Fire prevention project
Category B and C activities require that a fire prevention project be drawn up, signed by a qualified technician, to be submitted to the prior assessment of the local competent Fire Brigade Command (Article 3 of Presidential Decree No. 151/2011).
Activities that cannot guarantee full compliance with technical fire prevention rules, must submit a specific exemption request to the territorially competent Fire Brigade Command (art. 7 of Presidential Decree 151/2011), in compliance with Ministerial Decree 07.08.2012, possibly resorting to the ESF. For many activities falling within the scope of the Ministerial Decree 03.08.2015, the use of the “derogation” was fortunately limited, since it was possible to use the so-called “alternative” solutions already in the planning phase.
Feasibility Clearance (NOF)
The managers of the “subject activities” of categories B and C, can request the Command for a preliminary examination of the feasibility of particularly complex projects, in order to release the feasibility clearance. This service is always used by the Firm, before undertaking complex design activities with the use of the ESF (for example to “fix” fire scenarios before quantitative processing with CFD or zone models).
To be authorized for firefighting purposes, the activities subject to the VVF control must file the S.C.I.A. (art. 4 DPR n. 151/2011). The service is certainly very “delicate” and the technician authorized by the customer to certify fire safety must have organizational and multi-disciplinary experience. He certainly assumes a primary position of “guarantee” of fire safety and, in the event of a fire, he can be sued.
The fire prevention file that he prepares (Ministerial Decree 07.08.2012) and that he delivers to the business owner must be “complete” and contain:
- structural fire resistance certifications (CERT.REI-2018 and annexes, such as: technical reports of analytical assessment, declarations of correct installation of companies, classification reports, report assessments, technical files, etc.)
- product-related declarations (DEC.PROD-2018 and annexes, such as: declaration of correct installation, declarations of conformity of TF, DoP doors, etc.)
- projects, declarations of conformity (DI.CO.), plant test reports, use and maintenance manuals for the plants
- any Certifications of systems by firefighting professionals (CERT.IMP-2018, with attachments)
- explosion protection document (title XI of Legislative Decree 81/2008) for activities with risk of explosion
- self-protection technical report of the activity from lightning (CEI EN 62305-2), for activities not protected against atmospheric discharges
Activities authorized for firefighting purposes must be subject to renewal of firefighting compliance, at least every five years (art. 5 DPR 151/2011). The renewal request is not a mere declaration of the owner of the activity, with purely administrative value. It is a real opportunity to check “in depth” the full correspondence of the activity with respect to the project commitment approved previously by the Fire Brigade and the technical documentation accompanied by the SCIA.
If “substantial changes” have been made for firefighting purposes, it must be checked that they have not entailed an increase in the fire risk and:
- in the event of an increase, submit a new project and a subsequent SCIA
- in case of absence of burden, submit a new SCIA, accompanied by a non-burden assessment of the fire risk, signed by a firefighting professional.