George Gunning on NFPA 731
Filed under: Intrusion Alarms System Integration Announcements Central Station Electronic Protection NBFAA— Al @ 8:57 am
June 3, 2005
COMMENTS ON NFPA 731
Standard for the Installation of Electronic Premises Security Systems The development of standards with the purpose of enhancing public safety and security is a worthy and valuable initiative. Every American who lives, works, shops, and goes to school is affected by the quality of the products, services and technology utilized to increase the level of safety and security in a community.
NFPA 731 claims to create a standard for the installation and service of premise security products in every commercial business property as well as a significant portion of the multi-family residential housing inventory in the United States.
NFPA 731, in its current form, does not meet the high standard that is required when addressing public safety and security and must be returned to committee for further development and review.
While we acknowledge the time, commitment and process dedicated to the development of NFPA 731, the draft presented is not complete, is not comprehensive, and does not reflect the reality of the public and private market which must adopt it to make it effective. We understand the NFPA process, but that process cannot, and should not, be used to defend a standard that is clearly flawed and must be returned to the committee for further review in the public interest.
Specifically, the draft propose standards contain what can be interpreted more than one way and which will result in inconsistent application, the standard is in conflict with itself in several sections, and the draft standard contains errors that must be corrected, even if you accept the standard as presented.
It is not acceptable to defend this work product because the adopting agencies are not fully aware of the standard. It could be argued that they should be aware at this stage of the process. I cannot imagine an NFPA fire code being developed in the absence of full and complete participation of the AHJs.
While the committee certainly has representation from some segments of the private industry, you should not be fooled into believing that the majority of the properties we protect will be served by this standard. NFPA 731 offers a standard based on UL protocols, but does not distinguish between the government defense installation, the retail bank, and the local beauty shop. This is a distinction that is applied in other NFPA standards and should be considered in this case.
Security is a custom, personalized service that relies on the expertise of the alarm company in open communication with the customer to determine what is necessary to secure people and property. An arbitrary standard, even one created at the highest level, does not advance security in this situation. It should also be considered that the standard will impact the cost factor that will remove valuable security from both commercial and residential multi-family properties.
We also question the basis of the work for developing NFPA 731. The committee has said it addresses the need to reduce false alarms, and the hope that instituting the standard will raise the quality of installations and products. The fact is that less than 5% of false alarms are related to installation or products. So, even if NFPA 731 was perfect, it would not have a significant impact on the issue.
In fact, it may cause harm to the very issue it says it will address. It distracts from the proven methods that are being utilized to reduce calls for service to police departments generated from alarm activations. A recent study indicated that false alarms have been reduced 63% over the past seven years, even as the number of protected properties has increase approximately two million each year. It also increases the risk of increased crime in a community because citizens may not have access to a proven crime prevention tool because of costs that are not relevant to public safety.
The security industry is a highly regulated business that uses thoroughly tested products to enhance safety and security. I am not comfortable with the NFPA establishing a standard on the basis that we do not provide quality service and products to our customers. It is simply not true, and it is offensive to the professional security industry. Under no circumstances should it be the foundation of an NFPA standard.
Finally, NFPA relies on an open and inclusive process to maintain the legitimacy of the standards it creates. In this case, NFPA 731 is flawed, in part, because of the absence of the National Burglar & Fire Alarm Association (NBFAA) on the committee. I understand that all organizations and individuals are offered opportunities to comment and propose changes throughout the process. This does not explain why NFPA would pursue this standard and not insist on inclusion of the NBFAA, the largest professional trade ssociation of security installing companies in North America whose members serve approximately 70% of the market.
We will not argue against your stated mission and purpose. What we can tell you is that your goals of enhancing public safety will not be advanced by adopting NFPA 731 in its current form. It does not promote safety and security, and it may do harm.
We ask that NFPA 731 be returned to the committee for further review. We also ask that NFPA initiate a process to determine the purpose of developing this standard, and restate the mission of NFPA 731. We believe this will result in a better standard that will, in fact, make a positive impact on the communities we serve.
George P. Gunning, CEO
USA Alarm Systems Inc.
138 E. Chestnut Avenue
Monrovia, CA 91016
George Gunning on NFPA 731