Honeywell - Understanding NFPA 72

FIRE & GAS DETECTION SYSTEMS FOR ONSHORE PROCESS AREAS Which Listings and Codes are required? Jared Thibodaux, P.E. Whitepaper TABLE OF CONTENTS 2 Background 2 Understanding NFPA 72 3 OSHA – The Ultimate AHJ 4 National Recognized Testing Laboratory (NRTL) 5 Standards – FM 3010 and UL 864 6 Equivalency (a.k.a., “Meets the Intent of NFPA 72”) 6 Summary 6 References Fire & Gas Detection Systems For Onshore Process Areas For Onshore Process Areas | Whitepaper 1 BACKGROUND Published by the National Fire Protection Association (NFPA), the NFPA 72 standard provides the latest safety provisions to meet society's changing fire detection, signaling, and emergency communications demand Although NFPA 72 is not meant to be a design guide, it nevertheless does contain certain application information that can be valuable in assisting fire alarm system designers in meeting challenges presented by a variety of industrial occupancies. UNDERSTANDING NFPA 72 Many individuals associated with the process safety industry believe NFPA 72 is not required in process areas. Among the various reasons ascribed to this belief are: NFPA 72 specifies the application, installation, location, performance, inspection, testing, and maintenance of fire alarm systems and fire/ emergency warning equipment. - NFPA 72 is only used for buildings in industrial facilities - The Authority Having Jurisdiction (AHJ)—the local fire marshal—does not look at the process area, so NFPA 72 requirements do not apply - The facility has its own fire brigade: the facility owner is the AHJ; he or she decides whether to follow NFPA 72 - The Process Area Fire and Gas System in not considered a Fire Detection System or Fire Alarm System, so it doesn’t have the same requirements. It is further argued that if NFPA 72 is not required, its prescribed installation practices and power/supervisory requirements need not be followed. This thinking questions the very need for process fire detection system controller to be listed or approved. The purpose of this white paper is to challenge the above misconception and explain why: - Fire Detection System Controllers for process areas need to be listed/approved for fire - NFPA 72 is required in process areas The whitepaper does not discuss hazard assessment or placement of devices in process areas. Rather, it describes why the installation practices listed in NFPA 72 should be followed. Figure 1: Federal, state, and local municipalities across the United States have adopted NFPA 72. Fire & Gas Detection Systems For Onshore Process Areas For Onshore Process Areas | Whitepaper 2 OSHA – THE ULTIMATE AHJ The mission of the United States Occupational Safety and Health Administration (OSHA) is to assure safe and healthful working conditions for personnel by setting and enforcing standards. Through federal and/or state regulations, OSHA covers most private sector employers in the US and most of its territories. OSHA does not have jurisdiction over government employees (including military). Some US states have their own OSHA plans, but must, at a minimum, follow Federal OSHA guidelines. The standards are where the topic of this paper begins. Industry experience has shown that Fire Detection System Controllers for process areas need to be listed/ approved for fire The standards that must be followed are specifically stated in the Code of Federal Regulations (CFR). 29 CFR Part 1910. Section 155 contains the requirements for fire detection and fire alarm systems. Section 164 discusses Fire Detection Systems and their requirements. The CFR does not specify when a Fire Detection System must be installed; rather, it describes what is required and why you have the system. Section 164 states the following about Fire Detection Systems: “The employer shall assure that all devices and equipment constructed and installed to comply with this standard are approved for the purpose of which they are intended.” The key word in this statement is “approved.” Under the definition section 29 CFR 1910.155(c)(3), “approved” means acceptable to the Assistant Secretary under the following criteria: accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory (NRTL). The following are definitions used in the paragraph above: - “Accepted” is if the equipment has been inspected and found by a NRTL to conform to specified plans or procedures of applicable codes (29 CFR 1910.155(c)(3)(iv)(C)) - “Certified” is if the equipment has been tested and found by a NRTL to meet nationally Figure 2: OSHA is responsible for assuring safe working conditions for industrial plant personnel. OSHA is very particular about the NRTL used to approve Fire Detection System devices and equipment in the United States. OSHA guidelines require Fire Detection Systems to be approved and list the standards that can be employed in their approval. recognized standards, to be safe for use in a specified manner, or is a kind whose production is periodically inspected by a NRTL; and if it bears a label, tag, or other record of certification (29 CFR 1910.155(c)(3)(iv)(D)) - “Listed” is if the equipment is of a kind mentioned in a list published by a NRTL, which make periodic inspections or the production of such equipment, and which states that such equipment meets nationally recognized standards or has been tested and found safe for use in a specified manner (29 CFR 1910.155(c)(3)(iv)(A)) - “Labeled” is if there is attached to the equipment a label, symbol, or other identifying mark of an NRTL, which makes periodic inspections of the production of such equipment, and whose labeling indicates compliance with nationally recognized standards or tests to determine safe use in a specified manner (29 CFR 1910.155(c)(3)(iv)(B)) One thing to note is that 29 CFR 1910 is for employee safety. The process area fire and gas system, if horns and strobes are connected, is for employee safety as well. OSHA does not differentiate between process area and non-process area, and