A fire protection installation can comply with the RIPCI and the RSCIEI and still fail to meet the requirements of its industrial insurer.
They are two different levels. The regulation sets the minimum required by law; an insurer such as FM Global also applies its own engineering criteria, which the policyholder accepts through the policy.
This article sets out what being “FM approved” means, where the two frameworks diverge, and what documentation and impairment management programme must back the installation.
What “FM approved” means: product, design and maintenance programme
FM Global, which has operated under the FM brand since 2024, is a commercial property insurer focused on loss prevention. FM Approvals, its certification programme, tests products and services; those that pass the tests may carry the FM Approved mark and are listed in the Approval Guide.
When a specification or a policy refers to “FM approved” equipment, it means products with that certification. The approval applies to the product; it does not in itself prove that the installation has been properly designed, built or maintained.
In practice it helps to distinguish four levels, each with its own reference document:
- Product: FM Approvals approval.
- Design and installation: the FM Global Data Sheets applicable to each system.
- Inspection, testing and maintenance: Data Sheet 2-81.
- Impairment management: Data Sheet 10-7.
RIPCI, RSCIEI and FM Global: two levels that do not replace each other
Royal Decree 164/2025, published in the Spanish Official State Gazette (BOE) on 10 April 2025, approved the new RSCIEI, repealed Royal Decree 2267/2004 and amended the Fire Protection Installations Regulation approved by Royal Decree 513/2017. Its preamble states that the provisions of both regulations must be aligned.
The RSCIEI also makes the owner responsible for ensuring that the establishment is used and maintained under the conditions for which it was designed (article 12.1) and refers the maintenance of fire protection installations to the RIPCI (article 12.2).
The regulation determines what is required to install and maintain in Spain; the policy and the recommendations of risk engineering determine what the insurer accepts as a risk. Neither replaces the other.
At the regulatory level, article 5 of the RIPCI requires equipment and systems to prove their conformity through CE marking, a standards conformity mark or a favourable technical assessment of suitability. FM approval is not among those routes: it reflects the insurer’s criteria and does not exempt a product from the regulatory accreditation that applies to it.
The two should not be confused: FM Approvals Europe also acts as a notified body in the EU, so the same product may carry CE marking certified by that entity and, separately, the FM Approved mark; only the former counts for the purposes of article 5.
This is why an installation can fully comply with the RSCIEI and the RIPCI and, at the same time, receive additional recommendations from its insurer or a requirement to use FM-approved equipment.
Where the two frameworks can diverge
- Equipment: the RIPCI refers to CE marking, the conformity mark or the technical assessment; the insurer may also require FM approval of the equipment.
- Design: Annex I of the RIPCI refers to UNE standards, such as UNE-EN 12845 for automatic sprinklers; FM Global refers to its own Data Sheets, and the criteria need not coincide. If the policy requires designing to a Data Sheet that departs from the applicable UNE standard, there are two routes: design so that both criteria are met, applying the more demanding one at each point, or process the design as an alternative technical solution under article 5.6 of the RIPCI.
- Alternative solutions: when the design departs from the standards in Annex I through an alternative technical solution, article 5.6 of the RIPCI additionally requires an independent third-party report issued by a control body, as well as justification, under the designer’s responsibility and with the owner’s agreement, of a level of safety at least equivalent. In the RSCIEI, the route for departing from the requirements of its articles 7 and 8 is article 5.1.b (equivalent safety techniques or performance-based design; more information in what is performance design in fire protection). Both routes are developed in the Ministry’s Guide for the application of alternative technical solutions for RIPCI and RSCIEI. The insurer will assess these solutions with its own criteria, so it is advisable to raise them with the insurer from the project stage.
- Maintenance: article 21 and Annex II of the RIPCI set the maximum time between two consecutive maintenance operations; Data Sheet 2-81 defines its own tasks and frequencies, which the policyholder may adjust with the FM engineer according to the conditions of the installation (section 2.4.1).
- Spare parts: article 17.a of the RIPCI requires the maintenance company to use original spare parts and components whenever they affect the product’s certification. The same logic applies to FM approval: replacing a component with a non-approved one may compromise it.
