BY SCOTT R. DRURY, PE, FBPE MEMBER
Fire protection engineering rules have been updated to clarify ambiguous items, establish consistency between the rules and other statutes, and reduce unnecessary work by engineers and contractors, while still upholding FBPE’s statutory charge to protect the health, safety, and well-being of the public.
The revised rules, which can be found in Chapter 61G15-32, Florida Administrative Code, Responsibility Rules of Professional Engineers Concerning the Design of Fire Protection Systems, were adopted by the Board in 2019.
A technical committee consisting of Board members, fire protection engineers, a fire protection contractor, and an authority having jurisdiction worked through various issues and concerns that members of the fire protection community had expressed for many years.
The most significant changes to the rules answered the following questions:
What must be included in “Fire Protection System Layout Documents?”
The previous wording of Rule 61G15-32.002(6), F.A.C., was mainly written around a water-based sprinkler system, but technically the “layout documents” can and do apply to other fire protection systems, such as fire alarm systems, gas agent fire suppression systems, and others. The modified language aims to generalize the description of what should be included in layout documents so that it applies to the various types of fire protection systems. The new language reads:
Are “Fire Protection System Layout Documents” required to be sealed by a Professional Engineer?
This has been a common question for years, and truthfully was somewhat confusing in the previous language. The real answer is… it depends. As mentioned in Rule 61G15-32.002(6), the layout documents are based upon “engineering documents” and require no additional engineering input. The previous rule language mentioned that the layout documents do not require the seal of a Florida licensed engineer. Depending on who prepared the layout documents, this could violate other rules found in Chapter 61G15, F.A.C. Therefore, the updated language in Rule 61G15-32.002(6) was clarified to read:
(a) If prepared by a licensed contractor, these documents do not require the seal of a Florida licensed engineer.
(b) If prepared by a licensed engineer, these documents are Engineering Documents and therefore meet the definition of Engineering Documents in subsection 61G15-30.002(4), F.A.C., and accordingly, require sealing by a Florida licensed engineer in accordance with Rule 61G15-23.001, F.A.C., Signature, Date and Seal Shall Be Affixed.
(c) If prepared by a licensed engineer other than the engineer who prepared, signed, dated, and sealed the Fire Protection System Engineering documents, that engineer shall additionally meet the requirements of Rule 61G15-27.001, F.A.C., Procedures for a Successor Professional Engineer Adopting as His Own the Work of Another Engineer.
A licensed engineer is required to seal any final work product that meets the definition of engineering documents found in Rule 61G15-30.002(4), F.A.C., as required by Rule 61G15-23.001, F.A.C. Additionally, if a licensed engineer other than the licensed engineer who prepared the engineering documents provides the layout documents, then that engineer must comply with the successor engineer procedures found in Rule 61G15-27.001, F.A.C.
The layout documents are different than the engineering documents. Is this considered a “material deviation?”
Under Rule 61G15-32.003(6), F.A.C., any “material deviation” made in the layout documents from the engineering documents are not compliant unless revised engineering documents, sealed by the Engineer of Record, accompany the layout documents.
This has caused much confusion and additional work in the past, given the old definition of material deviation in Rule 61G15-32.002(8), F.A.C. Under the old definition, a material deviation constitutes any deviation from the design parameters. Some individuals interpreted this to mean a minor modification, which could include additional pipe fittings or rerouting a pipe around an obstruction, even though this did not affect the system performance. The definition was revised to clarify that a material deviation is a variance from the design parameters that “significantly alters the ultimate performance requirements of the system.” In other words, if a change is made to the layout that does not affect system performance, then that is not constituted as a material deviation.
The modifications on this project could be designed by a licensed contractor, so do I really need to show all the minimum design quality information from Rule 61G15-32, F.A.C.?
There are many renovation projects that require minor modifications to fire protection systems, such as modifications to sprinkler heads or fire alarm devices. More often than not, these changes are minor in nature and do not ultimately affect the system performance.
There are provisions adopted directly or referenced by Chapter 633, Florida Statutes, Fire Prevention and Control, the Florida Building Code, and the Florida Fire Prevention Code that provide a means for a licensed contractor to modify an existing system without requiring the seal of a licensed engineer. However, if an engineer was working on a project, they are required to design the system and seal the plans. Many engineers were concerned about meeting the minimum requirements for design quality as indicated in various rules under Rule 61G15-32, F.A.C. This resulted in a lot of extra work by the engineers to comply with all provisions of the Responsibility Rules.
For example, someone might say: “I know we are only relocating 20 sprinklers on the third floor of this 20-story building and that we are only getting paid commensurate with that scope, but I am required to show the entire fire sprinkler system back to the point of service.”
Therefore, the following rule language was added to both Rules 61G15-32.004 and -32.008, F.A.C.
The intent behind this language is to provide a means for the Engineer of Record to specify only the minimum requirements for the modified system requirements, while allowing licensed contractors working under the provisions of Chapter 633, F.S., or other codes and standards to provide these services.
What about smoke control systems?
Smoke control systems are specialty fire protection systems that require engineering design, as well as much coordination between other design services, such as architectural, mechanical, electrical, fire sprinklers, fire alarms, etc. When required by codes, these systems are life safety systems, pivotal to our responsibilities as engineers in protecting the health and safety of the public. However, there was no rule concerning these systems. Therefore, Rule 61G15-32.010, F.A.C. Design of Smoke Control Systems, was added.
61G15-32.010 Design of Smoke Control Systems.
(1) Smoke control systems include, but are not limited to, smoke exhaust systems and pressurization systems for the purpose of providing a tenable environment to allow occupants to exit the building
(2) The Fire Protection System(s) shall be based on the Florida Building Code, the Florida Fire Prevention Code, applicable NFPA standards, when available, or on alternative engineering sources and good engineering practice when required.
About the Author
Scott R. Drury, PE, is a licensed Professional Engineer in Florida with expertise in both mechanical and fire protection engineering, and is a certified Commissioning Authority (CxA), Certified Firestop Inspector, and LEED Accredited Professional (LEED AP BD+C). He is the senior associate for H2Engineering Inc. with offices in Tallahassee and Gainesville, Fla. Mr. Drury began serving on the Board in February 2018 and is currently chair of the Mechanical Rules Committee and formerly chair of the Fire Protection Rules Committee.