treats all fire detection systems the same. As such, we can safely conclude that it is important to have fire and gas detection system controllers approved, especially if the installation is in a location subject to the Untied States Code of Federal Regulations. NATIONAL RECOGNIZED TESTING LABORATORY (NRTL) OSHA is very particular about the NRTLs that can be used to approve Fire Detection System devices and equipment in the United States. In fact, as of March 2019, there are only four: - Factory Mutual (FM) - Underwriters Laboratory (UL) - CSA - Intertek OSHA lists these NRTLs and defines the standards they are allowed to test. Two of the NRTLs listed above, CSA and Intertek, only perform testing and do not create their own standards for fire detection. The other two, FM and UL, have created standards as listed below: Fire & Gas Detection Systems For Onshore Process Areas For Onshore Process Areas | Whitepaper Figure 3: Approved NRTLs for Fire Detection System devices and equipment in the US. 4 - FM 3010 – Approval Standard for Fire Alarm Signaling Systems - UL 864 – Control Units and Accessories for Fire Alarm Systems OSHA only accepts FM 3010 and UL 864 as suitable approving standards for Fire Detection Systems. It should be noted that NFPA 72 in not listed under any NRTLs for testing. Rather, this standard is mentioned in “Non-mandatory Guidelines” in 29 CFR 1910 Subpart L, Appendix C. Honeywell offers both listed Fire Detection systems and consultants to ensure that an installation meets all required codes According to Federal Register Notice, Vol. 74, No. 176 dated Sept 14, 2009, NFPA 72: - Is no longer considered “appropriate test standards and is being withdrawn” - Has no replacement test standard Any listings that show testing to meet NFPA 72 are no longer accepted in the US as of September 14, 2011. The list of approved NRTLs and Standards can be found at www.osha.gov. STANDARDS – FM 3010 AND UL 864 OSHA requires Fire Detection Systems to be approved and lists the standards that can be used for the approval. This document must explore the standards to ensure they are followed. Specifically, is there anything in a standard requiring the use of NFPA 72 in the field, namely, the process area? The answer can be found in standards listed for the two approving NRTLs, FM and UL. FM 3010, section 3.2.1.5 states: “The fire alarm control equipment shall accommodate secure wiring methods in accordance with NFPA 70 (National Electric Code) and NFPA 72 (National Fire Alarm Code).” Fire & Gas Detection Systems For Onshore Process Areas For Onshore Process Areas | Whitepaper 5 UL 864 section 1.1 states: “These requirements cover discrete electrical control units and accessories for fire alarm systems to be employed in accordance with the following National Fire Protection Association (NFPA) Standards: 72.” In both cases, NFPA 72 is referenced whether in the “wiring methods” or the “system to be employed in accordance with.” When read in more detail, both standards follow NFPA 72 when discussing power and supervisory requirements. From the aforementioned information, it is clear that NFPA 72 is required in process areas, too. EQUIVALENCY (A.K.A., “MEETS THE INTENT OF NFPA 72”) References FM 3010 (2010) – Approval Standard for Fire Alarm Signaling Systems NFPA 72 (2016) – National Fire Alarm and Signaling Code OSHA – www.osha.gov UL 864 (2012) - Control Units and Accessories for Fire Alarm Systems Many people talk about meeting the “intent” of NFPA 72. Section 1.5 of the standard discusses this topic and is termed “Equivalency.” It basically states that the code doesn’t prevent users from doing things in a different way (i.e., equivalent or superior). The process allowing for the use of an equivalent method requires users to submit technical documentation to the AHJ and obtain approval. In the case of controllers, they would have to submit technical documentation to OSHA. With OSHA’s removal of NFPA 72 as a test standard and strict guidance on what standards to test to, it is reasonable to assume that deviation or the use “Equivalency” is not permissible. This means controllers must be tested to the standards mentioned above. SUMMARY The path is clear. OSHA requires Fire Detection Systems to be “approved.” It implies that companies installing these systems in land-based process areas must be listed by FM 3010 and/or UL 864 standards. Only few SIS/ESD-type controllers on the market are currently listed, and so it is imperative for users to do their own research to ensure compliance when designing Fire and Gas systems using these same type of controllers. The FM 3010 and UL 864 standards stipulate that the installation meets NFPA 72. The main requirements are line monitoring of inputs and outputs (for wire breakage and shorts). This is another aspect that must be checked with the SIS/ESD controllers, as some commercially available controllers do not offer line monitoring. Last, but not least, is the need to meet the standard for battery backup. Many systems only have the required battery for a couple of hours, since there is less chance of fire if the process is down. NFPA 72, however, does not approve of this approach and mandates 24 hours of battery backup. Honeywell can offer both listed systems and consultants to ensure that an installation meets all required codes. The company serves as a “One Stop Shop” for process and non-process fire detection systems. Fire & Gas Detection Systems For Onshore Process Areas For Onshore Process Areas | Whitepaper 6 For More Information Learn more about Honeywell Fire and Gas Solutions, visit www.honeywellprocess.com or contact your Honeywell account manager. Honeywell Process Solutions 1250 West Sam Houston Parkway South Houston, TX 77042 Honeywell House, Arlington Business Park Bracknell, Berkshire, England RG12 1EB UK Shanghai City Centre, 100 Zunyi Road Shanghai, China 200051 www.honeywellprocess.com WP-19-05-ENG I Rev 06/19 © 2019 Honeywell International Inc.