Third Party Compliance Verification for Fire Alarm Systems
Proposal 72-388 adds par. 4-1.2.1 to NFPA 72, The National Fire Alarm Code. It requires that all nonresidential fire alarm systems monitored by a continuously attended supervising station demonstrate compliance with NFPA 72 by providing a means of third party verification. The means of third party verification specified is that the installation be either certificated or placarded. This proposal has the potential to significantly elevate the quality of fire alarm system installations in the United States and deserves your support.
The requirement for third party verification of compliance complements existing model code requirements for plan review, acceptance inspection and acceptance testing. Many, if not all, public authorities having jurisdiction (AHJs) have local processes in place to provide a level of compliance assurance before a Certificate of Occupancy is issued for a premises. However, few have effective programs in place to assure ongoing compliance of the installation or alarm service requirements of NFPA 72.
Proposal 72-388 changes this scenario by giving AHJs a basis in code for implementing an ongoing, third party administered compliance assurance program. Certification or Placarding is defined in par. 1-4 of NFPA 72 as being a systematic program using randomly selected follow-up inspections of the certified systems installed under the program that allows the listing organization to verify that a fire alarm system complies with all of the requirements of NFPA 72. In times when many communities are struggling to stretch public resources, third party verification allows AHJs to achieve a higher level of ongoing compliance assurance without the need to significantly increase jurisdictional expenses.
Third party verification offers the following advantages:
· Identification of a single point of responsibility for an alarm system and service to that system
· Assurance of ongoing contractual arrangements that provide timely servicing and periodic testing and maintenance
· Audits performed at the protected property that include system inspection, spot tests and records review of signal handling, responses, servicing and testing
· Tracking of variations from NFPA 72 found during an audit that must be corrected in timely manner for certification to continue. Variations trigger additional focus on the issue involved and may result in audits of additional systems
· Flexibility - AHJs can utilize local requirements and still obtain certification
· Deficiency reports which can be provided to the AHJ
· Control of enforcement actions in cases of non-compliance retained by AHJ
· Review of specific locations (problem systems) by third party can be arranged by the AHJ
· Modest costs to the business owner with a code complying system in place. No cost to jurisdictional authority from two nationally recognized certification organizations
· Variety of reporting means offered by third party certifiers to help keep AHJs informed of compliance status within the jurisdiction
· Reduced false alarm rate claimed by current AHJ users of third party verification requirement
Call To Action
Where a fire alarm system transmits alarm, supervisory and trouble signals from a protected property premises to a central station, proprietary supervising station, or remote supervisory station, such a system must achieve a benchmark of quality to assure the system will perform the intended function. This type of system, by design, summons emergency response from public or private agencies. The system also serves to assist the management of a facility in overseeing the integration and operation of the many fire protection systems at a facility. Thus, the assurance that any particular fire alarm system meets this quality benchmark becomes critically important.
For over 30 years, various insurance organizations have gathered statistics to support the assertion that a code-complying fire alarm system performs more consistently with minimal false signals. Therefore, in helping to manage and provide life safety, property protection, mission continuity, heritage preservation, environmental protection, or any combination of these, the need to assure code compliance of the fire alarm system is reinforced even more strongly.
In virtually all phases of our society, where persons, professionals, or organizations must meet quality benchmarks, the success in reaching those benchmarks is measured by some type of verification. For supervising station fire alarm systems, the requirement for verification by providing a certificate or placard achieves this objective.
If you are a voting member of NFPA, your positive vote on acceptance of the Technical Committee Report on The National Fire Alarm Code, NFPA 72 will help assure the AHJs have a basis in code for implementing effective ongoing code compliance programs in their jurisdiction.
Support for Proposal 72-388 is endorsed by:
· Central Station Alarm Association (CSAA)
· Professional Alarm Services Organizations of North America (PASONA)
· National Electrical Manufacturing Association (NEMA)
· Automatic Fire Alarm Association (AFAA)
· California Automatic Fire Alarm Association (CAFAA)
Frequently Asked Questions About Third Party Verification
1. Why is a requirement for a means for third party verification for non-central station fire alarm systems being added now?
The requirement for a means of third party verification for central station fire alarm systems has been in The National Fire Alarm Code, NFPA 72 since the first edition was published in 1993. Previously, the requirement was in the 1989 edition of The Standard for the Installation, Maintenance, and Use of Signaling Systems for Central Station Service, NFPA 71.
Fully compliant central station service is not available in all parts of the US. In addition, it is often concluded that the risks associated with some types of properties do not justify the cost of full central station service. However, experience has shown that the issue of the limited resources for ongoing compliance inspections by AHJs is common to both central station and non-central station type systems. Proposal 72-388 gives a basis in code for implementing an effective, third party administered, ongoing compliance assurance program.
2. Does the third party verification described in NFPA 72 replace plan reviews and acceptance inspections & tests done by local AHJs?
