Guidance

Fire prevention plans: environmental permits

Updated 11 January 2021

You can use our fire prevention plan template to develop your plan. You do not have to use it, but if you do, it will help you produce a plan that follows this guidance.

1. Fire prevention objectives

The fire prevention measures in this guidance have been designed to meet these 3 objectives:

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

Minimising the likelihood of a fire happening is the highest priority to prevent environmental harm.

You can use our enhanced pre-application advice service to discuss your fire prevention plan before you submit it. We can explain the level of technical detail needed and assess whether your plan can meet the 3 objectives. You will need to pay for this service. Use the pre-application advice form to request our advice.

If you think any measures in this guidance are not relevant to you, or you want to propose alternative measures, you should discuss this with the Environment Agency.

You can propose:

  • alternative fire prevention measures – if you can demonstrate you will still meet the 3 objectives
  • that you do not need to extinguish a fire within 4 hours at your site, for example because it is not close to sensitive receptors – but you must still meet the 2 other fire prevention objectives

Contact the Environment Agency as soon as possible if you want to propose either of these options.

Your fire prevention plan must set out clearly what your alternative measures are and how they will make sure you meet the 3 objectives.

We will ask you to demonstrate that your alternative measures can meet the 3 objectives. In some cases we may ask you to carry out a physical demonstration. We may visit your site to watch you carry this out, or we may ask you to film a timed demonstration and send it to us.

We have provided some case study examples of alternative measures.

If you follow the measures in your fire prevention plan it is likely you will be able to operate in a way that meets the objectives of this guidance. Where this is not the case, your permit will include a condition that requires you to use all appropriate measures to comply with the objectives of the guidance. This may mean you will need to use additional measures to those in your fire prevention plan.

Existing permits will either:

  • have a specific condition requiring you to take appropriate measures to prevent fires on site and minimise the risk of pollution from them, including but not limited to those measures in an approved fire prevention plan
  • require you to maintain a fire prevention plan as part of your written management system which identifies and minimises the risks of pollution from your operations

If you do not put in place and use your fire prevention measures, the Environment Agency may take enforcement action.

This guidance does not replace statutory requirements or other applicable legislation. It is your responsibility to check which statutory requirements apply to you.

2. Who this guidance applies to

This guidance applies to operators that accept any amount of combustible waste.

This guidance may also apply to storing combustible waste that takes place as part of a storage and treatment process. If you are unsure whether it applies, contact the Environment Agency for advice.

Whilst this guidance applies to all combustible waste, some wastes will have such low combustibility that you may not need to take specific measures to comply with the 3 objectives.

You will not need a fire prevention plan if both of these apply:

  • you only store waste with low combustibility
  • we are satisfied that you can meet the 3 objectives without using any of the measures in this guidance (or alternative measures)

If you store waste with low combustibility and other combustible waste you will need a fire prevention plan. If we are satisfied that you can meet the 3 objectives for the waste with low combustibility without using any measures, you must mark on your site plan where you store this waste.

This guidance applies to operators from these sectors:

  • waste metals (end of life vehicle (ELV) sites and scrap metal)
  • non-hazardous waste
  • waste electrical and electronic equipment (WEEE) – both hazardous and non-hazardous WEEE

It also applies to operators in any of these sectors but you may not have to include all of your activities in your fire prevention plan:

  • biowaste treatment (open windrow, in-vessel composting and dry anaerobic digestion)
  • agriculture (intensive farming only)
  • incineration
  • combustion
  • paper and pulp
  • cement lime and minerals

If you’re in one of these sectors, contact the Environment Agency for more information.

2.1 When we will ask to see your fire prevention plan

We will request to see and approve your fire prevention plan if:

  • you are making a new permit application
  • you are varying an existing permit and this could lead to an increased fire risk
  • there is a serious risk of a fire occurring, or we have serious concerns about the fire risk posed by your operation

We may request to see and approve your fire prevention plan if:

  • you are transferring a permit
  • there is a fire incident on your site
  • there is a risk of a fire occurring, or we have concerns about the fire risk posed by your operation

If required, you must send your fire prevention plan to the Environment Agency for approval and you must implement it as approved.

2.2 A risk-based approach

Not all sites will present the same level of fire risk. We will assess each fire prevention plan on a site by site basis, based on the nature and scale of the waste management activity and its associated risks.

