Understanding fire sprinkler inspection, testing, and maintenance requirements in California
Just like many regulations, the rules for the inspection, testing, and maintenance (ITM) of fire sprinkler systems can differ from jurisdiction to jurisdiction. To promote safety and standardization, the National Fire Protection Association (NFPA) and the International Code Council (ICC) publish model standards and/or codes for all aspects of fire protection, including ITM.
Both the NFPA and the ICC are private entities, so anything they say is just model guidance—until a government uses a version of these documents as law.
In the U.S., numerous NFPA and ICC documents are widely adopted into law, including:
- The International Building Code (IBC), adopted by all 50 states
- The International Fire Code (IFC), adopted in 41 states
- NFPA 101: Life Safety Code, adopted in full by 43 states
- NFPA 1: Fire Code, adopted in 19 states
- NFPA 13: Standard for the Installation of Sprinkler Systems
- NFPA 25: Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems
The relationship between model documents and local and state codes can be complicated. Governments may adopt entire model codes and standards into law, but they may also change, add, and remove requirements to suit their needs.
This is the case in California. The most populous state in the union has adopted the IFC as the basis of the California Fire Code (CFC). However, the government makes many alterations.
Two state codes contribute to the CFC: the California Health and Safety Code and the California Code of Regulations. The latter references NFPA 25 California Edition (2013 edition) as the go-to standard for fire sprinkler ITM. This last standard is based on the 2011 edition of NFPA 25: Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems.
Together, all of these documents create California’s unique requirements for maintaining fire sprinkler systems. This article helps you make sense of the who, when, and how—including licenses, schedules, and procedures—of fire sprinkler inspection, testing, and maintenance in California.
Licenses for fire sprinkler ITM in California code
Who is qualified? That’s the first question for any kind of fire protection work, and ITM is no different. Section 4.1.1.2 of NFPA 25 says that ITM has to be done by “qualified personnel.” The meaning of “qualified” may be left up to individual jurisdictions.
But in all of California, a license is required to test or maintain a fire sprinkler system:
From the California Health and Safety Code
13196.5. (a) Except as provided in subdivisions (b), (c), and (d), no person shall engage in the business of servicing or testing automatic fire extinguishing systems without a license issued by the State Fire Marshal pursuant to this chapter.
The chief authority having jurisdiction (AHJ) in California is the State Fire Marshal. As the California Health and Safety Code explains, this office is the central license-issuing authority. But there are exceptions. One is licensure under the Business and Professions Code. In certain other job functions, no license is required at all.
In this section, we’ll cover three core California fire protection licenses—the AES Licenses, the C-16 license, and the Fire Sprinkler Fitter license. First, though, we’ll look at cases where no license is needed.
When no license is required
California fire code releases fire protection professionals from licensure requirements for ITM in several scenarios. The first is when an inspection requires no license. As the California Code of Regulations (Title 19, Division 1, §904.1) says, “any person designated by the building owner or occupant who has developed competence through training and experience” may inspect fire sprinkler systems. This allows property owners to handle more ITM activities in-house.
With some reservations, the California Health and Safety Code also allows industrial automatic extinguishing systems to be tested and maintained by in-house teams without a license:
From the California Health and Safety Code
13196.5. Servicing and Testing Licenses
(c) Industrial systems may be serviced or tested by, or under the supervision of, an engineer employed by a private entity who shall not be subject to the licensing requirements contained in this chapter unless he or she performs the service or testing for a fee outside of the employment relationship.
As long as an engineer supervises the work, employees can service and test sprinkler systems in an industrial setting—a major time- and cost-saver.
Finally, the same section of California Health and Safety Code (13196.5) waives licensure requirements for:
- Workers who test and maintain alarm or supervisory devices on fire sprinkler systems
- Specialty contractors, defined in Section 7058 of the Business and Professions Code
AES licenses from the California State Fire Marshal
California’s State Fire Marshal issues licenses to companies that work on automatic extinguishing systems (AES), including sprinklers. AES licenses are sometimes called “A” licenses in the California Code of Regulations; “AES license” and “A license” refer to the same thing.
There are several kinds of AES licenses for different systems, two of which apply to ITM work on fire sprinkler systems. They are the Type 1 license and the Type L (“limited”) license.
