5.2 Inspection/Test, Yellow and Red Labels and Impairment Notice

Why This Section Matters

These three rules contain the only hard impairment notification clocks in Texas fire alarm law. They are precise, they differ from one another, and they differ from the timelines used in other states — which is exactly why exam writers like them.

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1. The Inspection/Test Label (§ 34.622)

When it goes on

"After the inspection and testing of a fire alarm system, a fire alarm inspection/test label must be completed in detail and affixed to either the inside or outside of the control panel cover or, if the system has no panel, in a permanent location. The signature of the licensee on the inspection/test label certifies that the inspection and tests performed comply with requirements of the adopted standards."

Two conditional rules follow:

• § 34.622(b): If any service or maintenance is performed under the inspection or test, a service label, in addition to the inspection/test label, must be completed and attached.
• § 34.622(c): For new installation, an inspection/test label may only be applied AFTER the system has been accepted by the local AHJ.

Deficiencies found during inspection (§ 34.622(d)–(e))

If during any inspection or test the system does not comply with applicable standards adopted at the time it was installed, has a fault condition, or is impaired, the owner or representative and the local AHJ must be notified and the licensee must attach the appropriate yellow or red label in addition to the inspection/test label. The local AHJ must be notified when the fault or impairment has been corrected.

Specification and content

Required content (§ 34.622(j)): DO NOT REMOVE BY ORDER OF TEXAS STATE FIRE MARSHAL; INSPECTION/TEST RECORD; firm name, address, telephone number and certificate number; date of inspection, licensee's signature (stamped signature prohibited) and license number; the type of inspection/test performed — new installation, semi-annual, quarterly or annual; the last date of sensitivity test, if known; and the status after the inspection/test — acceptable, yellow label attached, or red label attached.

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2. The Yellow Label (§ 34.623)

The trigger

"If, after any service, inspection, or test, a system does not comply with applicable codes and adopted standards or is not being tested or maintained according to those standards, a completed yellow label must be attached to the OUTSIDE of the control panel cover or, if the system has no panel, in a permanent location, to indicate that corrective action is necessary."

The licensee's signature on a yellow label certifies that the conditions listed on the label cause the system to be out of compliance with applicable codes and standards.

The notification clocks

Yellow labels remain in place until the conditions are corrected and a service label is attached certifying that the corrections were made. They may be removed by a licensed employee or agent of a registered firm, an SFMO employee, or an authorized governmental representative.

Content (§ 34.623(g))

DO NOT REMOVE BY ORDER OF TEXAS STATE FIRE MARSHAL; "SYSTEM DOES NOT COMPLY WITH APPLICABLE CODES & STANDARDS"; firm name, address, telephone and certificate number; date attached, licensee signature (stamped prohibited) and license number; and a list of conditions resulting in the yellow label.

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3. The Red Label (§ 34.624)

The trigger

"If, after any service, inspection or test, a system or any part thereof is inoperable, has a fault condition, or is impaired from normal operation, excluding the area(s) of a building under construction, a completed red label must be attached to the OUTSIDE of the control panel cover … to indicate that corrective action is necessary."

Note the construction-area exclusion, and note that a red label is required for a part of a system, not only for a totally dead panel.

The split notification rule — the single most testable item

Red labels remain in place until the conditions are corrected and a service label is attached certifying the corrections.

Content (§ 34.624(g))

DO NOT REMOVE BY ORDER OF TEXAS STATE FIRE MARSHAL; status of the system to be marked — inoperable, impaired, or fault; firm name, address, telephone and certificate number; date attached, licensee signature (stamped prohibited) and license number; and a list of conditions resulting in the red label.

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4. The Complete Deadline Table

Everything in the label rules is measured in business days; the two § 34.617/§ 34.618 deadlines are in plain or calendar days.

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5. Worked Fact Patterns

Pattern A. During an annual inspection a technician finds the panel dead after a lightning strike. → Red label on the outside of the cover, marked inoperable. Immediately notify the owner/occupant and the local AHJ orally, and deliver written notice within the next business day.

Pattern B. A tenant build-out added four offices with no strobe coverage; the system otherwise works. → Yellow label — the system does not comply with applicable codes and standards. Written notice to owner and local AHJ within five business days, listing the conditions.

Pattern C. A single notification appliance circuit is open; the rest of the system functions. → Red label — "a system or any part thereof … has a fault condition." Written notice within three business days.

Pattern D. A newly installed system has not yet been accepted by the AHJ, and the technician wants to leave an inspection/test label. → Not yet. Section 34.622(c) allows an inspection/test label on a new installation only after AHJ acceptance. And § 34.620(a) forbids attaching yellow or red labels for a new installation.

Pattern E. The deficiencies on a red label are corrected. → Attach a service label certifying the corrections, mark the color and date of the red label on it (§ 34.621(b)), remove the red label, and notify the local AHJ within five business days.