3. Who this guidance does not apply to

This guidance does not apply to:

  • landfilling
  • biowaste treatment (wet anaerobic digestion)
  • biowaste use (land spreading)

This guidance also does not apply to the storage of coal, materials, or wastes that are:

This guidance does not apply to non-waste materials such as gas cylinders, aerosols and combustible liquids. They are covered by Guidance for the storage and treatment of aerosol canisters and similar packaged wastes: addendum to S5.06. However, you must still consider these in your fire prevention plan because they can cause or increase the impact of fire on a site. For example, you may need to use separation distances to manage the risk from these materials.

If you are not sure if this guidance applies to you, please contact the Environment Agency.

4. Types of combustible waste

Combustible waste includes:

  • paper or cardboard
  • plastics
  • rags and textiles
  • scrap metals contaminated or mixed with other waste such as oils or plastics
  • de-polluted and un-depolluted ELVs
  • refuse derived fuel (RDF) and solid recovered fuel (SRF)
  • compost and plant material
  • biomass
  • mixed waste containing any combustible wastes
  • WEEE

If non-combustible waste is contaminated with combustible waste we will generally regard the whole pile of waste as combustible, unless you can demonstrate that this is not appropriate.

The following are also types of combustible waste.

4.1 Rubber

This could be natural or synthetic and includes:

  • whole tyres
  • baled tyres
  • tyre shred, crumb and fibre

4.2 Wood

This includes:

  • planks
  • boards
  • sawdust
  • shavings
  • logs
  • firewood or chips
  • wood joined to form crates, pallets, casks or barrels

4.3 Fragmentiser waste

This includes waste from:

  • processing ELVs
  • plastics and metal wastes from materials recovery facilities

4.4 WEEE

All WEEE, including:

  • fridges
  • computers and televisions containing combustible materials such as plastic (including any batteries within this equipment)

These lists provide examples of combustible waste and are not exhaustive. If you’re not sure what to do contact the Environment Agency for advice about:

  • other materials and activities not listed in this guidance
  • whether you need a fire prevention plan

4.5 Persistent organic pollutants

Persistent organic pollutants (POPs) can be present in waste and can have significant effects on human health and the environment. They are subject to the POPs regulations 2019 – UK SI.2019 No.1099, implementing Regulation (EU) 2019/1021. These regulations specify the appropriate treatment for the recovery and disposal of POPs.

You should identify if any wastes on site contain POPs.

If a waste type is likely to contain POPs, then you must assume that it does unless you have evidence to prove otherwise, for example, through analysis.

You should segregate waste containing POPs from other waste and store it separately. You should mark the location of waste containing POPs on your site plan.

If there is a fire, you must tell the Fire and Rescue Service (FRS) that there are wastes containing POPs on site. If there is a fire involving POPs waste then any residue from the fire may contain POPs and so will need to be segregated and treated following the POPs regulations. This could include firefighting water.

5. Using your fire prevention plan

Your fire prevention plan forms part of your management system. It sets out the fire prevention measures and procedures you must put in place and use on your site. Your fire prevention plan should be a standalone document within your management system so that you and your staff can easily refer to it.

During an incident, you should show the FRS your fire prevention plan, if it is safe and practical to do so.

All staff and contractors working on site must understand the contents of the fire prevention plan so that they know what they must do:

  • to prevent a fire happening
  • during a fire if one breaks out

You must train your staff. In your fire prevention plan you must explain what the training will cover and how often it will happen.

You must carry out regular exercises to test how well your fire prevention plan works. Set out in your fire prevention plan how often you’ll carry out these exercises and what the training will consist of.

The exercises must include but not be limited to:

  • what staff need to do to prevent a fire occurring
  • what to do during a fire if one breaks out
  • anything site specific you consider is required

You need to design your exercises to fully test your fire prevention plan – they will normally need to be more than a simple fire evacuation drill.

You must keep your fire prevention plan under regular review and revise it where necessary for example if:

  • there is reason to suspect it no longer meets the objectives of the guidance
  • you have a fire or identify a near miss of a fire
  • you change your activities
  • the environment you are operating in changes, for example if a school or residential development is built nearby
  • we ask you to revise it due to some concern over the risk posed by your operation

If you revise your fire prevention plan, you must send your revised plan to the Environment Agency to approve. You must implement the approved, revised plan.

6. Fire prevention plan contents

Your fire prevention plan must set out all the measures you will put in place to reduce the risk of a fire breaking out.

