life safety training nebraska health care association · pdf filek511 – gas and electric...

LIFE SAFETY TRAININGNebraska Health Care Association

Chris MoranNovember 1, 2017

www.jensenhughes.comwww.jensenhughes.com

WHO WE ARE

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We are a global company offering specialty engineering and consulting services for the built environment.

We have nearly 1,200 engineers, consultants, scientists and professionals focused on evaluating risks and developing practical, cost effective solutions for our clients’ protection, safety and security needs.

36+ years of specialty engineering and consulting services experience

Our global clients include numerous Fortune 500 companies that encompass architects, designers, general contractors, developers, building owners and facility operators.


Learning Outcomes:• Top 10 k-tags• Inspection, testing, and maintenance (ITM)

requirements

• Fire extinguishers• Sprinkler systems• Fire alarm systems• Fire doors

• Facility personnel vs. licensed contractor ITM

Agenda

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Purpose:• Identify ways to avoid common deficiencies• Identify importance of fixing deficiencies • Understand what regular ITM applies to your facility• Discuss specific requirements for different life safety

systems in the facility• Understand level of expertise required to perform

ITM

Overview

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• This is a discussion, not a speech• Need input from you• Helps me help you better• Identify issues to follow-up on• Ask questions

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Discussions


Important Information• FSES – S&C 17-15

• 5 year waiver• Emergency Preparedness Rule

• 11/15/17• S&C 17-29

• Electrical Breaker Testing• Not recommended by manufacturers

• Fire Door Inspections – S&C 17-38• Full compliance by 1/1/18• Cited under K211• Non-rated doors as part of facility maintenance program

CMS Updates

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Important Information• K-tags with additional criteria

K224 – ‘No hazards’ for manual horizontal doorsK325 – ABHR inappropriate access protectionK712 – Quals for planning/conducting drillsK712 – Fire drill regularityK900 – Quals for risk assessmentK912 – Reference errorK918 – Circuit breaker testing not available from manufacturers

CMS Updates

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Important Information• Extent of CMS Survey

• Customary Access• Fire Alarm DACT

• Minimum of 1 POTS line• Risk Assessments

• New construction

CMS Updates

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PruittHealth – Palymra, 6-9-15

100 residents evacuatedFire in bathroom, mainly water and smoke damageNo life threatening injuriesTwo of 4 wings closed indefinitely

NURSING HOME FIRES

9Albany Herald


NHC Health Care Center, Nashville, 09-25-03

8 women dead, ages 76 to 9620 critically injuredFire on 2nd floor (cause undetermined)No sprinklers in residential area“The smoke was so thick you could cut it with a knife”

NURSING HOME FIRES

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King’s Manor Nursing Home, 1-27-14

60 displaced residentsFire in storage closet (ruled accidental)Extensive damage

NURSING HOME FIRES

11Amarillo Globe News


Henan Province (China) Nursing Home Fire, 5-25-15

38 residents killed, 6 injuredCause of fire not knownHome completely destroyedNot anticipated that sprinklers provided

NURSING HOME FIRES

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Bbc.com


Health Care DataCivilian deaths in health care facilities• 2004-2008: 6 deaths• 2009-2013: 4 deaths

Nursing home dataCivilian deaths in nursing home facilities• 2009-2013: 3 deaths88% of fires were confined to the object of origin3% of fires spread beyond the room of origin

1Richard Campbell, (2016). Structure Fires in Health Care Facilities. NFPA, Quincy, MA.

NFPA HEALTH CARE FIRE DATA1

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• Structure fires in health care facilities have followed a steady downward trend over past decade

• Fire departments responded to 5,650 structure fires in health care properties per year in 2009-2013

• $45 million in direct property damage• 2009 – 2013 cooking was the leading cause of fires

(65%)



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Importance of resolving deficiencies• Safety of patients• Safety of employees• Continuity of operations• Liability

Health Care Facilities Maintenance

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Top 10 Life Safety Deficiencies1. K353 – Sprinkler System Maintenance (32.1%)2. K363 – Corridors - Doors (22.7%)3. K321 – Hazardous Areas Separations (21%)4. K372 – Smoke Barrier Construction (18.8%)5. K511 – Gas and Electric Utilities (18.7%)6. K712 – Fire Drills (15.4%)7. K345 – Testing of Fire Alarm System (13.6%)8. K324 – Cooking Facilities (11.6%)9. K920 – Power Cords and Extension Cords (11.1%)10. K351 – Sprinkler System Installation (10.7%)

Top 10 Deficiencies

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K353 – Automatic Sprinkler System Maintenance

LSC 4.6.12, 9.7.5, 9.7.7, 9.7.8 18.7.6, 19.7.6NFPA 25 provides requirements for regular inspection, testing and maintenance (ITM)Up-to-date records• Date sprinkler system last checked• Who provided system test• Water system supply source• Provide in remarks info on coverage for any non-required or partial

system

CMS Top 10 Citations

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How to avoid?


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How to avoid?• Keep records on-site• 2 staff member knowledge• Review changes in occupancy/use


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Component Inspection Testing Maintenance

Control Valves Monthly Annually Annually

Alarm Device Quarterly Semi-Annually N/A

Sprinklers Annually 50 Years* N/A

Pipe/Fittings Annually N/A N/A

Fire Dept. Conn. Quarterly N/A N/A

Main Drain N/A Annually N/A

Alarm Valve 5 Years Annually N/A

Check Valve 5 Years N/A N/A

Dry-Pipe Valve Annually Quarterly/Annually Annually

Backflow Preventer Monthly Annually N/A




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Zone Control Assembly Alarm Check Valve




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Backflow Preventer

Dry Pipe ValveCheck Valve


K363 – Corridors - Doors

LSC 18.3.6.3 / 19.3.6.3Substantial construction or 20-min fire rated, resist smoke


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Roller latches prohibited S&C 07-18 – Permitted door gaps• ¼” gap in not fully sprinklered smoke compartments• ½” gap in gully sprinklered smoke compartmentsNo impedimentPositive latching hardwareAuto/ self- closing on exits, smoke barriers, etc. Unlimited height protective plates permittedPowered doors permitted


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How to avoid?




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No LatchingDoor unable to close



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How to avoid?



