When a company considers outsourcing its logistics, the conversation typically revolves around fulfilment fees, storage capacity, technological integrations, and delivery times. The intrinsic risk level of the warehouse rarely features on that list.
It's an error with concrete consequences.
A fire in your logistics operator's warehouse is not the operator's problem. It is a complete disruption of your supply chain: destroyed stock, halted orders in progress, missed deadlines, and a direct impact on your end customers. Warehouse fire safety, where you store your merchandise, becomes your business continuity variable the moment you outsource.
The high intrinsic risk level, and specifically level 8 (the absolute maximum degree on the scale), indicates that you are dealing with an establishment designed, built and equipped to operate with the highest load density, with the most demanding protection systems contemplated by Spanish regulations. This article explains what that means in technical terms and, above all, what it implies for you as a company outsourcing its logistics.
What is the inherent risk level and how does it range from 1 to 8?
The intrinsic risk level (NRI) is the official classification of the potential danger of an industrial establishment from a fire perspective. It doesn't just measure what is stored: it measures the energy a fire could release in that space, considering the type of goods, their quantity, the storage method, and the establishment's surface area.
The classification is established by the Fire Safety Regulations for Industrial Establishments, known by its acronym RSCIEI. Until 2025, the regulatory framework was Royal Decree 2267/2004. That regulation has been repealed and replaced by the Royal Decree 164/2025 of 4 March, published in the Official State Gazette (reference BOE-A-2025-7190) and in force since 10 May 2025. For new projects, compliance with the new regulation is mandatory from the 10 November 2025.
How the official scale is divided, from low to high
The NRI scale ranges from 1 to 8, organised into three categories:
| Category | Levels | What does it imply |
|---|---|---|
| Low risk | 1 and 2 | Low fire load density. Minimum protection requirements. |
| Medium risk | 3, 4 and 5 | Moderate charge density. Intermediate demands for detection and extinguishing. |
| High risk | 6, 7 and 8 | High fire load density. Maximum demands on active and passive systems. |
The difference between a level 5 and a level 6 is not a matter of degree: it is a qualitative leap in the required protection systems, construction materials, distances, and the volume of goods that the establishment can legally hold.
Why is level 8 the ceiling of the scale, not just another one among the high ones
Level 8 is the absolute maximum grade of intrinsic risk classification. The highest possible within the highest category. This has direct consequences on what the regulations require of the establishment, and therefore, on the guarantees that establishment can offer.
A warehouse planned for occupancy level 8 has had to technically justify that it can operate safely with the highest fire load density contemplated by the RSCIEI. The detection, extinguishing, smoke evacuation, compartmentalisation, and fire resistance systems of the structural elements meet the highest threshold of requirement in the standard. For a company that outsources, this means that the protection systems for its facilities have no uncovered margin above this.
How is NRI calculated?
The NRI is not a free declaration by the site owner. It is the result of a documented technical calculation that must be explicitly justified in the fire protection project.
The calculation is based on the Weighted fire load, expressed in MJ/m² (megajoules per square metre). To obtain it, the fire load density of each type of stored merchandise, the actual volume stored, and the surface area of the fire sector (the compartment bounded by fire-resistant construction elements that forms the unit of analysis for the purposes of the RSCIEI) and the correction coefficients established by the standard according to the hazard of the materials and the risk of activation.
The result determines which level of the scale the establishment falls into. The higher the weighted fire load per unit area, the higher the level of intrinsic risk and the more demanding the protection systems required by the regulations.
What changes with Royal Decree 164/2025
Royal Decree 2267/2004 was the regulatory benchmark in Spain for fire safety in industrial establishments for two decades. Its successor, RD 164/2025, maintains the classification structure by NRI but introduces relevant changes that directly affect logistics operators and companies that store goods in their warehouses.
The latest developments that most affect logistics warehouses
Higher demand for project documentation. The new regulation mandates that theNRI [Necessary Risk Index] must be explicitly calculated and justified in the fire protection project, using the methodology established by the standard. A mere declaration is insufficient; the designer must demonstrate the calculation of the weighted fire load density with complete consistency regarding the actual intended use of the establishment.
