Firestop Special Inspection wasn’t always part of the International Building Code (IBC); but with some persistence and a “Don’t-Take-No-For-an-Answer” attitude, Firestop Special Inspection is now included in the IBC’s Chapter 17, and it’s here to stay.
What is required by the International Building Code (IBC) for Special Inspection as it relates to Firestopping?
This is the REAL story.
Firestopping to ASTM E 2174 & ASTM E 2393 Inspection Standards
Special Inspection for Firestop Systems has ben specified in 07-84-00 Specs for quite some time, and still is sometimes overlooked. However, it’s a small – but critical – part of the “DIIM” of Firestopping.
FCIA Standards Development
Recognizing that this needed to change and identifying that this was unlikely to happen unless specified in the International Building Code (IBC), FCIA hired a standards and code consultant in 2001. FCIA’s Consultant wrote the first draft of ASTM E 2174, Standard for the On-Site Inspection of Installed Penetration Firestops. FCIA worked at ASTM with manufacturers and consultants to develop the standard. The standard for the Inspection of Joints, ASTM 2393, came a few years after introduction of ASTM E 2174.
FCIA & Special Inspection Code Development
FCIA then began the task of getting Special Inspection (and Approved/Qualified Firestop Contractors by an Approved Source like FM & UL/ULC) added to the International Building Code. From 2003-2008, FCIA and our code consultant, Koffel Associates, submitted through the ICC’s Code Development Hearings a proposal that ultimately resulted in the addition of ASTM E 2174 and ASTM E 2393 to the IBC’s, Chapter 17, Special Inspection for Firestopping.
Special Inspection Agencies AND Special Inspectors ‘Approved’ by the AHJ
While the ASTM E 2174 and 2393 Standards, do have a passage on Inspector qualifications, they are very limited. The Standards only outline the criteria for the Special Inspector. No mention is made of the Special Inspection Agency Company that employs the Special Inspectors.
The IBC’s Chapter 17, which focuses on Special Inspections, clarifies that regardless of the industry, it is critical to have Special Inspection Agency Companies that ‘meet applicable requirements’ – in other words, agencies who understand the industry enough to be able to spot deviations from the specified SYSTEM requirements.
The International Building Code, Chapter 17, further states that BOTH Special Inspection Agencies AND Special Inspectors need to be ‘Approved’ by the Authority Having Jurisdiction (AHJ). This is an important distinction that the code makes – a level of quality-control built into the codes that ensures that Special Inspection Agencies are employing highly-trained, qualified personnel to inspect the Life Safety Systems installed in fire-resistance-rated construction.
How Firestop Special Inspection Agencies Become an Approved Agency
The first approval required by the Building Code Official or AHJ is to appoint the Special Inspection Agency the ‘Approved’ Agency.
An ‘Approved Agency’ is “an established and recognized agency regularly engaged in conducting tests or furnishing inspection services, when such agency has been approved” [IBC 202. Definitions]. Put simply, the Special Inspection Agency has to be found acceptable to the AHJ by providing “all information as necessary for the Building Official to determine if the Agency meets the applicable requirements in Sections 1703.1,.1-1703.1.3”. [IBC 1703- Approvals, then, 1703.1 Approved Agency]. The Agency can be a company of any type…Sole Proprietor, Limited Liability Corporation (LLC), S-Corporation, C-Corporation, Limited Liability Partnership (LLP), etc.
Once the Agency is approved by the AHJ, the company is required to provide an “independence Statement”:
- Independence – The Approved Agency shall by objective, competent and independent from the contractor….[IBC 1703.1.1];
- Equipment – An Approved Agency shall have adequate equipment….[IBC 1703.1.2]; and
- Personnel – An Approved Agency shall employ personnel educated in conducting, supervising and evaluating tests and special inspections [IBC 1703.1.3].
At this point, the IBC delves further into the Special Inspector qualifications and the procedure for their approval by the AHJ, a process that is initiated once the Agency is ‘Approved’.
Special Inspector Qualifications
As stated in Chapter 17 of the IBC, the Approved Agency (Special Inspection Agency Company) has a responsibility to “provide written documentation to the building official demonstrating the competence and relevant experience or training of the special inspectors….”[IBC 1704.2.1].
FCIA worked with FM and UL towards the creation of the FM 4991 Approval for the Standard of Firestop Contractors and UL/ULC Qualified Contractor Programs. This collaboration resulted in the FM and UL/ULC Firestop Exams. These third-party exams are used to quantify the individual’s knowledge of Firestop Systems, systems selection and the zero tolerance needed to get firestop products installed to the Systems. The FM and UL Firestop Exams can also be used by the AHJ to determine the knowledge of the Special Inspector since it is a knowledge based exam.
This provides the AHJ a neutral, third-party assessment of the qualifications – and ultimately acceptability – of the Special Inspector.
Special Inspection Agency Approval – Accreditation, etc.
The Special Inspection Agency has one additional option to prove their worth to the Building Official: through Accreditation. Accreditation is a quantifiable verification of the Special Inspection Agency’s management System. The Building Code Official may use accreditation by a third-party, independent organization that conforms to ISO 17020 to approve a Special Inspection Agency.
Again identifying a need, in 2008 FCIA approached the International Accreditation Service (IAS) and proposed the addition of Firestopping to IAS’ AC 291 Accreditation for Special Inspection Agencies. This proposal was accepted by IAS, and IAS AC 291 was born.
IAS AC 291 is similar to the FM 4991 Standard for the Approval of Firestop Contractors and the UL/ULC Qualified Firestop Contractor Programs because it also focuses on the company’s Quality Management System. The difference is that it is designed for the ‘Approved Agency’. By definition, the ‘Approved Agency’ is a third-party firm (Sole Proprietor, LLC, C-Corp, S-Corp) that employs an ‘Approved’ Special Inspector. The IAS AC 291 program focuses on the Company, while the inspectors working for the firm are also tested for knowledge to the FM and UL/ULC Firestop Exams. The IAS AC 291 is not mandatory for ‘Approval’ of the Agency; and, other organizations may have programs similar to IAS AC 291.
FCIA’s hard work and persistence has resulted in the inclusion of Special Inspection for Firestopping in Chapter 17 of the International Building Code. Once the Special Inspection Agency has satisfied the requirements for Agency ‘Approval’ by the AHJ, through outside, third-party assessment or other means, the AHJ can accept the ‘Approved’ Agency. Then, the Special Inspector can demonstrate the requisite knowledge required to perform Special Inspections through allowing for their approval by the AHJ.
Without both elements – a Special Inspection Agency that understands Firestopping and a Special Inspector that understands Firestop SYSTEMS analysis – at work, the quality control built into the International Building Code is voided, leaving a greater possibility for error – a risky undertaking when it comes to matters of Fire and Life Safety.
Specifiers: Consider adding IAS AC 291, with the Firestopping Endorsement to specs. Also, add that the Special Inspector pass the FM or UL/ULC Firestop Exam. This sets up an easy approval process for the AHJ – and a safer building.