The Environment Agency is reviewing its waste site fire prevention guidance.
There is also significant impact on the waste business itself, which is likely to lead to a loss of trade, while some waste fires have been so severe that they have forced businesses to cease trading.
In response to the large number of waste fires in recent years, the Environment Agency (EA) has reviewed its standard rules environmental permits and introduced permit conditions for fire prevention plans (FPPs) where combustible waste is being stored.
Having previously worked as an environment officer regulating facilities across a rangeof waste sectors, I have seen first-hand the devastation that fires cause, and the time and resources it uses from those responding to the incident: fire and rescue services, police, councils, the EA and Public Health England.
So while there has been a mixed reception to the FPP guidance, I think all involved would agree there is a need to implement measures that successfully prevent, detect, suppress, mitigate and contain fires on waste sites. This is to ensure that, in the unfortunate event of a fire, they are extinguished quickly and with minimal effect on nearby surroundings and the waste management business itself (see also Equipment round-up, page 29).
The FPP guidance is currently under review following a period of consultation. We wait to see what changes this will bring, as well as the results of fire tests that have been undertaken to determine burn rates, stockpile sizes and separation distances by various regulatory authorities and trade associations. There are two key issues that waste sites will face when the revised guidance is implemented.
The first is sufficient space: the key to fire prevention is how waste is stored and for how long. In order to implement the recommended stockpile sizes and separation distances for combustible waste, potential sources of ignition and off-site receptors, waste sites will need considerable space. Where space is limited, consideration can be given to a change in operations by reducing stockpile sizes and storage times, turning and monitoring stockpiles to prevent combustion, and using bays or push-walls to act as thermal barriers.
At present, the guidance applies to indoor stockpiles, and many companies may find it difficult to implement the minimum separation distance of 6m at their sites. The proposed guidance will remove the requirement for the separation distances for indoor storage, but will place the onus on the site to have a suitable detection and suppression system that will be able to extinguish a fire within the building in a maximum of three to four hours.
The need for fire suppression systems within buildings brings with it further issues such as the need for an adequate water supply. This may need the installation of water storage tanks, which again require space on-site. Waste facilities also need to make allowance for ‘quarantine’ areas that can be used in the event of a fire to either spread out burning waste for fast extinguishing or to move stockpiles away from those on fire. The guidance stipulates that the quarantine area should be 10m away from other routine waste storage areas.
Sites also need to be able to contain firewater using bunds or lagoons, and sufficient space needs to be set aside for pollution prevention.
The second issue is capital expenditure. In common with all legal compliance issuesand matters of good business stewardship, waste operators will need to allocate sufficient funds or investment into the running of their site to ensure ongoing compliance with the FPP guidance.
Some businesses may find the initial outlays difficult to fund when considering the cost to install fire suppression systems such as sprinklers, water spray systems or water curtains, and providing containment facilities for firewater run-off, although the precise measures taken will depend on the types of waste accepted and the surrounding conditions, which vary from site to site.
In my experience, by increasing the level at which the compliance bar is set, it is more likely to have an effect on which companies remain in business and force the closure of others. It is foreseeable that many smaller waste facilities are likely to find it increasingly difficult to implement the FPP guidance because of the constrained nature of their sites and the lack of economies of scale that the larger waste industry players can take advantage of.
In time, we may see a trend towards larger waste sites that operate at the upper end ofthe standard rules environmental permit throughputs of 75,000 tonnes a year. It could also become the norm that larger waste sites – occupying between five and 10 acres – will be located out of towns and away from sensitive environmental receptors rather than have smaller sites in more vulnerable locations. For all waste businesses, the key to success is to process waste quickly and efficiently to prevent a build-up of stockpiles and ensure that there are multiple outlets for each waste stream to account for market changes. Well-managed and efficient sites will already be compliant with the guidance and adjust easily to the new regime, but there will be some businesses that for whatever reason cannot operate in a safe and proper manner.
Since 2013, there has been a collaborative effort from the waste management and insurance sectors, alongside strategic leaders from fire and rescue services and central and local government departments, to achieve consensus on key issues following more than 50 major waste fires in the sector in the past few years.
As a consequence, many insurers are selective about what they will insure and many have withdrawn from the market altogether. Those who remain want to understand what their exposure is, and the introduction of the Insurance Act places the onus of accurate risk declaration on both parties.
The upshot of the introduction of FPPs could be the reassurance that insurers need to encourage them back into the market. But establishing an accurate value of risk is also paramount to insurers, particularly due to recent rises in construction costs. So it is hoped that this new EA requirement, combined with proactive risk management, will ensure a mitigated risk by all parties.
Some of the smaller sites that struggle to implement the FPP guidance may well have to change their function, perhaps becoming transport hubs with minimal processing/waste retention, although they are likely to require further capital expenditure. In some parts of the UK where land values are high, there may be a shift away from waste management activities towards alternative higher value land uses, which could assist in the promotion of urban regeneration.
Helen Bayliss is principal due diligence consultant at Bilfinger GVA