Subscriber Discussion

Can I Legally Use Non-Listed Smokes In A Non-Listed Commercial Burg System?

UI
Undisclosed Integrator #1
Feb 07, 2018

I just wanted to open some dialog about this.

Specifically about smoke alarms in commercial settings, and whether or not we can install them on a panel not listed for commercial fire. 

For example, customer is not required to have a fire alarm but has a room with sensitive material that they want protected with a smoke detector. They are installing a DSC system for burg which is not UL listed for commercial fire, is it ok to add one?

 

13.7.1.6 *  Nonrequired Coverage.

13.7.1.6.1 

Detection installed for reasons of achieving specific fire safety objectives, but not required by any laws, codes, or standards, shall meet all of the requirements of this Code, with the exception of prescriptive spacing criteria of Chapter 17 of NFPA 72. [72:17.5.3.3.1]

Even where detection is not required by some applicable law, code, or standard, 13.7.1.6.1 requires that detection must still comply with all the requirements of NFPA 72, including the specific detector location, installation, operation, and maintenance requirements for the type of detector being used. The technical committee adopted this requirement to help ensure that purchasers of nonrequired systems receive systems that work. Decades of experience in fire alarm system design, installation, and maintenance have demonstrated that compliance with the criteria in NFPA 72 results in systems that have a high probability of providing consistent, reliable service.

The exception in 13.7.1.6.1 permits the use of detector spacing that is different from the spacing specified in the prescriptive sections of NFPA 72. This exception was adopted because, with some system objectives, using detection at the required spacings specified elsewhere in NFPA 72 is not necessary to attain the performance intended for the nonrequired system.

Whenever any system is designed, 17.6.1.1, 17.7.1.1, and 17.8.1.1 of NFPA 72 require that the objectives for that system be stipulated in the design documentation. Consequently, these paragraphs apply to nonrequired systems. Although the exception in 13.7.1.6.1 exempts nonrequired detection from the prescriptive spacing rules of Chapter 17 of NFPA 72, the spacing selected must still be substantiated in the design documentation to show that design objectives for the system will be satisfied when the detectors are selected and installed on the spacing selected.

 

UI
Undisclosed Integrator #2
Feb 07, 2018

Ask the appropriate AHJ.  

Some allow this, some don’t.  They can approve a couple of cans and a string as a notification system or be very stringent.

This is a common question.

UI
Undisclosed Integrator #1
Feb 07, 2018

Is there specific code that says an AHJ can approve this scenario that you cite?

UI
Undisclosed Integrator #2
Feb 07, 2018

I was NICET II, C7, C10, ACO, ACQ so that makes me an expert :)

Ask the AHJ and get it in writing.

They might say it can’t be done, any fire detectors that prompt a fire response must be a complete system.  The fact that fire will respond puts it under their clear authority.

They might refuse to even entertain a discussion and not care.  I have had jurisdictions refuse submittals for required sprinkler monitoring systems. 

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Avatar
Brian Rhodes
Feb 08, 2018
IPVMU Certified

They might say it can’t be done, any fire detectors that prompt a fire response must be a complete system. The fact that fire will respond puts it under their clear authority.

I had not even thought about this. As much as it is backward, I can easily see this rationale being used to creep authority for a hungry AHJ.

Avatar
Brian Rhodes
Feb 07, 2018
IPVMU Certified

You're not allowed to use non-listed fire detection equipment in areas where listed protection is required.

Residential alarm panels (in this case, DSC) don't abide by these listings because other panels are intended to be used for commercial fire protection.

The discussion of sensor spacing is semantic if the sensor or panel monitoring the space don't meet commercial fire requirements.

Does this space require commercial fire monitoring?

 

UI
Undisclosed Integrator #1
Feb 07, 2018

No it does not, thats the whole point. Its non required

Avatar
Brian Rhodes
Feb 07, 2018
IPVMU Certified

That point is unclear in the OP.  There is not much room for an objection to lean on if you're using non-listed equipment in a space that doesn't require it.

If an AHJ gives you a problem about it you can logically challenge the basis of their objection.

UI
Undisclosed Integrator #1
Feb 07, 2018

Sorry I should have clarified, but it says it in the title and again "For example, customer is not required to have a fire alarm"

I cant find the edit button to clarify in the section above that though where it is not clear. 

Avatar
Brian Rhodes
Feb 07, 2018
IPVMU Certified

I'll edit things so it is more apparent.  Citing a code section name does not define application, so your clarification helps.

The smoke detector you are mentioning here is for convenience.  As long as this DSC system is not sold or applied as a (listed) fire notification system, this sort of application is not an issue nor is uncommon.

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Avatar
Ethan Ace
Feb 07, 2018

When I did non-required fire alarm work in the past, most AHJs didn't even look at it. But it can get sticky based on this clause:

Even where detection is not required by some applicable law, code, or standard, 13.7.1.6.1 requires that detection must still comply with all the requirements of NFPA 72, including the specific detector location, installation, operation, and maintenance requirements for the type of detector being used. 

Some AHJs might read that as requiring listing for the use. I can tell you about a local guy who would absolutely say so. I think it's definitely an ask first sort of situation. 

 

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Avatar
Mark Jones
Feb 08, 2018

IMO, this reads pretty plainly. The only exception is spacing.  The exception does not include detector listing. Detectors must be listed for use on that panel, and for that purpose. I am not saying I agree with it, but it does read the way it reads.  

In past years, I have installed Smoke Detection, not a fire system, as a matter of convenience for a customer. Plenty of customers wanted extra smoke detection in a vault where Fire Systems were not required.  The extra protection is considered a measure of caution.

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