Inspection, testing, and maintenance (ITM) reporting services improve the reliability of fire protection systems; however, the implementation of these services is not without concern and caution. This position paper addresses nearly every aspect of concern for authorities having jurisdiction (AHJ) who, by necessity or convenience, chooses to use an ITM-reporting service to enforce and track the inspection, testing, and maintenance of fire protection systems in their jurisdictions. Some of these concerns are:
- Security, regulatory, and liability: the reporting process must be secure and guarded against cyber intrusions.
- Data: the system should produce data that can be used to improve code development and enforcement.
- Cost: the system should utilize uniform and predictable cost model that will not alienate the stakeholders.
- Enforcement: the ultimate objective of this system should be for increased code compliance.
- Process: providing user-friendly software interface.
- Collaboration: early collaboration and continuous communication post implementation of all stakeholders is the key for better adoption and implementation of this system.
Why to consider this multi-industry stakeholder position BEFORE adopting innovative technology
It is critically important to have communications with all stakeholders before a reporting service is sought and selected, during the implementation phase, and after the system is up and running. AHJs would be well-served to communicate the intention of moving to a third-party system with all stakeholders before a specific reporting service is sought and selected. Contractors may already have been using a third-party service in another jurisdiction, and their input can help AHJs avoid pitfalls and streamline implementation.
Clear role definition among stakeholders goes a long way in reducing frustration and ensuring implementation success. Reporting services operate best in the role of holding and reporting the ITM data; they should leave “enforcement” issues to the AHJs. AHJs that believe moving to a third-party reporting model will allow them to abdicate communication and enforcement authority are setting up all stakeholders (including themselves) for frustration and confusion
Fire codes require inspections, testing, and maintenance through codes and standards
Fire codes, such as NFPA 1, the Fire Code, or the International Fire Code (IFC) require fire protection and life safety systems to be inspected, tested, and maintained (ITM) on a regular basis through referenced installation and maintenance standards, requires that certain records be generated during the ITM process. The following standards mandate that the records are maintained by the property owner, and that they be made available to the AHJ upon request:
- NFPA 25, the Standard for Inspection, Testing and Maintenance of Water Based Fire Suppression Systems for fire sprinkler systems, standpipes, fire pumps, water mist, and more.
- NFPA 72, the National Fire Alarm and Signaling Code for fire alarm systems.
- NFPA 12, NFPA 12A, and NFPA 2001 for the gaseous agent extinguishing systems
- NFPA 17 and NFPA 17A for dry and wet chemical fire extinguishing systems
- NFPA 2010 for aerosol extinguishing systems
- NFPA 770 for hybrid extinguishing systems
- NFPA 1225 for emergency services communications
Stakeholders in ITM reporting
When such reporting services are utilized, the ITM process has the following four stakeholders:
- Property owner, owns and has the responsibility to maintain their life safety system(s) in accordance with the applicable codes and standards, and who contracts with the ITM service provider to perform those services.
- ITM service provider, a fire protection and life safety system contractor (fire sprinkler, fire alarm, etc.) who provides the required ITM service at the owner’s property, provides the owner and the AHJ with the report indicating either a full compliance or with deficiencies and impairments that might have been established, and tags the system(s) accordingly.
- Authority having jurisdiction (AHJ), who accepts and reviews the ITM reports and receives confirmation from the owner or the ITM service provider that any deficiencies identified during the ITM process are corrected within the timelines allotted by the adopted codes and standards. Typically, fire prevention bureaus through the fire department are AHJs that enforce ITM codes and standards reports such as NFPA 25, NFPA 72 and many more.
- ITM-reporting service, a software provider sometimes referred to as “third-party reporting,” who facilitates the electronic delivery of ITM reports to the AHJ, and inspections management service employed typically by the AHJ. Every ITM-reporting service has other service lines and products.
How ITM-reporting services work
ITM-reporting services typically contracts directly with an AHJ who requires that the ITM service providers submit their inspection reports via the ITM-reporting platform. Other services are sometimes provided by the ITM-reporting service such as notifying the owner of deficiencies or when ITM is due.
Where are ITM-reporting services
A map of over 610 jurisdictions and ITM-reporting services is available of the software service providers and fees across the US.
Full considerations for jurisdictions
The purpose of this document is to provide all the stakeholders in this process with information that was gathered by the NFSA, AFAA, and NAFED. The concerns are categorized specifically in six key areas for improvements that were identified and discussed during the summits.
#1 – Security, regulatory, and liability
While most users of ITM-reporting services are comfortable with data security, careful consideration should be given to how the data is stored and who has access to it.
- Security of data from both a physical (ensuring the data is adequately backed up) and privacy (accessible by appropriate parties) standpoint should be considered.
- Inspectors (AHJ and ITM service provider) with portable devices, such as tablets and cell phones with access to the ITM-reporting service software, should be equipped with appropriate security.
- Information that is entered by the service provider who performed the ITM service, i.e., deficiency, impairment, or repair should remain confidential and not be shared or disclosed with any other contractors or potential competitors.
- Some ITM-reporting services store ITM records on multiple servers which are not owned by the municipality. This leads to questions and concerns about who ultimately owns the data and who has the authority to share it and with whom.
