Environment Agency Cites “Alternative Measures” in Updated Fire Prevention Plan Guidance

The Environment Agency (EA) has updated its fire prevention plans (FPP) guidance for waste sites with examples of alternative measures that operators have put forward. The revised guidance stipulates if an operator wishes to offer alternative measures, they should discuss this with the EA.

The fire prevention plan must set out clearly what the alternative measures are, and how they will meet the 3 objectives. The 3 objectives fire prevention plans must meet are to:

  • Minimise the likelihood of a fire happening
  • Aim for a fire to be extinguished within 4 hours
  • Minimise the spread of a fire within the site and to neighbouring sites

In some cases, it may be necessary for a physical demonstration to take place or for the EA to visit the site to witness the demonstration. Alternatively, a demonstration can be filmed and timed before being sent to the EA to consider. Please find below a summary of one of the five case study examples of alternative measures proposed by operators.

Case Study: Exceeding Maximum Pile Sizes for Pre-Crushed Waste Wood

A waste wood operator wanted to store pre-crushed wood in piles sizes larger than the maximum sizes allowed under the fire prevention plans guidance. The operator proposed storing the pre-crushed wood for 120 days. There were concerns of mass self-heating, so the operator carried out a sieve test on a sample of the pre-crushed wood which revealed 10% of the sample contained fraction sizes less than 100mm.

As the smaller fraction size can lead to self-heating, a sample was sent for basket testing which revealed the time to ignition was 200 days. The EA were reassured mass self-heating would not occur within this timeframe because the operator agreed to not store wood for longer than 120 days. Despite this reassurance the EA still required the operator to have additional measures in order to deal with other common causes of fire.

Therefore, the operator also:

  • Used a thermal imaging system to detect hotspots within the pre-crushed wood stacks, with an appropriate trigger temperature.
  • Implemented good security measures to reduce the risk of arson.
  • Parked cars away from the stacks and washed them down at the end of each shift to reduce the risk of fire from wood dust coming into contact with exhaust pipes.
  • Employed an early detection system which used a thermal imaging system that would alert staff 24/7. Staff would be available 24/7 to use diggers and loading shovels to reduce stack sizes to ensure a fire could be extinguished within 4 hours.

The operator provided a timed demonstration which included the travel time for staff to reach the site.