Certain sectors of the waste industry have voiced their concerns about how workable the EA’s fire prevention plan (FPP) guidance is to businesses operating in the sector and warn there will be business casualties.
Robert Fell, chief executive of the British Metals Recycling Association (BMRA), has called FPPs the “biggest issue of my tenure”.
He said: “With restrictions on distances between piles and pile sizes, for example, I believe that it will be those scrap yards with the space to comply or the ability to embrace alternatives such as an increased use of bays that will prevail.”
Howard Bluck, BMRA technical director, added: “The BMRA is working with consultants to better understand the root cause of fires at metal recycling facilities, and to analyse those FPPs that have been approved by the EA. As it stands, it may not be cost-effective for some metal recycling facilities to take measures necessary to meet the current EA guidance.”
Currently, operators have to apply for FPPs only if they are applying for a new permit, renewing a permit, extending a permit or have had an incident on-site. But all operators will eventually be required to have an FPP. From 1 April 2018, such plans will cost a fixed charge of £1,241.
The EA told MRW it approves around 300 FPPs a year. A spokesman said: “The vast majority of these plans allow for alternative fire prevention measures, provided the main objectives of minimising risk are met.”
The Wood Recycler’s Association (WRA) told MRW it did not know of any member that had a non-standard FPP approved which “contained measures vastly outside of the standard FPPs”. It added: “This is where the concerns lie and is the next piece of significant work we need to do with the EA – to determine what the list of alternative acceptable measures are for operators needing to move away from the standard.”
The WRA developed a draft wood FPP template for members to use as guidance earlier in 2017, but said this had faced setbacks after feedback from the EA. It attributed this largely to “changes of personnel within the EA which has delayed them in being able to put the resources into looking at the alternative measures”. But it remains hopeful that its template will be published in 2018 with the EA’s approval.
The Tyre Recovery Association (TRA) also submitted a sector-specific template to the EA a few months ago, and is awaiting a response. Peter Taylor, TRA secretary general, said the original guidelines – which he emphasised are guidelines as opposed to regulation – “would simply have put most of us out of business because our sites aren’t that elastic, and what they were asking for would have drastically reduced site capacities”.
Its proposed modifications included stack heights, sizes, separation distances and better use of bunkering. It also takes issue with the fundamental assertion that tyres self-combust, which Taylor dismisses as “ridiculous”.
He added that the EA lacked commercial awareness and warned that “regulation without enforcement is no answer at all”. He wants to see exemptions outlawed for tyres, as is the case in Scotland, and would welcome a system of earned responsibility.