You must identify all the possible causes of a fire at your site. You must then set out the measures you will put in place to address those fire risks. These measures will depend on the activities you are carrying out. The Environment Agency expects your plan to include the measures covered in this guidance or alternative measures that still meet the 3 objectives.

You must consider any additional fire risks posed by both:

  • planned events – such as planned downtime
  • reasonably foreseeable unplanned events – such as temporary site closure

6.1 Activities at your site

Your fire prevention plan must provide details of the different types of activities you carry out at the site. You must explain where you do it, how you do it and what machinery is used. This includes your waste management activities but also any other activities that could be a fire risk.

6.2 Site plans and maps

Your fire prevention plan must include a site plan(s) that is drawn to a scale that is large enough to clearly identify:

  • the layout of buildings
  • any areas where hazardous and flammable materials are stored on site (location of gas cylinders, process areas, chemicals, piles of combustible wastes, oil and fuel tanks)
  • all permanent ignition sources on your site and show they are a minimum of 6m away from combustible and flammable waste
  • any areas where you are treating or storing combustible waste or combustible non-waste material
  • all separation distances
  • any areas where you are storing combustible liquid wastes
  • any area where depollution of ELVs take place
  • any area where crushing, shredding, baling of metals or ELVs take place
  • main access routes for fire engines and any alternative access
  • access points around the site perimeter to assist firefighting
  • hydrants and water supplies
  • areas of natural and unmade ground
  • drainage runs, pollution control features such as drain closure valves, and fire water containment systems such as bunded or kerbed areas (this may be easier to show on a separate drainage plan)
  • storage areas with pile dimensions and fire walls (where applicable) – this includes wastes stored in a building, bunker, or containers – include indicative pile layouts and ensure it is geographically representative
  • the location of fixed plant or where you store mobile plant when not in use
  • the location of spill kits
  • the quarantine area
  • anything site specific you consider needs to be added

You must have plans showing all sensitive receptors within a 1km radius of your site that could be affected by a fire. Examples of sensitive receptors may include:

  • schools, hospitals, nursing and care homes, residential areas, workplaces
  • protected habitats, watercourses, groundwater, boreholes, wells and springs supplying water for human consumption – you can find some habitat information on the Defra MAGiC map website
  • roads, railways, bus stations, pylons (on or immediately adjacent to the site only), utilities, airports

Your plans must have a compass rose showing north and the prevailing wind direction.

7. Manage common causes of fire

You should understand common causes of fire and the measures you can take to reduce the risk. Some of these risks may not apply to your site or there may be others you need to include in your fire prevention plan. It is your responsibility to identify all possible risks, depending on the activities you carry out on your site.

Common sources of ignition include the following.

7.1 Arson

You must have security measures in place, such as security fencing, intruder alarms and CCTV. These must include arrangements for outside of working hours. You must describe the location of CCTV and alarms.

7.2 Plant and equipment

You must:

  • have a maintenance and inspection programme for static and mobile plant and equipment
  • fit vehicles with fire extinguishers
  • keep mobile plant that is not being used away from combustible waste

7.3 Electrical faults including damaged or exposed electrical cables

Electrical equipment and electrical installations on site must be fully certified by a suitably qualified person and you must have written procedures in place that set out regular maintenance.

7.4 Discarded smoking materials

You must apply a no smoking policy or have designated smoking areas away from combustible waste. This must apply to everyone using the site.

7.5 Hot works

You must make sure staff and contractors follow safe working practices, such as a permit to work system, when carrying out hot works such as welding and cutting. You must carry out a fire watch for a suitable period after hot works have ended, particularly at the end of a working day.

7.6 Industrial heaters

You must have written procedures that set out the use and regular maintenance of industrial heaters.

7.7 Hot exhausts

You must carry out a fire watch at regular intervals during the operating hours to detect signs of a fire caused by dust settling on hot exhausts and engine parts. Set out in your plan how regular these intervals are. You must also do this at the end of the working day. A fire watch can simply be carrying out visual checks.

7.8 Ignition sources

You must keep naked flames, space heaters, furnaces, incinerators and other sources of ignition 6m away from combustible and flammable waste.

7.9 Batteries

Batteries are commonly disposed of incorrectly and found in a variety of different waste streams. You must describe the measures taken to reduce the fire risk caused by the incorrect disposal of batteries.

