Sprinkler System Exceptions

Q: Are there any exceptions in NFPA 13 for smoke detectors in lieu of sprinklers in areas such as radiology rooms or other high tech equipment rooms and still be considered “fully sprinklered”?

A: No. There is an exception in Section 8.15.10.3 of NFPA 13-2010 that allows electrical rooms not be sprinklered, and the building can still be considered fully sprinklered, provided the room is dedicated to electrical equipment only; only dry-type electrical equipment is used; equipment is installed in a 2-hour fire-rated enclosure including protection for penetrations; and no combustible storage is permitted in the room.

And, you can install clean agent suppression systems in lieu of wet sprinklers and the building is still considered fully sprinklered, but there are no exceptions allowing smoke detectors in lieu of sprinklers in any type of room, and still consider the building “fully sprinklered”.

Sprinklers in Lieu of Smoke Detectors

Q: We are seeking to reduce activation of smoke heads contained in our construction areas. In your opinion, if the construction area has existing sprinkler coverage or if new active sprinklers are installed in the construction area, would it be acceptable to remove the smoke heads in this space? In other words, are sprinklers a proper substitute for smoke heads?

A: No… sprinklers are never an acceptable substitute for smoke detectors, because sprinklers do not sense the presence of smoke. Conversely, smoke detectors are never an acceptable substitute for sprinklers because they do not extinguish a fire. However, if the smoke detectors are not required by code or regulation, then they can be removed without any alternative life safety measures applied.

According to 4.6.10.1 of the 2012 Life Safety Code, only deficiencies of required features of life safety necessitate alternative life safety measures (ALSM), also known as Interim Life Safety Measures (ILSM). However, be aware that not all surveyors will likely understand this and they may cite an organization for impaired smoke detectors even if the smoke detectors are not a required feature of life safety.

It is not uncommon for designers to over-install smoke detectors and place them in areas where they are not required. But if the smoke detectors are required, and you desire to remove them for construction purposes (not a bad idea) then you will have to assess them for ALSM and likely implement a fire watch, which can be very costly since it is now required to have a continuous fire watch. Replacing the smoke heads with heat detectors still does not change the result. If the smoke detectors are required then a heat detector is not an acceptable substitute.

Business Occupancy Smoke Detectors

Q: What are the requirements for the use of smoke detectors in a business occupancy physician office that does not have an automatic sprinkler system? The fire marshal is telling me that this is not required, but I cannot find a specific clause in NFPA and want to confirm that statement.

A: The fire marshal is sort-of correct. Smoke detectors are not mandatory in a business occupancy, if the building already has manual pull stations. According to section 39.3.4.2 of the 2012 LSC, only one of the following means to initiate of the fire alarm system is required:

  • Manual pull stations
  • Smoke detectors
  • Sprinkler system water-flow

Of course, you can have more than one type to initiate the fire alarm system, but if you have manual pull stations, then smoke detectors are not required. But, if you don’t have manual pull stations or a sprinkler system, then smoke detectors would be required if the building requires a fire alarm system. Some smaller business occupancies do not require a fire alarm system. Check with your state and local authorities to see if they have other regulations concerning initiating devices.

Fire Alarm Testing Qualifications

Q: I have a question regarding testing and repair of fire alarm system in a hospital setting. Is a maintenance person who is employed by the hospital as an electrician but who has 10-years of on-the-job training qualified to swap out a bad smoke detector or smashed fire pull station? Is he allowed to test the notification and transmission equipment also? Just trying to make sure I am interpreting the NFPA standards correctly.

A: Only if that individual has met the requirements of NFPA 72-2010, section 10.4.3.1, which describes the certification(s) needed in order to provide service, testing or maintenance on the fire alarm system:

“Service personnel shall be qualified and experienced in the inspection, testing, and maintenance of systems addressed within the scope of this Code. Qualified personnel shall include, but not be limited to, one or more of the following:

  • Personnel who are factory trained and certified for the specific type and brand of system being serviced;
  • Personnel who are certified by a nationally recognized certification organization acceptable to the authority having jurisdiction;
  • Personnel who are registered, licensed, or certified by a state or local authority to perform service on systems addressed within the scope of this Code;
  • Personnel who are employed and qualified by an organization listed by a nationally recognized testing laboratory for the servicing of systems within the scope of this Code.”

Now, the Annex section A.10.4.3.1 of NFPA 72-2010 says it is not the intent to require personnel performing simple inspections or operational tests of initiating devices to require factory training or special certification, provided such personnel can demonstrate knowledge in these areas. While the Annex section is not part of the enforceable code, it is explanatory information from the Technical Committee on what they were thinking when the standards were written. Most AHJs follow the Annex section and enforce it as part of their own standards.