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How to avoid?• Keep records on-site• Repairs breaks or damage immediately • Visual inspections

– Labels– Damage– Hardware


K321 – Hazardous Areas Separated by Construction

LSC 18.3.2.1 / 19.3.2.1Self / auto-closing doorsNew construction: 1-hr fire barrier, 45 minute fire doorExisting Construction: 1-hr fire barrier or sprinkler protection with smoke partition


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Hazardous areas include:


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Boiler Room Fuel Fired Heater Room





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Laundries > 100 ft2 Repair, Maint. & Paint Shops





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Laboratories Combustible Storage > 100 ft2





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Trash Collection Rooms Soiled Linen Rooms




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How to avoid?



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How to avoid?• Check functionality of doors

– Self-closing or automatic-closing– Field applied protective plates limited to 48” from floor

• Check for unprotected penetrations in walls


K372– Subdivision of Building Spaces: Smoke Barrier Construction

LSC 18.3.7, 18.1.6 / 19.3.7, 19.1.6Fire resistance in accordance with LSC 8.5Windows protected by fire-rated glazing or wired glass panelsMinimum of 2 compartments per floor


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NFPA 101 NFPA 101


K372– Subdivision of Building Spaces: Smoke Barrier Construction

Buildings subdivided as follows:• In-patient sleeping/ treatment rooms divided into at least 2

compartments• Stories with occupant load > 50 divided into at least 2

compartments• Compartments cannot exceed 22,500 ft2

• Limit travel distance to 200 ft


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K372– Smoke Barrier Construction


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Typical smoke barrier penetrations


K372– Smoke Barrier Construction


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NEW EXISTINGNFPA 101 NFPA 101



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K372 – Smoke Barrier Construction

How to avoid?



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K372 – Smoke Barrier Construction

How to avoid?• Check for unprotected penetrations• Verify functionality of door-closing device• Doors are not required to be tested per NFPA 105


K511– Gas and Electric Utilities

LSC 18.5.1.1, 19.5.1.1, 9.1.1, 9.1.2Equipment using gas or related gas piping complies with NFPA 54Electrical wiring and equipment complies with NFPA 70Existing installations can continue in service as long as there is no hazard to life


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K511 – Gas and Electric Utilities

How to avoid?



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K511 – Gas and Electric Utilities

How to avoid?• Keep on-site records• Verify hazard of existing conditions


K712 – Fire Drills

LSC 18.7.1.2 / 19.7.1.2Held quarterly on each shiftShift change drills only count for 1 shiftCoded announcement permitted when drills conducted between 9 pm and 6 amDocumented and records maintained


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today.duke.edu



Employees periodically instructed on their duties during a drillEmployee response includes:• Removal of all occupants directly involved with fire emergency• Transmission of fire alarm signal to warn building occupants• Confining fire by closing doors• Relocation of patients as detailed in fire safety planBedridden patients not required to evacuate


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How to avoid?



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How to avoid?• Keep on-site records• Ensure staff is familiar with routines and procedures• Ensure staff competent and responsible


K345 – Testing of Fire Alarm

LSC 9.6.1.4Up-to-date records2 staff member minimum knowledgeITM requirements in NFPA 72


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Device Visual Inspection Testing

Smoke/Heat Detector Semi-Annual AnnualPull Station Semi-Annual AnnualDuct Detector Semi-Annual AnnualTamper Switch Quarterly Semi-AnnualFlow Switch Quarterly Semi-AnnualHorns/Strobes Semi-Annual AnnualDACT Semi-Annual AnnualRemote Annunciator Semi-Annual AnnualControl Equipment Annual AnnualBattery* Semi-Annual/Monthly Annual/Semi-Annual*Frequency dependent on battery type



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How to avoid?



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How to avoid?• Keep on-site, up-to-date records• 2 staff member minimum knowledge• Check devices for visual damage


K324 – Cooking Facilities

LSC 9.2.3 / 18.3.2.5.1 / 19.3.2.5.19.2.3 – Commercial cooking equipment in accordance with NFPA 96, Standard for Ventilation Control and Fire Protection of Commercial Cooking Equipment


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Residential cooking equipment (small appliances) permitted to be used for food warming or limited cookingCooking facilities protected according to NFPA 96 are not required to be enclosed as hazardous areas, but shall not be open to corridor


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18.3.2.5.3 / 19.3.2.5.3Cooking facilities open to the corridor in smoke compartments with 30 or fewer patients shall comply with the following:

Cook top has a suppression system (UL 300A), grease collection, and 500 cfm minimum exhaustInterlocks to shut down fuel and electrical powerSmoke zone limited to 30 bedsTwo smoke alarms located 20 – 25 feet awaySmoke detectors not located within 20 ft


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K324 – Cooking FacilitiesTIA 12-2

Applies to cooking facilities in new and existing healthcare occ. (Ch. 18/19)Permits smoke alarm to be located outside of kitchen area to meet distance requirementsSmoke detector permitted to be used in lieu of smoke alarm• Can emit local signal without activating building fire alarm• Local silencing of the audible notification is permitted

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How to avoid?



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How to avoid?• Compliance with NFPA 96• Ensure proper use of equipment

– Small equipment used for limited cooking and heating• Ensure proper separations to the corridor unless

exceptions met


K920 – Power Cords and Electric Cords

LSC 9.1.2Used only for components of movable patient care related equipment (PCREE) that meet the conditions of 10.2.3.6Power strips may be used for computers, monitors, and printers outside patient care vicinity MEDICAL DEVICES allowed within limitations


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Power strips for PCREE meet UL 1363A or UL 60601-1Power strips for non-PCREE in the patient care rooms (outside of vicinity) meet UL 1363Extension cords are not used as a substitute for fixed wiring of a structureExtension cords used temporarily are removed immediately upon completion of the purpose for which it was installed and meets the conditions of 10.2.4


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How to avoid?



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How to avoid?• Ensure proper use

– Computers, monitors outside patient vicinity– Components of movable patient care equipment– Extension cords not used as substitution for fixed wiring


K351 – Sprinkler System Installation

LSC 18.3.5 / 19.3.5Sprinkler protection required in accordance with NFPA 13, Standard for the Installation of Sprinkler SystemsIn Type I & II construction, alternative protection measures permitted in lieu of sprinkler system in specific areas where AHJ prohibits sprinklers


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Sprinkler devices connected to FA panelClosets, built-in wardrobes and bathrooms require sprinklersExterior combustible canopies > 4’


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NFPA 101



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How to avoid?