7.9.1 Batteries in ELVs

Vehicle batteries left connected in un-depolluted ELVs can short circuit and cause fires. You must disconnect or remove batteries from un-depolluted ELVs as soon as practicable after they arrive, and before you stockpile the ELVs.

7.9.2 Battery storage

You must store batteries in either appropriate weatherproof containers, or in appropriate containers under cover. If they are damaged, you must isolate them from other batteries.

You must store lithium batteries and Li-ion batteries from electric vehicles separately from other batteries. You must store them in a way that prevents them from:

  • coming into contact with any liquids
  • being damaged

You must quarantine damaged Lithium and Li-ion batteries and store them away from buildings and other combustible materials. You must store them in a suitable waterproof container filled with sand or similar inert material. ELV sites which accept electric vehicles must explain in their plan how they will identify and manage the risk from these batteries.

7.10 Leaks and spillages

You must prevent fuels and combustible liquids leaking or trailing from site vehicles and ELVs. For example, this includes from vehicles:

  • being tracked around the site
  • before or after the de-pollution process

Describe in your plan how you will deal with leaks and spillages.

7.11 Build-up of loose combustible waste, dust and fluff

Your plan must state how regularly you will inspect and clean the site to prevent the build-up of loose combustible waste, dust and fluff and the procedures you will use.

7.12 Reactions between wastes

You must have written procedures for waste acceptance checks to prevent reactions between incompatible or unstable wastes, including lithium batteries. You must use a quarantine area where necessary.

7.13 Waste acceptance and deposited hot loads

When receiving waste it is critical that you identify waste at elevated temperatures or containing contaminants that could lead to ignition. You must tell us about your procedures for managing wastes when they are received at the site to ensure that fire risk is minimised.

You must have a written procedure for identifying, isolating, monitoring, cooling and potentially extinguishing hot loads as soon as is practicable. You must have a quarantine area for hot loads received on site.

All waste streams can contain contaminants that could pose a risk of fire. Things to look out for include:

  • signs of heating, for example, steam or smoke
  • batteries, in particular lithium-ion batteries
  • oils or other contaminants
  • rags soaked in oils or chemicals

7.14 Hot and dry weather

Explain in your fire prevention plan how you will check for any external heating of waste during hot and dry weather, and what you will do if it happens. Some examples may include:

  • shading waste from direct sunlight where practicable
  • enabling heat generated within the waste to be released
  • more frequent temperature monitoring
  • minimising storage times
  • rearranging site layout
  • moving or covering any reflective surfaces to prevent sunlight reflecting onto waste

8. Prevent self-combustion

Many materials can self-combust under certain conditions. Self-combustion happens when a material which can self-heat generates heat at a faster rate than it can be lost to the environment. The temperature continues to rise until the auto-ignition temperature is reached and the material then self-combusts.

You can prevent self-combustion by carefully managing storage times, pile volumes and height, and the temperature of the wastes.

8.1 Manage storage time

To help prevent self-combustion your plan must define the maximum storage time of all materials on site and how you’ll control and monitor this.

You must use good stock rotation for all stored materials. Your fire prevention plan must show that you have a clear method to record and manage the storage of all waste on site.

You must make sure that any combustible wastes are stored for less than 6 months (unless the material is compost and the Environment Agency has agreed that you can store it for longer).

Storing combustible wastes for longer than 6 months could increase the likelihood and duration of a fire. If you propose doing this, the Environment Agency is unlikely to approve your fire prevention plan unless you can demonstrate that the 3 objectives can still be met.

If you’re storing combustible wastes in the maximum pile sizes for longer than 3 months, you must show what extra measures you’ll use to prevent self-combustion. For example, this could include monitoring temperatures in the waste.

At these maximum dimensions, the possibility of self-combustion can increase when combustible wastes are stored for more than 3 months.

If there are seasonal variations in demand or supply for the combustible waste, you must demonstrate how you’ll manage these variations. You must show how you will follow the ‘first in, first out’ principle so that wastes are stored for no longer than 6 months.

You must consider the reasonable worst case situation when storing waste for longer periods over the summer months. You must also consider planned and unplanned shutdown and how you manage waste during these periods.

