Saturday, November 4, 2017

Upcoming changes NFPA 1 in 2018

Upcoming changes NFPA 1 in 2018 edition, minimum fire prevention inspection frequencies for existing occupancies


Looking back, one part of the Code that I don’t spend a lot of time talking about, but should, is how it is applied and how it is enforced.  Practically speaking, when does one even use a Fire Code?  Who needs to know how to enforce it?  When is it enforced? How often does the fire inspector, responsible for the enforcement of NFPA 1, need to inspect a building for fire safety provisions? These administrative requirements and general provisions, as contained in Chapter 1, Chapter 4 and parts of Chapter 10, provide the fundamental provisions for those responsible for its application and enforcement.  Compliance with these requirements is critical to the effectiveness of NFPA 1.
NFPA 1 is applicable to both new and existing occupancies.  Per Section 10.1.1, every new and existing building or structure shall be constructed, arranged, equipped, maintained, and operated in accordance with this Code so as to provide a reasonable level of life safety, property protection, and public welfare from the actual and potential hazards created by fire, explosion, and other hazardous conditions. I highlight the words constructed and maintained to emphasize how the Code plays a role in a building during both construction of the building as well as maintenance throughout the life of the building. The enforcement of a building does not stop once its construction is complete and a certificate of occupancy is received. 
New to the 2018 edition is Section 10.2.7 which prescribes the minimum fire prevention inspection frequencies for existing occupancies.

This Section was added, in part, to recognize the publication of new NFPA 1730, Standard on Organization and Deployment of Fire Prevention Inspection and Code Enforcement, Plan Review, Investigation, and Public Education Operations, and in addition, to provide guidance to AHJs and inspectors for ensuring existing occupancies remain in compliance with the fire code. Section 10.2.7 reads as follows:

10.2.7 Minimum Fire Prevention Inspection Frequencies for Existing Occupancies.
10.2.7.1 Fire prevention inspections shall occur on existing premises in accordance with the minimum inspection frequency schedule specified in Table 10.2.7.1. [1730: Table 6.7]
10.2.7.2 Where required or permitted by the AHJ, the required fire prevention inspection shall be conducted by an approved party that is qualified in accordance with NFPA 1031.

10.2.7.3 The AHJ shall be permitted to approve alternative qualifications for the approved party specified in 10.2.7.2.

10.2.7.4 The provisions of 10.2.7 shall not apply to detached one- and two-family dwellings or townhomes.
NFPA 1730 contains minimum requirements relating to the organization and deployment of code enforcement, plan review, fire investigation, and public education operations to the public.  The addition of new 10.2.7 incorporates the standard of care, as specified in NFPA 1730, into NFPA 1. The default is that the local AHJ should conduct the inspection. However, if staffing does not permit or if the local jurisdiction does not have a qualified individual, the owner, occupant or operator can retain an AHJ approved NFPA 1031 qualified individual to conduct the inspection. Thereby, fire code compliance is achieved in accordance with the 1730 standard.

The frequencies of the fire prevention inspection are based on the occupancy risk classification.  Table 10.2.7.1 includes four classifications: high, moderate, low and critical infrastructure with frequencies ranging from annual to triennially or per the AHJ.  What is a high risk occupancy? What is critical infrastructure? The 2018 edition of the Code also added the corresponding definitions from NFPA 1730 to Chapter 3 to assist with the application of the new table.  For example, a low risk occupancy is “an occupancy that has a history of low frequency of fires and minimal potential for loss of life or economic loss.  Examples of low-risk occupancies are storage, mercantile, and business.

How does your jurisdiction manage fire prevention inspections for existing buildings?  Do you use the provisions in NFPA 1730?  What issues have you faced with existing building inspection?