Federal Real Property: Lightning Protection Systems for Federal
Buildings (19-MAY-05, GAO-05-682R).
A Congressional letter, dated June 30, 2004, to the Comptroller
General expressed concern that the federal government may not
have a uniform approach to protecting its facilities from
lightning strikes. As a result, Congress requested a GAO study on
issues related to whether the federal government should adopt a
uniform standard for lightning protection systems. We selected
four agencies for this study--the General Services Administration
(GSA), the Veterans Health Administration (VHA), the U.S. Postal
Service (USPS), and the Department of Defense (DOD). These
agencies hold over 80 percent (in terms of square footage) of the
government's owned and leased property. The objectives of this
study were to determine (1) to what extent these selected federal
agencies use applicable lightning protection standard(s) to help
protect buildings they own from lightning strikes; (2) how these
selected federal agencies assess the need for lightning
protection systems on their buildings; (3) what practices and
lightning protection standard(s) the General Services
Administration uses when leasing privately owned buildings; and
(4) what data exist related to the financial impact of lightning
protection and damage to the federal government, such as the
number of buildings with lightning protection systems, the costs
associated with installing lightning protection systems, and the
costs to repair buildings struck by lightning.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-05-682R
ACCNO: A24398
TITLE: Federal Real Property: Lightning Protection Systems for
Federal Buildings
DATE: 05/19/2005
SUBJECT: Building codes
Buildings
Data collection
Federal facilities
Safety regulation
Safety standards
Standards and standardization
Weather
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GAO-05-682R
* Ordering Information.pdf
* Order by Mail or Phone
United States Government Accountability Office Washington, DC 20548
May 19, 2005
The Honorable Robert E. Andrews The Honorable Steven C. LaTourette House
of Representatives
Subject: Federal Real Property: Lightning Protection Systems for Federal
Buildings
Your letter, dated June 30, 2004, to the Comptroller General expressed
concern that the federal government may not have a uniform approach to
protecting its facilities from lightning strikes. As a result, you
requested a GAO study on issues related to whether the federal government
should adopt a uniform standard for lightning protection systems. We
selected four agencies for this study-the General Services Administration
(GSA), the Veterans Health Administration (VHA), the U.S. Postal Service
(USPS), and the Department of Defense (DOD). 1 These agencies hold over 80
percent (in terms of square footage) of the government's owned and leased
property. The objectives of this study were to determine (1) to what
extent these selected federal agencies use applicable lightning protection
standard(s) to help protect buildings they own from lightning strikes; (2)
how these selected federal agencies assess the need for lightning
protection systems on their buildings; (3) what practices and lightning
protection standard(s) the General Services Administration uses when
leasing privately owned buildings; and (4) what data exist related to the
financial impact of lightning protection and damage to the federal
government, such as the number of buildings with lightning protection
systems, the costs associated with installing lightning protection
systems, and the costs to repair buildings struck by lightning. We
conducted our work from December 2004 through April 2005 in accordance
with generally accepted government auditing standards.
This report summarizes information we provided to your staff during our
April 29, 2005, briefing. The briefing slides are attached as enclosure I.
Background
According to the Lightning Protection Institute, 2 lightning kills nearly
100 people every year in the United States, injures hundreds of others,
and causes billions of
1 For purposes of this report, we use the term "agency" to include all
four federal entities.
2 The Lightning Protection Institute is a nationwide not-for-profit
organization. According to the Institute, it seeks to promote and enforce
quality and safety in the design and installation of lightning protection
systems.
dollars in property damage; it often results in fire and total property
loss. In the 1700s, Benjamin Franklin proposed a method of protecting
structures from the effects of lightning. The method was based on his
observations, which suggested that (1) lightning preferentially strikes
elevated objects and (2) the energy from lightning can be transmitted to
and dissipated in the earth (thereby redirecting the energy away from a
building's structure) through a suitable network of conductors and
grounding electrodes-a lightning protection system. Various approaches to
lightning protection have been tried over the past 250 years, and many
have been described and published as lightning protection standards.