8.2 Monitor and control temperature

Your fire prevention plan must show that you will control heat to prevent self-combustion for any waste stored for more than three months. You must:

  • reduce the exposed metal content or proportion of ‘fines’ within the waste (exposed metals can oxidise which will generate heat, while fine particles are more prone to self-combustion)
  • allow any heat generated during treatment such as shredding, chipping or producing crumb to be released so that the waste is cool before you form it into piles for storage
  • monitor the temperature of the pile using a probe or other device as appropriate

You must explain in your plan the triggers you will use in relation to temperature, these may include temperature, rates of temperature change over time or visual signs of heating. Also explain actions you will take in response – including making sure staff are trained to detect and manage hotspots.

You must routinely turn piles to make sure the waste remains cold and any localised warming is dissipated quickly. Where this method is not appropriate you must explain the reason.

Surface temperature monitoring is unlikely to provide an accurate temperature at the core of a waste pile. However, you may use surface temperature monitoring to:

  • identify localised self-heating
  • provide trend analysis to identify atypical temperature rises over time

8.3 Waste bale storage

If you are storing waste in bales (for example RDF, cardboard, paper) and they are being stored on site for more than 3 months your plan must show:

  • what sampling and testing protocol you will use to make sure you assess a representative number of bales (minimum 10%) during monitoring
  • that you get representative temperature readings from the centre of the bales and from bales within the centre of a pile
  • that you turn the bales to minimise the risk of heating

8.4 Waste ELV bales

If you store waste ELV bales you must ensure that ELVs are fully depolluted before being baled.

9. Manage waste piles

If you manage waste piles carefully, you will:

  • help prevent the risk of self-combustion
  • limit the scale of a fire if one breaks out

You must:

  • minimise pile sizes (small piles with appropriate separation are safer than one big one)
  • store waste materials in their largest form

Here are measures you must use to manage piles of waste effectively.

9.1 Storing materials in their largest form

Treating waste to reduce particle size can increase the risk of fire due to self-combustion. To reduce the risk of self-combustion, store waste material in its largest form for as long as practicably possible before treating and moving it off site.

Consider the different fire risks posed by self-combustion and localised ignition and explain how you intend to store your waste material taking these different risks into account.

9.2 Maximum pile sizes

Waste type Loose and more than 150mm 30 to 150mm or baled Less than 30mm
Tyres and rubber 450 cubic metres 300 cubic metres 300 cubic metres
Wood 750 cubic metres 450 cubic metres 300 cubic metres
Compost and green waste (excluding during the active composting process) 750 cubic metres 450 cubic metres 450 cubic metres
RDF and SRF 450 cubic metres 450 cubic metres 450 cubic metres
Plastics 750 cubic metres 450 cubic metres 300 cubic metres
Paper and cardboard 750 cubic metres 750 cubic metres 450 cubic metres
Textiles 750 cubic metres 750 cubic metres 400 cubic metres
WEEE containing plastics, including fridges, computers and televisions 450 cubic metres 450 cubic metres 450 cubic metres
Metals other than WEEE (including crushed ELVs, which are classed as ‘baled’ waste for the purpose of this table - for whole ELVs see the section ‘Whole end of life vehicles’) 750 cubic metres 450 cubic metres 450 cubic metres
Fragmentiser fluff 450 cubic metres 450 cubic metres 450 cubic metres

For all waste piles, the maximum height allowed is 4m.

When measuring height, you must use the longest measurement between the base of the pile and the top. This is to allow for any uneven ground beneath the waste. For all waste piles, the maximum length or width allowed (whichever is the longest) is 20m.

If your waste piles contain a mixture of combustible wastes, you must work out the maximum limits based on the type of waste that makes up most of a mixed pile.

You must consider the design, access and layout of a building when storing waste so a fire can be extinguished easily.

Avoid using general terms such as wood and metal. In your plan you must describe the fraction sizes or grades of material and where they are stored.

10. Where maximum pile sizes do not apply

Maximum pile sizes do not apply for these types of waste.

10.1 Whole ELVs

You must set out in your fire prevention plan how you will store ELVs. Each vehicle must be accessible from at least one side:

  • to allow active firefighting
  • so unburnt vehicles can be accessed and moved to prevent the fire spreading

These rules will limit any row to a depth of 2 vehicles.

Where you store vehicles one on top of another, or on racking, you must limit this to 3 vehicles high so the stack can remain stable during a fire. You must maintain a separation distance of 6m between rows or blocks of vehicles.