- The AES Type 1 license is required for anyone who does business installing, maintaining, or testing fire sprinkler systems. Applying for an AES Type 1 license involves listing the company’s equipment and supplies and outlining the licenses and certifications (namely the “Fire Sprinkler Fitter” license) held by employees.
- The AES Type L (“limited”) license is less challenging to obtain than the Type 1 license. It is “limited” because it’s not for work-for-hire. As NFPA 25 California Edition (1.4.2) explains, this license allows property owners or lessees with experienced and trained employees to “Conduct annual testing and maintenance of wet pipe sprinkler systems, standpipe systems or private fire service mains in structures or properties they own or lease.”
C-16 Fire Protection Contractor license
As mentioned, there is an alternative business license for fire protection contractors under the Business and Professions Code. As NFPA 25 California Edition explains (4.1.4.2), this is the C-16 Fire Protection Contractor license. California’s Contractor’s State License Board issues the C-16 license. It requires applicants to pass an examination covering job site safety, estimation and planning, installation of underground mains, system installation, and ITM.
Fire Sprinkler Fitter license
The Fire Sprinkler Fitter license, issued by the State Fire Marshal, is the primary license that individuals need to work on fire sprinkler systems in California. There are two versions of it: Commercial and Multi-Family Residential. To be registered as a Fire Sprinkler Fitter, applicants must:
- Hold a C-16 contractor’s license.
- Alternatively, complete a California or federally-approved apprenticeship. For a commercial license, this means five years and 7,000 hours. For a multi-family residential license, this means two years and 3,500 hours.
- Pass a written exam.
If the holder of a business license intends to do work themselves (whether because they don’t have employees or for other reasons), they must also have a Fire Sprinkler Fitter license in addition to their business license. One person with a Fitter license is required per job site; the rest may be apprentices or trainees.
Even though the Fire Sprinkler Fitter and the C-16 licenses are issued by different agencies, there is a special relationship between them. To register as a Fire Sprinkler Fitter apprentice or trainee with the State Fire Marshal, applicants must show proof of employment by a person or company with a C-16 license.
Inspection and testing frequencies in California
If “Who is qualified?” is the first question of ITM in California, “When should it happen?” is the second.
NFPA 25 describes how frequently different parts of fire sprinkler systems must be inspected and tested. Regular inspections of systems ensure that deficiencies and impairments are caught early and fixed promptly so that the equipment remains, as NFPA 25 frequently says, “in conformance with NFPA 13.” Proper inspections make sure fire sprinklers work!
California adjusts these timelines in its version of NFPA 25. This ITM schedule is summarized in Table 5.1.1.2 of NFPA 25 California Edition, and many “bread-and-butter” tasks stay the same. Sprinklers, pipe and fittings, hangers, and seismic bracing still get inspected annually. The schedule for testing sprinklers is also unchanged in California’s version.
In this table, we’ve summarized major ITM schedule differences between NFPA 25 California Edition, the 2011 edition of NFPA 13 upon which it is based, and the current 2020 edition of NFPA 13:
| Task | NFPA 25 (2011 edition) | NFPA 25 (2020 edition) | NFPA 25 California Edition |
|---|---|---|---|
| Inspect sprinkler in concealed spaces | Never | Never | If accessible by an opening, every 5 years |
| Inspect spare sprinklers | Annually | Annually | Quarterly |
| Inspect pipe and fittings in concealed spaces | Never | Never | If accessible by an opening, every 5 years |
| Inspect hangers and seismic braces in concealed spaces | Never | Never | If accessible by an opening, every 5 years |
| Inspect gauges on wet-pipe systems | Monthly | Monthly, and at other intervals | Quarterly |
| Inspect gauges on dry, preaction, and deluge systems | Weekly | Monthly, and at other intervals | Quarterly |
| Inspect waterflow alarm and supervisory devices | Quarterly | Quarterly | Never, test annually |
| Test vane-type and pressure-switch-type waterflow alarm devices | Semiannually | Quarterly | Annually |
| Test mechanical waterflow alarm devices | Quarterly | Semiannually | Annually |
One notable difference between ordinary NFPA 25 requirements and California’s rules is the treatment of concealed spaces. Ordinarily, NFPA 25 exempts ITM professionals from having to check pipes, fittings, hangers, seismic braces (5.2.2.3), and sprinklers (5.2.1.1.6) that are in concealed spaces.
