The Art of Pleasing the A. H. J. when Firestopping (Authority Having Jurisdiction)
By: Mike Tobias CEO – Unique Fire Stop Products
I have 38 years in the cabling business and 20 years as a firestop manufacturer so I am confident I can help you if you are routing cables through fire rated barriers.
Inspectors are always the same in that they all 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 he/she makes 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 group in the hole is the very individual who will point a finger at you if there is a fire.
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 is. 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 Trating. 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 has 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. Be sure the product you select has been listed for use in Canada by an Independent Testing Facility. Print out the listing as you will use it for your submittal to the AHJ for pre approval. Yes, ask permission. If we ask permission and the AHJ pre-approves our method then we are, approved! Use the AHJ Consideration form provided at the end of this article. Always keep all written records of the pre-approval process indefinitely.
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 alpha-numerical 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 all ready proven you are qualified for. Keep the pictorial updated as each penetration is re-entered. Be sure to get close enough to see the ID # as well as the # 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 un-necessary parallel penetrations.
Acquire Factory Certification training for your Installers. Nothing makes an Inspector happier that a fully qualified individual who has formal and “verifiable” factory training. It makes it easy for an AHJ to check your qualifications and make pre approvals 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 pit it in. As changes and upgrades are made, you will be in the loop. Many Firestop Companies also have Contractor programs allowing product to be purchased direct at Contractor pricing for Certified Technicians.
To summarize the concept. 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 customers 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 with 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 him/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.
CEO – Unique Fire Stop Products, Inc.