Fire prevention planning is carried out to ensure people’s safety in the event of fire. Italian Presidential Decree 151 of 2011 regulates this area, it is a regulation of the Interior Ministry published in the Official Journal on 22 September of the same year.
Ratio legis and scope of application
The regulation defines the activities subject to control by the National Fire Brigade (“VVF”). The aim of the regulation is to make the Fire Brigade’s activities in terms of checks and inspections more efficient, while making the company – the owner and the fire prevention specialist – responsible for the implementation of a correct fire prevention system in the workplace.
The activities subject to the regulation, according to Annex I of Presidential Decree 151/2011, are organised into three groups (A, B, C) and are regulated by specific vertical rules referred to in the same Presidential Decree 151/2011.
Changes introduced with DPR 151/2011
The main development introduced with DPR 151/2011 is the simplification of procedural requirements for category A, B and C businesses according to a principle of proportionality – procedures are diversified according to the company’s size, activities and sector.
To give more detail, this means all category A businesses do not need to obtain the Fire Department’s opinion as a mandatory requirement. The correct implementation of a fire-fighting system is the responsibility of the owner, who is supported by competent figures such as a qualified technician and a fire prevention consultant “818”. These companies are no longer obliged to obtain certified permission from the fire brigade, such as the Fire Prevention Certificate “CPI”. When companies in category A begin their activities, they prepare the document referred to as “SCIA” Certified Declaration of the Start of Activities).
Businesses in categories B and C need to follow different procedures: in this case it is compulsory to deliver a fire prevention plan to the National Fire Brigade in order to obtain a positive or negative opinion, implementing any corrective measures indicated by the Fire Brigade. The process ends when a compliance report is issued, at this point the companies may begin operations.
Key points for the application of the regulations
To ensure correct application of the legislation, it is important to pay attention to the following points.
– Identify the category into which company activities fall, and the interconnection between one type of activity and another, seeking an appropriate compromise in the event of collision between different vertical standards.
– Incorporate fire prevention planning into the timing and design of workplaces and related facilities. Retrofitting the structure to make it compliant with fire safety regulations would be much more costly than integrated ex ante planning.
– Compliance with deadlines for renewing the “SCIA” and all the documentation that certifies conformity with fire prevention regulations. This applies at all times, but must be remembered in particular when substantial changes are made to the structure or the systems installed which are relevant to fire safety. In such cases, the procedures are the same as those followed for a new project. Failure to fulfil the obligations may also impact insurance policies.
Many of the vertical standards are outdated and no longer reflect the actual conditions in which companies operate: when this is this case, simply following the indications in the legislation is not sufficient. PLS’s best practices support companies in this direction, ensuring that planning is consistent with fire safety requirements, going further than the regulations
Activities
A critically sensitive area like fire safety requires a competent professional expert, one who is listed in the Interior Ministry’s register, one who has full, in-depth knowledge of the applicable regulations, one who can oversee every detail related to this aspect of workplace safety. This professional needs to be able to understand the types of responsibility, the planning options and the repercussions in the choice of risk category into which the building falls, or will fall, on the basis of those envisaged in DPR 151 of 1 August 2011;
These choices may have implications, not only in terms of company compliance but also in terms of insurance or the protection of company assets.
It is often possible to find a solution even to the most complex issues by means of an accurate appraisal of design and planning stages, by checking the robustness of the technical data in the reports filed, or to be filed, with the competent authorities (the Fire Brigade), thanks to knowledge of vertical and horizontal standards regarding fire prevention, and of the performance of different materials (both innovative and more commonly used). These same skills also make it possible to suggest and define acceptable improvements in order to preserve assets and avoid liability for company managers in the framework of legislative decree 81/08, where the assessment of fire risks is concerned.
Our consultancy services also offer support with specific documentation, with particular reference to:
• Declaration of correct installation;
• Correct use of ministerial standards;
• Checking Test Reports/Approval Certificates of all products used;
• Correspondence between building floor plans and the equipment used;
• Effective conformity between the proposed fire engineering models and the company’s facilities as well as the expected scenarios;
• Checking that the documentation files are complete;
• Checking the documentation submitted to the authorities in relation to works, at the same time as the previous activities are concluded;
• Checking compliance with the requirements of the supervisory and inspection authorities;
• Checking expiry of the certification granted to the single activities that are subject to regulation.
