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 22.214.171.124 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 (126.96.36.199), 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 188.8.131.52 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 (184.108.40.206), and sprinklers (220.127.116.11.6) 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 (18.104.22.168). 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