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How to avoid?• Ensure sprinklers installed in all rooms, especially

when walls are relocated• Listed quick-response sprinklers or listed residential

sprinklers are used throughout smoke compartments with patient sleeping rooms in new facilities


923 (Gas Cylinder/Equip Storage) – 10.6%918 (Essential Electrical ITM) – 9.9%521 (HVAC) – 9.6%271 (Exit Discharge) – 9.5%211 (Means of Egress Requirements) – 9.3%

OTHER CITATIONS

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SUMMARY OF K-TAGS

Majority of citations concern regular maintenance or drillsKeep track of maintenance and recordsEnsure sprinkler protection provided throughoutMaintain exits, doors and walls in working order

CONCLUSION

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OPEN DISCUSSION

Survey TrendsRecent Experiences

RECENT SURVEY DISCUSSION

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OPEN DISCUSSION

What can your facility do to minimize deficiencies?What are the benefits of keeping up with facility maintenance?

DISCUSSION

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Inspection, Testing, and Maintenance Service: A service program provided by a qualified contractor or qualified property owner’s representative where all system components are inspected and tested at the required frequency and necessary maintenance is provided

What is ITM

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Qualified

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A competent and capable person or company that has met the requirements and training for a given field acceptable to the authority having jurisdiction.


THE OWNER IS RESPONSIBLE FOR ITM

International Fire Code

NFPA 101 and Referenced Standards (excerpt from NFPA 25)

Who is Responsible for ITM?

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• It is REQUIRED by code• NFPA 101 – 2012 Edition (CMS) adopts:

• NFPA 10 – 2010 Edition• NFPA 25 – 2011 Edition• NFPA 72 – 2010 Edition• NFPA 110 – 2010 EditionState Fire Code Adopts:

• NFPA 101 – 2000 Edition• NFPA 10 – 2002 Edition• NFPA 25 – 2002 Edition• NFPA 72 – 2002 Edition• NFPA 110 – 2002 Edition

• Mitigate the owner’s liability• Stay on top of deficiencies

ITM – Why Test & Inspect?

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• Continuity of building operations

• General life safety• Liability associated with not

performing ITM

ITM – Why Test & Inspect?

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NFPA 10, 2010 Edition

Standard for Portable Fire Extinguishers

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• LSC 18/19.3.5.12 – portable fire extinguishers shall be provided in all health care occupancies in accordance with 9.7.4.1

• LSC 9.7.4.1 - where required by the provisions of another section of this Code, portable fire extinguishers shall be selected, installed, inspected, and maintained in accordance with NFPA 10

• K355

ITM: Fire Extinguishers

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Fire Extinguisher Symbol Marking

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• Internal examination at intervals based on type of extinguisher (varies from 1-6 years)

• Maintenance, servicing, and recharging performed by certified persons

• Technician must be “certified by an organization with a certification program acceptable to the AHJ” and “have the proper tools, listed parts, and appropriate manufacturer’s service manual.”

ITM: Fire Extinguishers

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• 7.1.1. The owner or designated occupant is responsible for ITM

• 7.1.2. Personnel

• Certification required• Persons training for certification permitted to perform

maintenance under direct supervision of a certified person• Persons passing the testing process issued a certificate • Persons performing 30-day inspections not required to be

certified

Chapter 7: Inspection, Maintenance, and Recharging of Portable Fire Extinguishers

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• 7.1.4 Tags or labels

• Tags for recording inspections not placed on front of fire extinguisher

• Labels indicating use or classification placed on front of fire extinguisher


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• 7.2 Inspection

• Manually inspected when initially placed in service• Inspected manually at a maximum of 30-day intervals


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• 7.2.2 Procedures check list

1. Location in designated place2. No obstruction to access or visibility3. Pressure gauge reading or indicator in the operable range

or position4. Fullness determined by weighting or hefting for self-

expelling-type extinguishers, cartridge-operated extinguishers, and pump tanks

5. Condition of tires, wheels, carriage, hose, and nozzle for wheeled extinguishers

6. Indicator for non-rechargeable extinguishers using push-to-test pressure indicators


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• 7.2.2.1 Additional visual inspection required where the following conditions exist

1. High frequency of fires in the past2. Severe hazards3. Locations that make fire extinguishers susceptible to

mechanical injury or physical damage4. Exposure to abnormal temperatures or corrosive

atmospheres


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• 7.2.2.2 Additional inspection procedures

1. Verify that operating instructions on nameplates are legible and face outward

2. Check for broken or missing safety seals and tamper indicators

3. Examine for obvious physical damage, corrosion, leakage, or clogged nozzle


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• 7.2.4 Inspection record keeping

• Records kept for all fire extinguishers inspected

• Date of inspections and initials of inspector recorded

• Inspection records kept on tag attached to extinguisher, on inspection checklist maintained on file, or by an electronic method


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• 7.4 Recharging

• Extinguishers recharged after any use, as indicated by inspection, or when maintenance is performed

• Amount of recharge agent verified by weighing• Recharged gross weight required to be the same as the

gross weight marked on the nameplate• Where a gross weight is not provided on nameplate, a

permanent label indicated gross weight shall be provided


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Frequency of Internal Maintenance of Fire Extinguishers

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Frequency of Internal Maintenance and Hydrostatic Testing of Fire Extinguishers

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• What are the procedures for inspection?• What information must be recorded during ITM?• Benefits of fire extinguisher ITM?• Common deficiencies?

Discussion

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• Visual Inspection required at a minimum of 12 times per year

• Follow inspection procedure checklist• Keep detailed records of inspections

Summary of Fire Extinguisher ITM

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Standard for the Inspection, Testing, and Maintenance of Water-based Fire Protection

Systems

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ITM: Sprinkler Systems

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• LSC 9.7.5 Maintenance and Testing

• All automatic sprinkler systems and standpipe systems required by this code inspected, tested, and maintained in accordance with NFPA 25


• Property owner or designated representative responsible for proper maintenance

• Building owner responsible for ensuring all areas of the building containing water-filled piping maintained at a minimum temperature of 40° F

• Property owner must notify AHJ, the fire department, and alarm-receiving facility before testing or shutting down a system or supply

4.1 Responsibility of the Property Owner or Designated Representative

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• 4.1.8 Information sign

• Permanently marked metal or rigid plastic information sign placed at the system control riser supplying antifreeze loop, dry system, preaction system, or auxiliary system control valve

• Sign secured with corrosion-resistant wire or chain providing the following information:

1. Location of area served by system2. Location of auxiliary drains and low-point drains for dry pipe

and preaction systems3. Presence and location of antifreeze or other auxiliary systems4. Presence and location(s) of heat trace

4.1 Responsibility of the Property Owner or Designated Representative

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• Where an impairment occurs, compliance with Chapter 15 required

• Tag used to indicate a system or part thereof has been removed from service

• Tag posted at each system control valve

• Emergency impairments

• System leakage• Interruption of water supply • Frozen or ruptured piping• Equipment failure

4.1.9 Impairments

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Sample Impairment Tag

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• Impairment coordinator shall verify the following procedures have been implemented:

1. Any necessary inspections and tests have been conducted to verify affected systems are operational

2. The following have been advised that protection is restored:

• Supervisors, fire department, property owner or designated representative, insurance carrier, alarm company, other AHJ

3. Impairment tag removed

Restoring Systems to Service

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• Records made for all ITM readily available to AHJ upon request

• Indicate procedure performed, organization that performed work, results, date

4.3 Records

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• What gets a visual inspection?