The architectural layout of the building and its current and, where applicable, previous conformation in terms of the structure and the technical systems will also be carefully studied as part of the consultancy service. The intended uses of the structures will be checked, assessing any internal separations that are physically present or planned, and therefore any subdivisions, together with any other current or foreseeable company facilities within the buildings being evaluated, that may result in interference.
In the final planning phase, it may prove necessary to envisage certain civil construction works, such as the creation of new partitions (walls, cavities, etc.). These are executive activities to be assessed in detail together with the client company, taking advantage of the synergy between the PLS technical experts, a skilled team able to provide full support ranging from expertise in construction sites to safety in the workplace and compliance in the broadest possible sense.
From a practical point of view, the following are some of the phases for which support is provided:
1. An analysis of the existing situation, identification of the legal obligations, technical standards and special requirements for each individual activity;
2. Presentation of technical reports and documentation, discussion with the Client company taking in any indications/observations;
3. Reworking the solutions on the basis of the client company’s observations;
4. Preparation of the technical report in order to obtain approval of the Project Appraisal from the Fire Brigade with regard to the companies that are subject Fire Brigade inspection as per DPR 151 of 1 August 2011;
5. Preparation of the building floor plans to attach to the abovementioned technical report;
6. Where applicable, delivery of the Project Appraisal to the Provincial Fire Brigade Headquarters, where approval is required (categories B and C of DPR 151 of 1 August 2011);
7. Technical assistance for the entire duration of the preliminary evaluations by the Provincial Fire Brigade until the necessary certification “CPI” is obtained (for companies in category C support is also guaranteed during the inspection by the Fire Brigade);
8. Achievement of “CPI”/“SCIA” certification from the Fire Brigade.
In the case of Due Diligence, in order to ensure the fire safety assessment is complete and correct, an extensive report will be prepared at the end of the evaluation of the preliminary or executive project carried out by the PLS consultancy service, including:
1. A technical report;
2. Explanatory graphs and tables;
3. An evaluation of the photographic/illustrative materials;
4. Preparation of the technical specifications of the activities to be carried out;
5. An itemised bill of quantities;
6. Technical data sheets for the materials proposed or selected.
Fire prevention consultant “818”
A qualified fire prevention officer, this is a technical role achieved on the basis of the training programme envisaged in Italian Law n.7 818 of December 1984. Qualification is obtained on passing the relative examination and the holder is listed in the ministerial register. This officer is in charge of handling all the Fire Department dossiers for businesses classified under Presidential Decree 151 of 2011.
Main duties:
• Assess the potential hazard level of the company activities and verify whether they are subject to fire brigade inspection;
• Prepare the required documentation, including the Technical Report on Fire Prevention and the project document (if applicable);
• Submit the “SCIA” (Certified Declaration of the Start of Activities) to the Fire Department.
Fire Prevention “SCIA”: Certified Declaration of the Start of Activities
The adoption of appropriate fire prevention measures is implemented in the procedures and controls included in the documents that make up the “SCIA” (Certified Declaration of the Start of Activities).
More details on the “SCIA”
What is a SCIA? This document certifies compliance with fire regulations according to Italian Presidential Decree 151/2011 which regulates the procedures and technical solutions that must be adopted regarding fire prevention. It is mandatory for all categories of business activities (A, B and C) listed in Annex I of Italian Presidential Decree 151/2011. Proof of submission of the “SCIA” to the provincial fire brigade (directly or through the local one-stop business advisory office “SUAP”) is the authorisation for the company to carry out its activities where fire safety regulations are concerned.
Contents: it contains a series of documents, including: fire safety certification, fire resistance certification, declarations regarding products and the fire prevention system.
Who is responsible for preparing it? The person responsible for the company in question with the support of the qualified 818/84 fire prevention officer/consultant.
Legal framework: DPR 151/2011, articles 1, 4 and Annex I.
The aim of correct fire safety planning is to identify the most suitable and least invasive fire prevention measures and solutions, ensuring full compliance with the relative legislation, taking production requirements and the cost/benefit ratio of individual solutions into due account.