Incorporation of benefit methods. Royal Decree 164/2025 expands the possibilities for demonstrating regulatory compliance through safety engineering studies based on performance-based methods, such as temperature control and smoke evacuation studies. This allows, in certain establishments, the replacement of static constructive compartmentalisation solutions with dynamic evacuation systems, provided that the performance-based study proves that an equivalent safety level is maintained.
Accreditation process in three distinct phases. Validation no longer depends solely on the technical project. The new framework requires three phases, detailed below.
The three phases of accreditation, from project to OCA
It is advisable to be aware of these three phases when evaluating the facilities of a logistics operator.
Phase 1. The fire protection project. The designer draws up the fire protection systems project. In it, the NRI is calculated and justified with all the parameters established by the standard: fire compartment surface area, type of goods, weighted fire load density, correction coefficients. The result is a technical document that sets the risk level and the corresponding protection systems.
Phase 2. The favourable report from the Fire Brigade. The project is submitted for review by the competent authority's Fire Brigade. The Fire Brigade assesses the consistency between the declared risk level, the projected protection systems, and the applicable regulations. A favourable report signifies technical validation by the fire safety authority.
Phase 3. OCA inspection report. An Authorised Inspection Body (AIB) carries out an on-site visit to the premises to verify that the actual facilities comply with the specifications set out in the approved project. The favourable inspection report is the document that concludes the process.
The three phases are cumulative. A project approved by the Fire Brigade without a subsequent inspection report is an incomplete process. Full accreditation requires all three.
Periodic inspections every 5 years
Royal Decree 164/2025 establishes the obligation of periodic inspections every 5 years to maintain regulatory compliance. Accreditation is not a one-off milestone: it requires continuous verification throughout the establishment's lifespan. For the contracting company, the date of the last inspection and the next one are concrete data points that make sense to request.
Operational advantages of a Level 8 warehouse for the outsourcing company
A high level of inherent risk has direct operational implications for you as a company that stores its goods and outsources its logistics operations.
Why your operator's security becomes your problem
The most relevant advantage of working with a Level 8 warehouse is not technical. It is operational.
A fire at your logistics provider’s warehouse brings your pending shipments to a standstill, can destroy the stock you have stored there, and has an immediate impact on your end customers, regardless of whether the fire was caused by the provider or not. The question you should ask yourself when evaluating a logistics operator is not just "Do they have sufficient capacity?" but "What happens to my operations if there is a fire at their premises?".
A warehouse designed to meet the highest regulatory standards is equipped with automatic detection systems, sprinklers sized to cope with the declared fire load, compartmentalisation to limit the spread of fire, and evacuation and access routes designed in accordance with the current RSCIEI criteria. It is not an absolute guarantee against any incident. It is the highest level of preparedness provided for by Spanish regulations.
For companies with strict regulatory compliance requirements, with merchandise insurance that considers the warehouse operator's conditions, or with the desire to manage operational risk well, the operator's facility level is part of the risk analysis, not an add-on.
Compatibility with a wider range of goods
An establishment classified at a high intrinsic risk level offers the broadest possible technical framework within the RSCIEI for operating with goods of higher fire load density. In practice, this translates into greater flexibility in working with varied product types.
It is worth clarifying a nuance: level 8 is not an authorisation to store any goods without restriction. The compatibility between the stored product and the installed protection system, particularly sprinklers, is always decisive. There are goods whose form of combustion or interaction with extinguishing agents requires specific systems regardless of the establishment's level.
What Level 8 does offer is the highest threshold of technical capability. A warehouse designed for the maximum level of demand covers a wider range of scenarios than one at a medium level, which reduces operational restrictions for the client company and allows it to scale volume or expand its catalogue without being limited by the operator's regulatory capacity.
For reference: the RSCIEI allows sectors up to 8,000 m² in high-risk premises without the need for automatic sprinkler systems, provided that the specified clearance and evacuation requirements are met. Where automatic sprinklers are installed, this limit may be extended under the conditions set out in the standard.
Layout without physical partitions
One of the less obvious benefits of level 8, when the project incorporates a Performance study on temperature control and smoke extraction (SCTEH), it is the possibility of operating without the physical barriers of compartmentalisation that are mandatory in lower-level establishments as a static construction solution.
