Is a test report enough, or is type approval required?

In short. For the upholstered furniture of a hotel a test report on its own is not enough: the technical rule calls for materials type-approved under the Italian decree of 26 June 1984, and type approval is an act of the Ministry which the test report precedes rather than replaces. Neither document, though, is what gets attached to the fire-safety filing: what gets attached is the technician's declaration of compliance, which has to cite those documents and keep them in the dossier.

The question, as the person signing puts it

On an Italian fire-engineering forum a consultant writes that he has to judge a colleague's work: in the filing for a hotel, for curtains and upholstered furniture, the colleague intends to attach a «test certification» or «test report» — the name changes with the laboratory — without the Ministry of the Interior's type approval certificate. And he adds the detail that decides the thread: one of those documents states that it «is not issued under Articles 8 to 10 of the decree of 26/06/1984». Can that be done? The only answer that arrives is a link to a collection of circulars, and the thread ends there.

Three documents that look alike, and are not the same thing

The decree of 26 June 1984 builds type approval in three steps, each with its own document.

• The test certificate, or test report. The maker sends the fire service's Centro Studi ed Esperienze, or a legally recognised laboratory, the application with the technical sheet; the laboratory tests the specimens and issues the certificate (Article 8.1). It says that those specimens, in that test, reached a class;
• The type approval certificate. With the technical sheet and that certificate the maker applies to the Ministry of the Interior (Article 8.2), which issues the authorisation to reproduce the prototype before the material is placed on the market (Article 8.3). Liability comes from the same line: the holder answers, civilly and criminally, for the conformity of production to the prototype;
• The mark, or the declaration of conformity. This is what travels with the piece, and by definition it carries the type approval references. The seller too must declare, under his own civil and criminal liability, that the material sold comes with it (Article 8.4).

They are not alternatives: they are stages of one route, and the test report is the first. On its own it authorises no production and binds nobody to reproduce that specimen, because it is not a title: it is the record of an experiment.

What the hotel rule actually requires

This is where the matter closes. The decree of 9 April 1994, at point 6.2, lists the classes room by room and at letter e) requires upholstered furniture and mattresses to be class 1 IM. Immediately after the list comes the line most specifications leave out: the materials referred to in the preceding letters must be type-approved under the ministerial decree of 26 June 1984. The only alternative allowed is attestation under Article 10, for named cases: materials already installed, those installed within one hundred and eighty days of the decree coming into force — a window that closed in 1994 — and the other cases provided for by that article.

Anyone designing under the Italian fire safety code finds no different rule. The chapter on reaction to fire says it in a single line: minimum requirements are verified under the decree of 10 March 2005 for construction products, and under the decree of 26 June 1984 for other materials. A sofa is not a construction product (here is why). So neither the date of the filing nor the choice between the two regulatory routes changes the answer: both arrive at the same decree.

What goes into the filing, and what stays in the dossier

There is a second misunderstanding, and it concerns where those documents belong. Attached to the filing is the qualified technician's asseveration, and attached to that the certifications and declarations of Annex II to the decree of 7 August 2012.

For products classified for reaction to fire the annex asks for one precise thing: a declaration that the materials used comply with the required performance, signed by the qualified technician in charge of the works — in the absence of that figure, by a fire-safety professional — showing the type, the commercial identification data and the location of the materials, including the type approval code or the number of the test or classification certificate or report, or the data relating to CE marking. It is the form published as PIN 2.3, Dich. Prod.

The product documents — declarations of conformity for type-approved products, test certificates for products classified under Article 10, test reports for products neither type-approved nor CE-marked, declarations of correct installation — are not attached: they sit in the dossier the owner keeps available for the fire service command.

That is where the mistake starts. In the declaration the three references stand as alternatives and so look interchangeable; in the dossier there is an entry for «test reports for products neither type-approved nor CE-marked», and it looks like the way out. It is not: which box gets filled in is not decided by whoever writes the declaration, it is decided by the product's regime. That entry exists for products no rule obliges anyone to type-approve. A certificate in place of type approval stays legitimate only in the cases Article 10 names — among them materials already installed, whose procedure is in the guide on furniture that arrived without certificates — and then the document is asked for by that name and holds for that activity.

The line nobody reads

That leaves the detail the question started from. When a laboratory writes that the document is not issued under Articles 8 to 10 of the decree of 26/06/1984, it is declaring that the sheet is neither a test certificate issued for type approval purposes nor a certification issued for purposes other than type approval: it is a commissioned test, outside both regimes, by the declared choice of whoever issued it.

It is the easiest check in the whole dossier, and almost nobody makes it: the sentence sits where nobody looks, and the word «certification» at the head of the sheet is reassuring. But a document declaring that it is not the one required has already answered the question.

The difference shows on dates too. Type approval lasts five years, lapses on any modification of the material, and the Ministry may revoke it after spot checks: it is a live title, and somebody is watching it. A test report neither expires nor is revoked, because there is nothing to watch. How to read the date is in the dedicated guide.

What to ask for, and when

Four questions at order stage rather than on delivery:

• the type approval references for the model, not the test report for the fabric or the filling alone;
• the declaration of conformity to the approved prototype for the pieces in that order, carrying those references;
• where the document is an Article 10 certificate, which of the five cases it was issued for, and for which activity;
• for every sheet, the line on the regime: under which articles it is issued.

Everything that must travel with the furniture is in the guide to the documents; why a certificate for a fabric does not make an approved assembly, in the guide on class 1 IM.

How we work

We make the upholstery in house, as we do the wood, the marble and the steel, and the approvals sit on our own models: with the order go the type approval references and the declaration of conformity for the pieces, not a folder of reports to be interpreted. In a hotel contract the value that weighs most is time: goods that comply, are certified and arrive on schedule mean an opening that does not slip. The route is in the Contract section, and the contacts reach whoever follows it.

Frequently asked questions

The laboratory is accredited: does its report count for nothing?

It counts for what it is: a test properly run. Accreditation concerns the laboratory, not the regime of the document. The same laboratory can issue a certificate for type approval, a certification under Article 10, or a report outside both: three sheets, one signature.

The report states class 1 IM. Is that not enough?

No, because the hotel rule does not ask only for the class: it asks for materials type-approved under the 1984 decree. The class says how the test went on those specimens; type approval adds an authorisation to reproduce the prototype and somebody answerable for the conformity of production, and so ties that test to the pieces delivered.

Who has to sign the declaration attached to the filing?

The qualified technician in charge of the coordination, direction or supervision of the works; in the absence of those figures, a fire-safety professional on the ministerial registers. Not the supplier: he makes the product documents available, the signature is not his to give.

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This page cites the Italian decree of 26 June 1984 in its text in force, at Articles 2 (point 2.7), 8 (points 8.1, 8.2, 8.3 and 8.4), 9 (points 9.1, 9.2 and 9.3), 10 and 11. Point 6.2 of the decree of 9 April 1994 is cited in its text, including the closing requirement on type approval and the reference to the Article 10 cases. The attachments to the fire-safety filing are those of Article 4 and of Annex II, points 2.1 and 2.2, of the decree of 7 August 2012; the declaration form is the one published by the Italian fire service department as PIN 2.3 — Dich. Prod., and the form designations have been updated over time. The rule on which regime governs the verification of reaction to fire is chapter S.1 of the decree of 3 August 2015, in the paragraph of complementary indications. The wording «not issued under Articles 8 to 10 of the decree of 26/06/1984» is reported as an example of a formula actually found on a laboratory document, not as the formula of any particular laboratory. No prices, no response times, no company case histories, none of our own certifications cited. Assessing an individual case is for the professional who signs the filing and for the competent fire service command.