NFPA 25, Standard for Inspection Testing and Maintenance of Water-Based Fire Protection Systems, has had requirements addressing deficiencies and impairments since their introduction in the 2011 edition. It was not until the 2024 edition of NFPA 17A, Standard for Wet Chemical Extinguishing Systems, that NFPA followed suit and added requirements on this topic to help users of the standard categorize and prioritize work needed to correct problems with systems protecting restaurant cooking areas. Previously, only impairments were addressed, but there was nothing addressing deficiencies. Since adding this material, service companies, restaurant owners and managers, and the authority having jurisdiction (AHJ) now have specific criteria that can be relied upon for critical decisions impacting the performance of systems protecting commercial cooking area fire protection systems. Here is an overview of the information in NFPA 17A that will help you, your customers, and the AHJ understand the difference between system deficiencies and impairments. The information in this article is based on the most recent 2024 edition of NFPA 17A.
An impairment is any condition where a system, component of a system, or function of a system will not perform as intended [17A, 3.3.7]. Parts that are found during maintenance that could cause impairment or failure of operation of the system are required to be replaced by listed components in accordance with the manufacturer’s instructions [17A, 8.3.3.5]. Until such repairs are accomplished, the systems must be tagged as impaired. The owner or owner’s representative responsible for the system and the authority having jurisdiction must be notified of the impairment by the end of the following business day [17A, 8.3.3.5.1]. Only when all repairs have been accomplished and the system has been restored to full operation are the AHJ and the owner or owner’s representative (responsible for the system) informed [17A, 8.3.3.5.2].
For the purposes of inspection, testing, and maintenance of a restaurant system, a deficiency is a condition that will affect the performance of a system or portion thereof or has the potential to adversely affect performance but does not rise to the level of an impairment [17A, 3.3.2]. Some deficiencies, if not corrected, can or will affect the ability of the fire protection system to function as intended during a fire. Those deficiencies do not prevent a system from functioning properly when discovered, but if not corrected, could lead to an impairment. Despite the new definition, some deficiencies will likely not affect the ability of the system to function during a fire, but correction is needed for safety to meet the requirements of NFPA 17A or the system manufacturer’s manual. An example is damaged of missing labeling. In any case, whenever a deficiency is found, appropriate corrective action is required to be taken immediately. If the corrective action necessitates maintenance, it must be conducted by a service technician.
Definitions of deficiency and impairment were added to the 2024 edition of the standard to help categorize problems found during ITM. A new Annex C was also added that provides examples of common deficiencies and impairments found during system inspection, testing, and maintenance (ITM).
Tables were developed based on Annex C of NFPA 17A and are provided to assist technicians in the field in identifying and properly classifying impairments and deficiencies found during routine ITM of restaurant systems. Click here for a writeable PDF.
Safety is enhanced when the classification system outlined in NFPA 17A is used. When impairments and deficiencies are discovered and correctly classified during ITM of restaurant systems, appropriate corrective actions can be taken to restore system conditions to normal. This ensures that employees and customers of commercial cooking establishments will receive the best protection offered by these fire protection systems and that a reasonable level of safety is maintained.
“When impairments and deficiencies are discovered and correctly classified during ITM of restaurant systems, appropriate corrective actions can be taken to restore system conditions to normal.”