Guidance

Using waste fire extinguishers for training: RPS 221

Updated 5 February 2025

This regulatory position statement (RPS) does not change your legal requirement to have an environmental permit for a waste operation when you store waste fire extinguishers.

However, the Environment Agency will not normally take enforcement action if you do not comply with this legal requirement provided that:

  • your activity meets the description set out in this RPS

  • you comply with the conditions set out in this RPS

In addition your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:

  • cause a risk to water, air, soil, plants or animals

  • cause a nuisance through noise or odours

  • adversely affect the countryside or places of special interest

Activity this RPS applies to

This RPS applies to when you can store and use waste fire extinguishers to train people to fight fires.

Conditions you must comply with

You must:

  • be a recognised training provider of firefighting services
  • only store and use waste fire extinguishers for training exercises
  • only use waste fire extinguishers that do not need any treatment or repair
  • only use waste fire extinguishers that are accompanied by a material safety data sheet
  • only store and treat extinguishers classified as waste code 16 05 05
  • store waste fire extinguishers under cover and in a secure place
  • store and use waste fire extinguishers on an impermeable surface with sealed drainage
  • send any discharged foam offsite for appropriate treatment
  • keep records for 2 years to show that you have complied with this RPS and make these records available to the Environment Agency on request

You must not:

  • store more than 100 waste fire extinguishers at any one time
  • use any waste fire extinguisher containing Perfluoro octane sulfonate (PFOS), Perfluorooctanoic acid (PFOA) or Perfluorohexanesulfonic acid (PFHxS)

When you must check back

The Environment Agency intends to review this RPS by 31 December 2027.

The Environment Agency can withdraw or amend this regulatory position before the review date if they consider it necessary. This includes where the activity that this RPS relates to has not changed.

You will need to check back from time to time, including at and before the review date, to see if this RPS still applies.

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.

You can subscribe to email updates about this RPS. These will tell you if the RPS has changed and when it has been withdrawn.

If you cannot comply with this RPS

If you operate under this RPS but can no longer comply with it, you must:

Contact the Environment Agency

If you have any questions about this RPS email enquiries@environment-agency.gov.uk with RPS 221 in the subject.