To help protect people and property, the National Fire Protection
Association (NFPA) first adopted specifications for installing lightning
protection systems on buildings in 1904. Those specifications have evolved
over time and are now referred to as NFPA-780, Standard for the
Installation of Lightning Protection Systems. The most recent version of
the document was approved by the American National Standards Institute in
August 2004. 3 To help architects, engineers, and others decide whether
their commercial, industrial, farm, institutional, or residential
buildings (ordinary buildings) need protection from lightning, NFPA-780
also provides a methodology for determining whether a building is at risk
from lightning and for deciding whether lightning protection should be
installed. Other standards related to the installation of lightning
protection systems augment NFPA-780, including standards developed by (1)
the Underwriters Laboratories Inc. (UL) and (2) agencies with special
needs, such as buildings that house munitions and explosives (nonordinary
buildings).
Results of Our Study
We found the following:
o When decisions are made to install lightning protection systems, all of
the agencies in our review-GSA, VHA, USPS, and DOD-require the systems to
be installed in accordance with NFPA-780. This standard (1) describes,
among other things, the dimensions and the types of materials to be used;
(2) illustrates the correct placement of lightning conductors on various
types of roofs; and (3) contains additional material such as information
about lightning theory, measurement techniques, and methods for protecting
parked aircraft. The policies of all of the agencies also explicitly
require that the materials and installation comply with standards in UL 96
and/or UL 96A, respectively. 4 These standards contain requirements, such
as the use of certified installers, that help ensure that NFPA-780 is
followed and that the lightning protection systems will operate as
intended.
3 The American National Standards Institute is a private, nonprofit
organization that accredits the procedures of organizations that develop
standards. 4 GSA recently revised its policy on April 1, 2005, to require
the use of UL 96. Its prior policy was not explicit on this point;
however, GSA officials told us that the agency followed UL 96 and UL 96A
as appropriate.
* When designing new buildings or renovating existing ones, USPS,
VHA, and DOD's Navy specifically require the use of NFPA-780's risk
assessment and decision-making methodology for deciding whether to
install a lightning protection system. To determine whether a
lightning protection system should be installed, the methodology
assesses risk using such variables as
* the value of a building's contents, (2) the type and size of
the building,
* the number of occupants in the building, and (4) the frequency
of lightning strikes in the building's vicinity. 5 If the
estimated lightning risk exceeds an accepted (tolerable) level
of risk, NFPA-780 recommends the installation of a lightning
protection system. Another agency-GSA-did not explicitly
require the preparation of lightning risk assessments until
April 2005. 6 However, GSA officials told us that in practice,
the agency routinely required architects and engineers to use
NFPA-780's risk assessment and decision-making methodology
when designing or renovating buildings. Finally, although the
Army and the Air Force do not currently follow NFPA-780's risk
assessment and decision-making methodology, they have
identified related variables for assessing risk and making
decisions to install lightning protection systems when
designing new buildings or renovating existing ones.
Specifically, their current guidance requires installing a
lightning protection system on a building if the frequency of
lightning is more than five thunderstorms per year and if the
building (1) is 50 feet or higher; (2) has four stories with
elevators, stairwell penthouses, or other similar projections
above the roof; or (3) has five or more floors with or without
projections. Other factors, such as whether the building is
occupied or has valuable contents, may also be considered. The
three military services, as part of DOD's Unified Facilities
Criteria Development Program, are working to develop
consistent guidance across the services. A draft of that
guidance mandates the use of NFPA-780's risk assessment and
decision-making methodology and allows each service to
consider additional factors, such as whether the building is
mission critical and whether the value of the building's
contents is significant. According to DOD, a final draft of
this new guidance is expected late this fall.
o GSA leases buildings for its use and for many executive branch
agencies. 7 According to GSA officials, its lease agreements with
private building owners do not require buildings to have lightning
protection systems.
5 NFPA-780 risk assessment and decision-making methodology does not
explicitly include cost as suggested by guidance from the Office of
Management and Budget. However, our analysis indicates that cost may be
implicitly considered, because installation of lightning protection
systems is not recommended at all locations where lightning risk exists. 6
The agency's new policy states that "[t]he decision to recommend a
lightning protection system shall be made at the earliest stages of design
and shall be supported by a study as prescribed by NFPA-780." 7 Other
agencies have special requirements and have authority to lease their own
buildings. One such agency is VHA. VHA officials told us that because
their buildings house patients in critical care and support patients on
life-sustaining medical systems, their agency requires more stringent
standards than those provided by GSA.