However, under California’s requirements, these components should be inspected every five years if they are above a drop ceiling or otherwise accessible by an opening. If there is no access to these parts, they don’t require a check.
Paperwork procedures for California ITM
Recordkeeping is a huge part of ITM. California’s fire code has a few specific regulations for how owners and fire sprinkler contractors handle the paperwork. These rules are listed in NFPA 25 California Edition and the California Code of Regulations and cover the type of forms used, their contents, the length of time they must be kept, and the ITM professional’s duties to the AHJ and the property owner.
First, ITM records must be kept using AES forms from the State Fire Marshal (4.3.1.1). These forms documenting ITM activities on a system component must be kept five years (as opposed to one year under national requirements) after the next scheduled ITM event (4.3.5). Many forms must also be forwarded to the AHJ.
Second, while ITM professionals always have a responsibility to report their work and observations to property owners, California adds two transparency rules to the procedures. The California Code of Regulations (Title 19, Division 1, §904.2(e-f)]) requires ITM professionals to:
- Provide owners with an itemized invoice for parts and labor
- Offer to return all replaced parts to the owner (unless a warranty requires that they are returned to the manufacturer)
Third, as elsewhere, ITM professionals in California must provide their testing and maintenance results to their local AHJs. California Code of Regulations says:
Title 19, Division 1, §904.2(j)
Testing and Maintenance Requirements
(j) It is the responsibility of the contractor, company or licensee to provide a written report of the test and maintenance results to the building owner and the local fire authority having jurisdiction at the completion of the testing and maintenance.
NFPA 25 California Edition (Table 906.4(a)) lists which AES forms must be forwarded to the AHJ.
Fire sprinkler inspection requirements in California are mostly straightforward
Again, every jurisdiction has its own laws about fire protection, but most are based on NFPA and ICC model codes. This ensures that fire protection systems are installed and maintained safely and according to industry best practices.
California’s specific ITM requirements are distributed throughout several documents. IFC forms the California Fire Code basis, but documents like the California Code of Regulations and California Health and Safety Code modify it. NFPA 25 California Edition, a legally binding document, has many specific nuts-and-bolts rules for fire sprinkler ITM in the state.
Despite this complexity, the ITM of fire sprinkler systems in California is pretty straightforward. Systems still have to be maintained following NFPA 25. Some highlights of California ITM law include:
- Businesses who perform ITM need an AES (Type 1 or Type L) or C-16 license
- Individuals who work on fire sprinkler systems need a Sprinkler Fitter certification
- ITM records should be kept on AES forms
- Records of ITM activities should be maintained for five years after the next recurring ITM event
- ITM professionals must provide an itemized invoice to property owners and offer to return all replaced parts
This blog was originally posted at blog.qrfs.com. If this article helped you, check us out at Facebook.com/QuickResponseFireSupply or on Twitter @QuickResponseFS.
Do you have signs per California code for 1) ITV/Drain sign and 2) control valve sign? This is for restaurant sprinkler system test requirements for LA County Fire Dept.
Seymour Floyd
Potato Corner USA
(323) 951-1155
Seymour, thank you for reaching out. We will have someone from our QRFS Customer Support Team contact you.
Are Permits or Inspections required in the City of Santa Rosa when removing a Fire Sprinkler within a Parking Structure? The Sprinkler is installed within an Attendant Booth and the Booth is being removed.
Michael — for code questions like this, you can try our Ask a Fire Pro service. Click the link to submit your question with some information about your building or system, and a fire protection professional will provide an answer based on standards and codes. Our pros include AHJs, contractors, engineers, and code experts with 150+ years of combined experience!
Can an “A” license in California work on a fire sprinkler underground system or would they need a “C” 16,36 license? Its becoming an issue in multiple jurisdictions.
Josh — if it’s becoming an issue, it sounds like there may be some conflict between local and state authorities. We’d suggest contacting the state licensing board—they can provide a more definitive answer. Best of luck!
