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ITM Deficiencies & Impairments

Posted by ORR Protection on Aug 25, 2020 9:27:00 AM

During the MCFP Virtual Conference series, expert Lee Kaiser, covers deficiencies and impairments. In the video below, watch as Lee discusses what deficiencies and impairments are and the consequences if ignored.

Video Transcript:

There are new definitions defining deficiencies and impairments, so a lot of information about these topics in the codes. 

Deficiencies

Deficiencies are not minor, but they are things that don't completely take a system out of order. They are things that have potential to impact the system performance and the codes go on to define two levels of deficiencies; critical deficiencies and non-critical deficiencies. 

critical

A critical deficiency impacts an important feature of the system.  Let's look in this room, I see two horn-strobe devices on the wall and those are there to notify us of a fire alarm in the building. Let's say during testing one of the two doesn't work so there's still some notification in the room and in the eyes of the code, that would be a critical deficiency because part of the feature is full notifications in the room with adequate light coverage, even though the system still operates.  It's just that maybe one device has quit functioning. 

non-critical

The other level is non-critical deficiencies.  Those are items that need to be corrected to meet a requirement of the code or to perform proper inspection, testing and maintenance.  An example I like to use for that is for spare sprinkler head boxes.  So, in systems with sprinklers we're supposed to have a little box on the wall that has multiple spare sprinklers inside of that and that's there for if there's a fire. The fire department can go to that box and remove the sprinkler that activated and replace it with one of the sprinklers that's in that box or if something breaks during inspection, testing and maintenance or there's a sprinkler that needs to be replaced, the sprinklers are there to do that so the system doesn't need to be out of order for that long.

If you find during your inspection that that spare sprinkler head box is missing all the sprinklers then the code will call that a non-critical deficiency because it doesn't affect the operation of the system.  It's just a code requirement to have those spare sprinklers there. 

Impairment

The higher level of a problem is an impairment. That means that the system is out of order.  The complete system is non-functional, we refer to that in the industry as a red tag condition.  There are two types of impairments; emergency impairments or pre-planned impairments.  Pre-planned impairments are when we know ahead of time that the system is going to be need to be taken down for one reason or another. 

An example for emergency impairment is a lightning strike.  Let's say lightning strikes our building, takes out our fire alarm panel, and it's non-functional.  An example of pre-planned impairment, is when a water main needs to be repaired in the street. The city water department comes and shuts down the water main, which shuts down the water supply to my building's sprinkler system. So I would need to deal with that while the water company takes it down and do a fire watch or whatever we would do to address that impairment for that time. 

A Fire in Schenectady, New York

I brought with me a couple of our red tags.  This is what we red tag systems with when we find them impaired. Here is a story about this, I don't know if you've been following the fire inspection news out there, but right now there's a court case in Schenectady, New York that's just wrapping up from a fire that happened in 2015. It was in an apartment building where four people died, and there was a new building owner during this.

The building owner had a building superintendent that was responsible for maintaining the building and at some point the superintendent was made aware that the fire alarm system in that building was non-functional. Along with that, one of the code officials in the town was also made aware and that code official happened to have the responsibility from enforcing the code, making sure those systems were functional. 

Somewhere along the line it was discovered that the building superintendent and the code official were friends and the code official was allowing this condition to persist in the building without forcing the repair of the system. As the story goes, the day after the code official was there and passed the building so that his friend wouldn't have to make the repairs to the building, they had this fire where four adults died in the fire. 

Changes in Enforcement

As a leadership team for my organization were made aware of that story, we realized that somewhere along the line we needed to look at our risk when our technicians find a system that's out of order differently.  So, we've established a more robust red tag system for our company where we tag impaired systems with a red tag and then we escalate the actions that we take when we find a system again is red tagged. One of the things we do is follow the notification guidelines.  We get a written letter out to our contact for that building letting them know that their system is impaired.  We escalate the repair quoting process so they know how much it's going to cost to fix the system and get it back in working order.

Sometimes we don't hear from the customer.  They may or may not accept that repair quote so then we're forced, because of this court precedent, we have a responsibility to notify the local fire marshal or AHJ for that facility that they have a system in their jurisdiction that is out of order. This puts the service contractor in this awkward position where we're tattling on our customer aand we don't like to do that, but no matter how many nods I get from the fire marshals, we don't like to have to do that on the system owners. 

However, we feel like there is a precedent that's now been set in courts of law in the U.S., that we need to make some reporting.  We give them some time to accept that because we know the business realities of accepting quotes for repair, but eventually we reach out to the fire marshal and let them be aware of the conditions so we can reduce our risk, and document the whole thing.  We've done in response to some of the news that's out there.   

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