However, its lease agreements do require building owners to conform to all
applicable state and local building codes, including those concerning the
installation of lightning protection systems, where required. The
officials also said that unlike federally owned facilities, any costs to
repair federally leased properties struck by lightning are the
responsibility of the building owner. In some circumstances, GSA enters
into a "design/build" arrangement with private companies with the intent
of leasing back a building. We were told by agency officials that in such
cases, GSA requires that building design and construction be done in
accordance with federal standards, including those concerning the
installation of lightning protection systems, where required.
o Various data exist, but they are outdated, unreliable, or incomplete.
For example, industry data on the financial impact of lightning are
outdated and not specific to the federal government. Likewise, although
the National Oceanic and Atmospheric Administration (NOAA) collects data
on fatalities, injuries, casualties, and damages due to lightning strikes,
the data also are not specific to the federal government. Moreover, NOAA
acknowledged that the data are often unreliable and incomplete because the
agency's personnel are unaware of all of the incidents of lightning. As a
result, a number of incidents are never documented. GSA compiles
information on federal properties and annually publishes a worldwide
inventory of federal properties, which includes information about the
physical characteristics and value of each property. However, GSA does not
currently collect information about the number of buildings with lightning
protection systems. Finally, none of the agencies we reviewed collect data
on, among other things, (1) the number of buildings with lightning
protection systems, (2) the costs associated with installing lightning
protection systems, and (3) the costs to repair buildings struck by
lightning. Local agency officials also do not collect this data; although
they maintain information such as building maintenance records, the
information is incomplete and not readily available. According to agency
officials, agencies do not specifically maintain or track data related to
lightning strikes because such strikes are rare and, consequently, not a
problem. Nevertheless, agency officials identified 20 possible lightning
strikes associated with their buildings over the last 10 or more years.
According to the officials, the total cost of repairs was about $636,000
ranging from $300 to repair a roof at a GSA facility to $207,000 to
replace a fire alarm system at a postal facility. No deaths or injuries
were reported.
In summary, the four agencies in our review account for the vast majority
of the government's owned and leased property and have adopted NFPA-780,
the national standard for installing lightning protection systems. These
agencies also follow or plan to follow NFPA-780's risk assessment and
decision-making methodology for determining when lightning protection
systems should be installed. Although none of the agencies collect data on
lightning-related damages, federal agency officials we interviewed from
geographical areas where lightning incidents were relatively frequent did
not consider lightning a significant concern, partly because they believed
adequate measures had already been taken to protect their buildings.
Agency Comments and Our Evaluation
We provided a draft of our April 29, 2005, briefing to each of the four
agencies for their review and comment. We also provided NOAA with
applicable excerpts from the draft. All four agencies agreed with our
findings. GSA, DOD, and NOAA provided technical comments, which we
incorporated as appropriate.
Scope and Methodology
To satisfy the objectives of our engagement, we interviewed headquarters
officials from GSA, VHA, USPS, and DOD. These agencies hold over 80
percent (in terms of square footage) of the government's owned and leased
property. We obtained and reviewed the agencies' standards and policies
for assessing the need for and installing lightning protection systems on
their ordinary buildings, information about requirements for leasing
ordinary buildings, and available data on the financial impact to the
government. We also contacted officials from NOAA and Vaisala Inc. to
obtain data on the frequency and location of lightning strikes. Vaisala
Inc. is a private company that operates a national lightning detection
network and publishes flash density maps showing the locations and
frequency of lightning. 8 We used this data to select locations for 12
additional interviews with field officials at GSA, VHA, and USPS, as well
as officials from DOD's military services-the Army, the Navy, and the Air
Force. We conducted 6 of the 12 interviews with officials in areas that
have the highest incidences of lightning strikes according to Vaisala
Inc.'s data. 9 The other six interviews were conducted with field
officials in areas that experience fewer lightning strikes. 10 Finally, we
spoke with officials from NFPA, UL, 11 the Lightning Protection Institute,
and various lightning protection system manufacturers and installers to
obtain, among other information, their views on lightning protection
standards.
