-2010, which says the door release equipment is a function of the fire alarm system, and according to section 10.3, all equipment used in conformity with NFPA 72-2010 must be listed for the purpose for which it is used. If the manufacturer of the door release device obtained a UL listing for the threaded rod, then I stand corrected. But as far as I know, that has not happened.

 

 

Qualifications of Personnel

Q: We recently acquired a hospital that has been performing segments of their own fire system testing. What are the specific requirements or qualifications for an individual conducting testing or inspections on fire alarm systems and sprinkler systems?

A: NFPA 72-2010, section 10.4.3.1 requires a certified individual to perform service, testing, inspection and maintenance on fire alarm systems and components. The certification must be one (not all) of the following:

  • Factory trained and certified for the specific type and brand of systems being serviced
  • Persons who are certified by a nationally recognized certification organization (NICET, IMSA, etc.)
  • Persons who are registered, licensed or certified by the state
  • Persons who are employed and qualified by an organization listed by a national recognized testing laboratory for servicing fire alarm systems.

I have seen some larger hospitals that do employ people who meet one of the above requirements, but most hospitals contract this work to a qualified vendor who has these credentials. When it comes to sprinkler system testing/inspecting, NFPA does not require certification of the individuals performing the test/inspection. However, please check with your state and local AHJ to determine if they have additional requirements.

Fire Alarm System Strobes

Q: I work in a healthcare facility and we are in need to find an answer to a question regarding strobe lights. When we test our fire alarm system, and we silence the alarm, the strobe lights do not continue to flash. We were told that this is not “code” and the lights need to continue to flash even if system is silenced. I cannot seem to find this located in any part of the Life Safety Codes. Also, this is an older facility, so at some point/date do some healthcare facilities get grandfathered in if this is a newer code?

A: No… older facilities do not get to be grandfathered, or in any other way, exempt from complying with the code.

Section 19.7.1.4 of the 2012 Life Safety Code requires the transmission of the fire alarm signal during a fire drill. That means you cannot silence the audible alarms and you cannot disable the visual (i.e. strobe) notification devices. If you are doing either during a fire drill, then you are non-compliant and need to discontinue this practice and make sure the audible notification devices and the visual notification devices operate properly during each fire drill.

Now, having said that, there is one exception that you may qualify for and that is found in section 19.7.1.7 of the 2012 Life Safety Code, which says when drill are conducted between 9:00 pm and 6:00 am a coded announcement is permitted to be used instead of the audible alarms. But, the visual notification devices (i.e. strobes) must operate.

Fire Door Inspector

Q: My accreditation organization has a standard that says “testing and inspection of fire door assemblies needs to be conducted by a qualified person.” By what specifically do they mean when they say “qualified” and where are we able to find where they define their interpretation of what qualified is?

A: You will find the interpretation of what ‘qualified’ means under section 5.2.3.1 of NFPA 80-2010, which says functional testing of fire doors and window assemblies must be performed by individuals with knowledge and understanding of the operating components of the type of door being subject to testing. You may hire this responsibility out to a contractor with this knowledge and understanding, or you may assign the responsibility to test the fire doors to one of your own staff individuals, provided you ‘qualify’ them by determining they have the knowledge and understanding to perform this test.

If you decide on the latter, you need to document this decision by describing why you believe this individual has this knowledge and understanding of fire door operating components, and retain that document in case the surveyor asks to see how you qualified that individual. Your own staff individual could be qualified based on a certification course they may have taken (please understand there is no requirement that the person conducting the fire door inspections be certified, but it can be a good source of education), or the individual may be qualified simply because they have worked on doors for years and have accumulated this knowledge and understanding. The key is you may need to defend this decision, so it is best to document the decision and retain that to show to a surveyor.

Addressable Fire Alarm Systems?

Q: Are you aware of any accrediting organization requiring the hospital to have an addressable fire alarm system installed? If so, what organizations? Please explain the rationale and any supporting code behind this decision. Background: A hospital currently has a fully functional zone fire alarm system installed but heard that accrediting organizations are requiring addressable systems. In my review of NFPA 101 2012, I cannot find anything in chapters 18 or 19 that would differ from the 9.6 reference to NFPA 72 2010.

A: There is no NFPA Life Safety Code requirement for you to have an addressable fire alarm system. There is a requirement that the hospital have a fire alarm system that meets the requirements of 19.3.4 of the 2012 LSC, but that does not include being an addressable system. As far as I know, Joint Commission, HFAP, and DNV do not require an addressable fire alarm system, and CMS does not require an addressable fire alarm system.

Now, a state or local law may exceed the NFPA minimum and require an addressable fire alarm system, but you would have to check with your state and local authorities to find that out.