Is your Property Condition Assessment (PCA) expert checking fire sprinkler heads in a focused manner during assessment of the property you are purchasing? This has become a “hot button” and point of contention on many recent projects. Over the course of the past year we set out to find answers about the condition of sprinkler heads, namely, what is acceptable and what is not. Of particular concern are sprinkler heads in multi-family housing developments. Why? Because the finishes in an apartment are frequently painted at the time of tenant turnover, and because many painting contractors do not take the appropriate steps to avoid paint overspray on the sprinkler heads in both wall and ceiling locations. In addition, with variable degrees of housekeeping between residents, sprinkler heads can become dirty, dusty, laden with pet hair, or coated with hairspray or other contaminants.
What are the rules about sprinkler heads?
The National Fire Protection Agency (NFPA) Standard 25 is pretty clear on the subject:
Section 184.108.40.206 – “Sprinklers shall not be altered in any respect or have any type of ornamentation, paint or coatings applied after shipment from the place of manufacture.”
Section 220.127.116.11.4 – “Any sprinkler shall be replaced that has signs of leakage; is painted, other than by the sprinkler manufacturer, corroded, damaged, or loaded; or is in the improper orientation.”
Appendix A.18.104.22.168.2(5) – “In lieu of replacing sprinklers that are loaded with a coating of dust, it is permitted to clean sprinklers with compressed air or by a vacuum provided that the equipment does not touch the sprinkler.”
Appendix A.22.214.171.124 – “Sprinklers should be first given a visual inspection for signs of mechanical damage, cleaning, painting, leaking in service, or severe loading or corrosion, all of which are considered causes for immediate replacement.”
Source: NFPA Standard 25
What are the difficulties?
For starters, the inspection typically takes place visually, from the floor. In apartment units and wherever sprinkler heads and ceilings are the same color, it is difficult to discern paint or other contaminants from the sprinkler frame or deflector. In addition, the issue is often contentious. Owners obviously don’t want to spend money to replace fouled sprinklers, but recognize the life safety issues and liabilities associated with them. In addition, owners may have a fire safety vendor who has “let this go” in the past and as such, there is some confusion about what is allowed. Perhaps the most difficulty comes with the interpretation of the rules. How much paint is too much? How loaded can a sprinkler head be and still be functional? More and more, we are finding the condition of sprinkler heads is part of the protocol for municipal fire prevention departments during their annual or routine inspections. But the remedy allowed and the degree to which the fire departments enforce this issue seems to still be up for interpretation.
How do we reconcile this confusion?
In an attempt to clarify these somewhat muddied waters, VERTEX surveyed over 30 Fire Marshals throughout the United States to try to get a consensus answer to some “burning” questions, namely, at what point is replacement required? How much paint, corrosion or loading is too much? We received answers from officials in Pennsylvania, Wisconsin, Illinois, Idaho, Kansas, Kentucky, Colorado, Michigan, Arizona, New Mexico and Connecticut. Based on the answers we received, we concluded the following:
- All of the surveyed fire department prevention inspections do include a review of the condition of sprinkler heads, and all of the Fire Marshals consider any amount of paint on the actuator, frame or diffuser to be a “fouled” head.
- Some of the departments surveyed actually do allow the cleaning of paint from sprinkler heads by physically touching the sprinkler head or by the use of solvents to remove paint. This is in direct opposition to NFPA directives. The majority of respondents enforce this issue in strict accordance with NFPA.
- If deficiencies relating to sprinkler heads are discovered, the window in which corrective measures must be completed is 30-days. This was reported by all respondents.
How do we interpret what we learned and how it relates to NFPA-25?
While our respondents all considered any amount of paint on the working parts of the sprinkler head an issue, it seems that Fire Prevention Officials are taking a variable stance on how strictly to enforce replacement versus cleaning.
Given the clear direction given by NFPA and the types of potential liabilities (loss of property, loss of life) VERTEX sides with the more conservative fire officials on this issue as follows:
A loaded head (fouled with dirt, dust, contaminant or any amount of paint) must be:
- Removed and replaced with a suitable replacement head; or,
- Cleaned by using compressed air or vacuum methods (never with solvents, water or aggressive or abrasive methods).
- Any amount of paint or contaminant that cannot be cleaned by the methods above should result in sprinkler head replacement.