8 Vaisala Inc. operates a system of approximately 100 sensors throughout
the United States to detect and track lightning strikes. Its parent
company is headquartered in Finland. 9 We identified locations with the
highest incidences of lightning (nine or more lightning strikes per square
kilometer per year) using Vaisala Inc.'s 1996-2000 flash density map, as
of December 31, 2000. These areas generally include states in the
Southeast region of the country, such as Florida, Alabama, and Louisiana.
10 According to Vaisala Inc.'s 1996-2000 flash density map, these areas,
which include the states of Texas, Arkansas, and West Virginia, had fewer
than nine strikes per square kilometer per year. 11 According to UL, it
has been testing and certifying lightning protection equipment since 1908.
For a fee, UL issues certificates of conformance for systems, inspects
system components, and checks completed installations. Installations are
required to comply with UL's standards for lightning protection systems.
Copies of this letter are being sent to interested congressional members,
the Secretaries of DOD and VHA, the Administrators of GSA and NOAA, and
the Postmaster General. We will also make copies available to others upon
request. In addition, the report will be available at no charge on the GAO
Web site at http://www.gao.gov. If you or your staff members have any
questions about this report, please contact me at [email protected] or at
(202) 512-2834. Key contributors to this assignment were Tamera L.
Dorland, Steve Martinez, Kathleen
J. Turner, and Dale M. Yuge.
Director, Physical Infrastructure Team Enclosure
Lightning Protection Systems for Federal Buildings
Lightning Protection Systems for Federal Buildings
Briefing for Representative Robert E. Andrews and Representative Steven C.
LaTourette April 29, 2005
o According to the Lightning Protection Institute,1 lightning kills
nearly one hundred people every year in the United States, injures
hundreds of others, and causes billions of dollars in property damage,
often resulting in fire and total property loss.
o To help protect people and property, the National Fire Protection
Association (NFPA) first adopted specifications for installing
lightning protection systems on buildings in 1904. Those
specifications have evolved over time and are now referred to as
NFPA-780, Standard for the Installation of Lightning Protection
Systems. The most recent version of the document was approved by the
American National Standards Institute in August 2004.2
1 The Lightning Protection Institute is a nationwide not-for-profit
organization. According to the Institute, it seeks to promote and enforce
quality and safety in the design and installation of lightning protection
systems.
2 The American National Standards Institute is a private, nonprofit
organization that accredits the procedures of organizations that develop
standards.
o To help architects, engineers, and others decide whether their
commercial, industrial, farm, institutional, or residential buildings
(ordinary buildings) need protection from lightning,3 NFPA-780 also
provides a methodology for determining whether a building is at risk
from lightning and for deciding whether lightning protection should be
installed.
o Other standards related to the installation of lightning protection
systems augment NFPA-780, including standards developed by (1) the
Underwriters Laboratories Inc. (UL) and (2) federal agencies with
special needs, such as
buildings that house munitions and explosives (non-ordinary buildings).
3 A
lightning protection system helps protect a building from lightning by
redirecting the energy through the system and away from a building's
structure.
You asked us to determine
o to what extent selected federal agencies use applicable lightning
protection standard(s) to help protect buildings they own from
lightning strikes;
o how selected federal agencies assess the need for lightning protection
systems on their buildings;
o what practices and lightning protection standard(s) the General
Services Administration uses when leasing privately owned buildings;
and
o what data exists related to the financial impact of lightning
protection and damage to the federal government, such as the number of
buildings with lightning protection systems, the costs associated with
installing lightning protection systems, and the costs to repair
buildings struck by lightning.
o To satisfy the objectives of our engagement, we interviewed
headquarters officials from the General Services Administration (GSA),
the Veterans Health Administration (VHA), the U.S. Postal Service
(USPS), and the Department of Defense (DOD). These four agencies hold
over 80 percent (square footage) of the government's owned and leased
property.4
o We obtained and reviewed the agencies' standards and policies for
assessing the need for and installing lightning protection systems on
their ordinary buildings, information about requirements for leasing
ordinary buildings, and available data on the financial impact to the
government.
4 For purposes of this presentation, we use the term "agency" to include
all four federal entities.
o We also contacted officials from the National Oceanic and Atmospheric
Administration (NOAA) and Vaisala Inc. to obtain data on the frequency and
location of lightning strikes. Vaisala Inc. is a private company that
operates a national lightning detection network and publishes flash
density maps showing the locations and frequency of lightning.5 We used
this data to select locations for 12 additional interviews with field
officials at GSA, VHA, and USPS, as well as officials from DOD's military
services-the Army, the Navy, and the Air Force.