• Sprinkler riser components• Control & alarm check valves• Gauges• Sprinklers• Piping• Fire department connection• Dry pipe valves

5.2 Inspection

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5.2 Inspection

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• Why should you perform ITM?


• Why inspect?

5.2 Inspection

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5.2 Inspection

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• Inspect sprinkler system Backflow Preventer (NFPA 25 §13.7)

Physical damageLeakageIsolation valves in the open position

Sprinkler System Weekly Inspection

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• Inspect gauges on dry sprinkler systems [NFPA 25 § 13.2.7.1.3]

• If not supervised by the fire alarm system, confirm normal air and water pressures are being maintained

• Where air pressure supervision is connected to a constantly attended location can be quarterly [13.2.7.1.3.2]

• If you are in a freezing climate, conduct the following inspections:

• Enclosures around dry-pipe, preaction or deluge valves maintaining a minimum of 40° F (4° C)

Sprinkler System Monthly Inspection

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• Inspect locked or supervised sprinkler system valves (NFPA 25 §13.3.2.1.1 & 13.3.2.2)

• Normal position (open or closed - Critical on dry and preactionsystems)

• Properly sealed, locked, and/or supervised • Accessible• Appropriate wrenches when required for operation• No external leaks• Appropriate identification

Sprinkler System Quarterly Inspection

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• Inspect sprinkler system Alarm Check Valves (NFPA 25 § 13.4.1.1)

• Valve trim valves are correct position (i.e., open or closed)

• Is free of leakage from the retarding chamber or alarm drains


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• Fire department connections [FDC] (NFPA 25 § 13.8.1):

• Visible and accessible• Couplings and swivels not damaged

and rotate smoothly• Plugs or caps in place and

undamaged • Gaskets in place and in good

condition• Identification sign(s) in place• Check valve is not leaking• Automatic drain valve in place and

operating properly• Interior of the connection is inspected

for obstructions• Visible piping supplying the fire

department connection is undamaged


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• Inspect sprinkler system gauges monitoring water pressure (NFPA 25 § 13.2.7.1.2):

• Being in good condition and free of physical damage• Indicating normal water supply pressure is being maintained


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• Freezing climate: perform these inspections before freezing weather.

• What are we looking for:

• Adequate heat to areas where wet sprinkler piping is located? (NFPA 25 § 4.1.2)

• Check low temperature alarms, if installed in heated valve enclosures (NFPA 25 § 13.4.3.1.2, 13.4.4.1.2, 13.4.5.1.1.2)

• Check unit heater locations to prevent sprinkler activation

Sprinkler System Annual Inspections

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• 5.2.1 Sprinklers

• Inspected annually from floor level• Replace sprinklers if any of the following conditions exist:

1. Leakage2. Corrosion 3. Physical damage4. Loss of fluid in the glass bulb heat responsive element5. Loaded with dust6. Painting unless done by manufacturer 7. Installed at incorrect orientation

5.2 Inspection

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5.2 Inspection

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5.2 Inspection

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• 5.2.2 Pipe and Fittings• Inspected annually from floor

level• What to look for:

• Piping and fittings in good condition• Mechanical damage• Leaks• External condition• Mechanical couplings properly

aligned• Nothing hung or resting on pipes• Pipes and fittings installed in

concealed spaces do not required inspection

5.2 Inspection

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• 5.2.2 Pipe and Fittings

5.2 Inspection

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• 5.2.3 Hangers and Seismic Braces

• Inspected annually from floor level• Replace/refasten if damaged or loose• Hangers and seismic braces installed in concealed spaces

do not require inspection

5.2 Inspection

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• 5.2.4 Gauges

• Inspected monthly on wet pipe systems• Inspected weekly on dry, preaction, and deluge systems

• Monthly inspection permitted where air pressure supervision is connected to a constantly attended location

• When gauge near compressor reads higher than gauge near dry pipe valve, take air line out of service

• Open alternate air line to equalize pressure• Internally inspect air line taken out of service and reassemble

for future use

5.2 Inspection

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• Waterflow Alarm and Supervisory Devices

• Inspected quarterly for physical damage

• Hydraulic Design Information Sign

• Inspected quarterly to verify secure attachment and legibility• Inspected annually for standpipe systems

• Heat Tape

• Inspected per manufacturer’s requirements

5.2 Inspection

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Sample Hydraulic Design Information Sign

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• What tests can be performed by personnel on automatic fire sprinkler systems:

• All required, some may be better performed by contractors:• Main Drain Test• Inspector’s Test• Alarm Test• Dry Pipe Trip Test• Pump Test

5.3 Testing

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Owner’s Section on Inspection Report

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• Purpose

• Confirm water supply condition (pressure drop, unobstructed, clean)

• Frequency

• Annually [NFPA 25, 13.2.5]• Any time a riser main control

valve is closed• Quarterly, if backflow

preventer present [NFPA 25, 13.2.5.2]

Main Drain Test

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Main Drain Test Procedures

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Step 1

Step 2

Step 3

Call the fire alarm system out of service and notify occupants (i.e., controllers, etc.).

Visually inspect the discharge location.

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Note system pressure on both sides of the alarm check valve.


Main Drain Test Procedures

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Step 4

Step 5

Step 6

Open main drain valve.

Visually inspect the discharged water.

-Clean? Clear? No debris?

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Note system pressure on both sides of the alarm check valve.

- excessive drops from previous tests or as-builts?


Main Drain Test Procedures (cont’d)

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Step 7

Step 8

Step 9

Confirm outside water motor gong operation, if present.

Close main drain valve.

