Dry Pipe System Documenting Past Due Inspections

You asked the following question: During the annual inspection and testing of a dry pipe system, it was observed that the system was past due for a five-year internal pipe assessment. How should this be documented on an inspection report? Is it a recommendation, deficiency, or impairment?

In response to your question: We have reviewed NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, 2020 edition as the applicable standard. Our informal interpretation is it should be noted as an observation but not be documented on the official inspection report. Several variables come into play with this issue, most of which are outside the control of the inspecting contractor.

The performance of inspections, tests, and maintenance as prescribed in NFPA 25 is ultimately the responsibility of the owner or a designated representative through a contractual obligation. Section 4.3 covers the requirements for records and states that the records are to be maintained by the property owner and made available to the Authority Having Jurisdiction (AHJ) upon request. Unless the inspector is under contract to perform the five-year internal inspection, they would not have privity of contract to access the inspection report. Only the owner would know if the test was performed or not within the required interval.

Another variable would be the inspection interval itself. NFPA 25 does not define five years as five years; rather, it is defined as a window of time from 54 months to 66 months. Just because five years have passed since the last date on the inspection tag, does not put the system out of compliance. The system could have another six months before it is out of compliance or the inspection could have been performed by another agency and the records may be kept by the owner at another location or electronically. Either way, there is no way for an inspecting contractor to legally know if the test has been completed if they are not contracted to perform the work.

This issue was specifically discussed during the first draft meeting for the 2023 edition of NFPA 25. PI-92 proposed that “testing not performed in accordance with this standard shall be considered a non-critical deficiency.” This suggestion was resolved by the committee stating, “It is up to the owner to maintain their system and meet the required ITM frequencies.”

In that end, this would be an enforcement issue, and up to the AHJ to apply the adopted fire code and levy any penalties for noncompliance with NFPA 25. For items other than ITM work that is not performed within the required interval, Table A.3.3.8 is a useful tool within the standard that an inspector can use to classify deficiencies or impairments for documentation on an inspection report. While Table A.3.3.8 does not address all situations, an inspector may see in the field it does assistance on many issues to ensure they are documented accurately and handled appropriately.

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