Fire Protection and the Machinery Directive for Goods Lifts

• 1. Standards and Regulations in Conflict
• 2. Fire Protection in Goods Lifts
  • 2.1 Connection Between Fire Compartments
  • 2.2 Implications for Access Doors
• 3. Safety Technology from the Perspective of the Machinery Directive
  • 3.1 Requirements for Access Doors
  • 3.2 Typical Components
• 4. The Technical and Regulatory Conflict
• 5. Practical Solution Approaches
  • 5.1 Specialised Door 
  • 5.2 The Vestibule as a Planning Concept
• 6. Conclusion

During the planning and implementation of goods lifts, building regulations and the Machinery Directive come into direct interaction. Both sets of regulations pursue different protection objectives — particularly in the area of lift access doors.

While building regulations primarily govern the fire protection of buildings, the Machinery Directive focuses on the functional safety of the lift system. In practice, this often results in requirements that are difficult to implement using standard solutions.

A goods lift often connects multiple structurally separated areas within a building. As a result, connections are created between different fire compartments, which must be taken into account in the fire protection concept.

As a general principle, the lift shaft is assigned to a defined fire compartment. Openings to adjacent fire compartments must therefore be appropriately protected. Typical solutions include fire-resistant or fire-rated closures such as T90 fire doors.

The access doors at the lift landings therefore perform a critical fire protection function. Even minor modifications — such as the addition of extra components — can affect the regulatory approval of the fire door or, in the worst case, invalidate its certification.

From the perspective of the Machinery Directive, goods lifts are classified as machines. This results in several requirements for the access doors, including:

• Access doors must remain securely locked as long as a hazard exists.
• The locking mechanism must be monitored electromechanically.
• The safety function must achieve a defined Performance Level (PL) in accordance with EN ISO 13849-1.

Suitable safety interlocks and locking systems are available from various manufacturers, including:

• Schmersal
• Bernstein
• Euchner

These components are designed for machine safety applications, but they are not automatically approved for use on certified fire-rated doors.

In practice, a fundamental conflict often arises between fire protection requirements and machine safety.

Standard door locks supplied by fire door manufacturers frequently do not meet the safety-related requirements of the Machinery Directive, particularly with regard to the required Performance Level (PL). Conversely, retrofitting additional safety interlocks to a fire-rated door may affect or even invalidate the door’s regulatory approval.

As a result, standard solutions are often unable to satisfy both fire protection and Machinery Directive requirements at the same time. This frequently leads to custom-built solutions, increased coordination efforts between all parties involved, and potential delays during inspection and approval processes.

To meet the different requirements simultaneously, various solution concepts have become established in practice.

Particularly in buildings with complex technical and regulatory requirements, the vestibule concept can help reconcile technical, legal, and economic considerations.

It is a proven and well-established planning concept for goods lifts in fire protection–relevant buildings. By clearly separating building regulation requirements from Machinery Directive requirements, conflicts can be avoided, coordination processes simplified, and economic advantages achieved.

The most suitable solution ultimately depends on the specific building type, intended use, and available space. In many projects, however, the vestibule concept offers significant advantages in terms of planning reliability and practical feasibility.