The Wood Recyclers Association (WRA) has raised concerns about the Environment Agency’s guidance on fire prevention plans. The trade body, which represents 80% of wood recyclers in the UK, is urging its members to respond to a consultation before the deadline.
The Fire Prevention Plan (FPP) guidance sets out the minimum regulatory standards expected of operators of permitted waste sites that are storing combustible waste. The Environment Agency is updating the current guidance, which was produced in response to a number of high profile fires at waste sites and to assist action to tackle waste crime. The guidance requires permitted waste sites to have a fire prevention plan to reduce the risk of fire and minimise the consequences of an incident on the local community.
The Environment Agency is proposing some changes to the requirements and has asked for views on the principles of the updated guidance. Following an extensive review of the consultation documents, the WRA has raised a number of concerns about the guidance, which have no scientific backing. These include:
• A maximum burn time of three to four hours. The WRA says this proposal does not 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. The WRA says there is no scientific evidence to support the rotation of waste wood stock on this basis. It says no consideration has been given to the seasonality of the waste wood market place, which peaks with stock in the summer due to over supply, followed by a peak in demand during the winter months due to off-take from biomass, panel board and animal bedding.
• The reduction in stockpile sizes for internal and external stacks. The WRA believes stockpile sizes should be assessed on a site by site basis and says that this reduction will make many businesses unviable because they will be unable to store the amount of material required to operate their business on the land they have available.
• The inability to deviate from the minimum standards outlined in the FPP. The WRA feels this is wholly unreasonable and believes the EA needs to work with operators on an individual basis taking into account local circumstances, which means allowing for deviations.
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.”
Those wanting to take part have until 4 March 2016 and new guidance will follow in the spring. To read the consultation document or to give your views, visit the consultation page on the Environment Agency website.
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