The need for businesses that store combustible waste to submit fire prevention plans (FPPs) for their sites is seeing wood recyclers struggle to meet Environment Agency (EA) requirements. So what is causing the hold up?
The EA has set out three objectives that an FPP must meet: minimise the likelihood of a fire happening; aim for a fire to be extinguished within four hours; and minimise the spread of fire within the site and to neighbours.
To demonstrate compliance with those objectives, the EA makes clear recommendations about what that FPP should cover in their guidance. This includes (but not exclusively) activities carried out, site layout, types and amounts of waste stored, methods for storing each waste type, maximum volume of each waste pile, fire detection methods, water supplies and fire-fighting techniques.
In theory, if wood recyclers work through the EA guidance, apply the given structure and provide evidence under each prescribed point, then they will receive their approved FPP. In practice, the ‘one size fits all’ approach to FPPs presents significant challenges for different sectors of the waste industry because they all face their own operating constraints and practical considerations.
Under FPP guidance, stockpiles may not exceed a given footprint or height. With the challenge of seasonal fluctuations in supply and demand, wood recyclers may need to store greater quantities than the FPPs allow in order to be able to fulfil their contracts.
Without being able to stockpile in summer, when the demand for fuel is lower while the risk of fire is obviously greater, wood recyclers cannot provide continuity of supply. This conflict is causing one of the main sticking points in the approval of FPPs for the sector.
To overcome the challenges of individual sectors, the EA allows companies to propose ‘alternative measures’ for fire prevention and mitigation at site. These are assessed against the requirement to reduce the fire risk of the activities to an appropriate level, and to meet the three objectives outlined.
Assessing alternative measures places significant responsibility on EA officers who are not necessarily empowered or have the practical skills to analyse proposed divergence from FPP guidance. The effects of this are compounded by local priorities and pressures, which can result in inconsistencies in approval of certain alternative measures in different areas.
“The ‘one size fits all’ approach to FPPS presents challenges for different sectors of the waste industry because they face their own operating constraints and practical considerations.”
As a result, the assessment of alternative measures is often a protracted process which not only takes longer but uses more EA resources at an increased cost to the operator. So it’s a catch-22 for wood recyclers.
In fairness, the EA is also caught between a rock and a hard place. FPPs are one of the few documents that the agency is required to ‘approve’ which brings with it its own pressures. Failure to approve or delays in approving FPPs creates conflict within sectors that the EA oversees. Approving plans that could potentially fall short in practice negates the purpose of FPPs and could result in catastrophic incidents.
With some sectors of the waste industry so vulnerable to fires, FPPs undoubtedly have a role in protecting businesses and minimising fire risk. What is also evident is that dialogue is needed to break down the barriers to obtaining approval and to speed up the process, while achieving the shared goal that FPPs are fit for purpose.
Andrew Lake is senior consultant at Wiser Environment and former FPP technical specialist for the EA