Machinery in mind10 June 2024

Darren Hugheston-Roberts, Head of Machinery Safety, TÜV SÜD UK

The risk of damage to machinery from fire should be taken seriously in all industrial settings. The measures in place to prevent it include important procedural and operational requirements that should be closely noted. Darren Hugheston-Roberts explains more

The Supply of Machinery (Safety) Regulations 2008 contain detailed requirements for the design, manufacture and supply of safe new machinery to the UK market or putting into use for the first time within the UK, for example if you manufacture your own machine for your own use, and machinery manufacturers and suppliers must ensure that their product is compliant.

Within the regulations there are Essential Health and Safety Requirements (EHSR) that lay down the minimum conformity criteria. While the use of standards is not mandatory, if a standard is applied correctly conformance with the relevant EHSRs of the regulations may be presumed. They therefore represent the surest way to ensure conformance. However, the end-user must still ensure that the product complies with the regulations and is in fact safe when putting into use for the first time, and remains safe.


For machinery owners and those providing machinery for work, the Provision and Use of Work Equipment Regulations 1998 (PUWER) applies to all work equipment regardless of its age or if the equipment carries a CE or UKCA mark – or if it pre-dates this product requirement. PUWER describes what an employer needs to do to protect employees in the workplace. It is therefore their responsibility to ensure that all new machinery meets the requirements of The Supply of Machinery (Safety) Regulations 2008 and PUWER.

Purchasers and end users of machinery must understand their machinery supplier’s responsibilities when it comes to designing and producing machinery with fire prevention and protection in mind. This includes employers, employees, in-house maintenance staff or a maintenance service provider.

ISO 19353:2019 - Safety of Machinery - Fire Prevention and Fire Protection defines fire as: ‘Independent combustion, which can occur as controlled combustion or as uncontrolled combustion’. The standard is directly relevant to machinery manufacturers, as well as health and safety bodies, such as the Health & Safety Executive in the UK.

As a designated and harmonised standard (B-Type), ISO 19353 satisfies the relevant essential safety requirements (ESRs) where the relevant hazards have been identified during the design risk assessment stage. Compliance with it therefore gives a ‘presumption of conformity’ with the Machinery Directive in the EU – and The Supply of Machinery (Safety) Regulations for the UK. Products demonstrate their compliance by having a CE marking (EU) or UKCA mark (GB) affixed by the manufacturer and the drawing up of a Declaration of Conformity.


ISO 19353:2019 is the third edition and has therefore replaced the previous edition, ISO 19353: 2015. The updates from the previous edition are not significant and include:

  • Old Annexes A and B have become Annexes D and A, respectively;
  • A new Annex B covers an example of a methodology for selecting and qualifying a fire detection and fire suppression system;
  • The language in old Annex D has been improved and it is now Annex E;
  • The old Annex E (fire risk reduction measures) has been deleted.

  • ISO 19353 is a type B1 standard as stated within ISO 12100. This means that it relates to specific safety aspects of machines, describes general safety aspects and provides relevant solutions, such as the design of appropriate controls. Type B1 and B2 standards are laterally interlinked, but type B2 standards relate to specific products, such as EN 13850 (Emergency stop function -- Principles for design). They include notes on the design and testing of safety components, which both the product manufacturer and machine designer must take into account.


    ISO 19353 specifies methods for identifying the fire hazards presented by machinery and the methods for performing an appropriate risk assessment. It includes fire protection measures for the design and manufacture of machinery. It also gives the basic concepts and methodology of protective measures for fire prevention and protection to be taken during the design and construction of machinery. The measures consider the intended use, as well as the reasonably foreseeable misuse of the machine.

    Risk assessment is a vital step in ensuring compliance and must therefore be carried out to examine any potential hazards associated with the machinery. This provides information for a risk evaluation, in which a decision is made on the safety of that machinery, so that risks can be reduced where necessary to a reasonably practical level using the hierarchy of risk control.


