New Updates to 69A Uniform ITM Reporting

Effective September 1, 2021

Proposed Uniform Summary ITM Report:

The key objective is to provide a simple form that provides just a basic outline of the performed ITM services that are required to be reported to the AHJ. The FL Statute currently requires a submittal of the detailed ITM report to the AHJ, which negates the need to add a lot of data to this summary form. The statute above prescribes the exact data that is required to be on the summary report, and specifically states that any other data that is provided on the detailed ITM report is not required to be added to the summary report. Here is the breakdown of the proposed summary report form:

Suggesting “Uniform Summary ITM Report” title in lieu of “Uniform Summary Inspection Report” noted in the statute above, to better align with the NFPA’s “Inspection, Testing and Maintenance” language that covers these activities.

The statute requires only the name of the company performing inspection. However, their contact phone number might be useful to the AHJ if they needed to follow up on anything that might be of interest to them, and such phone number is not listed on the detailed report.

This is the exact requirement from the statute.

Property name is not required in the Statute language; however, it might be useful to the AHJ for easier reference to the inspected property. Inspection date is required by the Statute and Start and Finish dates align with Annex B of NFPA 25 for larger multi-day inspections.

This is the exact requirement from the statute.

This is the exact requirement from the statute. The “system(s) inspected: entry field will allow the user to either list a single system or multiple systems that were inspected. As the FL Statute does not mandate “one inspection report for one system”, the guiding principle here will be for the summary report to correctly reflect how the inspections are currently being reported to the AHJ with detailed report. So, if the ITM services provider currently reports single system inspections, a single summary report will be required for each system. If on the other hand, the ITM services provider currently reports multiple system inspections (e.g. all sprinkler systems in a building), that would again require a single summary report, listing the systems inspected and providing the overall inspection status. The “inspection status” would be reported by selecting one of the applicable tags that would either highlight it and gray out the other two that do no apply, or cross over the ones that don’t apply, or not show them on the report at all. The key here is to give the AHJ a quick compliance snapshot.

All three of these sections follow the same information entry logic. The Statute does not prescribe what “brief description” means, so neither should this form. This is therefore best left to the ITM services provider and their AHJ, with two basic options; either (A) stating “none”, relating to “Green Tag”, or providing some “brief description” of identified non-compliances, relating either to “Yellow Tag” for noncritical deficiencies or “Red Tag” for critical deficiencies and impairments. So some ITM service providers might note “painted sprinkler”, while the other might chose to add the reference to “NFPA 25 Section”. In that same example, the ITM services provider could also chose to add the entire language from that NFPA 25 section “Any sprinkler that shows signs of any of the following shall be replaced: (6) Paint other than that applied by the sprinkler manufacturer” but that could than quickly cross the line of “brief description” by some. The key driver here should be to provide AHJ with sufficient information to give them and idea of the issue to either know what this is about (e.g. “painted sprinkler”) or to know where to look for in the detailed ITM report that should accompany the summary report.

This is not required in the Statute language; however, it could be used to add anything else that might be of interest to the AHJ. For example, adding the note that the owner has engaged the company to repair non-complaint issues, or stating that in addition to the detailed ITM report the provider also uploaded a photo of the non-compliant issue as that might be important for AHJ to better understand it, etc.

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Applicable Language:

(3)(a) The inspecting contractor shall provide to the building owner or hydrant owner and the local authority having jurisdiction a copy of the applicable uniform summary inspection report established under this chapter. The local authority having jurisdiction may accept uniform summary inspection reports by United States mail, by hand delivery, by electronic submission, or through a third-party vendor that collects the reports on behalf of the local authority having jurisdiction.

(b) The State Fire Marshal shall adopt rules to implement a uniform summary inspection report and submission procedures to be used by all third-party vendors and local authorities having jurisdiction. For purposes of this section, a uniform summary inspection report must record the address where the fire protection system or hydrant is located, the company and person conducting the inspection and their license number, the date of the inspection, and the fire protection system or hydrant inspection status, including a brief summary of each deficiency, critical deficiency, noncritical deficiency, or impairment found. A contractor’s detailed inspection report is not required to follow the uniform summary inspection report format. The State Fire Marshal shall establish by rule a submission procedure for each means provided under paragraph (a) by which a local authority having jurisdiction may accept uniform summary inspection reports. Each of the submission procedures must allow a contractor to attach additional documents with the submission of a uniform summary inspection report, including a physical copy of the contractor’s detailed inspection report. A submission procedure may not require a contractor to submit information contained within the detailed inspection report unless the information is required to be included in the uniform summary inspection report.