Hello,
I just started up my business and rented a unit in a local shopping center. The city is requiring for the fire sprinkler system to be tested or a date of when it was last tested. My problem is the landlord says it is my responsibility to get it done, but 3 units share the same Riser. Do I have to pay for all 3 units because they are all tied into the same system? isn’t this the management company’s responsibility?
Thank you for your help.
Moises — The building owner (and their representative, if applicable) is ultimately responsible, though there may be provisions in your lease contract (or the contract with a management company) requiring others to do ITM. If you’d like us to assess your situation and local code and provide a written assessment of the rules, you can try our Ask a Fire Pro service. Click the link to submit your question with some information about your building, and a fire protection professional will provide an answer based on best practices, standards, and codes. Our pros include AHJs, contractors, engineers, and code experts with 150+ years of combined experience!
As a California C-16 Fire Sprinkler Contractor (license holder & RMO), am I required to obtain the additional 30 hours of training to perform NFPA-25 inspections & testing every 3 years as the Sprinkler fitters are?
Joe – For specific questions, we suggest contacting California’s Contractors State Licensing Board for the most accurate, up-to-date information.
Hi, does the 5 year sprinkler inspection supersede the annual inspection?
Sean — assuming you are referring to the 5-year inspection of pipe, hangers, braces, and sprinklers in concealed spaces (where accessible) — no, it shouldn’t supersede it. It’s just an additional requirement beyond the normal, annual visual inspection of sprinklers from the floor level. Thanks for reading!
Great article. We are currently in process of trying to understand California ITM requirements for the electronic fire alarm signalling (not-for-hire) in order to be able to perform our own annual inspections, complete like-for-like repairs (i.e. replace a manual pull station, or backup SLA battery), etc. in house. FWIW, we do have an “engineer” on staff who has as masters in mechanical engineering.
But if you ask a fire alarm vendor, they’ll tell you “These are FLS systems, you MUST be C-10 licensed to touch the systems in any way!”. When asking local (and even state) AHJ’s, they repeat the same highest-bar requirement “you should be C-10 licensed”. To replace a like-for-like pull station? or a smoke detector? …. a C-10? That’s a General Contractor / Electrician.
So this then all makes me wonder what the NFPA’s own CFAITMS certification is for? That is, the “Certified Fire Alarm ITM Specialist for Facility Managers”.
Anyway, if you have a NFPA 72 / electronic alarm ITM version of your article, that would be great.
Jay — Thanks for reading and the feedback, including a suggestion for another article!
Is there a requirement that al sprinkler heads must be tested is 20 years or older?
Bill — First, the interval depends on the sprinkler type (standard, dry, ESFR, etc). Without researching it, we are unsure if there are specific CA amendments to testing intervals but doubt any would apply, as a lot has changed in the last 10 years, with NFPA 25 tweaking the intervals based on evolving reliability data. You can read about the latest NFPA 25 testing requirements for different sprinkler types here.
Hello, thanks for this information, this is very useful.
Please help me with this: I understand to pass yearly inspection on a Apartment building with multiple units, sprinkles in common areas and ALL tenant Units must be accessed and inspected. Is that correct? And if so, Is there any official code number where it states that ALL units must be inspected to pass the yearly inspection?
I know it may be obvious, but I am not able to find or I am missing the wording
Thanks!
Dan — Without commenting specifically on California codes or the specific version of NFPA 25 in force in your area, inspecting all sprinklers that are visible is a standard requirement in NFPA 25. It’s in chapter 5 under the “inspection” subsection; here’s the reference in the 2023 edition (previous editions say the same thing):
5.2.1.1* Sprinklers shall be inspected from the floor level annually.
The standard does not talk about common areas vs. units in an apartment building, simply providing exceptions to the annual inspection for inspecting sprinklers in concealed, inaccessible, and some other spaces (the latter don’t apply). Thus, a resonable, standard interpretation of that section means an annual inspection should be done on sprinklers in units, too. (The sprinklers are visible and accessible). In practice, however, some condos and apartments only inspect the common areas due to the difficulty of coordinating inspections of all the units. There are solutions to this, however, such as doing phased inspections or training maintenance staff to become qualified on what to look for (it’s not complex) and having them do it when they change AC filters, etc.
Hope that helps!
