UL 864 10th ed 38.1.4 point/zone transmission requirement -- is this an _equipment_ requirement or a _system functionality_ requirement?

According to Intertek in their Standard Update Notice for UL 864 10th Edition, 38.1.4 in UL 864 now requires that

Transmitted alarm signals to the supervising station proposed to have minimum capability of actuated device address or zone identification.

based on the following normative text:

38.1.4 Alarm signals transmitted to the supervising station shall have the capability of including the actuated device address or the zone identification.

However, the inclusion of this requirement in UL 864, without any corresponding change I’ve been able to find to NFPA 72, NFPA 101, or the I-Codes, has left me with several questions:

  1. Is this a requirement imposed on installed fire alarm systems, or just on on fire alarm equipment (aka panels & communicators)? I ask because it’s possible for a system to have a panel that can report points or zones, and a communicator that can accept point/zone reports, but they are not wired to use that capability in practice, limiting the overall system to global alarm/supervisory/trouble reporting.

  2. If it is a systems requirement, where are the corresponding requirements in NFPA 72, NFPA 101, or the I-Codes that point/zone reporting capability actually be utilized? As I’ve indicated above, I have not been able to find them, so I would greatly appreciate chapter-and-verse citations that I can follow up on.

  3. If it is a systems requirement, does it apply to all communication paths, just the primary path, or…? One could imagine a system that can communicate point/zone information via one path (say IP or a DACT on a phone line) but not the other (say a cellular communicator connected via the panel’s relays or a city tie connection). (An example of such a system would be a Potter AFC-50 paired with a Honeywell CLSS communicator, using the CLSS as the primary path via discrete relays and IP/Ethernet directly from the panel as the backup path in case cell signal is lost.)

  4. If it is a systems requirement, and it is not mentioned/pulled in by NFPA 72, NFPA 101, or any of the I-Codes, then how is one supposed to know if they need to design their system to conform to this requirement, short of an explicit published bulletin or interpretation from the local AHJ/fire marshal saying so?

I ask all this because the Alula BAT-FIRE’s installation guide states that you can’t use the discrete inputs on it to monitor a multi-zone fire panel when UL864 10th edition conformance is needed, but it’s not at all clear when that’s even needed in the first place or when that manual language should be applied. Furthermore, many low-end panels (such as the Potter AFC-50 and Kidde FX-5s and 10s) don’t ship with a DACT in the base configuration, while most cellular communicators can only accept point/zone information via dial capture.

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Small update: I spoke with a Code reviewer at the state fire marshal’s office for my home state, and he was able to partially point me in the right direction on this.

The answer to this question, best I can tell, lies in the references sections of the model Codes. NFPA 72 up through 2016 permits 9th edition equipment, while 2019 and newer editions require 10th edition equipment, and from there we can determine that locations on 2021 or newer IBC/IFC reference a new enough edition of NFPA 72 to require 10th edition conformance, at least in theory.

It still doesn’t answer my questions about how this requirement applies to systems ITFP, though…

So, I found the answer to this question. As of 2025, NFPA 72 itself does not require the use of point/zone transmission:

26.6.1.2 The minimum signaling requirement shall be an alarm signal, trouble signal, and
supervisory signal, where used.

So, while UL 864 10th edition makes it so that a fire panel that lacks a dialer, serial port, network or cellular communicator, or support for additional relays cannot be listed to 10th edition, and likewise for communicators that do not support dialer capture, serial input, or expanded zone inputs, there is no requirement that an installed system must support the transmission of point or zone information, unless an AHJ amends their local Codes to say so.