An SCTEH is a safety engineering analysis that simulates smoke and temperature behaviour within a building under various fire scenarios. Where the study confirms that the equivalent level of safety is maintained by the proposed evacuation system, the RSCIEI permits the replacement of physical barriers with that dynamic system.
In terms of logistics operations, this translates into a storage space free from physical barriers that might restrict the layout of the racking, the routing of picking aisles or the location of dispatch areas. For a company whose operations need to adapt to seasonal changes, new product launches or fluctuations in volume, this flexibility in the layout is of direct value.
Emergency management without reliance on third parties
A facility classified as a single, separate unit, distinct from neighbouring facilities, simplifies safety management and clearly defines responsibilities. Emergency procedures do not depend on coordination with third parties or on the availability of shared facilities.
For the operator, it simplifies the management of the self-protection plan. For the client company, it means fewer uncontrollable variables in an emergency scenario and clearer traceability regarding which systems specifically protect the facilities where its goods are stored.
What protection systems does level 8 involve
A high level of inherent risk involves a combination of active and passive systems working in coordination. For a logistics manager assessing an operator, understanding these systems enables them to ask specific questions and grasp what lies behind a Level 8 accreditation.
ESFR sprinklers and the standard UNE-EN 12845
The ESFR sprinklers (Early Suppression Fast Response) systems are the gold standard for automatic fire suppression in high-bay, high-density logistics warehouses. Unlike conventional sprinklers, which control the fire, ESFR systems are designed to suppress it in its early stages, before it reaches a scale that is difficult to control.
Its design and sizing are governed by the standard UNE-EN 12845, which sets out the criteria for installation, operating pressure, discharge density and coverage of the heads. In a Class 8 warehouse with high-bay racking, the ESFR system must be specifically designed for the declared fire load and the actual storage configuration: on pallets, in double-depth racking, or in drive-in racking.
The presence of ESFR sprinklers compliant with UNE-EN 12845 is not a cosmetic detail. It is the difference between a fire suppression system designed for the operational reality of the warehouse and a generic one that may prove insufficient given the actual fire load density.
SCTEH as a technical alternative to physical compartmentalisation
The SCTEH (Temperature Control and Smoke Evacuation System) is the set of elements, natural or forced, that guarantee the evacuation of hot smoke and the maintenance of a smoke-free layer for the necessary time for evacuation and the intervention of emergency services.
In the context of RD 164/2025, the SCTEH can be the element that underpins the performance study allowing the warehouse to operate without conventional physical compartmentalisation. For that substitution to be valid, the study must demonstrate, through justified simulation or calculation, that the behaviour of smoke with the projected system guarantees an equivalent level of safety to the prescriptive solution.
For the logistics manager, the practical question is specific: does the operator's fire protection project include a validated smoke control study? If the answer is yes, the warehouse layout can be more flexible. If such a study does not exist, the establishment must comply with the compartmentalisation construction solutions that the standard prescribes directly.
Passive protection, fire resistance REI and compartmentalisation
active systems (sprinklers, detection, smoke evacuation) work together with the Passive protection: the building's own construction elements designed to resist fire and limit its spread. The indicator used by the regulations is the Fire resistance REI (Resistance, Watertightness, Insulation), expressed in minutes: REI-60, REI-90, REI-120.
The Fire compartmentation It is the first passive containment line. In a level 8 warehouse, the elements of the sector must have the fire resistance that the RSCIEI establishes for that level, and the openings in the boundary elements (doors, service penetrations) must meet the corresponding compartmentation requirements.
The combination of correctly designed active and passive protection means it is possible to operate with the charge density corresponding to level 8.
How does a logistics operator accredit the level of intrinsic risk?
Knowing whether the operator you are assessing has their facilities in order does not require you to be a PCI engineer. It requires knowing what documents to ask them for and what to expect from each one.
The fire protection project
The project is the base document. It must include the calculation of the intrinsic risk index (NRI) with the parameters of the standard, the justification of the installed protection systems and, if applicable, the smoke control study. If the operator cannot provide you with the intrinsic risk index specified in their fire protection project, the accreditation process has not begun or is not correctly documented.
The favourable report from the Fire Brigade
The favourable report from the Fire Service attests that the project has been reviewed by the competent authority and is consistent with the declared risk level and regulations. It is the technical validation of the design phase. Without it, the accreditation process lacks administrative support.