No. Providing a means for third party verification is only one part of a larger framework for code compliance laid out by NFPA 72. Sec. 1-7.1 allows an AHJ to conduct plan reviews. Initial acceptance testing and inspections are required by Sec. 7-1.6.1. Virtually every jurisdiction in the country has permitting and approvals mechanisms in place to manage compliance with these and other fire and building code requirements. These permitting mechanisms put the local AHJ in the best position to determine pre-occupancy compliance.
3. If the third party doesn't verify compliance of every aspect of an alarm system before the system is commissioned, what value does it add?
A means for third party verification makes it possible for a public AHJ to maintain a high level of confidence in the ongoing compliance of fire alarm systems, long after the Certificate of Occupancy has been issued. In times when many communities are struggling to stretch public resources, systematic, ongoing inspection programs can be difficult to implement. When they are implemented, the inspections usually cover a broad range of subjects, the fire alarm system being only one. The increasing complexity of fire alarm technology presents additional challenges.
A third party can structure a program that provides a systematic audit of installed alarm systems and alarm service provided to a protected property. The auditors employed can specialize in fire alarm technology. Programs operated at the national level make possible audits at both the protected property and remote monitoring station ends of a single fire alarm system, something many AHJs do not have the resources to do alone.
The relationship between an AHJ and third party verification provider works best when both sides operate as partners. Each performs tasks it is best suited to do. Both understand each other's operating methods and the expected levels of communication. The local AHJ does plan reviews and acceptance tests. The third party verifier conducts ongoing audits of installations and service records. The AHJ and third party verifier collaborate on unannounced service tests. The third party verifier communicates noncompliance findings to the AHJ. The AHJ takes appropriate enforcement action.
4. How can an audit program that uses randomly sampling instead of 100% inspections be considered a "verification" program?
A program that called for third party re-inspection of every detail of every alarm system on an annual basis would be prohibitively expensive. In the vast majority of jurisdictions today, there is little or no involvement with fire alarm systems on the part of the AHJ after the Certificate of Occupancy. The "systematic program using randomly selected follow-up inspections" described in the definition of Certification in par. 1-4 of NFPA 72 makes possible a reasonably priced tool that allows AHJs to change the status quo.
If the third party verifier finds deviations from code during an audit of an installation, those deviations are tracked until they are either corrected or cleared with the AHJ. If chronic, systemic problems are found with an alarm company's practices, additional systems are selected for audit at an increased level of audit detail. The additional audit work is done at the alarm company's expense; above and beyond the annual fee. Alarm system owners end up bearing the costs of third party inspections. A verification program with sampling style inspections attempts to draw a line at a point where returns on additional detailed inspections start to diminish in value. When collected data supports additional detailed inspections, additional costs are incurred by the appropriate party, not the community at large.
This audit process for installed fire alarm systems is modeled after third party certification follow-up programs for manufactured products which have been successful in reducing hazards associated with products for over 100 years.
5. Has the current requirement for third party verification for central station systems been effective?
Yes. In a recent survey, 100% of AHJs that have accepted UL Certificates as a means of third party verification for 2 years or more indicated that the program meets their needs and expectations. Thirty of 31 indicated that they would be willing to share their experiences with other AHJs considering implementation of a third party verification program.
A Factory Mutual Research Corp (FMRC) review of data from its Placarding Program revealed significantly lower failure rates of signals from fully compliant systems:
From a non-approved central station 14%
From a non-placarded system receiving service from an Approved central station 7%
From a fully compliant, Placarded system 3%
Failure rates of signals refers to instances where signals were not received, not documented, or misidentified by the central station
6. How many active UL Fire Alarm Certificates are in force? How many FM Placards?
As of 3/1/99, there were 5,222 active UL Fire Alarm Certificates in force. Of these, 3,745 (72%) cover properties located in the 37 public fire jurisdictions that fully enforce NFPA 72 and are known to accept UL Fire Alarm Certificates as providing a means for third party verification. Most of the remaining Certificates are in force as a result of private AHJs' requirements (usually insurance carriers).
As of 3/1/99, there were fewer than 3,000 Placards in the United States.
7. Why aren't there more active Fire Alarm Certificates and Placards in force?
There are three primary reasons.
a. In most jurisdictions, national model building and fire codes form the basis of local codes. Code revision cycles are such that only the most recent editions of the national model building and fire codes refer to The National Fire Alarm Code, NFPA 72 (for example, the 1997 edition of the Uniform Fire Code incorporates NFPA 72, 1993). In addition, there is lag time between publication of a national model code and actual adoption at the local level. Therefore, even though the requirement has been in NFPA documents for sometime, it has not been enforceable in many jurisdictions until just recently.
b. Fully compliant central station service is not all that common. Often, one or more elements of NFPA 72 defined service are not provided. This can result in the system being designated as a remote supervising station type, which still fulfills many minimum building and fire code requirements. Currently, NFPA 72 does not require remote supervising station type systems to be covered by a means of third party verification.
c. Many AHJs continue to operate under the misconception that simply requiring fire alarm systems to be monitored by a Listed or Approved central station guarantees all the benefits of third party verification programs.
