NFSA Submitted The Following Public Comment to the Arkansas Department of Health - Food Rules
Cindy Giedraitis
This public comment references the changes to the retail food rules, specifically the mention of leaking sprinklers in several sections, such as, but not limited to 3-305.11, 4-401.11, and 4-903.12. While the National Fire Sprinkler Association (NFSA) agrees retail food should not be stored under leaking sprinklers, where leaking sprinklers are found, they are required to be replaced immediately per the fire code.
The 2012 Arkansas Fire Prevention Code per Section 901.6 require fire sprinkler systems to be inspected, tested, and maintained to the (referenced) 2011 edition of NFPA 25 (Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems). NFPA 25, Section 5.2.1.1.1 and 5.2.1.1.2 states, “Sprinklers shall not show signs of leakage…any sprinkler with leakage shall be replaced…” Sprinklers are not manufactured to leak, at all, and when leaks are found, it often is a clue to a much larger problem with the establishments fire protection system. The fire code requires frequent inspections on fire sprinkler systems.
The retail food rules protect retail food, however, it should not ignore other state and local codes that protect consumers by other codes and standards. Where retail food inspections find leaking sprinklers, it should trigger the local code official, or state fire marshal to investigate and enforce the AR fire code to remedy the status of the fire protection system.