The OCA inspection report
The certificate from the Accredited Control Body (OCA) confirms that the actual physical facilities correspond to what the approved project specifies. It is the validation of reality, not of paper. Without this document, accreditation is incomplete even if the project is technically impeccable and has been approved by the Fire Service.
Four questions to ask your next operator
Before committing to a logistics operator, these questions will give you the information you need about the real state of their facilities:
- What is the specified inherent risk level in the warehouse's fire protection project?
- Do you have the favourable report from the Fire Brigade? From what date?
- Is the OCA inspection certificate issued and in force? When does the next periodic inspection expire?
- Does the project incorporate a study of smoke performance (SCTEH)?
If the operator cannot provide documentation, or if the accreditation process has not been concluded, it is advisable to assess that risk, especially if your goods insurance or compliance requirements take into account the warehouse keeper's conditions.
How do we do it at Grupo Akoma?
At Grupo Akoma, we have been working for some time with facilities designed to meet the highest demands of fire safety regulations. Our warehouse is designed with a high intrinsic risk level (level 8) in accordance with the new Fire Safety Regulations in Industrial Establishments regulated by Royal Decree 164/2025.
The accreditation process is underway and at an advanced stage. The fire protection project envisages level 8 and We now have the favourable report issued by the relevant Fire Brigade.. The final validation phase, inspection by an Authorised Control Body which issues the inspection certificate, is currently underway, pending the inspector's visit. It is a milestone in progress, not a closed certification, and we state this with precision because transparency regarding the actual status of the facilities is part of the trust placed in us by those who entrust us with their operations.
The project incorporates a smoke control study (SCTEH) that allows operation as a single zone without physical compartmentation barriers, resulting in a cleaner and more adaptable logistic layout. The sprinkler installation is sized for the fire load density corresponding to Level 8, and the establishment's design complies with the sectorisation, emergency access, and fire resistance REI requirements for structural elements that regulations stipulate for this level.
What does this mean for companies that work with us? It means their merchandise is in a warehouse designed with the most rigorous safety criteria stipulated by Spanish regulations for industrial establishments. It means the operator has already passed the technical review by the Fire Department and is in the final stages of the accreditation process. It means the infrastructure where their logistics operate is not an adapted space: it is an establishment specifically designed to operate at the highest level of safety.
For companies with strict regulatory compliance requirements, with merchandise insurance that considers warehouse conditions, or with a desire to properly manage business continuity risk, this level of facilities is part of the cost of operating with guarantees.
If you want to know more about our infrastructure and the integrated logistics services what we offer, or if you want to understand how your operation would fit into our facilities, the team is available for an initial conversation. You can also see what Sectors we serve, how we adapt our operations for each type of client and the details of our Order picking and preparation service.
Speak with the Grupo Akoma team
If you are evaluating logistics operators and want to understand how the operator's facilities affect your business continuity, regulatory compliance, and merchandise insurance costs, the Akoma team can explain the state of our facilities and how operations work in practice in detail.
Preguntas frecuentes
What is the intrinsic risk level of a warehouse?
The intrinsic risk level (NRI) is the official classification of the hazardousness of an industrial facility from a fire perspective. It is expressed on a scale of 1 to 8 grouped into three categories: low (1-2), medium (3-5), and high (6-8). The higher the level, the greater the potential energy that a fire in that space would release, and therefore, the greater the demands on active and passive protection systems that the facility must incorporate according to the RSCIEI.
How is inherent risk level calculated?
It is calculated from the Weighted fire load (expressed in MJ/m²), the fire compartment surface area and storage height, applying the correction factors established by the RSCIEI. The result is the fire load density per unit area of the compartment, which determines the level on the scale to which the establishment falls. The calculation must be documented in the fire protection project and be consistent with the actual intended use.
What is the difference between a medium and a high inherent risk level?
The difference is qualitative. A medium-risk establishment (levels 3-5) can operate with less demanding protection systems: automatic detection and manual extinction may be sufficient in some cases. For high-risk (levels 6-8), the standard requires automatic extinction systems specifically sized for the declared fire load, compartmentation solutions or equivalent performance studies, and an accreditation process with the intervention of the Fire Brigade and an OCA. It is a different threshold of requirement.