However, changing out smoke detectors and/or pull stations is not within the purview of what the Annex section is saying.  To directly answer your question: If your electrician does not have any of the certifications identified in section 10.4.3.1, then no, he is not permitted to replace detector and/or pull stations.

Strange Observations – Ceiling Penetrations

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

This picture was taken in an electrical room. Where the conduits extend upwards and penetrate the suspended ceiling, the gaps around the conduits are too large.

Most surveyors will use the NFPA 80 maximum 1/8-inch gap rule fire door clearance to frames as a standard for the maximum gap around conduit penetrations, where the ceiling is required to act as a membrane for smoke detectors or sprinkler heads.

In situations like this, the easiest and best solution is to remove the suspended ceiling from the electrical room, and relocate the lights in the ceiling to the deck above.

Strange Observations – Smoke Detectors

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

According to NFPA 72-2012, Annex A.17.7.4.1 smoke detectors should not be located in direct airflow, or any closer than 36-inches from an air diffuser. This would include return-air diffusers, exhaust-air diffusers, as well as supply-air diffusers.

While the Annex section is not part of the enforceable code, it is explanatory information provided to give the reader direction on how the Technical Committee viewed certain standards. Any authority having jurisdiction (AHJ) may use this Annex information in determining compliance with the standard, and most AHJs do. Therefore, the 36-inch rule is widely enforced in all surveys.

But some smoke detectors have UL listings for use in high-velocity airflow areas and are recommended by the manufacturer to be mounted close to air-diffusers. This would lead one to believe they would be permitted within close proximity to an air-diffuser, such as the one in the picture indicates. But I have read reports where surveyors still cite the organization for installing the special high-velocity smoke detectors too close to air-diffusers because of the perception that the airflow would prevent ambient smoke from being detected by the smoke detector.

Rather than fighting this battle with over-zealous surveyors, it is best to just make sure all smoke (and heat) detectors are at least 36-inches from all air-diffusers.

Smoke Detectors in Patient Restrooms

Q: Can I provide a smoke detector in an existing hospital patient restroom? The smoke detector was recommended by the hospital safety committee to avoid smoking in these rooms. Our patient restrooms have bathtubs but no showers. Some restrooms are protected by sprinkler systems and some are not. Some restrooms are provided with heat detectors, but of course, they do not activate during patient smoking. Even though the safety committee recommended changing to a smoke detector, I am afraid of false alarms from the high humidity a restroom can generate.

A: While the Life Safety Code and NFPA 72-2010 do not require smoke detectors to be installed in patient bathrooms, designers usually do not place them there for fear of nuisance alarms. But experience shows a smoke detector in a bathroom that has a toilet and a bathtub is not the same risk that a smoke detector located in a bathroom with a shower has. The shower will atomize water droplets to form high concentrations of water vapor and will more likely cause nuisance alarms. The bathtub and toilet would not raise the relative humidity much at all.

Try it and see how it works for you.

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 – Part 25

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

I guess I like my smoke detectors mounted tight to the ceiling….

Fire Door Smoke Detectors

Q: I have a life safety consultant doing our annual inspection, and he keeps saying that I need to have individual smoke detectors for my corridor fire rated doors. The corridors on both sides of these doors are completely protected with smoke detectors, but he says regardless, that area smoke detectors are required next to the doors. Is this correct?

A: No, I don’t believe what the consultant is telling you is correct. Section 17.7.5.6.1 of NFPA 72 (2010) allows for either area smoke detectors or complete corridor smoke detector protection to activate the release of a hold-open on a door serving a fire barrier or a smoke compartment barrier. So, in regards to the cross-corridor doors that are held open by magnets connected to the fire alarm system, you are permitted to have one of the following:

  • A smoke detector on either side of the door mounted within five feet of the door; or smoke detectors mounted on both sides of the door within five feet if the transom above the door is greater than 24 inches.
  • The entire corridor where the cross-corridor door is located is properly protected with smoke detectors. A smoke detector must then be located within 15 feet of the door. For mounting locations for an area protected with detectors, the detectors must be no more than 15 feet from the wall (this is based on one-half of the maximum spacing distance between detectors which is 30 feet). The cross-corridor doors must be considered ‘closed’ when designing the detector locations, so that constitutes a “wall” and a detector is required within 15 feet of that wall.

Where consultants and surveyors have problems is they see a cross-corridor door held open by a magnet, and then they do not see a detector within five feet, and they believe that is a violation of NFPA 72. What they don’t consider is the corridor is completely protected with smoke detectors and NFPA 72 (2010) 17.6.3.1.1. (1) allows a detector to be one-half of the maximum spacing.