Fire Prevention at Waste Sites: How the Guidance is Evolving

For those involved in life safety fire risk assessment, the idea of a fire-risk assessment to protect the environment may seem a little strange.

But that’s precisely what is required of most businesses which store or treat combustible waste.

What’s the story?

It’s believed that there are fire and rescue call outs to on average one fire per day at waste and recycling sites within the UK. And once fire takes hold in a waste pile, it can take weeks to bring under control.

For example, as we reported in 2012 a man was jailed for two years for allowing a fire to take hold at a site in Dewsbury which then burned for over a month. The cost of the clean-up and fire-fighting operation was estimated at £1.2 million. There have been numerous similar examples in the news.

The environmental impact of such fires can be considerable involving contaminated fire-fighting water which may reach ground water our surface water courses, air pollution and ground contamination in the vicinity. Environment Agency research based on 25 waste fires has concluded that there is a potential that people can be affected within a radius of at least 1km of the site where the fire occurs.

They have also concluded that the harmful health effects are more pronounced where a fire continues for more than 3 or 4 hours. This is based on the expectation that the public can take shelter for a few hours, but beyond that they are more likely to be exposed to the harmful smoke, suffering from sore eyes, runny nose, sore throat, coughing, difficulty breathing, nausea and vomiting.  The greatest risk is to the elderly, children and those who already have a respiratory illness, for example asthma and bronchitis.

Regulatory approach

The Environment Agency has issued guidance which applies to all those who hold, or are applying for, a permit to store or treat combustible waste. (The permits are issued under the Environmental Permitting (England and Wales) Regulations 2010). There are also other situations when the EA may specify that a fire prevention plan is required.

The EA recommends that operators who are exempt from the requirement for a permit, but who store combustible wastes, should also the guidance and take from it the relevant principles.

What’s in the guidance

“Fire Prevention Plans” (version 2 March 2015, which replaced the previous TGN 7.01) sets out in detail what is required of the plan, i.e.:

• the types and quantities of waste stored
• hazardous substances
• sources of ignition
• site layout including any environmentally vulnerable features and access routes for both normal and emergency use
• an assessment of fire risk
• storage methods and management arrangements
• measures to prevent fires from starting
• details of monitoring arrangements and fire detection
• details of fire-fighting arrangements
• emergency procedures
• environmental protection measures such as the collection of fire-fighting run-off.

The types of combustible materials to be assessed include paper, cardboard, plastics, rubber, wood, textiles, scrap metals, waste electrical equipment, compost and more.

The guidance includes plenty of practical details about storage methods including maximum pile sizes, separation and rotation.

Flexibility

This “guidance” is highly prescriptive and although you can choose to do something different you must show that your plan is just as good or better for the environment.  This will entail detailed “modelling assessments” to demonstrate the likelihood of fire, expected impact and the emergency response required. Due to the expense associated with bespoke plans, for most businesses, following the guidance is the most attractive option.

The future

The EA has undertaken a consultation on the effectiveness of the guidance issued in March 2015. This consultation is now closed, and it seems that we won’t hear more about the EAs plans until the end of 2016. It says that has co-funded a series of “waste fire burn tests” along with the Waste Industry Safety and Health forum (WISH) to find out more about the behaviour of waste when it burns. The results of this research are anticipated later this year, and will then be considered along with the consultation responses to amend the guidance.

However, based on the contents of the consultative document it appears that the majority of the changes will be minor. It seems that the essential structure of the guidance is likely to remain unchanged and that specific points might alter, e.g. setting a minimum separation distance of 6 metres for all waste types, reducing the maximum pile size permitted for wood waste, requiring plans to include environmentally sensitive localities and so on.

Tell us what you think

If you work in the waste sector we’d be interested to hear your comments below on your experiences of fire prevention planning and the application of this sector guide.