Remove bypasses and call system back into service.

DONE!


• Purpose

• Simulate sprinkler activation• Confirm operation of flow

switches, water motor gong, etc.

• Confirm water delivery time for Dry Pipe System

• Frequency

• Every 6-months for paddle-type water flow switch [NFPA 25, 13.2.6.2.2]

Inspector’s Test

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Inspector’s Test Procedures

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Step 1

Step 2

Step 3

Call the FA system out of service and notify occupants.


Open the Inspector’s Test valve.


Inspector’s Test Procedures (cont’d)

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Step 4

Step 5

Step 6

Visually inspect the discharge.

Re-close the inspectors test valve.

Call system back into service.Finally

Confirm water motor gong operation, if present. (must ring within 5 minutes)

Note: May be an electric bell activated by a flow switch.


• Special testing considerations?

• Often installed because freezing is anticipated!

• Must be drained after testing!

• Test Types & Frequency

• Partial trip - Annual [NFPA 25, 13.4.5.2.2]

• Full Trip - Every 3 years [NFPA 25, 13.4.5.2.2.2]

Dry Sprinkler Systems

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Dry System Full Trip Test Procedures

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Step 1

Step 2

Step 3



Open the Inspector’s Test valve.-Note the time!


Dry System Full Trip Test Procedures (cont’d)

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Step 4

Step 5A

Visually inspect the discharged water.-Clean? Clear? No debris?

Confirm waterflow and fire alarm activation within 60 seconds and…

Confirm water motor gong operation, if present. (must ring within 5 minutes)

Step 5B


Dry System Full Trip Test Procedures (cont’d)

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Step 6

Reset dry pipe valve. Remove bypasses and call system back into service.


Step 7


• Special testing considerations?

• Valve will trip so be prepared to reset

Dry Sprinkler System Partial Trip Test Procedures

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Dry Sprinkler System Partial Trip Test Procedures

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Step 1

Step 2


Partially close the main water control valve located under the dry valve.• Ensures the riser does

not flood.• Will introduce a

supervisory on the Fire Alarm system


Dry Sprinkler System Partial Trip Test Procedures (cont’d)

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Open the Inspector’s Test valve.

Step 4 Listen for the dry valve clapper to open.

Step 3

Step 5

1

Reset dry pipe valve. Remove bypasses and call system back into service.


Step 6

e clapper to open.


Once the valve trips, fully close the control valve.


• Purpose

• Confirm water motor gong or Electric Bell operation

• Frequency

• Quarterly [NFPA 25, 13.2.6.1.2]

• Can be included as part of dry sprinkler trip tests

Dry System Alarm Test

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Dry System Alarm Test Procedures

143

Step 1

Step 2

Step 3

Call the FA system out of service and notify occupants (i.e., controllers, etc.).

Locate the pressure switch trim piping and associated valve.

Open the trim piping alarm valve.


Dry System Alarm Test Procedures (cont’d)

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Step 4

Step 5

Step 6

Confirm water motor gong or electric horn is operating. (Must ring within 5 minutes)

Close alarm line trim piping.

Remove bypasses and call system back into service.


• Annual • Must flow pump at minimum, rated

and peak flows [NFPA 25, 8.3.3.1]• Monthly

• Electric pump run for minimum of 10 minutes [NFPA 25, 8.3.1.2.2 & 8.3.2.3]

• Weekly• Diesel pump run for minimum of 30

minutes [NFPA 25, 8.3.1.1.1 & 8.3.2.4]

• Automatically started• Run without flowing water

• Who should perform• Contractor• Equipment and labor intense

Fire Pump Tests

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• Replaced if in service more than 50 years, or representative samples tested

• Test procedures repeated at 10-year intervals• Replaced if manufactured prior to 1920

5.3 Testing

146



• Sprinklers using fast-response elements in service for 20 years shall be replaced or representative samples shall be tested and re-tested every 10 years

• Representative samples: 4+ sprinklers or 1% of sprinklers in sample, whichever greater

• Sprinklers tested on 5-year basis where subjected to harsh environments

• Manufacturers permitted to make modifications in the field that restore original performance where acceptable by AHJ

5.3 Testing

147


Sprinkler Operating Element Identification

148


• 5.3.2 Gauges

• Replaced every 5 years or tested every 5 years by comparison with calibrated gauge

• Replace or recalibrate gauges not accurate to within 3% of the full scale

5.3 Testing

149


• 5.3.3 Waterflow Alarm Devices

• Vane-type and pressure switch-type tested semiannually• Testing devices on wet pipe systems shall include opening

inspector’s test connection• Bypass connection used where freezing weather conditions

exist

5.3 Testing

150


• 5.3.4 Antifreeze Systems

• Freezing point tested annually• Measure specific gravity with a hydrometer or refractometer

• Listed CPVC sprinkler pipe and fittings protected from freezing with glycerin only (new to 2011 edition)

• Use of antifreeze systems in accordance with state or local health regulations

• If test results indicate incorrect freeze point at any point in the system:

1. Drain system2. Solution adjusted3. System refilled

5.3 Testing

151


5.3 Testing

152


5.3 Testing

153


• Maintenance to be performed to keep the system equipment operable (§4.8).

• Sprinklers (§5.4.1):Sprinklers removed for any reason not reinstalledCharacteristics for replacement sprinklers

• Dry pipe systems (§5.4.2):Dry pipe systems kept dry at all timesAir driers and compressors maintained

Sprinkler System Maintenance

154


• Standpipe and hose systems (NFPA 25, 6.4 & 6.2.3):

• Replace missing or damaged valve caps• Repair damaged fire hose connections• Replace missing or damaged valve handles• Replace missing or deteriorated cap gaskets• Repair leaking valves• Remove visible and physical obstructions to

hose connections• Repair valves that do not operate smoothly• Replace valve where threads are damaged


155



• Replacement sprinklers shall have the proper characteristics for intended application, including:

1. Style2. Orifice size and k-factor3. Temperature rating4. Coating5. Deflector type6. Design requirements


156


• Dry-pipe systems being maintained in dry condition? (NFPA 25, 5.4.2)

• Interior of dry-pipe, preaction and deluge valves cleaned? (NFPA 25, 13.4.4.3.2)

• Low points drained in dry-pipe, preaction and deluge systems prior to the onset of freezing weather? (NFPA 25, 13.4.4.3.3)

• Air leaks in dry-pipe system resulting in pressure loss significant to sound warning alarms located and repaired

Dry Systems Maintenance

157


• Conducted every 5 years at a minimum• For the presence of foreign organic & inorganic

material• If tubercules or slime is found required to be tested

for microbiologically influenced corrosion (MIC)• Performed at the following minimum four points:

• System valve; Riser• Cross main; Branch line

Internal Piping Condition Obstruction Investigation

158


Facility• Visual inspections

• Information signs• Corrosion• Damage• Obvious deficiencies• Leakage

• Record keeping

Facility ITM vs. Contractor ITM

159

Contractor• Quarterly, monthly, and

annual tests

• Main drain test• Inspector’s test• Alarm test• Dry pipe trip test• Pump test

• Restoring systems to service

• System replacements


• Importance of ITM?• Steps to take to make sure ITM runs smooth and is

done properly?• Questions?

