There are approximately 250 waste fires in England each year. In 2015, 74% of waste fire incidents were at permitted sites with poor OPRA (Operational Risk Appraisal) ratings. In response, the EA has made a Fire Prevention Plan (FPP) a requirement at the application stage for waste permits – not yet for established operators.
The latest guidance published in July 2016 assists operators in developing plans that consider the fire risk on site and implement suitable prevention and mitigation measures. There has been much debate about the guidance, and among this, it’s easy to forget the substantial social, economic and environmental impacts of waste fires.
Fires release pollutants harmful to people’s health and the local environment via smoke plumes and firewater. Waste fires have financial consequences for the local economy, by diverting fire rescue and other public services and closing roads; and to operators and their customers, through damaged property, increased insurance premiums and interrupted service provision.
At the moment, FPPs are only required by the Environment Agency (EA) for new permit applications or for operators requesting a significant permit variation, and for sites having recently had a fire.
While there is strong feeling in the industry that sites with a history of poor performance should be targeted next, it’s unclear what approach the EA will take. Even if an FPP is not currently required there may be operational and financial benefits to operators being an early, voluntary adopter.
FPP Guidance can be used to review current operations to reduce the risk of site fires and limit any impacts if one should occur.
The three main objectives of the FFP Guidance are to:
• Minimise the likelihood of a fire happening.
• Aim for the fire to be extinguished within four hours.
• Minimise the spread of fire within the site and to neighbouring sites.
Many of the issues the FPP Guidance covers are also worth considering for business-focused reasons. It can help increase business resilience, reduce reputational risk, cut insurance premiums, smooth the approval process once FPPs become mandatory for all and potentially improve OPRA scores – lowering an operator’s annual subsistence charge. It’s worth remembering that poor site management or negligence which leads to a fire could, in extreme cases, lead to prosecution – as seen recently in the case brought against Averies Recycling in Swindon.
There are a couple of areas that operators interested in early adoption should focus on, including site infrastructure, management, layout and operational procedures.
The guidance aims to make large piles of uncontained waste a thing of the past and the FPP site layout and infrastructure adjustments aim to help contain and extinguish a fire.
Potential changes could include reducing pile sizes, introducing separation distances or firewalls, and ensuring firewater supply and disposal facilities are in place.
Operators can minimise the financial and operational implications of retrospective installation if these design implications are considered at the start of their site search, especially in relation to the fire suppression system, water supply and fire water disposal. If site constraints prevent changes to layout or infrastructure, improvements to fire prevention and mitigation can be achieved through amending operational procedures or site management techniques to take account of fire risk.
Introducing robust equipment maintenance programmes, including identifying hot loads in waste acceptance procedures or specifying pile turning requirements for waste stored over certain time periods can help reduce fire risk and spread.
While early adopters may not be audited against their FPP until it is integrated into permit requirements, it is important to note that once it is a permit condition, compliance is necessary to operate legally.
FPPs should be designed not just for the immediate future but also be future-proofed, allowing for higher material throughputs or longer storage times, to ensure operations remain compliant.
Aspects of the FPP guidance that inform site modifications could improve elements of site operation as well as reducing the fire risk.
Once embedded, FPPs could make sites safer and cheaper to run through better management. There is no reason to wait to investigate setting up a FPP until it becomes mandatory for established sites.
Eunomia will be hosting a series of webinars on developing a compliant FPP in the coming months. For more information, email email@example.com. Crosswell works with public and private sector clients on planning and permitting consent, data analysis and regulatory compliance in Eunomia’s waste operations team