#2 - Data
ITM codes and standards establishes specific minimum requirements for what information ITM reports must contain. Many ITM-reporting services and AHJs expand on those minimums.
- For consistency and to help ensure that the expectations of the AHJ fall within the scope of ITM codes and standards, the classification of deficiencies and/or impairments should match the definitions and recommendations of those standards.
- Software should be capable of running analytics on deficiencies, impairments, repairs and more. This is to facilitate in-house training of ITM inspectors, technicians, AHJs or building owners.
- The deficiency and impairment trends should be produced by the software so that they can be analyzed and used to improve ITM codes and standards.
- The data should not be used to solicit building owners or be used beyond the intentions of ensuring a properly working fire protection and life safety system compliance.
#3 – Cost
Costs for these services can vary extensively. A best-case scenario would be one where all costs incurred are either neutral or will result in actual cost-savings.
- Special attention should be paid to how fees are based, i.e., per system vs. per building and the frequency in which fees are paid, i.e., per year vs. per inspection.
- Where AHJs ask for extra information on ITM reports, such as community or building data not required by ITM codes and standards, it should result in rebate or cost-neutral submission fees.
- Where multiple communities in an area utilize ITM-reporting services, filing fees, if any, should be consistent and coordinated.
- Consideration should be given to property owners and ITM contractors for reduced filing fees for high volume batched reports.
#4 – Enforcement
The focus of data collection and the use of that data should be ongoing process of improving life safety and enhancing the enforce ITM codes and standards. The ability of the AHJ to enforce the deficiencies and impairments identified during the ITM is one of the cornerstones of the entire ITM process. The main intent of the ITM-reporting services approach is to provide the AHJ with more information for enforcement and compliance.
- State-wide tagging systems, such as those in Texas and Florida, increase enforcement and the number of buildings in compliance. Any ITM-reporting service should result in the same level of improvements.
- Fire protection systems, such as fire sprinklers, standpipes, fire alarm, and suppression systems that are not in the AHJ’s database need to be identified, included in the ITM-reporting system, and brought into compliance, with due care not to punish those complying with the locally adopted codes and standards.
- The effect of the influx of added information on overall code enforcement efforts should be evaluated, as should the impact of using an ITM-reporting service on any accreditation, such as ISO grading, the AHJ may have received.
#5 – Process
Implementation of the ITM-reporting service systems inevitably impacts the current stakeholders in the process. To assure that no interruption in the ITM compliance occurs during the implementation period and afterwards, the service interface should be user-friendly and accessible from all types of technology and contractor platforms.
- The ITM-reporting service software often lack any of the follow- up features for deficiencies and impairments. Follow-up reports, such as filing an “all clear” or “deficiency cleared” report should be covered by the original fee.
- An Application Programming Interface (API, a software intermediary that allows two applications to talk to each other) should be available to access and upload ITM reports that is accessible to all systems utilized in the jurisdiction.
- Grouped jurisdictions (such as in a metropolitan area) contracting with multiple ITM-reporting services can make data entry confusing and result in unnecessary delays. Consideration should be given to a regional approach in this case.
- ITM-reporting forms, inputs and formats should be uniform and follow ITM codes and standards.
#6 – Collaboration
Every stakeholder benefit in the ITM-reporting program when it works as intended. Each in the process has a common goal: better fire protection saving lives, property, and investment(s). Getting fire protection and life safety systems to 100% compliance benefits all involved, most importantly, the public.
- Having several different ITM-reporting services in their operating area requires the ITM service providers to train employees in different software platforms or APIs that are being implemented within their operating area, a cost which is, in turn, passed on to the owner.
- ITM-reporting service providers shall supply training to the AHJs and ITM service providers on how to use their platform. Follow-up “town-hall” style meetings, where all stakeholders can work through any issues that might have been met, will further improve the ITM system and the overall compliance.
- AHJs and the ITM-reporting service providers should work with the ITM service providers on defining and improving the reporting forms and input interface.
- ITM-reporting services should be open to contractor input and integrating processes.
Industry support from NFSA, AFAA, and NAFED Chapters
Because of its impact on the fire protection and life safety industry, the Board of Directors of the following trade associations formed committees to study the current practices of ITM-reporting services that have been implemented in several jurisdictions in the US. AHJs should involve local NFSA, AFAA, and NAFED chapters for input and support before, during, and after ITM-reporting services implementation in their area.
The NFSA, AFAA and NAFED recognize the potential benefits associated with the inclusion of the ITM-reporting service systems into the current ITM process and are suggesting that the decision on utilizing an ITM-reporting service is delegated to the local stakeholders, under the conditions of meeting current fire protection and life safety codes and standards, and not adding any costs or complexity without a clear and quantifiable benefit to all stakeholders. The named fire protection industry associations remain in an open dialogue with all stakeholders and are encouraged and determined to improve compliance while addressing any concerns with this growing technology that might be identified by their members.
NFSA, AFAA, NAFED and other fire protection trade associations are key stakeholders who can assist all fire protection personnel with NFPA 25, NFPA 72, and other ITM requirements in NFPA codes and standards with training as well as provide an information exchange and expert technical assistance.