The consultation period looking at proposed Fire Prevention Plan (FPP) guidance issued by the Environment Agency recently ended. This has been a contentious issue among many in the waste and recycling sector since it was introduced in 2015, says Andy Hill, chairman of the Wood Recyclers Association…
Anyone working within the waste sector, handling materials that have the potential to combust, will be familiar with working with a fire prevention plan. No one in their right mind could argue that such a plan – something that is there to protect not only the public and the environment, but ultimately our own businesses – is not an essential part of our everyday working lives.
The problem does not lie in the fact that FPP exists, but instead in what the guidance requires business to do. Is the guidance reasonable? Does it take into account individual circumstances? Is it realistic? Is it workable?
Prior to the latest FPP guidance being issued in 2015, we had been working closely with the Environment Agency (EA) to advise on this guidance and we had hoped we were making progress in getting them to understand our position and that of our sector. Unfortunately, a number of fires at waste sites then occurred over a relatively short period of time and suddenly everything we thought we were working towards was disregarded. FPP was issued in March last year, replacing its predecessor TGN7.01 and completely ignoring any comments or thoughts we had previously provided.
For many, the initial introduction didn’t pose a problem. But as more and more wood sites applied for permits it became apparent that some of the key elements of the latest FPP guidance were going to make it almost impossible for many businesses to survive.
The Main Concerns
Our key concerns about FPP are centred around a number of issues, the mains ones being:
- a three-to-four hour proposed burn time, which has no scientific backing and which we believe is an unnecessary target that doesn’t take into account individual circumstances such as tonnages, material types, weather conditions and the local fire-fighting strategy
- the rotation of waste wood stock on a three-to-six month basis, which the EA has no scientific evidence to support. No consideration has been given to the seasonality of the waste wood market, which peaks with stock in the summer, and peaks in demand during the winter months due to off-take from biomass, panel board and animal bedding
- a reduction in stockpile sizes for stacks that has no scientific backing. We believe such sizes will make many businesses unviable because they won’t be able to store the amount of material they require to operate their business.
The inability to deviate from the minimum standards outlined in the FPP, which we feel is unreasonable when operators are willing to implement additional safety and security measures.
We believe the tactics to tackle a fire should be a Fire & Rescue Service decision, rather than an EA decision. Our industry has spent hundreds of thousands of pounds over recent years updating and improving sites with the latest equipment and techniques to prevent and detect fires and we are committed to doing that going forward.
Our point is not that we want to operate a cowboy industry, putting the environment and people’s lives at risk. Instead, we want to create and develop a professional waste and recycling sector; a sector that helps build the UK’s economy; which stands proud and able against our counterparts in Europe; a sector that helps the UK Government reach its recycling targets and beyond.
But to do that we need the EA to work with us, not against us. We need it to understand the restrictions we face and why we face them, and to work with us and the Fire Service to overcome the those hurdles.
We hope the consultation will result in common sense prevailing and a workable solution being found to the benefit of everyone concerned. We await the results with interest.<
Andy has worked in the UK organics and alternative fuels sectors for over 11 years, with the last seven years at SUEZ UK. Andy’s particular focus is on the commercial development of alternative fuels for the wood, RDF and SRF markets.
The views expressed here are those of the author.