The Wood Recyclers Association (WRA) is urging its members to formally respond to the Environment Agency’s consultation on its latest Fire Prevention Plan (FPP) guidance, following a number of issues it has raised with the guidance.
The trade body, which represents 80% of wood recyclers in the UK, says it has extensively reviewed the FPP guidance and highlighted a number of issues it is concerned about.
The key issues raised include a 3-4 hour “proposed burn time”, which it says has no scientific backing. It believes this is an “unreasonable and unnecessary” target because it does not take into account individual circumstances such as tonnages, material types, weather conditions and the local fire-fighting strategy.
It says the tactics to tackle a fire should be a Fire & Rescue Service decision rather than an EA decision.
Andy Hill, Chair of the WRA – “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”
It also says there is no scientific evidence to support the rotation of waste wood stock on a 3-6 month basis. It says no consideration has been given to the seasonality of the waste wood market place, which by its nature 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. This is industry-wide and is how the market has always operated.
It says such limitations prevent bespoke storage capacity within wood supply chains and would require every load of recycled wood to have an age audit trail which would be impossible for anyone involved to police. It also assumes that stockpiling of combustible waste – including wood – for more than a short period represents an unacceptable fire risk, which we fundamentally disagree with. Each site should be considered on its individual off-take requirements.
The WRA has also taken issue with the reduction in stockpile sizes for internal and external stacks, which it says has also been proposed with no scientific backing.
“We believe such sizes will make many businesses unviable because they will not be able to physically store the amount of material they require to operate their business on the land they have available. The proposed sizes are a significant reduction from what has been previously allowed in both the EA’s own guidance (TGN 7.01) and WISH guidelines and the WRA industry view, and will result in an increase in landfill. We believe stockpile sizes should be assessed on a site by site basis.”
The inability to deviate from the minimum standards outlined in the FPP the WRA says is “wholly unreasonable” when operators are willing to implement additional safety and security measures.
“To date, of 80 bespoke permits applied for under this new guidance, only four have been issued to our knowledge,” it says. “The EA needs to work with operators on an individual basis taking into account local circumstances. But to do this the FPP would need to allow for deviations.”
Andy Hill, Chair of the WRA, said: “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.”
It is now actively contacting its members to support them in responding to the consultation before the closing date (4 March).