The RSCIEI 2024 consolidates a structural shift in fire protection design for Spanish industrial establishments. Complying with tables and maximum distances is no longer enough: the administration now admits alternative routes based on the real behaviour of fire and occupants, provided they are demonstrated through rigorous engineering.
In this scenario, performance-based engineering, internationally known as Performance-Based Design (PBD), becomes essential when prescriptive design fails to address the complexity of high-bay logistics warehouses, chemical plants, datacenters or facilities with ESFR rack storage.
Performance-based design does not replace the prescriptive route: it complements it where the regulation is insufficient, restrictive or silent. Its correct application demands deep knowledge of both the standard and simulation tools.
RSCIEI 2024 and the shift toward performance-based design
The Royal Decree approving the new Fire Safety Regulation in Industrial Establishments introduces adjustments in compartmentation, materials and extinguishing systems, but its most relevant novelty is the explicit recognition of alternative solutions through documented technical justification.
The regulation remains prescriptive in essence. However, it opens the path for a designer to prove that their design meets the safety objectives —protection of people, assets and business continuity— through a route different from the one prescribed in the tables. This is, essentially, performance-based engineering.
Prescriptive design: the general rule
The prescriptive approach establishes closed requirements: maximum compartment areas, evacuation distances, minimum allocations of extinguishers, hose reels or sprinklers, fire resistance times for structures. Its main advantage is legal certainty and speed of validation.
Where it works well
- Conventional industrial buildings with low intrinsic risk.
- Establishments with configurations, materials and processes covered by the regulation.
- Minor refurbishments and limited extensions.
Where it falls short
- Singular buildings with geometries that the regulation does not contemplate.
- High-bay warehouses with steel racks and ESFR hydraulics.
- Industrial processes with thermal loads not covered by standard classifications.
- Facilities with lithium batteries, hydrogen or BESS, where fire phenomenology is atypical.
Performance-based engineering: what it is and how it is built
The performance-based engineering approach starts from measurable safety objectives and demonstrates that the design achieves them through physical models, testing and quantitative analysis. Tables are not followed: calculations are made.
The procedure, set out in the reference technical guide from the Society of Fire Protection Engineers, is structured in five successive phases.
- Definition of objectives: protection of lives, assets, environment and operational continuity.
- Acceptance criteria: maximum temperatures, minimum visibility, evacuation time, admissible structural damage.
- Design fire scenarios: identification of representative critical fires.
- Modelling and calculation: CFD, zone models, evacuation simulation.
- Documentation and validation: technical report and contrast with the competent administration.
The core of PBD is not the extinguishing systems, but the safety objectives. Every decision —ESFR sprinklers, water mist, inerting, smoke and heat control— is selected because it demonstrably meets those objectives in the analysed scenarios.
Simulation tools
Performance-based projects rely on software validated by the National Institute of Standards and Technology, such as FDS (Fire Dynamics Simulator) and Pathfinder for evacuation. Model reliability depends on the quality of input data and the engineer’s experience configuring them.
PBD versus prescriptive: a practical comparison
The operational differences between both approaches concentrate on the design origin, its flexibility and the documentation required.
- Design origin: prescriptive starts from the regulation; performance-based starts from the objectives.
- Geometric flexibility: prescriptive assumes typical geometries; PBD models the real one.
- Economic optimisation: PBD adjusts allocations to verified risk; prescriptive applies uniform minimums.
- Documentation load: PBD requires extensive technical reports, simulations and administration review; prescriptive is justified with plans and allocation tables.
- Approval times: PBD requires prior dialogue with authorities; prescriptive has faster approval.
When to apply PBD in industrial establishments
The performance-based approach delivers real value when any of these conditions is met:
- Warehouses with heights above 12 metres and intensive racking.
- Data centres with electrical load densities exceeding standard models.
- Plants storing or processing lithium batteries, green hydrogen or flammable liquids.
- Buildings of complex geometry, atriums, double heights or interconnected compartments.
- Facilities where operational continuity is a critical objective (pharma, semiconductors, financial).
In these cases, prescriptive design leaves questions unanswered: how much smoke will be produced? Will visibility allow evacuation? Will the structure resist long enough? Will the extinguishing system control the fire before it spreads? The active fire protection designed under PBD answers these questions with numbers, not tables.
Administrative validation and regulatory references
Acceptance of a performance-based project by autonomous authorities requires prior work in defining criteria. There is useful precedent in the performance-based guides published by the Generalitat of Catalonia, which set quantitative limits for visibility, radiation and exposure of people and firefighters.
The technical framework relies on internationally recognised standards, among others:
- NFPA 101 Life Safety Code and NFPA 5000.
- SFPE Engineering Guide to Performance-Based Fire Protection.
- UNE-EN 12845 for automatic sprinklers and UNE 23585 for smoke and heat control systems.
As a leading Fire Protection company with more than five decades of experience and the backing of the Minimax Viking group, at Pefipresa we approach every performance-based project by combining systems engineering, CFD simulation and deep knowledge of Spanish and European regulation. Request a no-obligation technical study of your installation from our PCI engineering team.
Frequently Asked Questions about performance-based design
What is performance-based engineering applied to fire protection?
It is a design methodology that starts from measurable safety objectives and demonstrates, through calculations, physical models and simulations, that the fire protection system meets them, without literally following the tables of a prescriptive regulation.
When is it advisable to apply PBD instead of prescriptive design?
When the establishment has a geometry, a use, a fire load or an intrinsic risk that the prescriptive regulation does not contemplate, or when the goal is to optimise the protection investment without losing safety. High-bay ESFR warehouses, data centres, chemical plants, BESS and singular buildings are typical examples.
Does RSCIEI 2024 allow performance-based design in industrial establishments?
RSCIEI 2024 maintains a mostly prescriptive approach, but admits alternative solutions provided they are technically justified and the safety objectives are accredited before the competent administration. This route is, in practice, performance-based engineering.
Which standards and guides serve as reference for a performance-based project?
The usual references are NFPA 101, NFPA 5000, the SFPE Engineering Guide to Performance-Based Fire Protection, UNE 23585, UNE-EN 12845 and, at the regional level, the performance-based guides published by the Generalitat of Catalonia on visibility, radiation and exposure.
What real advantages does performance-based design offer compared to prescriptive design?
It allows allocations to be adjusted to the real risk, addresses geometries and uses not covered by the regulation, optimises investment, integrates advanced technologies such as inerting or water mist, and provides the owner and their insurer with quantitative evidence of the safety level achieved.