What changes with Royal Decree 164/2025 with respect to the previous regulation?
Royal Decree 164/2025 (in force from 10 May 2025, mandatory for new projects from 10 November 2025) replaces RD 2267/2004 and updates the technical criteria for classification, documentation, and validation. The three most relevant changes are: increased stringency in the technical justification of the NRI in the project, incorporation of performance-based evaluation methods that allow greater flexibility in space design, and a structured accreditation process requiring differentiated intervention by the Fire Department and an OCA. Furthermore, it establishes periodic inspections every 5 years to maintain compliance.
What are ESFR sprinklers and why are they relevant at level 8?
ESFR (Early Suppression Fast Response) sprinklers are a type of automatic fire suppression system designed to suppress fires in their initial stage. They are the benchmark for high-rise, high-density storage logistics warehouses, precisely the conditions that characterise a level 8 establishment. Their design and sizing are governed by the UNE-EN 12845 standard. A correctly calculated ESFR system for the declared fire load and storage configuration is one of the elements that make it technically viable to operate with the density corresponding to the maximum level on the scale.
What is a study of smoke performance (SCTEH) and why does it matter?
A Smoke Control and Evacuation System (SCTEH) is an engineering analysis that simulates the behaviour of smoke and temperature within a building under different fire scenarios. When the study demonstrates that the equivalent safety level is maintained with the projected evacuation system, the RSCIEI permits the replacement of conventional physical fire compartmentation barriers with this dynamic system. In a logistics warehouse, the practical result is a space without physical interruptions that constrain the layout: greater flexibility for organising shelving, picking aisles, and dispatch areas.
Can a level 8 warehouse store any type of merchandise?
No. Level 8 offers the broadest technical framework within the RSCIEI, but it is not an authorisation to store any goods without restriction. The compatibility between the product and the installed fire protection system, particularly the sprinkler system, is always decisive. There are goods whose combustion pattern or interaction with extinguishing agents requires specific systems regardless of the establishment's level. What Level 8 does offer is greater flexibility than a medium-level warehouse to operate with a wide range of product types, within the limits set by the installed system and verified technical compatibility.
How do I know if the logistics operator I'm evaluating has its facilities in order?
Ask the operator for the intrinsic risk level specified in their fire protection project, the favourable fire brigade report, and the OCA inspection certificate. Under RD 164/2025, the complete accreditation process requires these three phases. If the operator cannot provide documentation, or if the process has not concluded, it is advisable to assess this risk, especially if your cargo insurance or compliance requirements stipulate warehouse keeper conditions.
Does the level of inherent risk affect the cost of cargo insurance?
The intrinsic risk level of the establishment where the goods are stored is a factor insurers consider when calculating the premium and coverage for goods in store insurance. A warehouse with fire protection facilities corresponding to the highest regulatory level, and with its accreditation process in order and documented, presents a different risk profile from a medium-level warehouse or one with undocumented facilities. Before engaging an operator, it is advisable to consult your insurer.
What is the difference between the favourable report from the Fire Brigade and the inspection report from the OCA?
These are two distinct documents issued at different stages of the process. The favourable report from the fire brigade validates the project: the fire brigade reviews that the project is consistent with the declared risk level and with the regulations. The inspection certificate from the authorised control body (OCA) validates the physical reality: an independent inspector visits the establishment and checks that the actual installations correspond to the approved project. Both are necessary for the accreditation to be complete; neither replaces the other.
Why does the intrinsic risk level matter when choosing a 3PL provider?
Because the operator's facilities are a business continuity variable for the outsourcing company. A fire in the operator's warehouse paralyses pending shipments, can destroy stored stock, and generates a direct impact on end customers. The NRI and the state of the warehouse protection systems indicate how prepared the operator is to prevent such a scenario and to contain it if it occurs. It is a criterion that does not usually appear in initial comparative analyses of operators, but it becomes relevant when operational risk is fully assessed.
How often are periodic inspections carried out under RD 164/2025?
The Royal Decree 164/2025 establishes periodic inspections every 5 years. This means that NRI accreditation is not a one-off procedure: the establishment must undergo inspection by an OCA at this frequency to maintain regulatory compliance. For the outsourcing company, the date of the last inspection and the next one are relevant data when assessing the actual state of the operator's facilities.
