Annual Fire Pump Test

Q: Is it required to dropped power to your electric driven fire pump while it is running to ensure it starts back up and continues to run on emergency power?

A: If you are referring to the annual fire pump flow test, the answer is yes. Section 8.3.3.4 of NFPA 25-2011 requires a simulated power failure while the pump is operating at peak capacity (150% of nameplate capacity) and confirm that the fire pump continues to operate at peak capacity under EM power. This means a second set of pitot readings are necessary while the pump is operating on EM power at peak capacity. Check with your contractor who conducts this test. Surprisingly, many contractors who perform the annual fire pump test fail to include this procedure.

Fire Pump Phase Reversal

Q: On our fire pump, we monitor the “Fire Pump Run” and “Fire Pump Loss of Power” on our supervisor points, but the fire pump control panel has a point which could be monitored for “Phase Reversal”. My question is, are we required to monitor “Phase Reversal” as a supervisory point?

A: That answer depends on the version of NFPA 20 “Standard for the Installation of Stationary Pumps for Fire Protection” that was enforced when the pump was installed or renovated (upgraded).

According to NFPA 20-2010, section 10.4.7, where the fire pump room is not constantly attended, audible or visual signals powered by a source not exceeding 125 volts must be provided at a point of constant attendance, for each of the following points:

  • Pump running
  • Loss of power
  • Phase reversal
  • Connected to EM power

According to NFPA 72-2010, section 23.8.5.9, the building fire alarm system is to be used for fire pump monitoring.

There was a time when NFPA only required the points for “Pump running” and “Loss of power” to be monitored, so you may not have to connect “Phase reversal” to the building fire alarm system. According to section 1.4.1 of NFPA 72-2010, the NFPA 72 code/standard is not retroactive to existing equipment.

When was this fire pump controller installed? I checked the 1999 edition of NFPA 20, and that edition required all four points to be monitored. If the controller was installed or updated since March 11, 2003 (the date CMS adopted the 2000 Life Safety Code) then I would say “Phase reversal” is required to be monitored.

Frequency Between Fire Pump Tests

Q: How long is a grace period for the annual fire pump test to be past due?

A: Well, technically, there is no grace period. Either you are compliant or you are not. But most AHJs usually have their way of determining time when it involves frequencies for testing and inspection.

One AHJ may be “by the NFPA book” and when the NFPA code or standard says annually, that means it needs to be done within 12-months of the previous annual test. CMS typically does not allow for more than 12-months for an annual test. In other words, there is no “12-months plus 30-days” for CMS.

But accreditation organizations (AO) seem to have a slightly different interpretation of time. Where NFPA says annually, one AO could mean 12 months from the previous test, plus or minus 30 days. But, as mentioned, CMS does not like the “plus” side of the equation, meaning they don’t mind if you do your flow-test before 12 months has pass from the last test, but they don’t care for one day beyond 12 months. So, state agencies surveying on behalf of CMS would likely cite an organization if the test is one or more days beyond 12 months from the last test, but many accreditation organizations would allow up to 30-days past the 12-month date.

This is one area where NFPA has not clearly defined how they interpret the different time periods for testing or inspection. They purposefully leave this open for the AHJ to decide, but the problem is, hospitals typically have 5 or 6 different AHJs who inspect them for compliance with the Life Safety Code. Chances are, you will never get all 5 or 6 AHJs to agree on what it means. It’s a crap-shoot sometimes. You don’t know how one particular AHJ will respond until they are onsite and write a citation. So, the hospital has to follow the most restrictive interpretation.

Monthly Fire Pump Test

Q: I have always tested my fire pumps on a weekly basis, but now I’ve heard from a consultant there is a new standard that says only a monthly run is required. Is this true?

A: Yes, it is. With the adoption of the 2012 Life Safety Code, the 2011 edition of NFPA 25 is now the standard to use regarding inspection, testing and maintenance of sprinkler systems. Section 8.3.1.2 of NFPA 25-2011 now allows electric-motor driven fire pumps to be tested under no-flow conditions on a monthly basis rather than weekly, which was required under previous editions of NFPA 25. However, engine-driven fire pumps still must be tested weekly.