5 Vaisala Inc. operates a system of approximately 100 sensors throughout
the United States to detect and track lightning strikes. Its parent
company is headquartered in Finland.
Enclosure I
o Six of the twelve interviews were conducted with officials in areas
that have the highest incidences of lightning strikes according to Vaisala
Inc.'s data.6 The other six interviews were conducted with field officials
in areas that experience fewer lightning strikes.7
6 We identified locations with the highest incidences of lightning (nine
or more lightning strikes per square kilometer per year) using Vaisala
Inc.'s 1996-2000 flash density map, as of December 31, 2000. These areas
generally include states in the Southeast region of the country, such as
Florida, Alabama, and Louisiana.
7According to Vaisala Inc.'s 1996-2000 flash density map, these areas,
which include the states of Texas, Arkansas, and West Virginia, had fewer
than nine strikes per square kilometer per year.
o Finally, we spoke with officials from the NFPA, UL,8 the Lightning
Protection Institute, and various lightning protection system
manufacturers and installers to obtain, among other information, their
views on lightning protection standards. We conducted our work from
December 2004 through April 2005 in accordance with generally accepted
government auditing standards.
8 According to UL, it has been testing and certifying lightning protection
equipment since 1908. For a fee, UL issues certificates of conformance for
systems, inspects system components, and checks completed installations.
Installations are required to comply with UL's standards for lightning
protection systems.
o When decisions are made to install lightning protection systems, all
of the selected agencies require the systems to be installed in
accordance with NFPA-780-the standard approved by the American
National Standards Institute.
o The policies of all of the agencies also explicitly require that the
materials and installation comply with standards in UL 96 and/or UL
96A, respectively.9 These standards contain requirements, such as the
use of certified installers, which help ensure that NFPA-780 is
followed and that the lightning protection
systems will operate as intended.
9 GSA recently revised its policy to require the use of UL 96. Its prior
policy was not explicit on this point; however, GSA officials told us that
the agency followed UL 96 and UL 96A, as appropriate.
o In addition to NFPA-780 and UL standards, some organizations also
require adherence to more stringent standards, such as military
standards applicable to explosive manufacturing and storage
facilities.
o When designing new buildings or renovating existing ones, three of the
six organizations-USPS, VHA, and DOD's Navy-specifically require the
use of NFPA-780's risk assessment and decision-making methodology for
deciding whether to install a lightning protection system. To
calculate whether a lightning protection system should be installed,
the methodology assesses risk using several variables, such as (1) the
value of a building's contents, (2) the type and size of the building,
(3) the number of occupants in the building, and
(4) the frequency of lightning strikes in the building's area.10 If the
estimated lightning risk exceeds an accepted (tolerable) level of risk,
NFPA-780 recommends the installation of a lightning protection system.
10 NFPA-780's risk assessment and decision-making methodology does not
explicitly include cost as suggested by guidance from the Office of
Management and Budget. However, our analysis indicates that cost may be
implicitly considered, since the installation of lightning protection
systems is not recommended at all locations where lightning risk exists.
o Until recently, GSA did not explicitly require the preparation of
lightning risk assessments. However, GSA officials told us that, in
practice, the agency routinely required architects and engineers to
use NFPA-780's risk assessment and decision-making methodology when
designing or renovating buildings. The agency's new policy, effective
April 1, 2005, states that "the decision to recommend a lightning
protection system shall be made at the earliest stages of design and
shall be supported by a study as prescribed by NFPA-780."
o While the Army and the Air Force do not currently follow NFPA-780's
risk assessment and decision-making methodology, they have identified
related variables for assessing risk and making decisions to install
lightning protection systems when designing new buildings or
renovating existing ones. Specifically, their current guidance
requires installing a lightning protection system on a building if the
frequency of lightning is more than five thunderstorms per year and if
the building (1) is 50 feet or higher; (2) has four stories with
elevators, stairwell penthouses, or other similar projections above
the roof; or (3) has five or more floors with or without projections.