10.2 Waste stored in containers

If you store waste in containers that can be moved then maximum pile sizes do not apply. Each container must be accessible from at least one side so a fire can be extinguished. Examples of these types of containers include skips, roll-on roll-off skips, or shipping containers.

If you have a fire, you must be able to move containers as soon as is reasonably practicable to prevent the fire spreading. You must set out in your fire prevention plan the procedures for how and when you will move them.

10.3 Compost production

For composting activities, the maximum pile sizes do not apply when the waste is actively managed and monitored during the composting process. Waste stored before and after active composting must follow the maximum pile sizes.

11. Prevent fire spreading

There are 2 main ways to prevent a fire from spreading.

11.1 Separation distances

Separation distances between piles of waste can prevent fire spreading between waste piles and allow active firefighting to take place. Setting an appropriate separation distance will depend upon the nature of the material you are storing.

You must:

  • store your combustible waste piles with a separation distance of at least 6m
  • have a separation distance of at least 6m between waste (whether in piles or containers) and the site perimeter, any buildings, or other combustible or flammable materials

If you are storing materials of higher calorific values in piles, then you may need greater separation distances or fire walls. Graphs in Appendix 1 (section 4.2) of the Waste industry safety and health forum guidance (Waste 28, Reducing fire risk at waste management sites) may help you choose the appropriate separation distance.

These rules do not apply if you are composting the waste through an actively managed process.

11.2 Fire walls and bays

You can reduce separation distances by using fire walls and bays. Fire walls and bays must be designed to:

  • resist fire (both radiative heat and flaming)
  • have a fire resistance period of at least 120 minutes to allow waste to be isolated and to enable a fire to be extinguished within 4 hours

You must show in your fire prevention plan how the specification, construction and dimension of the walls offer a thermal barrier.

If you store waste in a bay, your fire prevention plan must show how you:

  • will carry out full and frequent stock rotation, ensuring you have a first in, first out policy, and how you will monitor and record this
  • will check the temperatures of all the waste within the bay so that you carry out representative checks on the entire volume of the pile
  • have taken into account the calculation of flame height and radiation in preventing the spread of fire between piles
  • will prevent brands or lighted material moving outside the bay walls and igniting other wastes
  • will keep clear a ‘freeboard’ space of 1m minimum at the top and sides of the walls at all times to prevent fire spreading over and around the walls
  • will quickly and effectively remove wastes at risk of ignition to the quarantine area to isolate any bays with burning waste during an incident

12. Quarantine area

A quarantine area is somewhere you can place burning wastes to extinguish them. You can also move unburnt wastes into the quarantine area to isolate and prevent them catching fire.

The quarantine area must be within the boundary of the site for which you hold a permit.

You must have a quarantine area which is large enough to both:

  • hold at least 50% of the volume of the largest pile, row or block of ELVs or containers on your site
  • have a separation distance of at least 6m around the quarantined waste

You must set out in your fire prevention plan the location of this area and the volume of waste that it can hold.

For operational reasons you may want to keep the location of the quarantine area flexible. If so, you must identify on your site plan all the areas you could use.

You must keep at least one specified quarantine area clear at all times – unless it’s being used in the event of a fire.

If you use your quarantine area to store material temporarily (for example, non-permitted wastes) you must make sure you remove those wastes as soon as is practicable. In the event of a fire, you must remove it immediately. Your fire prevention plan must include details of the procedure you will use to do this.

You must set out how you will use your quarantine area in the event of a fire. You must be able to move waste to it as soon as possible or, at most, within 1 hour of a fire starting.

13. Detecting fires

You must have procedures in place to detect a fire in its early stages so you can reduce its impact. You must demonstrate in your plan how the detection system will raise the alarm if a fire is detected both during working hours and when the site is closed.

Your detection system must be proportionate to the nature and scale of waste management activities you carry out and the associated risks. Your system may therefore be an automated or manual system.

Appropriate automated systems may include:

  • smoke and heat detectors including temperature probes
  • CCTV visual flame detection systems
  • spark, infrared and ultraviolet detection

The design, installation and maintenance must be covered by an appropriate third party certification scheme such as UKAS, or meet an appropriate recognised standard such as a British Standard. You must provide evidence of certification in your fire prevention plan. If you do not meet a recognised standard or accreditation, you must demonstrate that you can still meet the 3 objectives.

