KEN KIRSCHENBAUM, ESQ
ALARM - SECURITY INDUSTRY LEGAL EMAIL NEWSLETTER / THE ALARM EXCHANGE
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comments on smoke detector replacement and NFPA
February 5, 2018
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comments on smoke detector replacement and NFPA from January 27, 2018 article
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Ken
    Stand alone smoke alarms (not part of an alarm system) used in residential homes should be replaced every 10 years.  Smoke detectors used in an alarm system which are functionally tested annually should be replaced whenever they don’t pass their functional or periodic sensitivity test.
Tom Hoefer
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Ken
    In response to the question regarding the mandatory replacement of smoke detectors, the following two points need to be made: 
    1.  When a manufacturer is granted a listing for any life safety device it is always contingent upon certain conditions, applications and of course it's limitations. These important details are always formally documented and included with the device as a requirement for maintaining its listing. NFPA 72 clearly mentions, and in multiple chapters, that devices are to be installed as per manufacturer's documentation, and that is of course part of the listing of that device.
    2.  That being said, NFPA 72 (2007) 10.4.7 clearly states that "Smoke Alarms", installed in one and two family dwellings "shall not remain in service for more than ten years from the date of manufacture".     It is very important to note the difference between "Smoke Alarms" and a smoke detector. Anyone in the this industry for more than 40 years should of course know the difference between them.
Frank Scotti, President
Balco Alarm Services Corp
NICET Level III
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Ken:
    Smoke alarms are to be replaced at 10 year intervals.  However Smoke detectors do not have a prescribed end of life and can stay in service as long as they past function and sensitivity tests. Please see http://www.systemsensor.com/en-us/Documents/Smoke-Detector_lifeExpectancy_techbulletin.pdf
Mark Fischer
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Ken
    There is considerable confusion concerning replacing smoke DETECTORS versus smoke ALARMS.  The 2002 edition of NFPA 72 requires smoke ALARMS to be replaced not to exceed 10 years from installation. The 2007 Edition of NFPA 72 required replacement within 10 years of manufacture. The requirement is only for installation in singe and two-family dwellings. Although recommendations by some manufacturers might state 10 years for smoke DETECTORS there does not seem to be any code reference at this time.
    The point taken concerning sensitivity testing of smoke detectors might apply here, but such is not the case for smoke ALARMS - please do not confuse the two. The code does not require sensitivity testing of smoke alarms – only detectors.  Typically enforcement is a Superior issue when discussing single and two-family dwellings. Most code authorities are not empowered in the private dwelling arena. Currently NFPA 72 of 2013 (governing rule and code in New York State) requires testing by a qualified technician every year. Try enforcing that requirement!
    Please do not confuse the household requirement for alarms with any for detectors (UL 268 type).  A few years back one unnamed manufacturer inadvertently stated in their technical data sheets that all detectors are to be replaced every 10 years. The Engineered Fire Alarm industry quickly responded that this statement was in error and the manufacturer immediately redesigned the spec data sheet for its detectors.  It is the intent of the Household Technical Committee that smoke ALARMS (UL 217) only are to be replaced within 10 years of manufacture.  One reason is that the sensitivity does change over time.
    Hope this provides some clarity. Oh - and BTW if you feel NFPA 72 is deficient in the area of sensitivity or elsewhere - when NFPA 72 is open for proposals to the 2020- edition - why not write one, or two or 35 in order to keep the requirements relevant.  If you need help with that effort - please indicate on the discussion list and one or more. Technical Committee members would be more than inclined to provide assistance.
    Also, in response to "anonymous"  statement “.... I know the manufacturers recommend smoke detectors should be junked/replaced after 10 years but I haven’t seen yet where the NFPA MANDATES that by code”  In responding to that statement suggest you look in your 2013 edition of NFPA 72 Under 29.8 Installation and more specifically 29.8.1.4 (5) (b) which states "Smoke alarms in one and two-family dwellings shall not remain in service longer than ten years from the date of manufacture."  If you do not have a copy on the shelf you might want to contact NFPA customer service or the NFPA Standards link at nfpa.org to obtain one.
    Respectfully,
James M. Mundy, Jr. 
CDT, CFI, CFPS, CHS V, CPP, CSI, mSFPE, NYS CCEO, SET     
President     
Asset Protection Associates, LTD                  
Wantagh, New York
smokedetector@msn.com
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Ken
    Only makes since to me that when the Manufacturer recommends you replace the product they made after so many years, then DO I.   Also the Manufacture recommends testing monthly, Test it the way the instruction say to and replace when fails.
anon

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Ken
    Responding to Anonymous' question on Smoke detector replacement:
    According to NFPA 72, 2016 Edition, Section 14.4.5.4: Smoke ALARMS (emphasis added) shall be replaced when they fail to respond to operability tests.
    14.4.5.4.1 Smoke alarms shall not remain in service longer than 10 years from the date of manufacture, unless otherwise provided by the manufacturer's published instructions.
    29.8.1.4 (5)(b) Smoke alarms installed in one- and two-family dwellings shall not remain in service longer than 10 years from the date of manufacture.
    Sections 14.4.4.3.1 through 14..4.4.3.3.1 tells you that smoke detectors must be tested when installed, 1 year after installation and then every alternate year and if the tests are acceptable, the testing may be extended to a maximum of 5 years between tests.
    Anonymous also needs to research Table 14.4.3.2
Roy Pollack, CPP SET
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Ken,
    On the comment of the January 27th  regarding smoke detector replacement, this guy needs to get his facts straight instead of complaining to you.   Perhaps he should contact the smoke detector manufacturers to confirm his belief that a smoke detector must be replace after 10 years that is false.   The NFPA refers to the manufacturer’s instructions regarding replacement.   What stated does apply to is smoke alarms not smoke detectors.   As far as smoke detectors not meeting the calibration requirements, if in fact this person did check, he would have seen that if the detector does not meet them has to be replaced regardless if it operates with smoke test spray etc.   So what is the problem here if they are 10 plus years?   Regardless of the age nothing says that they could not stay (other than JZ).    Also, how is he checking the calibrations?   Has he invested in a $1000.00 dollar tester to do this?   I know of no manufacturer that their smoke detector is manufactured in this country that states that they must be replacement after 10 years.   This person needs to do his homework and stop complaining to you a lawyer and not an alarm guy to get something confirming what he want to believe to sell smoke detectors.   If he believes in the 10 year rule or the likely hood that an old detector may not work when called upon then he should state that to his customer period.   Does he also believe that lighting switches and electrical outlet also  be changed after 10 years as well?   Too much whining and not enough action!
    Yours truly,
All Smoked Out And Burnt To A Crisp
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Response
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    This forum is a great place to find out all kinds of information on and about the industry.  It's also a good place to complain.
    Thanks to the fire experts for their comments.  So there is distinction between smoke alarm and smoke detector.  Wouldn't a smoke alarm include the panel, wires, strobes, sirens, heat and smoke detectors?   I doubt, but could be wrong, that devices to be changed every 10 years or sooner if necessary, would be the smoke detectors and maybe heat detectors.  Correct?  The comments above make it clear that NFPA requires smoke alarms to be replaced within 10 years.  What comprises the smoke alarm by definition?  I'm confused.  Good thing I don't install fire alarms.
    One thing I do know, don't do any fire alarm work without the Commercial Fire All in One.  Residential fire alarms are covered in the Residential Fire All in One.  If ordering the Residentialor Commercial All in One be sure to get the Disclaimer Notice.
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Ken Kirschenbaum,Esq
Kirschenbaum & Kirschenbaum PC
Attorneys at Law
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