Field Changes Without AHJ Approval at a Courthouse
A contractor is upgrading the fire alarm system in a county courthouse. The approved plans show 28 smoke detectors, 12 pull stations, and four notification circuits. During installation, the foreman deletes three smoke detectors in mechanical rooms because of nuisance alarms and substitutes two heat detectors. In a corridor used as a return-air plenum, the crew runs non-plenum cable because the plenum-rated cable is on backorder; the foreman says the conduit is 'mostly sealed.' The contractor completes the job and submits as-built drawings 10 days after the final inspection. The AHJ had approved the original plans but was not told of the changes. The owner's representative says the system is working and asks the contractor to 'just document it.'
1. Evaluate the three field changes: deleted smoke detectors, heat detector substitution, and non-plenum cable in the return-air corridor.
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All three changes are problematic without approval. Deleting three smoke detectors changes the approved detection coverage, and nuisance alarms are not a sufficient reason to remove devices without an engineering review and AHJ approval. Substituting two heat detectors for smoke detectors may be acceptable in some mechanical spaces, but it is a design change that must be evaluated and approved; it cannot be made unilaterally by the foreman. Running non-plenum cable in a return-air plenum is a code violation unless the cable is specifically rated for plenum use or the installation is otherwise permitted. 'Mostly sealed' conduit does not convert a plenum into a non-plenum space. The contractor should not treat 'working' as equivalent to 'approved.'
2. What approval process should the contractor have followed, and does the late as-built submission fix it?
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The contractor should have stopped before making the changes and submitted revised plans or a change request to the AHJ and, where required, the owner's design professional. The AHJ would then approve, reject, or condition the changes. The non-plenum cable should have been corrected before concealment. Submitting as-built drawings after final inspection does not fix the violation because as-builts are a record of what was installed, not an approval of what was installed. The AHJ can require the contractor to expose and replace the cable, restore detection coverage, and retest. The contractor may also face re-inspection fees and scheduling delays. The proper sequence is approval first, installation second, and as-built documentation at completion.
3. What documentation should the contractor retain and provide to the owner?
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The contractor should retain the original approved plans, any approved change orders or revised drawings, the AHJ inspection records, the fire alarm record of completion, test results, device lists, panel programming records, and manufacturer documentation. If heat detectors were approved as substitutes, the approval should be in the file with the rationale. The contractor should also document the cable correction and any retesting. The owner should receive as-built drawings that match the actual installation and the record of completion required by the applicable fire alarm standard. The contractor should not provide a clean as-built that hides the field changes. Accurate records protect the owner during future inspections and protect the contractor if the changes are later questioned.