- Periodic inspections: in industrial establishments, article 13 of the RSCIEI requires an inspection by a control body at least every five years, which includes checks of the fire protection installations; the insurer also carries out its own risk engineering visits, with a different scope and frequency.
The inspection, testing and maintenance programme the insurer reviews
FM Global Data Sheet 2-81, “Fire Protection System Inspection, Testing and Maintenance”, governs the inspection, testing and maintenance programme (ITM) for systems that discharge extinguishing agent (water, foam, gases or dry chemical); design and installation are referred to other Data Sheets, and the inspection and testing of standalone detection systems to Data Sheet 5-48.
For water systems, the equivalent reference in the NFPA world is NFPA 25. Among the requirements of DS 2-81:
- tasks with a defined frequency and a record of each activity: system or equipment, type of task, results and corrective actions;
- an audit of the programme at least once a year, which includes reviewing outstanding work orders and witnessing the work of employees or contractors;
- trained in-house staff, with initial training and annual refreshers, or qualified contractors who meet local requirements (in Spain, an authorised maintenance company under the RIPCI);
- management of out-of-service periods under Data Sheet 10-7 when a system must be interrupted for these tasks;
- an out-of-service notice built into work orders, procedures or contracts whenever a task leaves a system out of service.
By way of example, DS 2-81 sets a weekly visual inspection of control valves (fully open position, locking and accessibility) and the start test of pumps, monthly for electric pumps and weekly for diesel pumps.
For reference, table I of Annex II of the RIPCI requires checking every three months the automatic and manual operation of the water supply and every six months that the valves of sprinkler systems are fully open, and for sprinklers it also refers to the annual, three-yearly and ten-yearly programmes of UNE-EN 12845.
The operations in that table I may be carried out by the owner’s own staff (Annex II, section 3), who are usually the ones who take on the weekly inspections the insurer requires.
As regards records, DS 2-81 requires keeping them for at least one year; the RIPCI requires keeping the maintenance reports for five (article 21.2), and Annex II, section 6, also obliges the owner to keep the documentary record of the maintenance programme for five years, so the regulatory period also covers the insurer’s. The documentation that the RIPCI already requires to be generated is, moreover, the basis of the programme:
- reports of each maintenance operation, signed by the qualified staff who carry it out, available to the regional industry authorities for at least five years (article 21.2);
- certificate of periodic maintenance, with a copy of the checklists used (article 17.e), and retention by the maintenance company, for at least five years, of the documentation on repairs and maintenance (article 17.d);
- technical report to the owner listing equipment with deficiencies that cannot be corrected during maintenance (article 17.c);
- maintenance contract with an authorised maintenance company, a requirement in general for commissioning (article 20.1.b);
- report of the periodic inspection by a control body: in industrial establishments, at least every five years under article 13 of the RSCIEI, with a maximum of six months to correct deficiencies (article 15 of the RSCIEI); in other cases without specific regulation, at least every ten years under article 22 of the RIPCI.
The insurer’s risk engineering assesses whether the programme is carried out, recorded and closed: whether the deficiencies found during maintenance have an owner and a resolution date.
Temporary out-of-service periods (impairment): Data Sheet 10-7
FM Global Data Sheet 10-7, “Fire Protection Impairment Management”, defines an impairment as the interruption of service of a fire protection system, or part of it, planned or not, with the intention of restoring it to full service. While it lasts, the risk is left wholly or partly unprotected.
The programme it sets out includes, among other elements:
- an impairment management policy adopted at each installation and backed by management;
- scheduling of the work for when the facility is not operational, limiting its scope and duration;
- a permit with an impairment tag (FM Red Tag Permit or equivalent);
- temporary protection while it lasts (hoses, extinguishers, charged lines or a temporary pump) and continuous fire watch in the unprotected areas;
- a person assigned to immediately reopen the closed valve or start the out-of-service pump in an emergency;
- a ban on hot work and smoking in the unprotected areas;
- notice to the fire brigade and the personnel affected;
- notification to FM at the start of the impairment, whether planned or unplanned, and when service is restored;
- restoration tests before the system is declared back in service, including the main drain test downstream of each valve that has been closed, and locking of valves in the open position.
