The Singularity of Italian Fire Safety Regulations for Historic Buildings

The historical heritage of buildings in Italy is extremely vast and, in addition to the most famous ones, includes the historic centers of thousands of cities and towns. In addition to the famous ones, there are buildings that are not only open to tourists, but are also used for schools, universities, and even host activities of particular complexity for fire safety such as hospitals and commercial activities.

Given the large number of these buildings, it is necessary to have a standard that provides uniform provisions but is flexible enough to allow the required level of safety to be achieved in the event of a fire. To achieve this ambitious goal, in 2015 the Ministry of the Interior – National Fire Brigade developed a coordinated set of technical standards, the “Fire Prevention Code”, also published in 2020 in English (the most updated version in Italian, at the date of this post, was published in 2022).

The regulatory complex of the Fire Prevention Code, which cannot be classified as either prescriptive or performance-based, provide a general framework for the risk assessment process – definition of safety strategies and selection of measures (horizontal rules) – together with specific measures for individual classes of activities (vertical rules), among which also historic buildings appear.

Using the nomenclature adopted by the Code, there are “vertical” technical rules for historic buildings, aiming to balance the preservation of cultural heritage with fire safety. In the specific case, vertical rules are Chapter V.10, which focuses on museums, galleries, exhibitions, shows, libraries and archives in listed buildings, while Chapter V.12 covers other activities in listed buildings, excluding the categories listed in Chapter V.10. However, there are some common measures.

Common Provisions for Historic Buildings

• Reaction to fire: Verification of reaction to fire requirements is not required for listed assets, including historic furnishings. However, in escape routes of activities with high risks, listed assets must meet reaction to fire requirements.
• Fire resistance: If compliance with the required fire resistance class is not possible due to the nature of the building, additional requirements are required, such as a low specific fire load (qf,d < 200 MJ/m²) and a level III fire safety management system.
• Exits: Compliant solutions are permitted with additional conditions, such as the use of materials with low reaction to fire in escape routes and enhanced emergency lighting in critical areas. Doors of historical-artistic interest that do not meet the safety requirements may be kept open during the operation of the activity.
• Fire safety management: In addition to compliant solutions, additional requirements are required, including frequent evacuation tests and a damage limitation plan.
• Fire control: When determining the specific fire load, it is possible not to consider the contribution of combustible structural elements and protected assets. The choice of extinguishing agents must consider their compatibility with the protected assets.
• Detection and alarm systems: For listed buildings with other activities (Chapter V.12) a performance level IV for detection and alarm is required.
• Smoke and heat control systems: Similar to fire control, the contribution of combustible structural elements and listed assets may be excluded in the calculation of the specific fire load.

Specific provisions for Museums, Galleries, etc.:

• Compartmentation: Exhibition areas and storage areas must not be located at heights lower than -5 m. Multi-storey compartmentation may be up to 18 m in height, instead of the standard 12 m, to suit the characteristics of listed buildings.
• Damage limitation plan: The person responsible for the activity must draw up a detailed plan for the protection of the building and listed assets in the event of a fire.

In summary, the vertical technical rules for listed buildings offer a balanced approach that recognises the unique challenges in protecting these buildings. The provisions allow for some flexibility in the application of fire safety measures, whilst maintaining an acceptable level of safety.

Fire safety strategies

The Code defines a fire strategy as a combination of fire measures aimed at achieving fire safety objectives. These primary objectives are the safety of human life, the safety of people and the protection of property and the environment. To achieve these objectives, the Code proposes three types of design solutions: compliant solutions, alternative solutions and derogation solutions.

Compliant solutions:

• These are prescriptive design solutions that do not require further technical assessments.
• They guarantee the achievement of the required performance level without the need for further demonstration by the designer.
• They are described in the relevant sections of the Fire Strategy and the vertical technical rules.

Alternative solutions:

• They offer alternatives to the compliant solutions, allowing the designer to adapt the design to the specific needs of the activity.
• They require the designer to demonstrate the achievement of the linked performance level, using one of the permitted fire safety design methods.
• They can be proposed in the relevant sections of the Fire Strategy and the vertical technical rules, or the designer can propose specific alternative solutions.
• They are only allowed in activities with project evaluation, so that the National Fire Brigade Corps can evaluate the demonstration.

Derogation solutions:

• These are design solutions for which the activation of the derogation procedure is required, as provided for by current legislation.
• They apply when it is not possible to effectively apply either the compliant solutions or the alternative solutions.
• They require the designer to demonstrate the achievement of the relevant fire prevention objectives, using one of the fire safety design methods.
• Any provision of the Code, including those defined in the vertical technical rules, can be subject to a derogation procedure.

