We’ve published our consultation response document on Gov.UK. This is a summary of the 161 responses that we received to the twenty one questions. We also explain our decisions and publish the data and evidence used to underpin these decisions. Some of the consultation questions generated a great deal of interest and a diverse range of views. We have balanced the needs of the waste industry with the need to protect the local community from the impacts of waste fires.
It was important that the guidance was thoroughly reviewed by independent recognised fire protection experts, and we commissioned Building Research Establishment (BRE) Global to carry this out. This review is published as an appendix within the consultation response. In addition to providing a range of test results which underpin the FPP guidance, the BRE Global report also provides a detailed explanation of thermal ignition theory and the science which determines whether wastes self-combust.
One of the key objectives of our FPP guidance is to aim for any fire on a site to be extinguished within four hours, where the site is near to a local community. We continue to see waste fires, which cause unnecessary impact on the public, critical infrastructure and the environment. All smoke is harmful if inhaled, and raising awareness of both the likely combustion products in smoke and also their impact on human health is something that as a regulator we are keen to address.
The consultation response document explains why exposure to smoke, even for a short period of time, can be harmful and which groups of people are most susceptible. We also explain why four hours is the maximum duration which we believe that local residents, especially those in vulnerable groups, can be expected to shelter indoors. Overtime sheltering can become less effective if outdoor concentrations remain high. In the response document, we list the major fires where we have worked with partners, to model, sample, monitor and interpret real-time air quality data, to predict the impact on local communities.
We also provide a copy of our own incident data for hundreds of waste fires which we have responded to over the last few years. This includes information on waste types, volume/ tonnage of material, incident duration and active fire-fighting. This information clearly shows that fires on sites which are operating within the minimum standards set out in the FPP guidance, can be extinguished within four hours and thereby reducing the impact on the local community. This is one of the reasons why we will be phasing in the requirements of FPP guidance, across all existing 7,000 sites storing combustible wastes, over the coming years.
Proposing alternative measures
Version 3 of FPP guidance aims to provide greater flexibility and proportionality in how operators reduce the risk of fire at their sites. We recognise that every site is different and so operators can propose alternative measures to those set out within the guidance, if these measures mitigate the risk of fire in an appropriate way then we may allow them to be introduced instead.
Recently we have approved an FPP at a waste transfer station in the South East of England that stored of 100m3 of light wastes within a container inside a three sided metal building overnight. The container which stored the waste was accessible from the open side of the building.
The Environment Agency worked with the company to agree site specific measures to address the risk this posed.
The company agreed that they would:
- Monitor the waste at end of each day for hotspots using IR thermometer
- If the stockpile passed the hotspot assessment it was would be covered using BS476, part 20 fire blanket to prevent any source of ignition coming into contact with waste overnight. The blanket is on a winch which can be operated from outside the building
- This waste will be stored for a maximum of 48 hours prior to removal from site.
- Any fire in this stockpile will be smothered using inert soils (adequate pile of soils is stored adjacent to this waste) but there is also adequate water supply on site.
- In addition the company also supplied measures for regular inspection of the fire blanket and winch or replacement if necessary. A smoke alarm placed close to stockpile and the site has 24 hour security & CCTV.
These measures were deemed to have appropriately addressed the risks of storing this amount of waste in a building at this site. However, measures will be assessed on a site specific basis and therefore these particular measures may not be suitable at another site. If you think you might need to take site specific measures to address fire risk at your site then please speak to your local area officer.
Business Impact Target Update
As we have mentioned previously, we conducted a survey before Fire Prevention Plans Version 3 was published, which we received a total of 56 completed responses from operators in a range of sectors. This information is being used to carry out a cost-benefit analysis in relation to the changes we have made to our Fire Prevention Plans guidance. Now the revised version has been published, we are seeking some further information to help us complete this assessment.
The further information we are asking for as part of this survey is needed to finalise our calculations; we will not need any further information after this survey. Once received, the economists supporting us with this exercise will check the data and calculations, before we then send our final report to the Regulatory Policy Committee. We expect this to be completed in October.
We have been at RWM this week talking about fire prevention plans. Senior Advisors James Finch and John McCarthy gave a presentation to delegates at the Local Authority Theatre on Tuesday 13 September.
The presentation focussed on how the guidance will reduce the frequency and impact of waste fires on public health and the environment; as well as exploring the rationale behind the 4 hour burn time, the science and evidence underpinning the guidance and the flexibility within our approach.
John McCarthy Senior Advisor said:
‘Presenting at the RWM conference was a great opportunity to engage with industry on our revised Fire Prevention Plans guidance.
We set out the 3 fundamental objectives of the guidance, and how the measures will enable operators to achieve them. We also set out the science and evidence which underpins those measures.
We hope the audience left with a better understanding of why the guidance is so important for the protection of public health, but also with some reassurance that there is flexibility built in, and it will be applied in a risk-based and proportionate manner.’
Additional articles relating to this presentation can be found at the links below:
Final FPP Bulletin
This is the final e-bulletin relating to the current Fire Prevention Plan guidance. We hope that you have found these updates useful. If you have any feedback on this e-bulletin then please email us