Sprinkler System ITM Discussion

160



161

National Fire Alarm and Signaling Code


• LSC 9.6.1.5

• To ensure operational integrity, the fire alarm system shall have an approved maintenance and testing program complying with the applicable requirements of NFPA 70, National Electric Code, and NFPA 72, National Fire Alarm and Signaling Code

ITM: Fire Alarm Systems

162


• Improve fire alarm system reliability• Reduce false / nuisance alarms

Why Test & Inspect?

163


• Lack of inspection, testing, and maintenance is a leading reason for fire alarm system failure

Why Test & Inspect?

164


Why Test & Inspect?

165


Why Test & Inspect?

166


Why Test & Inspect?

167


CONTINUITY OF BUILDING OPERATIONS – AVOID SYSTEM FAILURES

Importance of ITM

168


• NFPA 72 Section 14.2.2.1 states that the property or building owner or the owner’s designated representative shall be responsible for inspection, testing, and maintenance of the system and for alterations or additions to the system

• NFPA 72 Section 14.2.2.5 states that servicepersonnel shall be qualified and experienced in accordance with the requirements of 10.4.3


169


• NFPA 72 Section 10.4.3 states that qualified ITM personnel shall include:

• Personnel who are factory trained or certified for the specific type and brand of system being services

• Personnel who are certified by a nationally recognized certification organization acceptable to the AHJ

• Personnel who are registered, licensed or certified by a state or local authority to perform service on systems addressed within the scope of this Code

• Personnel who are employed and qualified by an organization listed by a national recognized testing laboratory for the servicing systems within the scope of this Code.


170


Visual Inspection

171

Device Visual Inspection TestingSmoke/Heat Detector Semi-Annual Annual

Pull Station Semi-Annual Annual

Duct Detector Semi-Annual Annual

Tamper Switch Quarterly Semi-Annual

Flow Switch Quarterly Semi-Annual

Horns/Strobes Semi-Annual Annual

DACT Semi-Annual Annual

Remote Annunciator Semi-Annual Annual

Control Equipment Annual Annual

Battery* Semi-Annual/Monthly Annual/Semi-Annual

*Assume sealed lead acid battery


• Start at control panel• Check for the obvious• Start testing after successful completion of visual

inspection

Visual Inspection

172


Visual Inspection

173

• Visual Inspections and Testing

• Smoke detectors are required to be tested with smoke

• All notification appliances must be operated annually and proper operation must be verified

• Periodically verify system is “normal”


The panel should indicate “normal”

Visual Inspection

174


Should NOT indicate trouble

Visual Inspection

175


Visual Inspection

176

Should not indicate “Alarm”

Should not indicate “Fault” or “Supervisory”


• No obvious wire breaks, corrosion, or other damage to connections

Visual Inspection

177


• Look for the obvious and take action

Visual Inspection

178


Visual Inspection

179


Visual Inspection

180


• Devices and appliances properly mounted and oriented

Visual Inspection

181


Visual Inspection

182


• Will this duct detector operate?

Visual Inspection

183



Visual Inspection

184

Not with the dust cover on!



Visual Inspection

185



Visual Inspection

186

Not with the sampling ports blocked!


• Will this bell work?

Visual Inspection

187


• Will this bell work?

Visual Inspection

188

Not without the gong!


• What is wrong with these arrangements?

Visual Inspection

189


• What is wrong with these arrangements?

Visual Inspection

190


Testing

191

Device Visual Inspection TestingSmoke/Heat Detector Semi-Annual Annual

Pull Station Semi-Annual Annual

Duct Detector Semi-Annual Annual

Tamper Switch Quarterly Semi-Annual

Flow Switch Quarterly Semi-Annual

Horns/Strobes Semi-Annual Annual

DACT Semi-Annual Annual

Remote Annunciator Semi-Annual Annual

Control Equipment Annual Annual

Battery* Semi-Annual/Monthly Annual*

*Dependent on battery type. Sealed lead acid shown


LSC 18.3.4.3 / 19.3.4.3 – Positive alarm sequence permitted

Trained personnel have 15 seconds to acknowledge alarm180 seconds then provided to investigate the alarm and reset the system

9.6.1.8 – Smoke detector required at location of control equipment

Testing

192


• NFPA 72 Section 14.4

• Before beginning testing, notify:1. Building occupants – place signs on exit doors, send emails,

signs in lobby, bulletin boards2. Fire department3. AHJ4. Monitoring company

Testing

193


• Minimize disruption of services

• Limit testing to distinct areas• Restore systems promptly

• Follow manufacturer's instructions for the specific device being tested

Testing

194


• 14.4.1.2 Reacceptance test done after changes are made to the system

• Initiating device, notification appliance, or control relay is added - functionally tested

• Initiating device, notification appliance, or control relay deleted – another device, appliance, or control relay on the circuit is functionally tested

• 10% Re-test

Reacceptance Testing

195


• 10.18.2.2 After any change, revise the Record of Completion

Testing

196


• Control equipment

• Tested to verify correct receipt of alarm, supervisory, trouble signals; circuit supervision; operation of evacuation signals

• Integrity of single or multiple circuits providing interface between two or more control units verified

• Lamps and LEDs illuminated• Secondary power disconnected and tested under

maximum load

Test Methods – Table 14.2.2

197


• Engine-driven generator

• If used, operation verified by owner in accordance with NFPA 110, Standard for Emergency and Standby Power Systems

• Uninterrupted Power Supply

• If used, operation verified by building owner in accordance with NFPA 111, Standard on Stored Electrical Energy Emergency and Standby Power Systems


198


• Secondary (standby) power supply

• All main power disconnected and occurrence of required trouble indication for loss of primary power verified