The choice of the most suitable design solution depends on several factors, including the complexity of the activity, the required performance levels and the specific characteristics of the building. The fire protection designer is responsible for evaluating the different options and selecting the solution that guarantees the best balance between fire safety and functional and economic needs.

The vertical technical rules for historic buildings offer a balanced approach that takes into account the unique challenges in protecting these buildings. The provisions allow for some flexibility in the application of fire safety measures, whilst maintaining an acceptable level of safety.

Performance level and compliant solution

The Code defines the concepts of “performance level” and “compliant solution” as follows:

Performance requirement. It is an objective specification of the performance required of the activity to implement the fire safety measure. In practice, the performance level defines the degree of safety that a specific fire safety measure must guarantee. The Code provides different performance levels for each measure, graded according to the increasing complexity of the expected performances and identified by Roman numerals (e.g. I, II, III, …).

Deemed to satisfy provision. It is a design solution for immediate application in the specified cases, which guarantees the achievement of the related performance level. In other words, a compliant solution is a prescriptive design solution that does not require further technical assessments to demonstrate that it satisfies the required performance level. Compliant solutions are presented in the Code as standard solutions that can be applied in a simple and direct way.

Here are some key points to consider:

• Relationship between performance level and compliant solution: The performance level defines the safety objective, while the compliant solution provides a specific way to achieve that objective.
• Design flexibility: The Code allows designers to use alternative solutions to compliant ones, provided they can demonstrate that the required performance level is achieved.
• Importance of compliant solutions: Compliant solutions provide a simplified approach to fire design, providing a basic level of safety without the need for complex engineering analysis.

The performance level sets the safety standard, while the compliant solution provides a practical and proven method of meeting that standard.

Fire Protection Grade

The Code does not impose any minimum performance requirements for the load-bearing capacity of structures in the event of fire or for internal compartmentation of the building work. In other words, for Performance Level I, no specific fire resistance class is required. However, it is important to note that this does not mean that fire resistance is completely ignored. Even with Performance Level I, some fire resistance measures may be necessary, for example:

• Separation distance: For Performance Level I, a separation distance in open space between the building work and other structures is required to limit the spread of fire.
• Specific assessments: Although there is no minimum fire resistance class required, the designer may need to carry out more in-depth assessments to ensure safety in the event of a fire, especially if the activity presents particular risks.

Furthermore, it is essential to remember that performance level I for fire resistance is not allowed for all activities. The specific criteria for assigning performance levels are detailed in Table S.2-2 of the document.

Finally, historic buildings may have specific requirement for fire resistance, even if performance level I is applied. For example, if compliance with the required fire resistance class is impossible due to the nature of the building, additional requirements are required, such as a low specific fire load and a level III fire safety management system.

Evacuation measures

The Code defines two performance levels for escape, described in Chapter S.4.
Performance level I. The objective of the level is that occupants reach a safe place before the fire causes incapacitating conditions in the areas of activity crossed during the escape. This performance level represents the ideal scenario, where all occupants are able to evacuate the building safely before the fire reaches a level that puts their health at risk.
Performance level II. The objective of the level is that occupants are protected from the effects of the fire at their location. This performance level applies in situations where immediate evacuation is not possible or safe. In these cases, occupants must be protected from the effects of the fire at their location, for example in a refuge area.
The Code does not define a third performance level for escape.
It is important to note that the Code mentions several types of escape, including:
• Simultaneous escape: all occupants evacuate at the same time.
• Phased evacuation: Evacuation occurs in successive phases, involving different groups of occupants at different times.
• Progressive horizontal evacuation: Evacuation occurs by moving occupants to a safe compartment on the same floor.
• In-place protection: Occupants remain in a protected area within the building.
The choice of performance level and type of evacuation depends on the specific characteristics of the activity and the results of the fire risk assessment.

Conclusions

The previous Italian regulations on fire safety in historic buildings were aimed almost exclusively at protecting the safety of the occupants. Given the objective difficulty of establishing common safety measures, caused by the heterogeneity of the problems to be addressed, the purely prescriptive approach could not go beyond such safety objective.
The new approach has the merit of separating the phases of evaluation and choice of measures, allowing designers to choose between different measures but imposing the adoption of prevention and protection measures. For this reason, it can be considered that the new approach, for historic buildings, constitutes a step forward.