14. Suppressing fires

If you store waste in a building, you must install a fire suppression system. This system should be proportionate to the nature and scale of waste management activities you carry out and the associated risks.

You will need to carefully consider the fire risk posed by your activity to decide on an appropriate and proportionate system. Your system:

  • can be an automated or manual system
  • must enable a fire to be extinguished within 4 hours

When deciding what type of system to install you need to take into account that:

  • the FRS may not be able to enter the building during a fire – they will use their dynamic risk assessment to decide this at the time of the incident
  • a suppression system may not extinguish a fire, although it may prevent a fire spreading , providing greater opportunity for successful intervention by the FRS

Automatic fire suppression systems may include:

  • sprinklers
  • water spray (deluge) systems
  • water curtains
  • fire monitors
  • powder or gaseous systems

Manual fire suppression systems may include:

  • water spray (deluge) systems
  • hose reels
  • fire blankets
  • fire extinguishers

You must make sure the design, installation and maintenance of all your automated and suppression equipment is covered by an appropriate third party certification scheme such as UKAS. Provide evidence of certification in your fire prevention plan.

Where you are proposing manual suppression, you must explain how it can operate when the site is closed. You must describe when and how any manual equipment will be inspected and maintained.

If your suppression system does not meet an appropriate standard or is not accredited, you must explain in your plan how the suppression system will work effectively.

15. Firefighting techniques

You must design your site to allow for active firefighting. This will help allow a fire to be extinguished within 4 hours.

Active firefighting does not mean that you or your staff have to fight the fire. No one should put themselves at risk by trying to fight a fire.

Active firefighting means having the resources available at all times to fight a fire during operating hours and when the site is closed.

The resources needed include:

  • plant you can use to move waste around the site, for example loaders, excavators, material handlers
  • staff
  • available water supply
  • finances

You can use a variety of firefighting techniques together or separately to extinguish a fire. These include:

  • applying water to cool unburned material and other hazards
  • separating unburned material from the fire using heavy plant
  • separating burning material from the fire to quench it with hoses or in pools or tanks of water

Firefighting techniques may also include suffocating the fire using soil, sand, crushed brick or gravel. However, you can only do this if:

  • the Environment Agency has agreed you can do this
  • you remove and dispose of contaminated material as soon as it is safe to do so

Your staff may use all of these techniques on the site if they are suitably trained and are supervised by the FRS. However, protecting the health and safety of people on site must be your priority.

16. Water supplies

Easy access to an immediately available water supply will give the FRS the best chance of extinguishing a fire and meeting the objectives of this guidance.

If possible, immediately available water supplies should be located within 100m of the site access. If not, you must explain how you will make sure you can get an adequate, immediately available water supply. You must consider the practicality of pumping water to the site in the event of a fire, taking into account, distance, roads, fences and other obstructions.

Other water supplies located more than 100m from the site access may be suitable as part of a longer term firefighting strategy.

You must have enough water available for firefighting to take place and to manage a reasonable worst case scenario. Depending on your site this could be water in storage tanks or lagoons on site, or access to hydrants or mains water supply.

A reasonable worst case scenario will typically be your largest waste pile catching fire.

If you do not take any other actions (such as creating a fire break) for a 300 cubic metre pile of combustible material you must have a water supply of at least 2,000 litres a minute for a minimum of 3 hours. You must show your calculation for the water supply required and confirm the source of water in your plan.

If you are storing ELVs, you will need to have 1800 litres of water to extinguish each vehicle.

Water supply to fire hydrants can vary by night and day due to fluctuating demands. Fire hydrants should be capable of delivering a reasonable flow of water if they:

  • conform to British Standard 750 or equivalent
  • are within 100m of the site access
  • are regularly serviced and maintained by the FRS or other suitably qualified provider

If you are relying on a water supply from open sources such as ponds, canals and rivers, you must take the seasons into account to make sure an adequate supply is available. Your fire prevention plan must set out how you will make sure the water is available, for example, by routinely checking the level in a pond is sufficient to deal with a fire.

You must consider the practicalities of the FRS being able to access water supplies.

You may be able to reduce the water supply requirements if you can demonstrate that:

  • a pile will not become fully involved in a fire due to early detection and action
  • waste stored in a bunker would need no more water than the volume of the bunker
  • waste stored in a container would need no more water than the volume of the container
  • the FRS have confirmed they are prepared to recirculate firefighting water and are able to access your system

It may not always be appropriate or safe to recirculate firefighting water.