Monthly Test vs. Weekly Test of Fire Pumps

Q: Electric fire pumps needed to be run once a week. Then that was changed to once a month. Now the new NFPA 25 has the pump being run once a week again. Is this correct? If my AHJ has adopted the most current code I need to follow that code and change my pump running from once a month back to weekly schedule?

A: Let’s look at the facts: The 2000 Life Safety Code referenced the 1998 edition of NFPA 25, which required all electric motor-driven fire pumps to be tested at no-flow on a weekly basis. The 2012 Life Safety Code references the 2011 edition of NFPA 25 which permits electric motor-driven fire pumps to be tested at no-flow on a monthly basis (see 8.3.1.2 of NFPA 25-2011).

Section 8.3.1.2.1 of the 2014 edition of NFPA 25, says: “Except as permitted in 8.3.1.2.2 and 8.3.1.2.3, a weekly test frequency shall be required for the following electric fire pumps:

  • Fire pumps that serve fire protection systems in high rise buildings that are beyond the pumping capacity of the fire department;
  • Fire pumps with limited service controllers;
  • Vertical turbine fire pumps;
  • Fire pumps taking suction from ground level tanks or a water source that does not provide sufficient pressure to be of material value without the pump.

 

Section 8.3.1.2.2 says a monthly test frequency shall be permitted for electric fire pumps not identified in section 8.3.1.2.1; and section 8.3.1.2.3 says monthly test frequency shall be permitted for electric fire pump systems having a redundant fire pump. So… since CMS adopted the2012 Life Safety Code on May 4, 2016 with an effective date of July 5, 2016, CMS and all of the accreditation organizations are on the 2011 edition of NFPA 25 which permits all electric motor-driven fire pumps to be tested monthly, without exceptions.

However, if one of your other AHJs adopted a more recent edition of the Life Safety Code that references the 2014 edition of NFPA 25, then you have an obligation to comply with the most restrictive requirements, which may be a weekly test of your fire pumps, if section 8.3.1.2.1 of NFPA 25-2014 applies to you.

In anticipation of your next questions, I do not know what “Fire pumps with limited service controllers” mean. If that is an issue for you, I suggest you contact your AHJ that is requiring you to comply with the 2014 edition of NFPA 25 and ask them to define it.

Monthly Fire Pump Test

Q: Do we have to conduct a monthly flow test on fire pumps in healthcare?

A: No… NFPA 25-2011, section 8.3.1.2 requires monthly test of the electric-driven fire pump at no flow conditions, or what is commonly called ‘churn’. The test is started with the water pressure being reduced at the pressure switch controller until the pump starts. The pump is operated for 10 minutes with suction pressure and discharge pressure readings taken, along with confirmation that the pump shaft packing glands drip water (approximately 17 drips per minute, but follow manufacturer’s recommendations). The pump housing pressure relief valve is required to release water so you confirm that happens as well. Once the pump has operated for 10 minutes then it can be shut off. Engine driven fire pumps still have to be tested weekly for 30 minutes. A test where water is actually flowed is required annually on all fire pumps.

Annual Fire Pump Test

Q: I read where the annual fire pump test requires a 30-minute churn test but does not differentiate between a diesel or electric pump (as in the weekly test). NFPA 25, 2011 edition requires only a 10-minute churn for the annual test on an electric pump. What happened to the 30-minute churn test?

A: NFPA 25-1998 did require the annual fire pump flow-test for both electric-motor driven fire pumps and engine-driven fire pumps to have a 30-minute churn test at no-flow conditions to begin the test. This was to ensure the pressure relief valve opened to allow circulating water to cool the pump when operating at standby (i.e. no-flow) conditions.

