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When routing cables
through fire rated barriers, a single bad inspection by the
authority having jurisdiction when trying to get a Certificate of
Occupancy for a new building could be the end of
your career and possibly the business you work for.
Fire rated barriers are getting the attention they deserve and are
being inspected with a vengeance. Some inspectors will require you
to seal the entire barrier for finding a single
penetration violation made by IS cables.
Inspectors are always the same in that they carry the burden of
being the individual who must approve or disapprove someone’s work
or product. All AHJ’s want themselves, as well as their
organization, to be protected from liability. So naturally, it is
important that we are able to identify who the AHJ is.
The American National Electrical Code says that the AHJ is the
local, State or Federal official designated and responsible for
approving equipment, installation or procedure. In essence, the AHJ
assumes some liability when making a decision.
This liability, in today’s lawsuit happy environment, requires the
AHJ to proceed with more caution than in the past. It is a fact that
the AHJ may even be someone other than the typical inspectors listed
above. The definition in the NEC book clearly states that the
Insurance
Inspectors or Risk Assessment Agents are AHJ’s.
A building owner or his designated agent may assume the role of the
AHJ. In the building industry, an OSHA inspector could be the AHJ.
An Underwriters Laboratories follow up inspector
is the AHJ if you are a manufacturer. That is certainly a lot of
authority to contend with. Even with all that we are faced with in
dealing with the AHJ, Inspectors are easy.
They are all consistent as far as what they are looking for when
cables penetrate fire-rated barriers. Why not give them what they
want? It makes it easy to develop a standard operating procedure for
dealing with any AHJ with reference to firestopping
telecommunications cabling.
Most inspectors are surprised when a telecomm installer even makes
an effort to properly firestop cables much less have a plan in place
to do it professionally.
You must bid the firestop procedure you select so do it as an
addendum if your competitors will not bid it. Just because firestop
is not in the scope of work, it does not mean that it does not
have to be done.
If compensated adequately for your firestop procedure, the
beneficiary is the customer who is in the structure if it ever
catches’s fire. The project manager or primary contractor may
inadvertently be placing the burden and in due time, the blame,
squarely on you. Don’t fall for it. If firestop is not in the bid or
scope of work, make an issue of it and go on record as seeking to do
it properly. The same guy who told you it was OK to just stick a
little red stuff in the hole, is the
very individual who will point a finger at you if there is a fire.
Protect yourself.
Forgiveness is NOT better than permission. If you are going to have
a guaranteed method of getting approved by the AHJ, you will need a
simple but effective way to approach them. The
AHJ wants their organization to be protected from liability. After
establishing which AHJ you will approach, confirm the rating of the
fire barrier.
Be sure to find out if there are other requirements in addition to
the typical “F” rating. You will need to meet any “T” or “L” ratings
as well. The F (flame) and the T (temperature) ratings
are measured in the amount of time the barrier will resist a fire.
The higher the rating, the more robust the barrier will be. The L
rating (cold gas) is measured by how much gas will pass through the
barrier during a fire prior to the flames reaching the barrier.
The lower the L rating, the better the seal. The best L rating for a
penetration is 0. meaning no gas has passed through the barrier for
the duration of the F and T rating. Watch for more L ratings in the
future as the F and T ratings are intended to save property. The L
ratings are intended to save Lives.
Once the ratings for a barrier to be penetrated have been
established, seek a “tested” penetration system for your
application. You will need to meet or exceed the barriers rating
with your selection. Manufacturers will help you with this task.
If the AHJ does not approve your system, he/she will tell you why
and you can take steps to respond to his/her concerns before you
ever step foot in the building. Once your proposal has been pre
approved, all you need to do is to insure that the selected system
is installed
to the limitations of the test and assembly procedure supplied by
the manufacturer.
Document and
keep a digital pictorial of
all the penetrations made by your group. If others disturb or
overfill your penetration system, you will easily be able to go to
your alphanumerical
Installation pictorial to show an AHJ how it was when you left it.
This procedure has created new opportunities for those who properly
ID and document their penetrations to a database of installations.
Many times these opportunities reveal themselves in an inspection
when others have disturbed your seal. Because you are in the
business and have shown you properly sealed the barrier, the cables
installed by others will need to be removed from your penetration
system and placed in
their own. It will be a task that you have already proven you are
qualified for.
Keep the pictorial updated as each penetration is re-entered. Be
sure to get lose enough to see the ID number as well as the number
of cables allowed on the documentation label. Many facilities do
this to track availability of space in existing fire stop systems in
a given
barrier. This practice will eliminate unnecessary parallel
penetrations.
Acquire factory certification training for your installers. Nothing
makes an inspector happier than a fully qualified individual who has
formal and “verifiable” factory training. It makes it easy for an
AHJ to check your qualifications and make preapprovals based on your
level of training.
Your certificate should accompany the submittal documents when you
submit your AHJ consideration request. Factory certification
training is offered by most major manufacturers of firestop material
or systems. Many offer it free of charge. Certification training
allows for effective communications between a manufacturer of a
tested system and the installer who will put it in. As changes and
upgrades are made, you will be in the loop. Many fire stop companies
also
have contractor programs allowing product to be purchased direct at
contractor pricing for certified technicians.
Seek permission instead of forgiveness. Acquire factory training.
Document your penetration systems. I have helped many installation
companies out of some difficult situations by advising
them not to EVER argue with an AHJ.
It will be a bad situation and it could result in you being removed
from a job as well as your customer’s building being red tagged and
evacuated until what you have done to upset the AHJ has been
corrected.
Remember that with the AHJ responsibility comes the authority to do
what is necessary to keep buildings safe and fire barriers up to
code. They will use their authority to insure you do the right
thing. What many people don’t understand and usually mistake as a
power or ego trip is actually the weight of the responsibility to
the people who inhabit the buildings in their jurisdiction.
Work with the AHJ instead of against her. You will find that most
are just regular people who are facing an ever increasing threat to
the built-in safety features of most commercial buildings
today.FSM
Mike Tobias is CEO of Unique Fire Stop products, Inc.
Contact him at mtobias@
uniquefirestop.com.
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