17. Managing fire water

You must be able to contain the run-off from fire water to prevent it reaching sensitive receptors and causing pollution of the environment.

The containment facilities and pollution equipment you need will depend on the:

  • size of your site
  • amount of waste you store
  • firefighting strategy

Read Containment systems for the prevention of pollution (C736F) to help you find out what facilities and equipment you need for your site.

You must take all the steps that are reasonably practicable to minimise pollution from fire water. For example, preventing fire water entering:

  • surface waters, for example rivers, streams, estuaries, lakes, canals or coastal waters
  • into the ground

If you do not you may be committing an offence and the Environment Agency may take enforcement action.

Secondary and tertiary containment facilities for fire water run-off include:

  • impermeable bunds
  • storage lagoons
  • shut-off valves
  • isolation tanks
  • modified areas of your site such as a car park
  • pollution control equipment such as fire water booms and drain mats to block drains or divert fire water

You must not plan to divert firefighting water to a foul sewer as this can cause pollution – see Water UK’s guidance on dealing with fire water run off. If your sewerage undertaker is willing to accept firefighting water discharges to foul sewer then they should confirm this in writing.

You must demonstrate in your plan that you can contain the amount of water required to put out a worst case scenario fire on your site.

You need to understand the risk of contaminated fire water draining off site and polluting surface and ground water, this is particularly relevant where POPs are present.

You should not allow any fire water to enter the ground or surface water.

Your environmental permit may let you store combustible wastes on hard standing rather than an impermeable surface with sealed drainage. If so, you must assess the potential effect of fire water on:

  • the local groundwater and surface water bodies
  • any well, spring or borehole within 50m used for the supply of water for human consumption, including private water supplies

Your fire prevention plan must set out how you’ll prevent fire water affecting these receptors, if applicable.

17.1 Assessing risks to groundwater from fire water

You must use groundwater vulnerability and source protection zone (SPZ) maps to assess the risk to groundwater from fire water running off the hardstanding areas of the site.

You need to consider whether:

  • the site is located within a groundwater SPZ1, SPZ2 or SPZ3
  • there are any private drinking water abstractions within 50 to 100m of the site
  • the groundwater vulnerability maps flag that the site is in a high, medium-high or medium risk category

In these circumstances, you will need to look at having additional measures to protect groundwater from fire water. These may include replacing hardstandings with impermeable surfacing, or containing fire water to impermeable areas of the site.

You need to consider the practicalities of using temporary containment measures such as booms and sandbags in the event of a fire. You must demonstrate how:

  • quickly you will be able to deploy these in a fire
  • you will train staff so they know how to deploy these safely and where they are stored
  • you will position them so they are far away enough to be unaffected by fire and in line with the manufacturers’ specifications where appropriate

It may be impractical and unsafe to deploy temporary containment measures in close proximity to a fire.

18. During and after an incident

Your plan must include contingency measures for dealing with issues during and after a fire. For example, these could include:

  • diverting incoming wastes to alternative sites during a fire
  • having a plan for how you will notify those who may be affected by a fire, such as nearby residents and businesses

You also need to set out in your fire prevention plan:

  • how you will clear and decontaminate the site
  • the steps you must take before the site can become operational again

During a fire waste material containing POPs may release the POPs into the air or water course. Where you have this type of waste material you must ensure that your clean-up operations take the presence of POPs into account.

If any POPs waste is involved in a fire, all residues from that fire may contain POPs and must be treated in line with the POPs Regulations.

19. Submit your fire prevention plan

If you are applying for a permit to carry out a waste operation involving combustible wastes, you must send your fire prevention plan to the Environment Agency with your application.

For other types of permits, contact the Environment Agency to find out if you need to send them your fire prevention plan.

20. Further information

You can find information to help you understand how we developed this guidance in the: ‘Fire prevention plan consultation: summary of consultation responses and decisions’, and the ‘Appendix 1: review of guidance and test results’.

21. Contact us

Contact us if you have a query or need more information.

General enquiries

National Customer Contact Centre
PO Box 544
Rotherham
S60 1BY

Email enquiries@environment-agency.gov.uk

Telephone 03708 506 506

Telephone from outside the UK (Monday to Friday, 8am to 6pm GMT) +44 (0) 114 282 5312

Monday to Friday, 8am to 6pm.