Since CMS adopted the new 2012 LSC, we are now on NFPA 25-2011. Section 8.3.3.2(1) of NFPA 25-2011 dropped the requirement for a 30-minute churn test for the annual fire pump flow-test, but still requires the churn test; it just doesn’t specify how long the churn test must be. I can only surmise that the industry figured a churn test for 30 minutes to ensure the relief valve opens is no longer required.

However, section 8.3.3.2(3) says “For electric motor-driven pumps, the pump shall not be shut down until the pump has run for 10 minutes.” This statement is in reference to the pump operating at flow conditions, and is not a reference to how long the pump must run at no-flow conditions.

The new 2012 LSC is now being enforced by accreditation organizations and by CMS. For annual fire pump flow tests from now on, you may run the churn test portion long enough to ensure the relief valve opens and dumps water. You no longer have to run the churn test for any given length of time.

Fire Pump ATS

Q: A state surveyor cited us for not doing a monthly fire pump automatic transfer switch (ATS) test. We are doing a weekly churn test and an annual fire pump flow test that includes switching over the ATS. I was not aware that this had to be done monthly.

A: Yes… NFPA 110-1999, section 6-4.5 requires all transfer switches in Level I and Level II systems (hospitals typically have Level I systems) to be tested monthly. The state surveyor is correct. I find that it is not uncommon for some hospitals to overlook the ATS serving the fire pump. I guess they don’t always see that it is part of the Level I emergency power supply system. Out-of-site is out-of-mind!

Weekly Fire Pump Testing

Q: The Joint Commission standard for weekly testing of the fire pump only requires us to record the test date of the inspection. We were cited for not recording the suction and discharge pressures. Is this a requirement?

A: Yes, recording the suction and discharge pressures, along with the amount of time required to start the weekly test (by lowering the water pressure) are required documentation for each weekly fire pump test. Even though these requirements are not specifically identified in the EC standards, they are identified in the NFPA 25 (1998 edition) which is referenced by the Joint Commission standards.

Get a copy and read the NFPA 25 (1998 edition) as it has a lot of testing requirements of the sprinkler system which are not identified in the Joint Commission standards, but are required.

Removal of a Fire Pump

Q: Recently, I was at a counter-part’s facility in our corporate system and wanted to review the Life Safety Code documentation to ensure everything was in order. Within a matter of minutes I realized there was no fire pump paperwork and asked my counterpart about the matter. I was told that the fire pumps were removed: I was shocked. The reason for removing the fire pumps was because they were told by the city that if they had enough pressure on the top floor of their facility to run the suppression system, then they didn’t need a pump. The reasoning for this increase in pressure was due to an expansion of the water mains leading into the facility. I have never heard of this before! Have you ever heard of such a thing? How would the hospital be able to ensure that at any given time the pressure wouldn’t fluctuate and decrease?

A: I have heard of situations where the supply of the fire protection water changes, and the fire pump could be removed, but if what your counterpart is telling you is the full story, then I would advise them to take further action. The need for a fire pump in any building is not determined solely by the pressure of the water. There are multiple factors that must be considered in NFPA 13 that arrives at the decision whether a fire pump is required, and the volume and flow rate of water are a big part of the equation. Proper procedure would be to have the entire fire protection system water supply recalculated by a registered Professional Engineer to determine if the fire pump could be removed. For the hospital to make a major change in their fire protection based on the comment of a single authority having jurisdiction (AHJ) is very irresponsible.

Once the design of the system calculates that the fire pump could be removed, then permission must be obtained from all of the AHJs that inspect the hospital for fire safety, such as:

  • State fire marshal
  • State department of public health
  • Local fire inspector
  • Accreditation organization
  • CMS
  • Insurance company

Without written authorization granting permission to remove the fire pump from the appropriate AHJs, the hospital is at considerable risk if there should be an unfortunate incident involving the discharge of fire protection water. These AHJs approved the hospital’s fire protection plan based on the presence of a fire pump: To remove the fire pump without allowing these same AHJs the opportunity to make a comment is dangerous and likely unlawful.