8. With regard to No. 7b above, aren't remote supervising station systems supposed to be monitored by a fire station, public fire service communication center or similar government agency?
Generally, yes. However, the exception to par 4-4.3.1 of NFPA 72 allows an AHJ to declare another location as acceptable to receive and retransmit signals from alarm systems. It is not uncommon for jurisdictions to declare "listed central stations" as acceptable remote supervising station facilities.
9. With regard to No. 7c above, what's the difference between a Listed or Approved Central Station and a Certificated or Placarded Alarm System?
"Listed central station" or "Approved central station" are a common way to refer to an alarm monitoring facility that has demonstrated the ability to provide Standards-complying service and is authorized to use the UL or FM Marks respectively in conjunction with alarm services that comply with applicable requirements. (For fire alarm systems the UL Mark is a Fire Alarm Certificate and the FM Mark is a Placard.) As a result, the company's name appears in UL or FM directories.
In the case of central stations, requirements cover building structure, receiving and monitoring equipment, and staffing issues, in addition to alarm system installation and ongoing service. In order to maintain the ability to provide Standards complying service, the building, equipment and staffing requirements have to be met at all times. However, the installation of a specific alarm system and the handling of specific signals from specific alarm systems is only audited if a Certificate or Placard is in effect for that alarm system.
A "Certificated alarm system" or a "Placarded alarm system" is one where the Certificate issuing alarm company declares that Standards complying alarm service is provided. It is equivalent to a manufacturer whose name appears in a UL or FM product directory choosing to place a UL or FM Mark on a specific production product. A Certificated or Placarded alarm system is subject to random audit by alarm system auditors to countercheck compliance, just as a product with a Mark is eligible for random factory audit.
10. In the case of remote supervising station systems monitored by a public dispatch center, wouldn't simply requiring a UL Listed or FM Approved prime contractor company be sufficient?
Simply requiring that a Listed or Approved prime contractor company do the installation assures that a level of competency has been demonstrated to a third party by the alarm company. However, unless a certificate or placard is issued covering a specific property, the third party verifier can not assist the AHJ in assuring ongoing compliance of the installation or service to the installation. Such a requirement would also not comply with Chapter 4 of NFPA 72 as proposed by 72-338.
Whether such a requirement would be sufficient or not depends upon your objectives. Alarm systems that are not covered by a certificate or placard may have been designed and installed with a goal in mind, but not necessarily a vision commonly held by all parties. A system covered by a certificate or placard complies with published, nationally recognized standards and codes that provide a baseline common understanding of the system and service provided. In addition, these systems are enrolled in a systematic program using randomly selected follow-up audits to counter-check compliance with the requirements of NFPA 72.
11. Does the prime contractor for an alarm system have to operate a supervising station?
No. The revised definition of prime contractor in Par. 1-4 of NFPA 72 states that the prime contractor is the one company contractually responsible for providing supervising station fire alarm service to a subscriber in accordance with the requirements of The National Fire Alarm Code. For central station fire alarm service, Par. 4-2.2.2 specifically describes acceptable contractual arrangements between a prime contractor and a company that provides monitoring services. For remote station and proprietary supervising station systems, NFPA 72 does not prohibit delivery of monitoring services through a contractual arrangement between the prime contractor and another company.
12. Will the requirement for a means of third party verification be retroactive to existing alarms systems?
Par 1-2.3 of NFPA 72 states that is not intended that requirements be applied to installations that were existing or approved before the effective date of the document, unless the AHJ determines that the existing situation involves a distinct hazard to life or property.
13. Does third party verification add significant cost to fire alarm service?
"Significant cost" is unfortunately such a subjective concept that is hard to offer a direct response that will be universally agreed to. The pricing noted below is simply a factual presentation of information obtained from two nationally recognized certification organizations. The significance of the cost has to be weighed against the significance of the demonstrated improvement in fire protection provided when there is a means for third party verification of compliance to NFPA 72. A measure of perspective might be gained by considering that the basic annual fees cost an alarm company less than $5.00 per day and would typically be spread across a company's Certificated customer base.
It is also important to note that occasionally, alarm systems or service have to be upgraded as a result of defects noted during third party audits. The cost of bringing a system into compliance has to be kept an issue separate from the cost of a third party verification process.
An unlisted/unapproved alarm service company generally pays a listing organization a one time fee for its qualification investigation. UL charges $900 for prime contractor company, $2,350 for a monitoring only central station and $3,275 for a full service central station company.
FM charges $2,200 for a prime contractor company, $2,200 for a monitoring only company and $2,650 for a full service central station company.
Once listed, an annual fee is charged to cover the annual audit expenses. UL charges a basic fee of $1,195 for prime contractor companies and $1,770 for central station companies. In addition, there is a $30 fee for each active Certificate.
FM charges are $1,325 for a once per year audit of any alarm company or for tri-annual audits the charge is $2,650 for full service central stations and $2,200 for monitoring only central stations and prime contractor companies. There is no additional fee associated with individual Placards.