    The first step is to identify anything that has the potential to cause harm. Secondly, an assessment must be made of the likelihood of a person coming into contact with these hazards and how much injury it would cause.

    A risk assessment would normally be carried out for each machine, the Preliminary Hazard Analysis (PHA) method uses a Hazard Rating Number system. Referencing a table, the most appropriate phrase that applies to the hazard is chosen, the corresponding score results in a hazard rating number (HRN), which corresponds to the level of risk.

    The PHA takes into consideration:

  • The likelihood of a person or persons coming into contact with a hazard;
  • The degree of possible harm that could be caused;
  • The frequency of exposure;
  • The number of people at risk at the same time;
  • Control measures can then be applied to mitigate the risk;
  • Design the hazard out;
  • Remove the need for man-machine interface;
  • Design-in safeguards;
  • Reduce the possibility of occurrence;
  • Reduce the degree of harm;
  • Warn and inform machine operators (but only if you can achieve adequate safety).
  • Once the control measures have been implemented, a re-assessment must then be actioned to ensure that they provide an adequate level of safety and to ensure no secondary hazards have been introduced. The process is repeated until an adequate level of safety is achieved.


    Regulation 6 of PUWER requires that inspections must be conducted ‘at suitable intervals’ if machines are exposed to conditions that may lead to deterioration. In reality, every machine is exposed to conditions that may lead to deterioration, so the requirement effectively means that they must all be regularly inspected. The function of a work equipment risk assessment is to identify those components that could deteriorate and identify how often they should be inspected, how they should be inspected and by whom.

    Although, risk assessments must therefore be conducted conscientiously and at appropriate intervals, we still visit sites that simply forget and haven’t taken any action for five years or more. The answer here is to set up an internal process, overseen by an individual who ensures risk assessments are carried out according to an agreed schedule. Creating an internal procedure in this way successfully integrates risk assessment into the everyday working practices. Taking this simple approach ensures that work equipment risk assessments are swiftly integrated into the everyday working practices of an organisation and are never neglected.


    Overall, the protective measures that are dealt with in ISO 19353 include inherently safe design measures such as minimising the use of flammable materials and liquids and safeguarding/technical protection measures such as spatial containment (encapsulation). They also include complementary protective measures such as integrated fire alarm and extinguishing systems, including: pre-fire alarm systems; fire alarm systems; manually release fire suppression equipment and systems; automatically released fire suppression systems and user information.

    However, the standard does not cover every machine type and is not applicable to:

  • Mobile machinery;
  • Machinery designed to contain controlled combustion processes (eg internal combustion engines, furnaces), unless these processes can constitute the ignition source of a fire in other parts of the machinery or outside of this;
  • Machinery used in potentially explosive atmospheres and explosion prevention and protection;
  • Fire detection and suppression systems that are integrated in building fire safety systems;
  • Machinery or machinery components manufactured before the date of the Standard’s publication.
  • The third area that must be considered for machinery safety against fire, in addition to prevention and protection, is the means of firefighting, which includes fire detection. Overall, this would include the technical, structural, organisational and fire suppression measures to be considered, and can it be implemented through a single measure or a combination of measures.

    It is the responsibility of machinery owners and employers to undertake a risk assessment and evaluate the potential for a fire on the premises. This must be carried out by a suitably competent person and control measures must be put in place to reduce the risk and effects of fire to as low as reasonably practicable.

    It is therefore vital that machinery end users have an appreciation of ISO 19353 as it describes the methods for identifying a machinery fire hazard and how a corresponding risk assessment should be conducted. It also describes the basic concepts and methodology of the technical measures for fire prevention, protection and fire-fighting that should have been taken during the design and construction stages of machinery. Therefore, with knowledge of its application users can be assured that their machine has reached the required level of fire safety according to its intended use, as well as any reasonably foreseeable misuse.

    Darren Hugheston-Roberts

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