• Standby and alarm current demand measured• General alarm systems operated for ≥ 5 minutes• Emergency voice communication systems operated for

≥ 15 minutes• Main power supply reconnected at end of test


199


• Batteries – general tests

a) Visual inspection• Inspect for corrosion, leakage, tightness of connections,

electrolyte levelsb) Battery replacement

• When current falls below manufacturer’s recommendationsc) Charger test

• Operation checked in accordance with appropriate charger test for battery type

d) Discharge Test• Load tested with battery charger disconnected

e) Load voltage test• Terminal voltage measured with battery charge disconnected


200


• Batteries – general tests


201


• Fire alarm control unit trouble signals

• Audible and visual• Disconnect switches• Ground-fault monitoring circuit• Transmission of signals off-premises location

• Remoted annunciators verified


202


• Initiating devices

• Correct operation of electromechanical releasing device verified

• Fire extinguishing system/ suppression system/ alarm switch verified

• Heat detectors• Manual fire alarm boxes • Smoke detectors


203


• Fixed-temperature, rate-of-rise, rate of compensation, restorable line, spot type heat detectors

• Heat test performed with listed and labeled heat source• Assure test method does not damage the nonrestorable

fixed-temperature element of a combination rate-of-rise/fixed-temperature element detector


204

Careful not to damage / melt detector


• Fixed-temperature heat detectors


205


• Fixed-temperature, nonrestorable spot type heat detectors

• Do not perform heat test• Test functionality mechanically and electrically • Measure and record loop resistance• After 15 years from initial installation, replace all devices or

have 2 detectors per 100 laboratory tested• If a failure occurs on any of the detectors removed, remove

and test additional detectors


206


• Fixed-temperature nonrestorable heat detectors


207


• Smoke detectors

• Tested in place to ensure smoke entry into the sensing chamber and an alarm response

• Use smoke or listed and labeled product acceptable to the manufacturer or in accordance with published instructions

• Magnet testing NOT acceptable


208


• Smoke detector functionality test

• Conducted annually (minimum)• Aerosol smoke acceptable• This is NOT a sensitivity test


209


• Duct smoke detectors

• Tested for smoke entry• Those utilizing sample tubes must be tested to ensure they

will properly sample the airstream in duct• Magnet/key-switch is NOT acceptable


210


• Waterflow switches

• Functionally tested• Water required to be flowed through an inspector’s test

connection


211


• Supervisory devices

• Control valve switch functionally operated• Signal receipt verified to be within first two revolutions of

hand wheel or one-fifth of the travel distance• High or low-air pressure switch operated• Signal receipt verified where the required pressure is

increased or decreased 10 psi (70 kPa) from required pressure level


212


Test Methods – Table 14.2.2 – Sprinkler System Devices

213

Fire Alarm Signaling Systems Handbook

Vane type waterflow indicator switch.

Roll Paddle to Insert Into Pipe Through Hole

SPDT SwitchesRetard

Adjustment Dial

Reset AdjustmentDirection of Flow Arrow

Polyethylene Vane

Pipe Saddle


• Audible/Visible notification appliances

• Strobes• Horns• Combination horn/strobes• Evacuation speakers• Combination speaker/strobes• Chimes• Textual visual appliances


214


• Visual notification appliances

• Test performed in accordance with manufacturer’s instructions

• Appliance locations verified to approved layout

• Verify candela rating marking agrees with approved drawing

• Confirm each appliance flashes


215


• 10.18.3.1 After tests are satisfactorily finished, complete Inspection and Testing Form

• Retain form in a safe place

• Recommend retaining at least 3 years

Test Records

216


• Generally follows manufacturer's published instructions

• Maintenance frequency dependent on type of equipment and ambient conditions

• Equipment cleaning frequency dependent on type of equipment and ambient conditions

• Records required for all maintenance

Maintenance – Section 14.5

217


• What visual inspections can you complete to ensure performance of devices/appliances?

• Obvious things to look for when performing visual inspections?

• Questions?

Fire Alarm ITM Discussion

218


Standard for Fire Doors and Other Protective Openings


219


• Integral part of buildings passive fire protection system and overall fire protection

• Properly operating fire door is key component to compartmentalization

• Limit spread of fire• Restrict movement of smoke

ITM: Fire Doors

220


• Components of a fire door:

• Frame• Fire exit hardware• Door closers• Hinges• Locks• Door bolts• Glazing• Labels

ITM: Fire Doors

221


• Categories of fire doors:

• Horizontal sliding• Fire shutters• Swinging• Vertically sliding• Chutes• Overhead rolling fire doors• Service counter fire doors

ITM: Fire Doors

222


• NFPA 101 Section 7.2.1.15.2 - compliance with:

• NFPA 80, Standard for Fire Doors and Other Opening Protectives – 2010 Edition

ITM: Fire Doors

223


• Fire door assemblies inspected and tested annually by a qualified individual• Operation• Door clearance• Coordinator • Latch• Closer

• Written record signed and kept for AHJ

5.2 Inspection

224


• Fire-rated door assembly visual inspection includes:• Labels are present and legible• No holes or breaks of door or frame• Glazing in tact (if provided)• No signs of damage to door, frame, hinges, hardware• No parts missing or broken• Door clearances are appropriate• Self-closing device operating properly• Coordinator working properly (if installed)• Latching hardware operates• No auxiliary hardware present that would interfere w/

operation• No field modifications that would void label

5.2.4 Visual Inspection

225


• Performed by individuals with proper knowledge and understanding of operating components of door

• Prior to testing, perform visual inspection to identify obvious deficiencies, missing parts, etc. that could create a hazard during testing or affect operation

5.2.3 Functional Testing

226


• Swinging doors normally held open shall be operated at frequent intervals to ensure operation

• Horizontal or vertical sliding and rolling fire doors tested annually for full closure

• When annually tested, rolling steel fire doors drop-tested twice

• First test to check proper operation and full closure• Second test to verify automatic-closing device properly

reset• Cannot paint fusible links or other heat-actuated

devices

5.2.14 Maintenance of Closing Mechanisms

227


• Damaged glazing replaced with labeled glazing• Any breaks in face covering of doors repaired

immediately • Where a door, frame, or other part is damaged:

1. Repair with parts obtained from original manufacturer2. Test door to ensure emergency operation and closing

upon repair completion

5.2.15 Repair of Fire Doors

228


Fire Door Assembly

229


Fire Door Parts and Functions

230


• Fire rated permanent label attached and legible

Fire Door Label

231


• NFPA 101 Section 8.3.3.1

• Hardware must match the capabilities of the door and frame used

• Check hardware is UL listed and tested for rating to match fire door

Fire Door Hardware Labeling

232


• Where fire doors require fire exit hardware, ensure labels on hardware match label on the door

Fire Exit Hardware

233


• What visual inspections can you perform to ensure doors are code complaint?

