NFPA 25 defines "deficiency" and "impairment" and discriminates between 
critical and non-critical conditions.   Just as we don't require drain valves 
to be listed (because they're not a critical link in the functionality chain) 
we can assign the value of "non-critical" to those conditions which may not be 
exactly right, but that don't encumber the ability of a system to work as 
designed.  

To your question about how to tag the system, that's purely subjective because 
requirements for reporting, tagging, certification, etc. all vary from state to 
state, jurisdiction to jurisdiction.   So if this jurisdiction requires that a 
tag be placed on the riser and you have to put it in black or white terms, the 
system will work and I think it's overkill to tag it non-compliant for a 3-way 
valve.  But your question was compound, so the next step is to create a 
correction/deficiency list and furnish copies to both owner and AHJ.  But I 
wouldn't "red-flag" a system for any non-critical deficiency.   

About the gap:  here in seismic country, such a gap is now REQUIRED if you 
don't use a swing joint or flexible hose connection for pendent drops.   This 
is prescriptive code and resides in ASCE 7, which is adopted in CA and also the 
basis for the seismic bracing practices in NFPA 13.   You can fill the annular 
space with an "oops" ring, but I'm not aware of anything in the code that ties 
the integrity of pendent sprinkler penetrations in ceilings to requirements for 
smoke barriers.   I appreciate that you cited NFPA 101, but that standard isn't 
even adopted in many states (including mine), and is superseded by code in 
others.  So again, I think you're going to get very subjective read-back on 
that from state to state, jurisdiction to jurisdiction.

My 2¢ and personal opinion only ...

Steve L.

 

-----Original Message-----
From: Sprinklerforum [mailto:[email protected]] On 
Behalf Of John Allen, CET, CFPS
Sent: Friday, September 02, 2016 6:40 AM
To: [email protected]
Cc: Robert Sauls; Tania Dodson; Cody Sauls; Tracie Ghee
Subject: I&T Roles and Responsibilities

I have a couple questions that pertain to the roles and responsibilities of a 
water-based inspector.

1st Question: Should an inspector inspect water-based systems outside the 
requirements of NFPA 25?  For example, NFPA 25 has no dialogue about 3-way 
shutoff valves for gauges.  However, NFPA 13 (2013) clearly defines the 
requirement of such: 

NFPA 13 (2013) 8.17.3.2    Each gauge connection shall be equipped with a 
shutoff valve and provisions for draining.

Therefore, if a 3-way shutoff valve is missing from installation, does this 
justify a non-compliant tag on the sprinkler riser and correction actions items 
identified to the owner(s)?

2nd Question: If there is a gap between my sprinkler head and the ceiling 
membrane, does this require a non-compliant tag on the riser.   NFPA 101 
outlines this as a smoke partition/barrier issue. NFPA 101 states:

NFPA 101  (2000) - 8.2.4 Smoke Partitions.
8.2.4.1 Where required elsewhere in this Code, smoke partitions shall be 
provided to limit the transfer of smoke. 
8.2.4.2 Smoke partitions shall extend from the floor to the underside of the 
floor or roof deck above, through any concealed spaces, such as those above 
suspended ceilings, and through interstitial structural and technical spaces.
Exception:* Smoke partitions shall be permitted to terminate at the underside 
of a monolithic or suspended ceiling system where the following conditions are 
met:
(a) The ceiling system forms a continuous membrane.
(b) A smoketight joint is provided between the top of the smoke partition and 
the bottom of the suspended ceiling.
(c) The space above the ceiling is not used as a plenum.

 Again, NFPA 25 does not identify this as a deficiency.  Should this be 
justified as non-compliant deficiency?

I do understand the role and responsibility of an inspection does not include 
the design of a water-based systems or of building code.  However, when faced 
with a deficiency from installation (from other codes), should it not be 
identified and corrected under the inspection and testing of a water-based 
system?

I look forward to your feedback and thoughts.

Best Regards,
 
John Allen, CET, CFPS
President



AFS: Allen Fire & Security
Your Safety is Our Success
Direct: 770.715.7261 | Office: 770.723.7280 Ext 2 | Fax: 678.894.4180 
 

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