17.3 ITM Documentation and Records

A test that is not written down did not happen — not for the authority having jurisdiction (AHJ), not for the owner’s insurer, and not for the technician who inherits the building in three years. Module 5.II expects testing discipline; Module 5.V expects inspection and maintenance paperwork. False-alarm reporting forms are Chapter 19. This section is inspection, testing, and maintenance (ITM) documentation plus the New York business-record overlay in 19 NYCRR (New York Codes, Rules and Regulations) 195.10.

This Independent OpenExamPrep discussion treats NFPA 72, National Fire Alarm and Signaling Code, Chapter 7 and Chapter 14 records as commonly taught system documents. It treats 195.10 as New York license law, which you can quote more tightly because it is a state regulation, not a copyrighted NFPA table.

Two layers, not one folder

Failing either layer is an exam-ready mistake. “We gave the fire marshal a form, so we can shred the contract” is wrong. “We kept the invoice, so we do not need an ITM report” is also wrong.

19 NYCRR 195.10 — what the regulation actually says

195.10(a). Each business licensed under Part 195 shall keep and maintain for three years records of all transactions performed by the business. Installation, service, maintenance, and the ITM visit you billed are transactions.

195.10(b). Keep employee records until each employee has not been in the licensee’s employ for at least three full years. Those records include the employee statement, application, business and employment identification number, length of employment, and payroll records.

195.10(c). Retain records longer if litigation is pending about the records or the employee. “Litigation” includes investigation or administrative action by the Department of State, whether started by a public complaint or by the department. Do not purge a file because the three-year calendar expired while a complaint is open.

195.10(d). Maintain employee and business records at a central location within New York State for company and personnel records that pertain to New York work. A server or box that exists only in another state, with nothing retrievable in New York, is the fact pattern the regulation is written to stop.

195.10(e). Prepare and retain a statement of services and charges agreed with the consumer; give the consumer a copy. Give the consumer a copy of any document the licensee and consumer signed. Retain any agreement a representative of the licensee and the consumer signed for services to be performed.

195.10(f). In conjunction with any transaction, identify any and all employees who work on the installation, service, or maintenance of the system. The ITM report and the business file should name the people on site, not “crew.”

Job-planning consumer-agreement ideas also appear in Chapter 9; here the testing angle is: the ITM visit is a transaction, so 195.10 attaches to it.

What an ITM report must be able to answer

Commonly taught NFPA 72 inspection and testing documentation (often an AHJ-accepted form equivalent to the Chapter 14 forms) records:

• Property, system type, fire alarm control unit (FACU) location, and monitoring account
• Date, time, and who inspected or tested (tie this to 195.10(f))
• Device identity and location (address, circuit, description)
• Method used (listed aerosol, heat, flow, pull, NAC operation, battery load)
• Expected result versus actual result
• Deficiencies, impairments, and corrections
• Retest after repair — “fixed” with no retest is incomplete
• Final system status and whether monitoring was placed in test and restored
• Sensitivity readings or listed self-test results when those tests were due
• Battery date codes, charger results, and load/discharge results when those tests were due

The report goes to the owner (or the owner’s designated representative). The AHJ may require a copy or an uploaded filing. Leaving results only in a technician’s phone notes fails both NFPA 72 teaching and 195.10.

Keep a copy of current system documents at the FACU or other approved location: Record of Completion, as-builts, and enough operating information for responders and the next technician. When the system is modified, revise those documents. Stale as-builts are a deficiency.

Programming changes are records

Software, firmware, zone maps, bypasses, access codes, and hours of operation are how modern systems fail silently. Assisting with those items is part of the 19 NYCRR 195.1 service definitions (Chapter 16 and Chapter 19). For this chapter, the ITM rule is simple: document the change. Typical entries include the revision identifier, date, who made the change, what points or functions changed, and a functional retest of affected outputs. If you disabled a point to stop a trouble, the report must show the disable and the restoration. A clear panel with a still-disabled smoke is a documentation and safety failure.

How long to keep which paper

Use this conservative teaching stack:

1. Life of the system: Record of Completion, as-builts, sequence of operation, software documentation, acceptance results.
2. Until the next test plus one year (commonly taught NFPA 72 14.6 practice): the periodic inspection/testing form for that cycle; keep longer-cycle tests for the cycle plus one year.
3. Three years minimum (195.10): invoices, consumer agreements, identity of employees on the job, and other business transaction records — even if the NFPA form has already been superseded by a newer annual report.
4. Until the matter closes: anything in (3) if a Department of State complaint, investigation, or lawsuit is pending.

If an owner asks you to “leave nothing on site,” you can discuss confidentiality of access codes (19 NYCRR 195.12, Chapter 16), but you still retain the licensee’s 195.10 file in New York and you still provide the owner an ITM report. Confidentiality is not a license to skip records.

In practice

A technician tests 200 devices, finds three dirty smokes, replaces them, and leaves. The owner later receives a fire-marshal deficiency because no report was issued, the as-built still shows the old detector addresses, and the firm cannot name who was on site last March. That is a 195.10(f) failure, an NFPA 72 documentation failure, and a service failure — even if the new detectors work.

On the exam

Expect options that dump records at 90 days, that keep New York files only in an out-of-state office, that withhold the ITM report from the owner, or that treat 195.10 as a replacement for NFPA 72 forms. Choose three-year New York business records at a central in-state location, owner-facing ITM reports, named employees, and written programming revisions.