Developed within the past 10 years, NFPA 3 and 4 provide a systematic approach for design commissioning and integrated testing of fire protection and life safety systems. You may be asking, “Why do we need new standards? I thought NFPA 13 and NFPA 72 already have commissioning requirements!” To answer this question, it is helpful to understand more about the scope and intent of the various standard testing requirements and the benefits to the building owner.

First, let’s review the more established standards, NFPA 13 and 72. 

NFPA 13, Installation of Sprinkler Systems Chapter 28 (2019 edition) requires testing by the installing contractor of various sprinkler systems and components. While the authority having jurisdiction (AHJ) is required to be notified ahead of time, the only connection to another system required to be verified is an alarm signal generated by a water-flow switch when a fire alarm system is present. The required documentation of the acceptance tests is a single document: a completed Material and Test Certificate for Aboveground Piping.

NFPA 72, National Fire Alarm and Signaling Code Chapter 14 (2019 edition) includes two tables listing the required initial acceptance testing of fire alarm systems. All components — every initiating device, notification appliance and system interface — shall be tested. But like the sprinkler standard, NFPA 72 does not mandate universal written documentation of systems testing. The standardized System Record of Completion is only required when enforced by the AHJ or required by project specifications. 

Why Do We Need NFPA 3 and 4?

While acceptance testing is performed by an installing contractor and witnessed by an engineer of record or an AHJ for final acceptance of the system, commissioning (Cx) is a systematic process with documentation extending from design through installation, testing and training. Although the acceptance testing required by NFPA 13 and 72 may be appropriate for many facilities, the systems are being treated as singular and autonomous entities within the facility when, in fact, they may be components within a much larger fire protection strategy. 

NFPA 3 and 4 provide a framework for planning and integrating the various systems all the way through building life. To be clear, Cx begins at project inception and continues through design, construction and project closeout and then throughout the facility’s operation so the owner’s needs are met. 

NFPA 3, Standard for Commissioning of Fire Protection and Life Safety Systems, establishes the “process, methods, and minimum requirements for documenting” that active and passive fire protection systems are “planned, designed, and constructed” in accordance with a project’s design basis. Additionally, “the services, products, and deliverables required by this standard shall provide the necessary documentation for the owner to verify the continued performance and operation of these systems.”  

Integrated fire protection and life safety systems Cx for a building or structure involves a systems approach, enabling the designers to analyze all the components and individual systems as a total fire protection and life safety system.

NFPA 4, Standard for Integrated Fire Protection and Life Safety System Testing, provides the protocol for testing and documenting the performance of the interconnection between multiple fire protection and life safety systems. NFPA 4 was originally included as Chapter 7 of the 2012 edition of NFPA 3 but was upgraded into its own standard in 2015 due to the “imminent need” for a standard for testing integrated fire protection systems by the technical committee responsible for the practice. 

What Does Commissioning Look Like?

First, we must learn some new terminology and roles to apply NFPA 3 and 4. There is a new role, an owner’s representative known as the fire commissioning agent (FCxA). This individual is not the same as the engineer of record, a registered design professional or AHJ. Instead, the FCxA is selected by the owner to lead, plan, schedule, document and coordinate Cx of the fire protection and life safety systems. The FCxA works with the overall full building Cx team, headed by the commissioning agent (CxA).

The FCxA team should be involved early in the project to review design documents for compliance with project requirements. The design phase is the optimal time in a project to identify potential design and integration opportunities. The FCxA should ponder possible failure modes and consider the connections needed between the various components to ensure that every fire protection system performs as intended. 

Solutions are much easier, much faster to correct, less expensive and less impactful to the construction schedule when compared to design/installation modifications during construction after system installation.

An integrated testing agent (ITa) implements and leads the integrated testing of the fire protection and life safety systems to confirm that they perform their intended function. The same professional can act as both the FCxA and the ITa, assuming minimum credentials are met. 

In addition to documenting design bases, another outcome of the Cx effort is developing comprehensive testing criteria so project stakeholders understand what equipment and systems will be tested and how the tests will be performed. Examples of comprehensive testing criteria include evaluating individual systems that activate through an interfacing device, conducting individual system tests, and considering a single or combination of mitigating events such as loss of normal power or presence of smoke. 

It’s also important to note system operations that should not occur. For example, fans that should shut down upon sprinkler activation may need to continue operation upon smoke detection in another part of the building. The scenarios are nearly endless and can depend on events occurring both inside and outside of a building.  

It seems obvious, but test scenarios shall verify that all required building functions and equipment perform according to their design function. That means no components should be silenced, placed in “test mode” or otherwise silenced during testing. For example, primary power should be isolated to test battery or generator backups, not simply depressing a manual test button. Recreating real-world scenarios is the only way to know if systems will perform as intended. 

Finally, it is possible to commission existing buildings, a process known as retro-commissioning. This process is for any fire protection and life safety system not previously subject to commissioning to verify that system performance and operating meet the original design intent, current owner requirements, and governing codes and standards.

Documenting the Process

Perhaps the most important aspect of Cx and integrated testing is documentation. In fact, NFPA 3 objectives require documentation of every step of the design, testing and Cx process, a significant departure from NFPA 13 and 72 requirements. NFPA 3 lists no fewer than 12 separate documents to be created during the Cx process, in addition to NFPA 4’s nine sample documents. 

When properly documented in accordance with NFPA 3 and 4, a building’s fire protection and life safety systems should be fully detailed with every function understood, tested and verified.

The commissioning and integrated testing of a building’s fire protection and life safety systems benefit the building owner and its occupants by validating the intended system design, installation, performance and operation.