Fire Protection of Machinery: Machinery Legislation, EN ISO 19353 and the “Fire Protection Regulation”

Is there a fire protection regulation?

Neither the EU nor Germany, Austria or Switzerland has a legal act of that name that applies to machinery. Whoever asks for the “Brandschutzverordnung” usually means one of these: the in-house fire safety rules under DIN 14096 with parts A, B and C; in Germany the interplay of the Workplaces Ordinance, ASR A2.2, the Hazardous Substances Ordinance and the state building codes; in Austria the Worker Protection Act, the Workplaces Ordinance and the fire police acts of the federal states; in Switzerland the VKF fire protection regulations, abbreviated “BSV”. Acts with exactly that name exist only in narrow cases, such as the Vienna fire protection ordinance for employees of the City of Vienna.

For CE marking only product legislation counts. The new EU act with a fire safety angle, the Construction Products Regulation (EU) 2024/3110, has applied since 8 January 2026 to construction products, not to machinery; it only matters for products that are both.

What machinery legislation requires

• Fire

  Section 1.5.6

  Machinery must be designed and constructed in such a way as to avoid any risk of fire or overheating posed by the machinery itself or by gases, liquids, dust, vapours or other substances produced or used by the machinery. The Machinery Regulation takes this over unchanged in substance and extends it to related products.

• Fire, machinery with mobility

  Section 3.5.2

  Depending on the hazards anticipated by the manufacturer, and where its size permits, machinery must either allow easily accessible fire extinguishers to be fitted or be provided with built-in extinguisher systems. According to the Machinery Directive Guide (§ 321) the manufacturer is not expected to supply the extinguisher itself; where the residual risk is high or the consequences of a fire may be severe, a built-in system must be fitted.

• Fire, machinery for underground work

  Section 5.5

  With highly flammable parts, the built-in extinguisher system is mandatory. The braking system must not produce sparks or cause fires; internal combustion engines are only allowed with low vapour pressure fuel and without sparks of electrical origin.

• Instructions

  Section 1.7.4.2

  There is no separate item on fire. The fire protection information belongs to the residual risks (point l), the protective measures to be taken by the user (point m) and the method to follow in the event of accident or breakdown (point q), plus the maintenance information.

Delimitation: explosions are section 1.5.7, burns from hot surfaces without fire section 1.5.5. The numbers are the same in the Machinery Directive and the Machinery Regulation.

EN ISO 19353 in five steps

EN ISO 19353:2019 is the type-B standard on fire prevention and fire protection. It is harmonised under the Machinery Directive (Implementing Decision (EU) 2020/480) and follows the method of EN ISO 12100. It does not apply to machinery with mobility, to machinery in potentially explosive atmospheres, to controlled combustion processes (except as an ignition source) or to building fire detection and suppression systems.

1. 1. Determine the limits of the machinery

   Use, life cycle phases, operating substances, processed material and environment, as in any risk assessment to EN ISO 12100.

2. 2. Identify fire hazards

   Where can combustible material, oxygen and an ignition source come together at the same place and time in sufficient quantity? Typical cases are oil or fuel leaking onto hot surfaces, oil mist in the working area, solvent vapours, dusts and chips, lithium-ion batteries and overheated processed material.

3. 3. Estimate and evaluate the fire risk

   Severity and probability of a fire including smoke and fire spread, for normal operation and foreseeable malfunctions such as leaks, jams or loss of cooling.

4. 4. Prevent fire by design

   Avoid or limit combustible material, avoid or separate ignition sources, limit temperatures, prevent deposits and leaks. Only where this is not enough: complementary protective measures such as fire detection, shutdown, compartmentation and an extinguishing system.

5. 5. Information for use

   Fire hazards as residual risk, suitable and unsuitable extinguishing agents with fire class to EN 2, action in case of fire, cleaning and inspection intervals of the fire protection equipment.

Typical fire hazards of machinery

Integrated extinguishing systems and safety functions

Machine tools using neat oil cutting fluids often get an integrated extinguishing system. The German social accident insurance DGUV treats it like a safety component in FBHM-087 (as of 10 October 2024) and lists safety functions with a required performance level:

• guard locking of the working area door on fire detection
• cutting fluid supply off
• extraction off or isolated
• machining and chip conveyor stopped
• no gas flooding with the door open
• operation only with the extinguishing system ready
• alarm to the responsible persons

The interface between the machine control and the extinguishing control is not standardised and is agreed with the manufacturer of the extinguishing system. Gas extinguishing systems, for example with CO2, need warning and delay devices where persons can enter the flooded area. DGUV Information 209-026 on fire and explosion protection of machine tools is a further practical reference.

Fire safety rules for users in Germany, Austria and Switzerland

Fire extinguishers, fire alarm systems and escape routes at the place of installation are determined by the user. For this they need information only the manufacturer has: combustible operating substances and their quantities, fire classes, suitable extinguishing agents, interfaces of the extinguishing system and the action to take in case of fire.

Special cases: fire doors, extinguishers, batteries

• Power-operated fire-resisting and smoke control doors are machinery and construction products at the same time. The Machinery Directive Guide (§ 92) names both legal acts for powered gates and doors. The performance is declared under EN 16034 together with EN 13241 or EN 14351-1; safety in use follows EN 12453 or EN 16005. Smoke exhaust ventilators (EN 12101-3) and fire dampers with actuators (EN 15650) have to be classified case by case.
• Portable fire extinguishers are pressure equipment under Directive 2014/68/EU and must be classified at least in category III; purchased extinguishers are placed on the market by their own manufacturer.
• Lithium-ion batteries are subject to the Batteries Regulation (EU) 2023/1542; evidence and firefighting information come from the battery manufacturer and belong in the instructions of the machine.

Standards on fire protection of machinery

All references under the Machinery Directive lose their presumption of conformity on 20 January 2027; the Commission expects the first list under the Machinery Regulation by the end of 2026. The standards database of CE-Copilot shows the current status.

How CE-Copilot covers fire protection

• Fire protection module in the risk assessment

  Appears as soon as the machine description gives indications, such as hydraulic oil, cutting fluid, solvents, a combustion engine, a lithium-ion battery, welding or laser. You record combustible substances, ignition sources and oxygen, the special cases mobility, underground and construction product, measures in four groups to EN ISO 19353, extinguishing agent, surface temperature, standards and evidence. The app derives the fire classes to EN 2 from the substances.

  from Starter

• Fire hazards adopted as hazards

  One hazard of type “fire” per combustible substance with scenario, ignition sources, reference under the legal regime of the project and measures in three steps; the AI hazard search knows the type as well.

  from Starter

• Notes that are easily overlooked

  Explosion protection for vapours and dusts, never water on metal or fat fires, the Batteries Regulation, gas extinguishing with a pre-warning time, the integrated extinguishing system as a safety function, the obligations under 3.5.2 and 5.5, construction products legislation for fire doors.

  from Starter

• Fire protection test section

  Nine test items, from identifying fire hazards to surface temperatures, fire detection, extinguishing equipment and marking; the mandatory items adapt to mobility, underground use and construction products.

  from Professional

• Fire protection information in the instructions

  Fire hazards, fire classes, intended extinguishing agent and fire protection equipment flow into the pre-filled content and AI chapters of the instructions, plus a note on the user's obligations in Germany, Austria and Switzerland.

  operating instructions module, from Professional

• AuxiAI

  The in-app help assistant knows fire protection: it answers questions such as “Is there a fire protection regulation for machinery?” or “Which extinguishing system does a machining centre need?” with the legal reference and the way through the app.

  in all plans

Plans are listed on the pricing page.

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