The reliability of active protection designed according to the national standard UNI EN 12845 has always been based on the dual approach of system design and management, from installation to maintenance. With the 2020 edition of UNI EN 12845, alongside the designer, installer, and maintainer, a new figure has been introduced: the independent inspection body, which operates through a qualified person. Chapter 21 of the standard states:
The sprinkler system must be inspected periodically at least once a year by a qualified person (see appendix Q). The inspection report should assess whether the system complies with this standard in terms of, but not limited to, maintenance, operation, and suitability for the present risk. A list of deviations should be created to take the necessary actions.
It's interesting to note that inspection is covered in a different chapter than those related to maintenance and all other standardized technical services. This isn't by chance, but it's necessary to emphasize that inspection isn't an extra task for the maintenance technician (whose duties are thoroughly covered in chapter 20) or for other parties. It's also a proper check that needs to verify not only that maintenance has actually been carried out and that the system is functioning, but also that it is still suitable for the current risks of the activity, which may have changed over time. This requires skills beyond those of a typical maintenance worker, but likely fall within the expertise of someone with cross-disciplinary knowledge.
It’s very important that this technician is a different person from the others identified by the standard. In this regard, Appendix Q of UNI EN 12845:2020 states:
“When the periodic inspection is carried out, it is recommended that the inspection of the system be handled by an independent body, that is, neither the system's owner, the building's occupants, nor the system installer (or competent installer).
A qualified person is a designated individual, properly trained, competent based on knowledge and practical experience with the necessary instruction to carry out tests and inspections.
At the moment, besides what is written in this appendix, there isn’t really a legal reference that clarifies the independence requirement for the periodic inspection body of sprinkler systems. However, as in legal matters, we can reason by analogy by looking at what happens with other types of checks similar to this, like the grounding of electrical systems. For these systems, with DPR 426/01 since 2002, it was established that grounding checks must be carried out by bodies that respect the principle of autonomy and independence: there must be no collaboration between inspection bodies, electricians, and electrical design offices. It is up to the employer to select individuals or entities with these requirements.
The most sensible choice therefore seems to be to rely on those who choose not to carry out design, installation, or maintenance of sprinkler systems.
It's also useful to consider that using the term 'independent body' excludes anyone who might have direct or indirect interests in the activity, like insurance companies.
In the absence of national references, we can reflect on the interpretation of this change in UNI EN 12845:2020 by looking at what happens abroad. For example, in Great Britain and Germany, where EN 12845 and DIN EN 12845 are followed respectively, there have long been independent bodies that carry out exactly the task of periodic inspection.
The latest version of the UNI EN 12845 standard, and consequently the management innovation of this new chapter, represents the state of the art for good engineering. Therefore, it is appropriate to refer to Legislative Decree 81/2008, and in particular Article 18, which establishes that the employer must 'update prevention measures in relation to organizational and production changes that are relevant for health and safety at work, or in relation to the degree of evolution of prevention and protection technology.' The periodic inspection fits perfectly with what is required by this article; therefore, it must be fully complied with by the employer. This change is administrative in nature and as such it does not apply only to plants built after the new UNI regulations came into effect (2020), but also to those existing before 2020. Specifically, for sprinkler systems built before 2020, which are the majority, it's necessary to clarify that the risk compliance at the time of inspection must refer to the standard declared as compliant at the end of installation. However, if the risk classification has changed from what was estimated at the time of installation and the consequent declaration of conformity, the new design of the system must refer to UNI EN 12845:2020.
It’s still unclear, though, whether the periodic inspection for sprinkler systems under UNI EN 12845 should also extend to hydrant systems according to UNI 10779. In fact, it’s common for the two systems to be part of the same fire protection setup. This connection is also highlighted by the fact that UNI 10779:2021 refers to UNI EN 12845 for the design of the water supply. Currently, paragraph 10.5 "Periodic system check" of UNI 10779:2021 states that the system manager should appoint "a technician with the necessary skills" to carry out specific functional and documentary checks so that safety objectives aren’t compromised in case of changes to the system or the activity. Definitely, entrusting the periodic inspection of the system to an independent body (according to 12845:2020) that operates through a technician with the necessary skills is a greater guarantee in terms of reliability and responsibility for the employer. However, this is a choice that, for now, we leave to the activity managers while waiting for institutional clarifications.
