Since the introduction of the Environment Agency’s (EA) Fire Prevention Plan (FPP) Guidance, waste operators have been battling with the national approval panel to achieve the compliant plans needed for their new facilities. Whilst July’s revised guidance went some way to clarifying the EA’s expectations and flexibility, gaining approval for a FPP still seems to be a hurdle many are having difficulty with.
Although the guidance may seem impossible at first, it is possible to navigate. The current FPP approval rate stands at around 50%. Whilst I am unable to offer a silver bullet to all FPP woes, I have compiled a list of key points for when developing a compliant FPP now or in the near future.
Going through fire and water?
Trying to achieve a compliant plan can feel like jumping through an increasing number of hoops. However, it is important to remember that a site fire can cause risk to life, the local amenity and the environment as well as damage to valuable equipment, and can result in the site being closed for a time.
If you are an existing operator, is it likely that you have already developed many of the procedural documents required to support an FPP. If this is the case, the guidance does not require you to re-invent the wheel, but rather to tailor and formalise your existing practices to each site, while including fire prevention and mitigation measures. For example, this could include extending your waste acceptance procedure to include a method for identifying hot loads, or considering the impacts of litter transported by plumes of smoke.
In the revised guidance published in July 2016, the EA recognised that for some sites it may not be possible to accommodate the minimum standards set out in the FPP guidance. At the recent Fire Prevention and Control Conference, the EA explained that many deviations are now being accepted, provided the operator continues to meet the three main objectives of the guidance, which are to:
- Minimise the likelihood of a fire happening;
- Aim for the fire to be extinguished within four hours; and
- Minimise the spread of fire within the site and to neighbouring sites.
The overall aims of the objectives are to reduce the environmental, social and economic harm that can result from a significant fire event. If, as an operator, you are able to show sufficient measures are in place and the risks and potential impacts have been minimised to an appropriate level, the EA is likely to accept your FPP. It is hoped that as the industry becomes more experienced at developing compliant FPPs more examples of best practice will become available to inform new or improved approaches.
The EA’s new Fire Prevention Plan Guidance aims to make waste fires a worry of the past. Image: U.S. National Archives and Records Administration (Public Domain), via Wikimedia Commons
It could be argued that the requirements of the FPP guidance are proposing a new status quo in the approach to designing waste facilities. With the need to consider smaller pile sizes, separation distances or the use of firewalls, water supply and disposal requirements, the days of large piles of uncontained waste are quickly becoming a part of history.
Whilst the new approach may place some limitations on operations, in most instances, with the use of guidance deviations, most activities could be accommodated. For new sites – or if you have to make a significant variation to your permit – you should use the FPP guidelines to inform the site design from the initial concept. This could help to minimise the financial and operational impacts of retrospectively applying the guidance, especially in relation to the fire suppression system, water supply and fire water disposal. Consulting the guidance at an early stage will allow you to consider options such as compartmentalising the site to provide for elements of business continuity if a fire does occur on site.
Context is everything
In April 2017 the EA will be disbanding its national FPP assessment panel and devolving approval granting powers on FPPs to its regional offices. Whilst it is hoped that this will result in those assessing the plan having local knowledge of the area and sites, there is also the potential for it to increase the level of personal interpretation of the guidance.
Until then, it is important to remember that those assessing your plan have limited experience of your operation and local context. Therefore, it is important to provide this information in your FPP. Think of it like a school test: you can only be given marks for the information you write down. Clearly explaining your operation and how it works, including what activities take place on site, the procedures to be followed and the plan if a fire did occur will help the EA to paint a mental picture of your operation. Contextual information could also be important in helping the EA understand any reduced risk at your site or why your deviations from the guidance are acceptable.
Guiding light
Presently, FPPs are only required by the EA for new permit applications, for sites having recently had a fire and for operators requesting a significant permit variation. Whilst there is strong feeling in the industry that sites with a history of poor performance should be targeted next, it’s unclear what approach the EA will take.
Although existing operators are not currently required to implement an FPP, it could be beneficial to consider how you could comply with the regulations and to start taking steps to reduce the risk of a fire at your site and limit any impacts if one should occur, prior to an FPP being requested. This could include looking at additional infrastructure required, such as fire suppressions systems and firewalls, and adjusting site procedures such as equipment maintenance, waste acceptance and waste storage to take account of fire risks. Considering the impacts the guidance could have on your waste operation in advance is likely to help to smooth the path to a compliant FPP should one be required in the future.
What’s more, many of the issues the FPP guidance covers are worth considering for the sake of business resilience, reducing insurance premiums and potentially improving your operational risk appraisal (Opra) score and thus reducing your subsistence charges.
One final point to consider is that the FPP that you submit to the EA does form part of your permit conditions. Site operators will be audited to check the procedures and equipment on site reflect that detailed in the FPP. If significant differences occur they could be in breach of their permit. So, making sure your FPP is practical and adapted to your site is key.
If all the aspects covered here are considered as a suite of site improvements, as opposed to EA restrictions, FPPs can not only help to reduce the risk of fire but may also improve many elements of site operation. A better planned and managed site will not only be safer, but also cheaper, more productive and a better place to work.
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