DA DB-SI / 1 - Justification of Construction Product Fire Behavior Compliance
The DA DB-SI / 1 is a Supporting Document (Documento de Apoyo) to the Basic Document DB-SI (Fire Safety) within the Spanish Technical Building Code (Código Técnico de la Edificación or CTE). Issued by the Ministerio de Transportes, Movilidad y Agenda Urbana, the December 2022 edition updates previous versions from 2011, 2014, 2016, and 2019. It serves as a regulatory framework for justifying that construction products used in works meet specific fire behavior requirements.
The document provides technical criteria for verifying the reaction to fire and resistance to fire of construction elements. It establishes the mandatory checks for products at the time of delivery to the building site, covering both products requiring CE marking and those that do not. Its scope includes specific documentation requirements such as classification reports from ENAC accredited laboratories, quality marks, and technical suitability assessments. It also defines the responsibilities of project management roles regarding the compilation of compliance evidence for the Libro del Edificio (Building Book).
The following sections detail the verification procedures for various product categories and the administrative requirements for technical documentation as specified in the DA DB-SI / 1 regulatory text.
Verification of CE Marking and Product Reception
Upon reception at the construction site, products must be checked for mandatory CE marking. If a product is required to have this marking and lacks it, it must be rejected. Verification should refer to the harmonized standards listed by the European Commission and the MINCOTUR (Ministry of Industry, Commerce, and Tourism) website.
- Mandatory CE Marking: Products must comply with the list published in the Official Journal of the European Union (DOUE).
- Voluntary Marking: Products not in the harmonized list may voluntarily adopt CE marking via a European Assessment Document.
- Performance Declaration: Products with CE marking must be accompanied by their corresponding Declaration of Performance to verify that fire resistance or reaction classes meet the project specifications.
Compliance for Products Without CE Marking
For products without CE marking, or those where the required fire characteristic is not listed, properties must be justified through specific documentary accreditation. The documentation must fully describe and identify the product through one of several regulatory paths.
- Accredited Laboratory Reports: Classification or characterization reports from Spanish laboratories must be backed by ENAC accreditation.
- Mutual Recognition: Products legally marketed in other EU Member States may be accepted under Regulation (EU) 2019/515, provided the testing laboratory is accredited by its national accreditation body.
- Quality Marks: Voluntary quality seals or marks of conformity to standards issued by Spanish certification bodies must be verified for ENAC accreditation.
- Technical Suitability Assessment: The document must be valid at the time of product reception at the site.
Complex Systems and Document Validity
Specific requirements apply to complex or non-conventional fire compartmentation systems, such as fire curtains (cortinas cortafuego). Their use cannot be justified solely by standard fire resistance tests; they require a technical suitability assessment issued by an authorized entity.
- Reaction to fire reports: Valid for a period of 5 years following the test date.
- Fire resistance reports: Valid for a period of 10 years following the test date.
- Language requirements: Documentation must be provided in Spanish or the co-official language of the relevant Autonomous Community. Translations by sworn translators are considered equivalent to those from accredited laboratories.
The Director de ejecución de la obra is responsible for collecting all accredited documentation, which must then be deposited with the relevant professional college or competent Public Administration and included in the Libro del Edificio by the Director de obra.
Frequently Asked Questions
How long is a fire reaction classification report valid for?
According to DA DB-SI / 1, a classification or characterization report for reaction to fire is valid for 5 years after the date the test was performed.
What is the validity period for fire resistance test reports?
Classification reports regarding resistance to fire remain valid for 10 years from the date the corresponding test was conducted.
Can fire curtains be justified with a standard fire resistance test?
No, complex systems like fire curtains require a technical suitability assessment from an authorized entity because a simple conventional test is insufficient to guarantee their critical functions.
What happens if a construction product arrives at the site without a required CE mark?
The product must be rejected if the CE marking is mandatory according to European Commission listings and harmonized standards.
In what language must the fire safety documentation be presented?
Documentation must be written in Spanish or any of the co-official languages of the Autonomous Community where the project is located.
Who is responsible for collecting the fire safety accreditation of products?
The Director de ejecución de la obra (execution director) is responsible for gathering all accredited documentation for the products used.
