Waste management sites
Fires in waste sites can be significant incidents for responding fire and rescue services (FRS), environment agencies and other agencies. They can be:
- Very large
- Difficult to extinguish
- High profile
- Resource intensive
The effects of such fires can include immediate or long term harm to firefighters, the public and the environment.
The economic impact of resolving these incidents can be large, these impacts are not limited to operators, FRSs, EAs, local authorities and other responders. They may also affect local communities, businesses and the taxpayer due to the disruption and pollution caused. For more information see, Fires in waste sites.
Waste legislation and fire prevention plans
Fire officers should be aware that if some or all of the materials stored on a site are classified as waste, then waste legislation enforced by environment agencies will apply as well as any requirements under the Regulatory Reform (Fire Safety) Order. The legislation includes requirements for the operator of any permitted site storing combustible waste to produce a Fire Prevention Plan (FPP) which sets out how they will prevent and mitigate the impact of a fire on people and the environment. FRS should also be aware that the deliberate burning of waste on such sites is illegal unless the operator has a specific exemption issued by environment agencies. They should therefore report such incidents to environment agencies.
Environment agencies view fire prevention as pollution prevention and require operators to take appropriate fire safety measures, as part of the fire prevention plan. If these measures are not in place, they can refuse to issue a permit, revoke an existing permit and take other enforcement action against the operator.
The regulatory requirements for operators of sites storing combustible waste sites in England are set out in the Environment Agency’s Guidance Fire Prevention Plans: environmental permits. Its principal aim is to:
- Minimise the likelihood of a fire
- Increase the likelihood that the fire is extinguished within 4 hours
- Minimise the spread of fire within the site and to neighbouring sites
Similar guidance is offered by the Fire prevention and mitigation plan guidance (Wales).
The 4 hour rule reflects the recommended 3-4 hour time period for which sheltering in a building is effective in reducing people’s short term exposure to high levels of air pollution. After this period sheltering can become less effective. The timeframe is aspirational and only to be used as a guide. For more prolonged fires the shelter advice must be reviewed according to the level of risk to ensure that advice remains appropriate and reasonable.
If an operator submits a plan which includes all the measures set out in the FPP Guidance the environment agency is likely to approve the FPP.
Operators can however submit a plan to the Environment Agency with other fire prevention and risk reduction measures. This can include:
- Alternative fire prevention measures, if an operator can demonstrate that they can still meet the three objectives
- Demonstrating that the fire does not need to be extinguished within 4 hours because it is not close to sensitive receptors. The operator must still however meet the other two fire prevention objectives in the FPP guidance.
Joint working to reduce the risk
Given the shared interest of FRSs, EAs, other agencies and legitimate operators to prevent and mitigate the impact of waste fires, joint working is actively encouraged.
Working together should help to:
- Identify solutions considering the characteristics of the site
- Enable the operator to run a successful business
- Reduce risk to an acceptable level
Joint working should consider both fire safety and prevention and fire response plans:
- Fire safety measures include, good site security, site procedures and waste management arrangements, for example measures to reduce the risk of self-combustion
- Fire response plans, including fire suppression and containment systems and tactics to mitigate the impacts of firewater and smoke
Joint working can include information sharing, input to permit applications and joint site visits.
Joint working should also take place at high risk sites where the operator is uncooperative, or the site is illegal or abandoned. Information and intelligence about high risk sites in the local area should be shared between stakeholders. If an operator is uncooperative and will not follow good practice or the site is illegal, enforcement action may be considered. In such case the FRS, environment agencies and if appropriate other regulators such as the HSE or local authority should decide between them which agency is best placed to take action as well as the level of support needed from the other parties. For more information see waste crime.
More details on how the joint working between Environment Agency and FRS Officers should be undertaken in England is covered in Annex 2 Preventing Waste and Industry site fire of the EA/NFCC MoU.
The environmental impact of fires at bulk storage sites, such as stacks of used fridges, tyres or wood can be limited by applying restrictions on stack sizes and separation distances. The installation of appropriate fire suppression and pollution prevention systems as well the implementation of regularly tested emergency response plan agreed with the FRS and environment agencies can also help reduce the impact.
Risk Reduction Measures
In addition to the FRS and environment agency guidance to reduce and tackle waste fires, there is also the Waste Industry’s own guidance ‘Reducing Fire Risk at Waste Management Sites’, published by the Waste Industry and Industry Forum (WISH) and also promoted by the Waste Industry and Industry Forum Northern Ireland (WISHNI). The NFCC and Environment Agency are both members of the forum. The WISH guidance is a detailed document reflecting the wide range of hazards and risks on waste sites and the measures available to reduce them.
FRS officers involved with risk reduction work at waste sites should familiarise themselves with all associated guidance and the regulatory requirements for these sites. An aide memoir, that can be used as a check list, for officers assessing the specific risks to the environment from a fire storing combustible waste and identifying measures to reduce them is provided below.
Checklist for assessing the risk to the environment from sites storing combustible waste
1 Description of site
2 Open water and hydrants for firefighting
3 Access. Is access restricted by:
4 Environmental considerations
Air & Smoke
5 On-site personnel
6 Rendezvous point(s)
Location of FRS primary and secondary rendezvous points and incident command location bearing in mind the slope of the ground and prevailing wind.
When considering rendezvous points: