Inspection, Testing and Maintenance Deficiencies & Impairments

Posted by ORR Protection on Sep 3, 2019 8:45:00 AM



Inspection, Testing and Maintenance (ITM) Deficiencies & Impairments Video

At one of our recent in-person events, Fire Protection Expert Lee Kaiser explained ITM deficiencies and impairments. If you're concerned about your system performance, don't miss the video and transcript below.



Lee: So, new definitions are defining deficiencies and impairments, and so a lot of information about this is in the codes.  Deficiencies are not minor, but things that don't completely take a system out of order. Okay. Things that have a potential to impact the system performance and then the codes go on to define two levels of deficiencies.

Critical deficiencies and non-critical deficiencies. So, a critical deficiency impacts an important feature of the system. So, 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. Okay. And so there's still some notification in the room and so, in the eyes of the code, that would be a critical deficiency because part of the feature is full notification in the room with adequate light coverage, but the system still operates. It's just that maybe one device has quit functioning.

Now, then 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:

1. If there's a fire then the fire department can go to that box and remove the sprinkler that activate and replace it with one of the sprinklers that's in that box or

2. If something breaks and we say during inspection, testing and maintenance that there's a sprinkler that needs to be replaced we've got sprinklers there to do that, so the system doesn't need to be out of order for that long.

Now, 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 effect the operation of the system. It's just that that's a code requirements to have those spare sprinklers there. So, it's a pretty useful example for that one. Now, the higher level of a problem is an impairment. Okay. That means that the system is out of order. The complete system is non-functional, and we tend to refer to that, or starting to refer to that, in the industry as a red tag condition.

There are two types of impairments; emergency impairments that we just discover or something happens and to take the system out or pre-planned impairments. We know ahead of time that the system is going to be needing to take down for one reason or another. So, you know, example for emergency impairment is a lightning strike.

Okay. Let's say lightning strikes our building, takes out our fire alarm panel, it's non-functional and something like that. Pre-planned impairment, let's say that, you know, a water main needs to be repaired in the street and so 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 need to deal with that while the water company takes it down and then we'll need to, you know, do a fire watch or whatever we would do to address that impairment for that time.

So, I brought with me a couple of our red tags. This is what we red tag systems with when we find them impaired, and so I've got a little story about this. I don't know if you've been following the, kind of 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 in an apartment building where four people died, and there was a new building owner of this.

That 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, and 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 forcing the code, making sure those systems were functional.

And so, somewhere, the story is kind of long and complicated, but somewhere along the line it was discovered that the, you know, 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, and I think as the story goes, I may have the details a little fuzzy, 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, the day after that visit they had this fire where four adults died in the fire.

And so, we were, 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, and so one of the things we do is we 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 to get that quote done so they know how much it's going to cost to fix the system and get it back in working order, and then, you know, here's the deal.

Sometimes we don't hear from the customer. They may or may not accept that repair quote so then we're sort of forced because of what we see in this court precedent that we have a responsibility then to notify the local fire marshal or AHJ for that facility that they have a system in their jurisdiction that is out of order, and it puts the service contractor in this awkward position where we're tattling on our customer. We don't like to do that.

No matter how many nods I get from the fire marshals, we don't like to have to do that on the system owners. But, we feel like there is a precedent that's now been set in courts of law here in the U.S. that we need to make some reporting.  So, we give them some time to accept that because we know the business realities of accepting quotes for repair, but eventually we just reach out to the fire marshal and let them be aware of the conditions so that we can reduce our risk and we of course document this whole thing.

So, just to let you know about kind of what we've done in response to some of the news that's out there.


Get More Mission Critical Fire Protection Resources

Was the above video and transcript helpful? Then don't miss the other MCFP resources available for you on our website. And don't forget about our educational conference dates or private lunch & learns from the ORR Protection team!


Topics: Featured Article, Nationwide

Featured Download

Subscribe to the Fire Protection Blog