reading the small print

AHJ Perspective: Remembering the Small Print

Did you ever sign a document without reading the small print? Personally, I have always thought that the small print was designed to keep attorneys well funded, because the only time small print is important is when it is violated.

The primary concern about your insurance policy or contract small print is that if you do not fulfill the intent of the small print, liability may be attached. I was reminded of this recently in a conversation with Janet Knowles when she was preparing for her retirement from the American Fire Sprinkler Association (AFSA). The issue was whether or not the fire service is aware of the NFPA 13, Standard for the Installation of Sprinkler Systems, requirement called “an owner’s certificate.” Janet is off to retirement now, but her conversation provoked me into researching why this could be important to you as an Authority Having Jurisdiction (AHJ). If you hadn’t heard of the owner’s certificate I am not going to be surprised. But, if you want to protect yourself against sprinkler system failures, you might want to become more knowledgeable.

Janet provided an excellent article on this already. It is in the March 2015 issue of Sprinkler Age entitled the “Owner’s Information Certificate.”  I do not wish to be redundant and repeat her column, but I do think it is important that we in the regulatory arena know of this requirement, and perhaps require it to be provided as part of our data collection. The specific requirement, as stated in Chapter 4 of NFPA 13 is as follows:

“4.3* Owners Certificate. The owner(s) of a building or structure where the fire sprinkler system is going to be installed or their authorized agent shall provide sprinkler system installer with the following information prior to the layout and detailing of the sprinkler system.”

I will leave it up to you to do the rest of the homework to look up this information requirement. There is even a two-page form in the NFPA 13 Annex, Section A.4.3.

The very first thing that I observed when reviewing Janet’s original article, is the fact that the AHJ is not part of this requirement regarding information. The second thing I observed is if we don’t ask for the information, who is going to enforce the provision? Understandably, contractors are not too crazy about more paperwork. And building owners are not likely to be excited about it either. However, this column is aimed at AHJs and I believe it is appropriate to ask the question of: why aren’t we making sure that the owner’s information certificate is completed? Maybe some of you out there already have. If you are, you are on the leading edge of change. But a more important question is what if you are not asking for it?

I will readily admit that this is a personal opinion and can be argued that it is not a requirement by the AHJ. My reason for stating this opinion is based on the practical experience of having to deal with occupancies that have gone through multiple changes over the years and there was no documentation of the issues that can result from change of occupancy. Going back to Section 4.3 there are three basic questions that this document provides. They are:

  1. Intended use of the building including materials within the building and maximum height of any storage.
  2. A preliminary plan of the structure along with the design concepts necessary to perform the layout and detail for the fire sprinkler system.
  3. Any special knowledge that the water supply including known environmental conditions that might be responsible for corrosion including microbiologically influenced corrosion (MIC).

You might think of this information as a time capsule. Looking at your own inventory of sprinklered buildings, how many of them are over 25 years old? How many of them are over 50? You are not going to be able to do much about lack of information on those systems. But, here comes a new hotel, a high-rise, a commercial occupancy that you are going to be dealing with immediately. If your record keeping system is robust, asking for a copy of this owner’s information certificate helps establish a starting point. Future fire marshals and fire inspectors will be glad you looked into it.

Currently, the NFPA standard requires the owners certificate to be filled out and submitted to the contractor. The NFPA standard does not require that the AHJ receive a copy of it but for all practical purposes they should. The primary reason why we, as an AHJ, should require it is to level the playing field regarding uniformity in our plan check processes. You will be doing the plan check or you will have it contracted out, so requiring this certificate placed in your sprinkler files is a prudent act.

rjcolemanmasterABOUT THE AUTHOR: Ronny J. Coleman is currently the president of Fireforceone. He is a past president of the IAFC and CFAI. Over his lifetime, he has received numerous awards including the AFSA’s 1989 Henry S. Parmelee Award, the 2011 Mason Lankford Award from the Congressional Fire Services Institute, and the Tom Brennan Lifetime Achievement Award from Fire Engineering in 2014. He continues as a contributor to the fire service in many ways.

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