The approval names a different end use: does it count?

In short. An approval covers a prototype tested in a laboratory, and for an upholstered item that prototype is the composite: frame, filling and cover together. The question to ask is not whether the document is valid, but whether it describes what was delivered. A different colour or pattern does not touch it; a change of cover, filling or frame does.

What does an approval actually certify?

The Italian ministerial decree of 26 June 1984 calls omologazione — approval — the "technical and administrative procedure by which the prototype of a material is tested, its reaction-to-fire class certified, and the Ministry of the Interior issues the authorisation to reproduce that prototype before the material is placed on the market".

One word in that sentence matters more than the others: prototype. What is approved is not a commercial name and not a drawing. It is a physical specimen tested in a laboratory, and everything that follows is permission to reproduce it.

For an upholstered item, the specimen is not the fabric. It is the composite: frame, filling and cover tested together under UNI 9175, reaction to fire of upholstered furniture subjected to a small flame. That test produces the classes 1 IM — the best — 2 IM and 3 IM, plus the condition of not classifiable. A certificate covering only the cloth says nothing about the composite: it is one step along the way, not the destination. The same logic underpins our guide on when Class 1 IM is required in hotels.

Why end use is part of the classification

This is the heart of the question. The same decree, in article 2, defines a material as "the component (or the variously associated components) that may take part in combustion depending on its chemical nature and on the actual conditions of installation for use". Circular no. 17 MI.SA of 16 April 1987 restated the point: that definition "refers expressly to the actual conditions of installation and of use".

Which means the class is not a property the material carries everywhere. It is the outcome of a test performed on a material under given conditions. Change the conditions and, in the eyes of the rule, you have another material — not a worse one, another one.

That is why the question is better asked the other way round. Not "is this document valid?", but "does this document describe what was delivered to me?" If it does, it holds. If it describes something else, no stamp makes it hold.

Which differences do not void it

Not every discrepancy counts, and some can be set aside at once.

• Colour and pattern. Circular no. 27 MI.SA of 21 September 1985 makes clear that an approval certificate is valid also for products whose apparent characteristics differ, limited to colour or pattern. A cover of the same construction in another shade needs no new test.
• Finishes of residual extent. Circular no. 1/2016 of the Fire Brigade Department, protocol 2307 of 24 February 2016, allows finishing materials different from those of the tested composite "provided they are residual in character, that is, they account for no more than 10% of the total surface". A braid, a contrast edge, a leather trim fall inside that figure.
• The model name and the order code. What has to match are the reference details of the act and the composition of the composite.
• Subsequent deliveries. The approval authorises reproduction; each delivery comes with the manufacturer's declaration of conformity, attesting that the material conforms to the approved prototype and carrying the approval's reference details.

Which differences void it

Three cases, and they are clear-cut.

A modification to the product. An approval is valid for five years, renewable on the manufacturer's application, and lapses automatically if the product undergoes any modification whatsoever. The tested prototype and the delivered piece have to be the same thing.

A different cover beyond colour. Changing the family of the fabric, moving from a textile to a leather, changing the filling: each is a modification of the composite, and the composite was what was tested. On choosing a cover, and on what changes from one leather to another, there is a guide of its own.

Expiry. Five years from the act. An expired approval does not become false; it becomes unusable.

"I have the approval for another model in the same range"

This is the most common case, and the most slippery: the document is genuine and the supplier acts in good faith. Three questions close it within half a day.

• What are the reference details of the act relating to this model.
• What is the composition of the tested composite, line by line: frame, filling, cover.
• Is there a declaration of conformity made out to this delivery.

If the answer to the first is that the act covers a different composite, the way forward is not to argue: it is to ask whether an approval exists that covers this one, or else to schedule the test. There is time for that only if the question is raised early, which is one reason a hotel supply calendar is counted backwards from the opening date.

In a hotel: what is required and what is not

The ministerial decree of 9 April 1994 requires upholstered furniture and mattresses to be Class 1 IM for reaction to fire. The Department's note, protocol P119/4122/1 sott. 3 of 23 February 2000, recalled this in answer to a query on exactly this point.

The same note sets the boundary, and the boundary is as useful as the duty: for materials not comparable to upholstered furniture or mattresses — pillows, bed bases, bed linen, quilts — proof of Class 1 IM is not required, but their combustible contribution is to be assessed within the overall fire load of the room. Rugs, pictures and the like, says another note from the same Department, protocol P226/4122/1 sott. 3 of 10 May 2001, "do not fall among the materials subject to the classification requirement for reaction to fire".

Knowing where the duty ends avoids two opposite mistakes: demanding certificates nobody has to produce, and forgetting that those materials still weigh on the fire load.

What to do when the document and the delivery do not match

• Put the two texts side by side: the composition described in the act and the composition in the order. Not the name — the composition.
• Isolate the discrepancy. Colour or pattern, a residual finish within ten per cent, or a change of cover, filling or frame.
• Check the date. Five years from the act, with the delivery inside that window.
• Ask for the declaration of conformity made out to this delivery, carrying the approval's reference details.

If the discrepancy is real, choose early among three routes: an already approved composite that matches, a new test on the composite specified, or a change to the design. All three are manageable, provided the question arrives before production.

And if the project is outside Italy?

The United Kingdom reasons in hazard levels rather than classes. BS 7176:2007+A1:2011 sets four hazard categories and, for upholstered hotel seating, the category indicated is the intermediate one, medium hazard. The tests called up are the match flame, the smouldering cigarette and ignition source 5 — widely known as crib 5 — specified in section 11 of BS 5852:2006.

The principle, however, is the same: what has to comply is the composite, cover and filling together, not the fabric alone. A surface treatment applied afterwards does not make a non-compliant composite compliant.

How we work

An approved prototype holds only as long as the composite stays the one that was tested: the same frame, the same foam, the same cover. Working frames, timber and filling in our own factory is what makes it possible to know, piece by piece, which prototype a finished item corresponds to.

So when a specification calls for a composite that is not among those already approved, the useful thing is to say so at once and put the three possible routes on the table with the lead time of each, instead of discovering the discrepancy when the documentation is handed over.

Frequently asked questions

Is a Class 1 certificate for the fabric enough for a sofa?

No. For an upholstered item the test applies to the composite, under UNI 9175. A fabric certificate is a useful document for whoever builds the composite, not a substitute for the composite's own approval.

If the cover is better than the one tested, does the approval still hold?

No. The approval covers the prototype that was tested. Any difference other than colour or pattern, or a finish beyond the residual ten per cent threshold, is a modification of the composite.

How long does an approval last?

Five years, renewable on the manufacturer's application. It lapses automatically if the product undergoes any modification whatsoever.

Who keeps the documents, the supplier or the client?

The manufacturer issues the declaration of conformity to the approved prototype with the delivery; the operator of the premises keeps it with the fire-safety file.

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The standards, classes and decrees cited on this page are verified at source and remain general guidance: the requirement that applies is the one in the approved fire safety design, to be read together with whoever signed it.