The notification to FM includes, among other data, the site index number, the description of the impairment, the system affected, the approximate duration, the reason, and the area and occupancy protected. The Data Sheet sets no numerical deadlines: it asks for service to be restored as soon as possible.
Article 17.f of the RIPCI requires the maintenance company to inform the owner of the dates of the periodic operations, which makes it possible to schedule impairments in advance rather than handle them as unplanned.
The role of the installation and maintenance company in the risk inspection
The relationship with the insurer belongs to the owner of the installation. The installation and maintenance company provides the technical evidence and carries out the corrections:
- delivers the reports, the periodic maintenance certificate and the checklists (article 17.e of the RIPCI);
- issues the technical report on equipment with deficiencies that cannot be corrected during maintenance (article 17.c) and, at the owner’s request, corrects faults and deficiencies (article 17.b);
- plans with the owner the work that involves taking a system out of service;
- proves its authorisation before the regional authority, with professional liability insurance and a quality management system certificate (articles 15 and 16).
To learn how Pefipresa works with insurance companies, see our consulting for insurance companies, AXA Insurance’s visit to the Pefipresa showroom and the information on CEPI certification in the inspection and control of fire protection installations under the NFPA standard.
How Pefipresa handles it: traceable fire protection maintenance for the insurer
PEFIPRESA brings the RIPCI schedules and, when the policy requires it, the tasks and frequencies of DS 2-81 together in a single preventive and corrective maintenance of fire protection systems contract, with issuance of reports, filing of the documentation and advance notice of each inspection date. It also identifies in the planning the operations that leave a system out of service, so that the owner can manage them with its insurer.
Every operation is traced and signed, and the owner can prove it to its insurer, its surveyor or the authorities themselves without depending on a physical archive.
If you want to check your installation against your insurer’s requirements, contact Pefipresa, a company specialising in fire protection, and request a technical audit of your fire protection system.
Frequently Asked Questions about FM Global Fire Protection Approval
What does it mean for a fire protection device or system to be “FM approved”?
It means the product has passed the tests of FM Approvals, FM’s certification programme, and may carry the FM Approved mark. The approval applies to the product: it assumes that it performs as expected when correctly installed and maintained, but it does not in itself prove that the installation has been properly designed, built or maintained, which is assessed against the FM Global Data Sheets and in the insurer’s risk inspection.
Can an installation comply with the RSCIEI and still fail FM Global’s requirements?
Yes. The RSCIEI and the RIPCI set the minimum required by law; FM Global’s requirements are accepted by the policyholder through the policy and reflect the insurer’s own risk engineering criteria, such as the use of FM-approved equipment or different maintenance frequencies. Complying with the regulation is necessary to install and maintain in Spain, but it does not guarantee that the insurer will accept the risk without recommendations.
What documentation does the industrial insurer require on the fire protection inspection and maintenance programme?
The specific documentation depends on the policy and on the insurer’s risk engineering, which relies on Data Sheet 2-81 for the inspection, testing and maintenance programme and on 10-7 for impairment management. DS 2-81 requires recording each activity and keeping the records for at least one year. The baseline the owner must already hold under the RIPCI is the maintenance reports, kept for at least five years, the periodic maintenance certificate with the checklists, the technical report on deficiencies and, where applicable, the report of the inspection by a control body (in industrial establishments, at least every five years under article 13 of the RSCIEI).
How is a temporary out-of-service period (impairment) of a fire protection system managed with the insurer?
FM Global Data Sheet 10-7 defines an impairment as the planned or unplanned interruption of service of a system, or part of it, and sets out a programme that includes scheduling the work while the facility is not operating, issuing a permit with an impairment tag, applying temporary protection and fire watch, banning hot work in the unprotected area, notifying FM at the start and when service is restored, and completing the restoration tests. The maintenance company, which must inform the owner of the dates of the periodic operations, makes it easier to plan this in advance.
What is the role of the installer-maintainer in an insurer’s risk inspection?
The relationship with the insurer belongs to the owner; the installation and maintenance company provides the technical evidence: reports, the periodic maintenance certificate and checklists, the technical report on deficiencies and the correction of the faults the owner commissions. It also plans the work that involves taking a system out of service and proves its authorisation before the regional authority.
