There has been a significant amount of discussion and confusion regarding the requirements of
61G15-32 by both Contractors and AHJ’s. In an effort to provide clarification, the following Frequently Asked Questions have been compiled.
Q1: Are 61G documents prepared by a professional engineer required for systems designed in accordance with NFPA 13D for one and two family dwellings?
A1: No. Florida Statutes 633.021 (5) addresses systems designed in accordance with NFPA 13D. A Contractor I, Contractor II, or Contractor IV may design a fire protection system, the scope of which complies with NFPA 13D, Standard for the Installation of Sprinkler Systems in One- and Two-Family Dwellings and Manufactured Homes, as adopted by the State Fire Marshal, notwithstanding the number of fire sprinklers. Even if the system consists of more than 49 sprinklers, engineering documents are not required.
Q2: Does the Engineer who specifies the fire protection systems in accordance with the 61G15 requirements need to be a Fire Protection Engineer?
A2: No. Florida does not license engineers by discipline. The requirement is for the Engineer to be currently licensed in the State of Florida and competent by education, experience and knowledge in fire protection
Q3: Can the AHJ require that the fire protection system contractor’s shop drawings be sealed by a professional engineer?
A3: No. FS 633.551(2) states “Nothing in this act limits the power of a municipality or county to adopt any system of permits requiring submission to and approval by the municipality or county of plans and specifications for work to be performed by contractors before commencement of the work, except that no municipality or county shall require a fire protection system contractor's shop drawings to be sealed by a professional engineer” Furthermore FAC 61G15-32 states “Fire Protection System Layout Documents are based upon engineering direction provided in the Fire Protection System Engineering Documents and require no additional engineering input. These documents do not require the seal of a Florida registered engineer.
Q4: Can the licensed fire protection contractor design fire sprinkler systems documents for a sprinkler system that involves not more than 49 sprinklers?
A4: Yes. A Contractor I, Contractor II, or Contractor IV, certified under FS 633.521 may design fire protection systems of 49 or fewer heads, and may design the alteration of an existing fire sprinkler system if the alteration consists of the relocation, addition, or deletion of not more than 49 heads, notwithstanding the size of the existing fire sprinkler system [FBC 126.96.36.199, FS 553.79(6)(c)].
Q5: Is the AHJ responsible for assuring that the permit plans and specification are reviewed and comply with the Florida Fire Prevention Code requirements?
A5: Yes. FS 553.79(2) states: “Except as provided in subsection (6), an enforcing agency may not issue any permit for construction, erection, alteration, modification, repair, or demolition of any building or structure until the local building code administrator or inspector has reviewed the plans and specifications required by the Florida Building Code, or local amendment thereto, for such proposal and found the plans to be in compliance with the Florida Building Code. In addition, an enforcing agency may not issue any permit for construction, erection, alteration, modification, repair, or demolition of any building until the appropriate fire safety inspector certified pursuant to s. 633.081 has reviewed the plans and specifications required by the Florida Building Code, or local amendment thereto, for such proposal and found that the plans comply with the Florida Fire Prevention Code and the Life Safety Code.”
Questions Specific to AHJ’s
Q6: If an existing occupancy equipped with an existing fire sprinkler system consisting of 40 sprinklers and there is a proposed renovation to the occupancy that would call for a modification to the exiting sprinkler system requiring an additional 20 sprinklers, are 61G documents required?
A6: No. Florida Building code (FBC) 188.8.131.52 (2) states that no permit may be issued for any building construction, modification, erection, alteration, modification, repair or addition unless the applicant for such permit provides the local AHJ with engineering documents. Item (2) addresses fire sprinkler documents and allows for a Contractor I, II or IV to design a fire sprinkler system of 49 or fewer sprinklers or may design the alteration of an existing sprinkler system if the alteration consists of the relocation, addition or deletion of not more than 49 sprinklers, notwithstanding the size of the existing fire sprinkler system.
Q7: Should signed and sealed shop drawings be automatically rejected?
A7: It is strictly forbidden for a local AHJ to require shop drawings to be sealed by a professional engineer as addressed in Florida Statues 633.551 (2), 633.021 (5) as well as the Florida Administrative Code 61G15-32.002 (6). However, nothing prohibits an engineer, if he/she so chooses, from signing and sealing shop drawing that were prepared under his/her responsible charge. It is important to note that when an engineer provides more information and direction than is established in FAC 61G15-32.004 (2), he or she shall be held responsible for the technical accuracy of the work in accordance with applicable codes, standards, and sound engineering principles. Some owner/engineer contract agreements may require more engineer involvement than specified in current laws.
Q8: Is it permitted to accept a 61G document for a building permit? If so, where can this requirement be found?
A8: Florida Building Code (FBC) section 184.108.40.206, item (2) addresses fire sprinkler documents. This section states the fire sprinkler documents shall be prepared by Florida Registered Professional Engineer, the exception being new systems or alterations to existing system containing 49 sprinklers or less. Since the FBC is requiring these documents to be a prepared by a Florida Registered Professional Engineer, these would be Fire Protection System Engineering Documents. Florida Administrative Code Chapter 32 outlines the rules for Professional Engineers Concerning the Design of Fire Protection Systems. FAC 61G15-32.002 defines the Fire Protection System Engineering Document (5) as well as the Fire Protection System Layout Document (6). 61G15-32.003 outlines the common requirements to all Fire Protections Engineering documents with 32.004 (2) (a-j) outlining the minimum information to be provided on fire protection engineering documents for water based systems. As stated in the definitions, the contractor is to develop the layout documents based on the design criteria provided in the Fire Protection Engineering documents by the Engineer of Record for the fire sprinkler system. The Fire Protection System Engineering documents are submitted for the master permit (building permit per FBC) and the layout documents are submitted for the fire sprinkler installation permit.
Questions Specific to Contractors
Q9: As contractors, we are required to install a code compliant system. How should situations be addressed, where fire sprinkler plans are developed by an outside professional engineer and are returned with errors?
A9: Initially, a request for information (RFI) should be sent, in writing, to the general contractor with whom you are preparing your bid, asking for clarification of the error in question. The GC should send this information back to the engineer who should analyze the question and issue revised documents as necessary. If the error is not resolved and the engineer and the GC proceed with permitting and installing a non-code compliant system, then a complaint should be filed with the Florida Board of Professional Engineers. The FBPE will initiate a review process and proceed with disciplinary action if necessary. It is important to note that when an engineer provides more information and direction than is established in FAC 61G15-32.004 (2), he or she shall be held responsible for the technical accuracy of the work in accordance with applicable codes, standards, and sound engineering principles.
Q10: I often have AHJs requiring us to submit revised shop drawings, sealed by an the engineer of record, for the addition of an extra 45° ell in the UG fire main supplying the system or some similar minor change made in the field. They cite this as being a material deviation to the system design.
A10: A material deviation refers to a deviation from the minimum design parameters established by the engineer as set forth in FAC 61G15-32.004. The addition of an extra ell in the UG main supplying the system or any number of fitting for that matter is not considered a material deviation. An example of material deviation would be a change in the density or system type outlined in the engineering documents. While nothing prohibits the AHJ from requesting a re-submittal based on the actual installation and requiring hydraulic calculations proving the system is still compliant, as discussed above, it is forbidden for the AHJ to require contractor developed shop drawing to be signed and sealed by a professional engineer.
This list of questions is certainly not all inclusive. Additional questions or requests for clarification can be sent to Lorrell Bush, Executive Director at firstname.lastname@example.org.