Hello,
I live in a residential home which has fire sprinklers. How do I find a professional which can come and inspect these sprinklers?
Thanks,
Roxana — This QRFS blog goes over some good best practices. Many of them apply to contractors working on commercial systems, but many of the principles are also the same. In particular, contacting the NFSA and AFSA industry organizations mentioned may provide good leads. Another great resource may be the Home Fire Sprinkler Coalition.
Otherwise, use a standard Google search/phone book search and vet contractors by their qualifications, including residential sprinklers experience, reviews, insurance and bonding, etc. Best of luck!
Just opening a new surgery center and am being asked for the 5-year inspection of our sprinkler system. How can we have a 5 year when our center has only just completed build? Our initial inspection was completed and approved by State Fire Marshal.
Cindy — Without knowing more context about who is asking and what they mean (if any context exists): it doesn’t make sense just after acceptance testing and inspection were completed, assuming they were. Some tests and inspections have 5-year intervals, so unsure if the party really means some sort of initial system acceptance testing (or maybe a bureaucratic mix-up). Best of luck and thanks for the question.
For condominium communities, does the NFPA 25 for California mandate a simple visual inspection (looking for damage, dirt, paint, or rust) of all sprinkler heads quarterly, or yearly? And if so does the inspecting party need to be licensed for this visual inspection of the sprinkler heads (and if yes, does it need to be C-16 licensed)?
LTGS — Free access to the specific NFPA 25CA standard is hard to find since NFPA revised its site, but we uncovered it here. Section 5.2.1.1 of this 2013 edition of NFPA 25CA states that “Sprinklers shall be inspected from the floor level annually,” with “quarterly” crossed out in the sentence (indicating a change from a previous edition). This mirrors the visual sprinkler inspection requirement in NFPA 25; we believe the additional interval mentioned in the above blog for sprinklers in concealed spaces is the main difference.
Regarding qualifications: the City of San Diego rules, for example, state “A license is not required to perform visual inspections.” This mirrors California Code of Regulations Title 19, Chapter 5: “(a) A license shall not be required to perform inspections. Inspections may be conducted by an employee designated by the building owner or occupant who has developed competence through training and experience.” The exception is anyone doing inspections “for a fee.” (Again, this is basically the same as NFPA 25, which just states someone must be “qualified.”)
Hope that helps. As always, you should check with a relevant authority having jurisdiction to verify your local, legally enforceable rules.
@QRFS Team Yes, that was immensely helpful, thank you so much. I ended up digging into it some more, and it appears that:
1. The county that our condo community resides in (Santa Clara County) – which I assume would be our AHJ – points to the California Fire Code, via this document (see “Monitoring” section)
https://www.sccfd.org/wp-content/uploads/documents/fire_prevention/standards/2.4.6_sprinkler_installation_standards_for_multi-unit_residences_sds_sp-5.pdf
2. The California Fire Code, points to the NFPA 25 document, via provision 901.6 of Title 24 Part 9. See the “Title 19, Division 1, §904(a)(1)” section.
https://codes.iccsafe.org/content/CAFC2022P2/chapter-9-fire-protection-and-life-safety-systems#CAFC2022P2_Pt03_Ch09_Sec901.6
3. The NFPA 25 document’s most recent edition is 2023, and it has a California edition, the NFPA 25C.
– In the NFPA 25 2023 edition I did not find any mandates of quarterly inspections relating directly to fire sprinklers.
– In the NFPA 25C 2013 edition for California, I also found no evidence of a mandate to visually inspect the sprinklers on a quarterly basis (as you pointed out, it was quarterly but was changed to annually in 5.2.1.1). However, I found evidence there of a mandate to inspect the spare sprinkler supply on a quarterly basis (5.2.1.4).
– The NFPA 25 2023 edition however, mandates spare sprinkler supply on an annual basis, not quarterly.
I am assuming that the 2013 25C edition of the NFPA for California, would supersede/trump the 2023 25 edition of the NFPA.
And so concluding from the above, the only quarterly inspection required for us in Santa Clara Country, would be the spare sprinkler supply, and no visual inspections of all the sprinklers in every unit would be required.
This is only my logical conclusion however. Is it correct or did I miss something?
