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Fire Prevention Plan

The Environment Agency now require that most waste permit applications are submitted with an Environmental Permit Fire Prevention Plan.

65% of submitted Fire Prevention Plans Fail upon Assessment by the EA

 Whether consultants are not providing enough detail, or whether the EA are being overtly meticulous is unclear, but a very large proportion of Fire Prevention Plans do not pass, muster on assessment leading to returned applications. This can cost weeks in delays.

This is a fire prevention plan that focuses on the environmental impacts of fire at waste sites and how best to avoid having a fire in the first place, there guidance document on the subject is available to help those who wish to write their own Environmental Permit Fire Prevention Plan, although this is not a task that should be undertaken lightly, as the checks made on the document upon submittal are extensive.

So what sort of information goes in to a Environmental Permit Fire Prevention Plan:

Potential Impacts of Fire Regulations & Guides Sources of Ignition Stack Spacing & Pile Sizing Amount and Type of Waste Received Daily
Managing Fire Water Temporary Contingency Measures Methods of Fire Fighting Seasonality & Pile Management Environment Agency Update June 2016

Potential Impacts of Fire

Fires involving combustible materials can cause significant harm to people and the environment due to: 

Regulations & Guides

We produce Environmental Permit Fire Prevention Plans that deal with environmental damage prevention and mitigation they do not cover risk to workers or site users. Good guides to read are:

Sources of Ignition

You can identify the potential ignition sources in your premises by looking for possible sources of heat which could get hot enough to ignite material found in your premises. These sources could include:

Stack Spacing & Pile Sizing

The separation distance you need between stacks on your site will depend on their size and what they’re made of.  Don’t exceed a maximum size for any one stack and make sure you have adequate water supplies and access for FRS vehicles. When calculating stack separation distances, apply these rules: ·        

  • The height should be taken as the longest length between the base of the stack and the top. This may not be the highest point if the ground is uneven.  ·        
fire prevention

 

Amount and Type of Waste Received Daily

For Example:

The maximum permitted daily throughput is 500 tons. This is a figure included within compliance documentation to create room for growth. Actual daily throughput of wastes at the time of writing is likely to be less than 100 tons.

Managing Fire Water

The water used to extinguish a fire often runs off site, or perhaps in to a stream or river and causes pollution. You have to tell the EA or Natural Resources Wales how you intend to stop this happening.

This might include simple measure such as drain covers, but also might include large capital works if necessary. You will have to specify Temporary Contingency Measures if you feel that current systems will not cope with fire water produced during a incident.

Methods of Fire Fighting

This needs to be included within the report, but in authors opinion the fire fighting technique should be left to the Fire rescue services discretion after all who are we to tell them how to do there job!

Seasonality & Pile Management

Pile should be managed so that large volumes of waste do not accumulate on site, as this will increase the impact of a fire, although it may not increase the likelihood.

Environment Agency Update June 2016

Below is a summary of the FFP Update, as a response to the consultation held in February - March 2016:

Business Impact Target Assessment

We recently carried out a survey inviting operators to submit the costs involved in implementing the requirements of the FPP guidance. Many thanks again to those who responded. The information provided is to be used to assess the costs and/or benefits of the changes we are proposing to make to the guidance. It is now a requirement for regulators to carry out economic impact assessment of any changes such as the FPP guidance.


We have now met with the DEFRA economists who are assisting us with this assessment, and they have provided us with a timetable for when it will be completed. Due to the complexities and range of variables involved, we will have to deliver this by a phased approach. We have been advised that it may take approximately 3 months to complete; longer than originally anticipated. We intend to publish the FPP guidance after scoping the first stage of this qualitative assessment.


We have discussed this with the Regulatory Policy Committee (which will be scrutinising the analysis), and it was agreed that the approach we are taking with this is the right one and will ensure we produce a robust and accurate assessment. We will keep you updated on this as it progresses.

FPP Assessment

Since July 2015 we have received a total of 237 FPPs. So far 82 (35%) of these plans have been accepted and 155 (65%) have been rejected. The quality of plans is improving and the acceptance rate has increased from its initial level of less than 10%.

Getting it Right

We spoke to the Director of a consultancy who has had a number of their Fire Prevention Plans approved on first time of submission. We asked them for their top tips for getting your plan approved:

• Understanding that the officer reviewing the plan may not have been to site, so presenting the plan in a logical order can really help. Following the order of the guidance makes it clearer and easier to find important information.
• Work your way through the guidance and make sure your plan answers any questions in the guidance
• Make use of any records or certificates you may already have on site, such as maintenance schedules and electronics certificates
• Make sure that you understand the fire risks your site poses and that you have the right measures in place to reduce those risks. For some sites this might be a £30 hose pipe for others it might mean changes to infrastructure or different equipment like a thermal camera to detect surface fires.
• Site plans - you need to have every point covered on the site plan guidance, otherwise it will be rejected, regardless of how insignificant it might seem for an individual site. For example, minor points like adding where the hydrants are outside the site - or alternatively adding into the site plan information key that there are no hydrants outside the site.

Complying with your FPP


Waste teams in Greater Manchester Merseyside and Cheshire (GMMC) have started auditing sites to assess compliance with approved FPPs. Other areas across the country will begin to do the same.


We spoke with Karen Henson an Environment Officer in GMMC who has been undertaking these audits with her colleague Claire Hayter, to get an idea of what you can expect when compliance is checked at your site. Karen highlighted some of the main areas when assessing compliance with an FPP:

• Paperwork & Records – Maintenance schedules, Daily Fire checks, Staff Training, transfer notes, stock rotation, location and site plans
• Procedures - Waste Treatment, Waste acceptance, ignition sources, dust management, integrity of infrastructure.
• Prevention- Pile sizes and distances checked and measured, detection systems, fire walls, suppression system, site security
• Emergency Response - Containment, disposal of waste, fire fighting equipment, water supply,
A compliance assessment may not be limited to these areas but it gives a good indication of what an assessment may comprise of.


Karen also added that:
"It is important that you are implementing what is written in the FPP to manage fire risk at your site. If circumstances or procedures have changed on site then you should ensure that your FPP is updated to reflect this and resubmitted to the Environment Agency."

For a PDF Document as released by the EA please click link below:

Environment Agency Update June 2016

Recent policy changes have resulted in the need for the majority of waste sites to produce and maintain a fire prevention plan, for their environmental permit.

A fire prevention plan sets out the site specific requirements for the storage of wastes in line with the relevant guidance. There are requirements for stack spacing sand fire rescue service access.

When a fire is extinguished it is often the case that large volume of fire water run off the site and on to surround land, or perhaps in to rivers. The fire prevention plan must set out measures that can be used to prevent this happening.

These new requirement for fire prevention plans are applied regardless of past performance, and are being requested more and more often during environmental permit applications of any type.

It is important that the Fire Prevention Plan considers down wind receptors.

Another huge consideration is drainage. You may have to make large scale alterations to your on site drainage systems to ensure that they can be isolated in case of a fire.

There are various documents on designing surface water drainage systems to account for emergency fire water and the CIRIA guidance is the most comprehensive of all.

The content requirement for a fire prevention plan can be considerable, especially during a bespoke permit application. The fire prevention plans produced by SWEL are for environmental protect matters only and do not deal with health and safety of workers or members of the public.