Wood recyclers urged to give views on fire prevention plan
The Wood Recyclers Association (WRA), a trade body representing 80 per cent of wood recyclers in the UK, has asked its members to respond to a consultation on the latest fire prevention plan (FPP) guidance issued by the Environment Agency (EA).
It says that it has identified a ‘number of issues’ with plans to update the FPP guidance that will impose ‘unreasonable and unnecessary’ pressures on wood recyclers and could ‘make many businesses unviable’.
The original FPP guidance, issued in March 2015, includes new safety measures for the storage of all combustible materials, including several types of wood. It was developed by the EA in collaboration with the Department for Environment, Food & Rural Affairs (Defra) after a series of high-profile fires at waste sites, with the intention of reducing the possibility of such incidents in the future.
An EA consultation on the FPP guidance, which opened in November 2015, invites comments on the measures outlined within it and ‘proposals on changes’ to the current plan. The EA claims it will update and issue a new, revised FPP in Spring 2016 after considering the responses received.
Following an in-depth review of the FPP guidance, the WRA has highlighted issues within the plan it regards as a cause for concern. It is now asking its members to respond to the consultation before the closing date on the 4 March.
Key issues raised
The FPP guidance consultation outlines new fire prevention standards, which would apply to all operators storing combustible materials on their sites. These include having a site-specific fire prevention plan in place, which assesses fire risk and minimises its potential impact. All waste sites must implement these safety measures or face EA enforcement action. Each site must provide an explanation of why the minimum standards are not adhered to and, if required, put ‘equivalent or superior’ measures in place.
The WRA has highlighted several measures stipulated in the FPP guidance that it is concerned about, such as the new limitation of three to six months on the storage time for combustible material, implemented to minimise the risk of self-combustion.
The WRA states there is no scientific evidence for the specified times and believes the EA has not taken into consideration the seasonality of waste wood, which peaks during summer months due to over supply and lessens in the winter when there is higher demand.
This, according to the WRA is an industry-wide practice, which has been in place for some time. It deems the current guidelines ‘unpractical’ for biomass operators.
The stipulation on storage time would require the formation of an age audit trail for every load of wood, which the WRA claims would be impossible to implement and maintain. The WRA also disagrees with the claim that the storage of any sort of combustible material for more than a short period of time is an unacceptable fire risk, believing that each site should be assessed individually.
Moreover, the WRA says there is also no scientific evidence to warrant the required implementation of a maximum burn time of three to four hours, calling it an ‘unreasonable and unnecessary target’. Individual circumstances should be considered such as material types, tonnages, weather conditions and local fire-fighting strategy.
The ‘inability to deviate’ from the measures included within the FPP guidance is also a problem, according to the WRA, as only four out of the 80 permits applied for under the new regulations have been granted.
Reduced stockpile size
This measure included in the FPP guidance to reduce stock pile size, which the WRA claims has also been proposed without sufficient scientific evidence, was designed to reduce the likelihood of self-heating and fire and allow the use of standard machinery to move the waste during an incident.
The implementation of the new guidelines means that maximum sizes of processed and unprocessed wood stacks are now 33 and 167 tonnes, respectively.
The requirement for the maximum height of piles of unprepared wood to be reduced from 10 metres to five metres, with the maximum volume changing to 750 cubic metres, has already posed problems for some wood waste sites as they don’t have enough space on their sites.
Hadfield Wood Recylers temporarily shut down its Middlesbrough site in July 2015 due to threatened enforcement action by the EA. Delivery of wood to its Manchester site was also stopped.
Hadfield claimed these targets were ‘completely unworkable’ for larger operators, as they were much smaller than previous EA or WRA guidelines, did not allow them to fulfil the contracts they had in place and would result in an increase in landfill.
The WRA belies stockpile size should be assessed on a site-by-site basis.
WRA want to ensure “industry’s feedback is heard”
Calling on members to take part in the consultation, Andy Hill, Chair of the WRA, said: “The WRA is committed to safety, professionalism and protecting the environment and we agree fundamentally that operators should have fire prevention plans in place.
“Many of our members have already invested heavily to improve fire detection and prevention and other health and safety measures on their sites. We are the first waste stream to hold fire tests to help inform this process and we have helped and encouraged that process and are now awaiting the results.
"We are concerned that both the EA’s FPP guidance and the consultation were issued prior to the results of any fire tests being known, when those results will undoubtedly help to determine some of the answers to these questions.
“We are contacting all our members to support them in understanding the EA guidance and the consultation and encourage them to take part in the consultation to ensure our industry’s feedback is heard.
“We are also encouraging our members to write to their own local MPs to raise the issues that concern them about the draft FPP [guidance].”
The consultation on the fire prevention plan guidance is available at the Environment Agency’s website.