• What should you do if you notice damages/improperly functioning doors?

• Questions?

Fire Door ITM Summary

234


Standard for Emergency Power and Standby Systems


235


• 8.1.1 Routine maintenance and operational testing program based on the following:

1. Manufacturer’s recommendations2. Instruction manuals3. Minimum requirements of this chapter4. Authority having jurisdiction

Chapter 8 – Routine Maintenance and Operational Testing

236


• 8.3 Maintenance and Operational Testing

• EPSS maintained to ensure to a reasonable degree that system is capable of supplying service within time specified for the type and time duration specified for the class

• Routine maintenance and operational testing program initiated immediately after EPSS passes acceptance test

• Written schedule established


237



• Permanent record maintained and readily available including the following:

1. Date of maintenance report2. Identification of servicing personnel3. Notation of any unsatisfactory condition and corrective action

taken, including parts replaces4. Testing of any repair for the time as recommended by

manufacturer


238



• Transfer switches and paralleling gear subjected to ITM program that includes the following operations:

1. Checking of connections2. Inspection or testing for evidence of overheating and excessive

contact erosion3. Removal of dust and dirt4. Replacement of contacts when required


239


• 8.4 Operational Inspection and Testing

• EPSSs inspected weekly and exercised under load at least monthly

• EPS test initiated by simulating a power outage using test switches on ATSs or by opening a normal breaker

• Transfer switches operated monthly• Routine maintenance and operational testing program

shall be overseen by a properly instructed individual • Full EPSS system tested at least once every 36 months for

duration of its assigned class


240


• 8.4 Diesel GenSet Testing

• Exercise monthly for 30 minutes by:• Loading that maintains minimum exhaust temps recommended

by manufacturer• Under operating temperature conditions and at not less than

30% of EPS nameplate kW rating.OR• Exercise monthly at available EPSS load and annually with

• At not less than 50% of nameplate rating for 30 min• At not less than 75% of nameplate rating for 1 hour


241


• 8.4 Natural Gas GenSet Testing

• Exercise monthly with available EPSS load for 30 minutes or until water temp and oil pressure stabilize


242


NFPA 99 – 2012 Edition

243

Health Care Facilities Codes


• 6.3.4.1 Maintenance and Testing of Electrical Systems

• Where hospital grade receptacles are required at patient bed locations, testing performed after initial installation, replacement, or servicing of device

• Non hospital grade receptacles tested annually

Chapter 6 – Electrical Systems

244


• 6.3.4.1 Maintenance and Testing of Electrical Systems

• Record maintained of tests required by this chapter and associated repairs or modifications

• Record shall contain the following:1. Date2. Rooms or areas tested3. Indication of which items have met or failed to meet

performance requirements

Chapter 6 – Electrical Systems

245


• 10.3 Testing Requirements

• Confirm physical integrity by visual inspection• Verify resistance of appliances in patient car vicinity with

grounding pin • Power cords connected in accordance with conventions of

a grounded system

Chapter 10 – Electrical Equipment

246


• 10.5.2.1 Testing Intervals

• Facility shall establish policies and protocol for type of test and intervals of testing for patient care-related electrical equipment

• Maintain records of ITM for several years• Extension cord / multitap adapter wiring tested for:

1. Physical integrity2. Polarity3. Continuity of grounding at time of assembly and periodically

thereafter


247


• 10.5.3 Servicing and Maintenance of Equipment

• Manufacturer of appliance shall furnish documents containing the following:

1. Technical description2. Instructions for use3. Means of contacting manufacturer

• Electrical equipment safety labels and condensed operating instructions on appliance are legible

• Personnel responsible for testing, maintenance and use receive continuing training


248


• 10.5.3 Servicing and Maintenance of Equipment

• Manufacturer’s document shall include the following:1. Illustrations that show locations of controls2. Explanations of the function of each control3. Illustrations of proper connection to the patient or other

equipment, or both4. Step-by-step procedures for testing and proper use of the

appliance5. Safety considerations in use and servicing of the appliance6. Precautions to be taken if the appliance is used on a patient

simultaneously with other electric appliances


249


• 10.5.3 Servicing and Maintenance of Equipment (cont.)

7. Schematics, wiring diagrams, mechanical layouts, parts list, other pertinent appliance data

8. Instructions for cleaning, disinfection, sterilization9. Utility supply requirements (electrical, gas, ventilation, heating,

cooling, etc.)10.Explanation of figures, symbols, abbreviations on appliance11.Technical performance specifations12. Instructions for unpacking, inspection, installation, adjustment,

alignment13.Preventive and corrective maintenance and repair procedures


250


• I contract out my testing and maintenance, what am I responsible for?

Who is responsible for ITM?

251


• Visual inspection

• Physical damage• Abnormal conditions• Obvious deficiencies

ITM: Facility Personnel

252



253



254



255



256



257



258



259



260


• Factory trained and certified• Certified by nationally

recognized certification organization

• Registered, licensed, certified by state of local authority

• Employed and qualified by an organization listed by nationally recognized testing laboratory

ITM: Licensed Contractor

261


• Documentation – hard copy and electronic copy of ALL reports• Keep in a safe, secure location

• Obtain copies of as-built drawings• Keep one copy current, as occupancy or system changes

occur

• Obtain copies of NFPA Standards applicable to your systems

Best Practice for all Systems

262


• Perform all annual testing at the same time• Hire qualified service providers to make repairs• Your plumber is NOT qualified• Your electrician is qualified in system wiring, NOT

system programming


263


• Ignoring deficiencies will make them WORSE


264




265




266


• Know all of your fire protection systems as well as you know your other building systems

• These are LIFE SAFETY systems• Set up inspection and documentation procedures• Designate and train personnel • Prioritize and repair deficiencies in a timely manner

ITM Conclusion

267


“A conclusion is the place where you got tired of thinking.”-- Steven Wright, comedian

CONCLUSION

268


QUESTIONS?

269

ContactChris Moran

+1 [email protected]

For More Information Visitwww.jensenhughes.com

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