Other factors, such as whether the building is occupied or has
valuable contents, may also be considered.
o The three military services, as part of DOD's Unified Facilities
Criteria Development Program, are working on developing consistent
guidance across the services. A draft of that guidance mandates the
use of NFPA-780's risk assessment and decision-making methodology and
allows each service to consider additional factors, such as whether
the building is mission critical and whether the value of the
building's contents is significant. According to DOD, a final draft of
this new guidance is expected late this fall.
o Because NFPA-780 and its risk assessment methodology continue to
evolve, agency officials told us that existing buildings, especially
older ones, may not have current lightning protection systems. As a
result, they said their agencies routinely upgrade buildings in
accordance with all current codes and standards when they renovate
them. Even when they are not renovating, agency officials told us that
they often add lightning protection systems to older buildings that
contain mission critical equipment.
o GSA leases buildings for its use and for most federal agencies.
According to GSA officials, its lease agreements with private building
owners do not require buildings to have lightning protection systems.
However, its lease agreements do require building owners to conform to
all applicable state and local building codes, including those
concerning the installation of lightning protection systems, where
required. Unlike federally owned facilities, any costs to repair
federally leased properties struck by lightning are the responsibility
of the building owner.
* In some circumstances, GSA enters into a "design/build"
arrangement with private companies with the intent of leasing
back a building. We were told by agency officials that, in such
cases, GSA requires the buildings to be designed and constructed
in accordance with federal standards, including those concerning
the installation of lightning protection systems, where required.
* Data exist, but they are outdated, unreliable, or
incomplete.
o Industry data exist on the financial impact of
lightning, but they are outdated and not specific to
the federal government.
o NOAA collects data on fatalities, injuries,
casualties, and damages due to lightning strikes;
however, the data are not specific to the federal
government. Moreover, NOAA acknowledged that the
data are often unreliable and incomplete because the
agency's personnel are unaware of all the incidences
of lightning. As a result, a number of incidences
are never documented.
o GSA compiles information on federal properties and
publishes a worldwide inventory of federal
properties, which includes information about the
physical characteristics and value of each property.
However, GSA does not currently collect information
about the number of buildings with lightning
protection systems.
* All four agencies we reviewed do not collect data on,
among other things,
* (1) the number of buildings with lightning protection
systems, (2) the costs associated with installing
lightning protection systems, and (3) the costs to repair
buildings struck by lightning.
o Local agency officials also do not collect this data and,
although they maintain information such as building
maintenance records, the information is incomplete and not
readily available.
o According to agency officials, agencies do not specifically
maintain or track data related to lightning strikes because
such strikes are rare and, consequently, not a problem.
o We spoke to over 50 agency officials, at headquarters and field
locations, who are responsible for thousands of federal buildings, and
determined that none of them views lightning as a significant concern
at their facilities. In fact, none of these officials could recall any
major consequences associated with lightning strikes to their
buildings. They said that, where lightning struck, the majority of the
damage occurred to the buildings' electrical systems-not the
buildings' structures.11 According to the officials, natural disasters
such as hurricanes and tornadoes cause far greater damage and are of
much more concern than lightning.
11 Lightning protection systems help protect a building's structure. Such
systems, however, are not intended to protect a building's electrical
systems when lightning strikes in the building's vicinity. Additional
measures are needed to protect electrical systems from power surges
associated with these strikes.
o While all of the agencies reported that lightning strikes to their
buildings were rare or nonexistent, officials in 6 of the 12 field
locations we contacted provided anecdotal information about lightning
incidents. The officials identified 20 possible lightning strikes
associated with their buildings over the last 10 or more years.12
According to the officials, the total cost of repairs was about $636,000,
and ranged from $300 to repair a roof at a GSA facility to $207,000 to
replace a fire alarm system at a postal facility. No deaths or injuries
were reported.
12 Based on available information, some of the 20 incidents appear to have
been caused by electricity spikes to electrical systems rather than by
direct lightning strikes to buildings.
o We provided a draft of this presentation to each of the four agencies
for their review and comment. We also provided NOAA with applicable
excerpts from the draft. All four agencies agreed with our findings. GSA,
DOD, and NOAA provided minor technical comments, which we incorporated as
appropriate.
(543116)
(543131)
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