LTGS — Again, with the disclaimer that can’t provide a definitive or actionable answer in this format—and you should contact a qualified local fire protection pro and/or your AHJ for that:
The quarterly inspections for wet pipe fire sprinkler systems in NFPA 25 focus on fire department connections, waterflow devices, gauges, any control valves with electronic supervision, and the main drain. The visual inspection of sprinklers is annually in NFPA 25 (and annually in the latest version of NFPA 25CA available at NFPA.org).
Regarding whether 2013 NFPA 25C supersedes 2023 NFPA 25, that is actually a good question, as the CA-specific standard has reached a decade old and doesn’t seem to have an update. We may investigate why there is such a lag and write a blog with an update, but we don’t have the answer at the moment! You should check with a Santa Clara or state fire authority (as we will likely do for a new blog; it’s a relevant topic!)
Thanks!
@QRFSTeam Thanks again for the helpful response.
Yes I have contacted the folks at https://osfm.fire.ca.gov/about-us/osfm-contact-list
Still awaiting an answer from them.
I also tried contacting my city’s (San Jose) fire department to see if they have any requirements which may supersede the county’s requirements. Haven’t had any luck so far.
Come to think of it, in California at least, is the city the AHJ or is it the county?
It’s been quite a journey and I’m a bit puzzled at how convoluted all this is!
Looking forward to what the QRFS team uncovers on the matter.
Your website is an excellent resource and a great service to Fire Safety – many thanks.
Hello, after 13 years of performing fire inspections for a couple of the larger fire inspection/monitoring companies I am eager to venture out start my own Fire Inspection company.
My services would include Nfpa 72 and (eventually) Nfpa 25 inspections.
What licenses are certifications are recommended and required to start my company and perform the inspections?
Anthony – It depends on where you are located. Your best bet is to contact your state and local licensing authorities. Good luck on your venture!
Just correcting some typos in the original comment:
I have a question in regards to testing the water that comes out of the sprinkler system. Is there a requirement during inspection that the water that comes out of the sprinkler system is tested to make sure it’s not contaminated or might cause harm to individuals exposed to it or maybe requirement to replace the water in they system at different intervals of time. In particular I’m asking for properties in LA county, city of Pasadena.
Thank you in advance
Alex — We are unaware of water testing requirements regarding potability/harm to humans in something like NFPA 25, the ITM standard for water-based fire protection systems, but we can’t comment on whether there may be any local requirements. Standards and some local governments do require backflow preventers in systems to ensure sprinkler water does not enter the potable water supply. Your best bet is to contact your local water authority or government to answer your specific question. Thanks for reading.
Hi, I have questions in regards to the 5 year annual test and those allowed to handle more ITM activities in-house.
Stated above for the 5 year annual test a requirement is to Inspect sprinkler in Concealed spaces – Per NFPA 25 California Addition – If accessible by an opening, every 5 years.
What is defined by an accessible opening – example, storage units are accessible to the owners when vacant. Once rented they are no longer accessible to the owners. To complete an inspection of a standard facility with over 800 individual owners, we would have to get customer keys or cut locks for entree. We are trying to complete a 5 year annual test but we are being advised we would fail until we provided access to all 800 units on the facility.
What are our options?
If we have an in house maintenance department that routinely completes inspections in units would this fall in line with the following statement. If not how would one qualify?
As the California Code of Regulations (Title 19, Division 1, §904.1) says, “any person designated by the building owner or occupant who has developed competence through training and experience” may inspect fire sprinkler systems. This allows property owners to handle more ITM activities in-house.
Cole — Unfortunately, we cannot provide a relevant answer to this detailed question in this format. However, if you would like an informal code/standards interpretation of your situation, you can try our Ask a Fire Pro service. An experienced pro and AHJ will evaluate your question, ask any necessary follow-up questions, and provide a well-researched, specific answer.
What are the license requirements to inspect a new automatic extinguisher system being installed for a commercial /new construction building. What type of license(s) is needed and does it
Srh —The answers to your question depend on a few things, including what you mean by “automatic extinguisher system” and where the system is located. Assuming you are in CA, contacting the California State Fire Marshal and outlining the situation is likely your best course of action for up-to-date and specific information. Thanks for reading!