July 11, 2015
Recalled Sprinklers “My company inspected a wet sprinkler system installed in a hotel. The sprinklers installed in the system have been identified as Central Omega recalled sprinklers. The AHJ is asking us to identify if this is an impairment, critical deficiency or noncritical deficiency. I have reviewed the table A.3.3.7 and cannot find anything that address this. Also they are asking us if the sprinkler need to be removed. Per A.4.1.5. it states Recalled products should be replaced or remedied. So my stance would be yes, but not quite sure since I am not able to identify the level of impairment or deficiency.” We have reviewed NFPA 25, 2014 edition that you indicated as the applicable standard as well as the International Fire Code (IFC), 2015 edition. Our informal interpretation is that it is an AHJ decision. This issue of recalled sprinklers is not a part of an NFPA 25 inspection as shown by it not being addressed within the standard. It is the responsibility of the owner to maintain their system and as you identified, A.4.1.5 states that they are to be replaced. Although not part of the inspection, the technical committee did want to mention recalled products so it was placed in section 4.1 - Responsibility of Property Owner in 4.1.5 - Corrections and Repairs. The real driving factor on recalled products is the IFC. In section 901.10, with Chapter 9 being Fire Protection Systems, it says: “Recall of fire protection components. Any fire protection system component regulated by this code that is the subject of a voluntary or mandatory recall under federal law shall be replaced with approved, listed components in compliance with the referenced standards of this code. The fire code official shall be notified in writing by the building owner when the recalled component parts have been replaced.” Enforcement of this document is the responsibility of the fire marshal (or fire code official). As such, the determination of the degree of hazard presented by this situation is also their call. Considering that this issue was given a number of years to be resolved, calling it an impairment would be extreme. On the other hand, considering that the recall ended some time ago and they are still in use, dictating an aggressive schedule for replacement also seems appropriate. If the owner has had the 20-year inspection required for sprinkler with fast response elements (25:5.3.1.1.1.3) performed, then they are aware of the recalled sprinklers. UL includes in its report if any of the products are recalled. ------------ Technical Update is prepared by the Technical Services Dept. of the AFSA: Roland Huggins, a PE registered in fire protection engineering, Vice President of Engineering and Technical Services; and Tom Wellen, a PE registered in fire protection engineering. This is provided with the understanding that the AFSA assumes no liability for this opinion or actions taken on it and they are not to be considered the official position of the NFPA or its technical committees. Copyright 2016, American Fire Sprinkler Association. All Rights Reserved. -------------- next part -------------- An HTML attachment was scrubbed... URL: <http://lists.firesprinkler.org/private.cgi/sprinklernotes-firesprinkler.org/attachments/20160711/41287c4f/attachment.htm>
