Enacted: 10/31/2012, Amended June 26, 2013

The Board of State Examiners of Plumbers and Gas Fitters (“Board”) has voted to provide these guidelines to its licensees and inspectors with regard to the installation of National Fire Protection Association (NFPA) 13D Multipurpose Piping Systems that exclusively use potable water (hereinafter “System” or “Systems”).  These Systems are potable water systems that have specialized sprinkler heads attached for protection against fire hazards in one- and two-family dwellings and manufactured homes.  The guidelines are being provided in light of the unique features of these Systems, as well as the absence of installation requirements for such Systems in codes that govern the installation of traditional sprinkler systems (780 CMR and 527 CMR).  The guidelines also are being provided to address any public safety concerns, and in light of the May 1, 2013 Department of Public Safety (DPS) memorandum on this subject.

Licenses and installations:

It is the position of the Board that, consistent with M.G.L. c. 142, §§ 1 and 3, the installation of these Systems by definition includes the direct connection of sprinkler heads to potable water piping, and thus the entire System including the sprinkler head must be installed by a licensed plumber.  When installing said System, the plumber shall adhere to the design plans of a Massachusetts registered professional engineer, who is responsible for ensuring that the design complies with 248 CMR and NFPA 13D (2013 edition), including the requirements as to pipe sizing and dimensions to ensure the proper functioning of the System as well as the safety of the consumers who will rely on the System. 

The Board recognizes that DPS has taken the position that sprinkler heads attached to a potable water supply must be installed by a licensed sprinkler fitter.  However, the Board reiterates that only a licensed plumber may install a potable water system or any fixtures directly connected to said system. 

Permits and inspections:

Once the installation of a System is complete but prior to final inspections, the plumber must provide the plumbing inspector with a written certification by the engineer that the installation complies with the design.  This requirement is in addition to the inspections that the plumbing inspector is required to perform on all potable water systems to ensure the system is in compliance with the provisions of 248 CMR. 

To the extent that other state or local authorities require non-plumbing permits or inspections with respect to the design and/or testing of a System, they are not the responsibility of the plumber or plumbing inspector, whose sole responsibility is to install the System in its entirety and ensure that the System meets the requirements set out in these guidelines.

Scope and term:

Plumbers and plumbing inspectors are reminded that these guidelines do not apply to NFPA 13D sprinkler systems that do not utilize potable water piping, nor to traditional sprinkler systems beyond the point where a direct connection is made with the potable water distribution system.

These guidelines shall be considered tentative pending further developments, including updates of the plumbing code to provide specific design, installation, and testing requirements for these Systems.