Commissioning, Defined

What does the document do?
Commissioning, as we define it in NFPA 3, is a systematic process that provides documented confirmation that all building systems function as they were intended. It's important to note that commissioning is a process-it's not a singular physical act in the field, it's not wiring something together, it's not testing a device. It's a process that runs from project inception to project completion and continues into occupancy with re-commissioning and periodic integrated testing. The process is intended to make sure that systems function as intended and processes have been carried out the right way.

What kind of systems are covered?
NFPA 3 focuses on active and passive fire protection and life safety systems. With active systems, it's everything from big-ticket sprinkler systems and fire alarm systems to systems that might be less frequently applied, like smoke control or water mist systems. Some are very common, some exist in one out of every thousand buildings that get built; NFPA 3 applies to all of them. The passive side includes rated wall construction, fire resistance rated doors and through-penetration protection systems, things that provide fire endurance and a passive means of life safety.

Why is the document needed?
At present there is no standardized approach for an owner to track the design and construction process. Often times an owner has a level of expectation of what he is paying for, but the finished product doesn't match up. Historically, there was really no way to quantify or monitor those expectations. That's what commissioning does. It's to make sure that there's a process that walks you through pre-planning, design, construction, and occupancy, and what's expected with all of a building's active and passive systems at all of those steps. It's designed so that building owners can rest at night knowing they got what they paid for and everything's been done the right way. Often times owners are really in the dark. They're not building experts, they're not fire protection experts, they're not roofing experts. They have to put a lot of trust in the people they hire.

Is it just for buildings?
Buildings, road tunnels, airports-almost anything. It's a systematic process for almost any project that makes sure you end up with what you wanted when you started. It works for a 2,000-square-foot retail outlet, where your commissioning team might only have five members, and it might take you three or four weeks to commission a build out. It also works for a new hospital, where you might have a commissioning team of 90 people and it takes you 30 months to go from design to construction. It's all over the map, which is why it was a hard thing to standardize. 

Is that why it's a recommended practice and not a code?
Exactly. A few years ago, when the document was being written, the idea was to make it a standard so that there would be enforceable language in it. The hope was that it would be adopted by states. The document slipped cycle and returned to the ROP stage. Over the last couple years the technical committee has gone back and forth on the question of whether you can actually enforce commissioning-it's a process and it's highly administrative, and it became very cumbersome to try to figure out. Ultimately, the committee decided you can't standardize this. But we can tell people, "here's what your thought process should be. Here are the types of things you should be doing, and here are the people who should be involved." That's why it's written as a recommended practice.

There's discussion of removing the integrated testing component from NFPA 3 and creating a new standard with that material. What's happening there?
Integrated testing is a field activity that assures that all of the systems that are interconnected can speak to each other as intended by the design team. The committee agreed that this is something that can and should be standardized. There's nothing in the IBC codes or NFPA codes that requires this integrated test. The NFPA 3 committee went to the Standards Council at its March meeting and requested a new project, which would be to take the integrated testing portion of NFPA 3 and start a new document called NFPA 4, Integrated Testing. The Standards Council is looking for public comments, and we'll know in August if we're able to separate that part of NFPA 3 into NFPA 4. I imagine you'll hear some conversation this year at annual meeting about the integrated testing portion and what's being done about it.

Are the practices for integrated testing not covered by other NFPA codes?
The scope of documents like NFPA 13 or NFPA 72 is to provide requirements for the design, installation, and acceptance testing of those systems, and those systems alone. None of the documents ever say, "when these systems communicate with other systems, you're required to test it, and here's how you're required to test it." Our other design documents can't do that, because it's not in their scope to address requirements for other systems. So we really need a separate document to do that, which is what we're trying to develop here. 

What's the genesis of the NFPA 3 idea?
About five years ago, the National Institute for Building Sciences approached NFPA to write a guideline on commissioning of fire protection systems. They went to several different organizations and asked them to put something together on commissioning for their respective areas of expertise.  They went to ASHRAE for HVAC systems, to IEEE for electrical systems, and the Roofing Contractors Association for roofing systems. They were all intended to sit within a NIBS total building commissioning package. The idea was that NIBS would put together this bundle of 10 or 15 standards or guidelines that tell you how to commission a particular building system. 

You're relatively new to NFPA. Where were you before?
I was a fire protection engineer and consultant, and I've worked all over the world-the Middle East, in Great Britain, and here in the U.S. 

And you have a range of experience with commissioning?
I do. I've done the plan review portion, where the designers have drawn something up and I have to make sure they've followed all the applicable codes, talked to the right people, and gotten the right approvals. I've done the construction part of it, doing field inspections as the systems are being installed, then going back later to do a final construction inspection to make sure the end result is ok. I've done acceptance testing of individual systems and integrated testing of systems.

From your experience, what are the trickiest parts of this kind of testing?
Just the fact that nobody's ever required you to do it. When owners are writing out contracts with their contractors, they'll include language saying, "make sure all testing complies with NFPA 72." So someone will do a component test or an acceptance test on all the 72-related equipment, but no one's doing anything that's really integrated. You get to the end of a project and everybody's kind of looking at everyone else, saying, "OK, I've done my part, I comply with my code." And the owner's sitting there wondering who's going to make sure it all works together. And that's how things can fall through-you don't know for certain that those systems work together, and you don't know who to go to for guidance. In some jurisdictions, the authority having jurisdiction will require you to do it, and they let you know that up front, but it's not mandated in writing.

What do observers tell you about NFPA 3? Do they think a recommended practice would actually be used?
They do. NFPA 3 will establish a benchmark for this kind of guidance. Because it's written by an internationally recognized standards development organization, and because it's really the first thing like it out there, it's going to be a very valuable and useful document