Site management The need for updated guidance arose on
the back of an increase in waste fires over the previous two to three years, which prompted the EA to look more closely at how waste and recycling sites were permitted, and what fire prevention and detection measures were in place. Unfortunately, the resulting guidance had a potentially catastrophic effect for the waste wood industry, even though the number of waste fires that had occurred on wood sites was in the minority. The main issues for our members and those
working in other material streams, including tyres and paper, were as follows: 1. Stack sizes: these had been reduced by half from the original EA guidance to just 4m high. We felt strongly that that was too restrictive, particularly for bigger businesses − including biomass plants − which would need to acquire additional land to be able to store the amounts of materials they need in order to operate. There was no scientific evidence to support this requirement and we believed, and still do, that with the correct measures in place on sites, stacks of waste wood do not need to be restricted to 4m.
2. Stock rotation: We were concerned about the issue of required stock rotation. Whilst we acknowledge that spreading hot stacks of waste wood is an established way to cool them down if required, we believed that
turning stacks for the sake of doing so increased the degradation of the pile, which could add moisture and oxygen to the centre of the stack, increasing the risk of hot spots and self heating. Our argument was that if the correct detection systems were in place, stock rotation is irrelevant and does not add any benefit to a site’s fire management plan, and could actually hinder it.
3. Three month storage: a three month storage limit was suggested for combustible materials, which we felt was too restrictive for certain businesses, including biomass plants and their suppliers. It did not take seasonality into account and was based on flawed assumptions. We did not believe time on site was a determining factor when looking at material self combusting. The key to reducing the likelihood of self combustion is the ability to vent heat from the pile and this is done by ensuring that the correct fraction size is selected for different storage situations and then building stock piles correctly, which ensures that the risks are limited and are monitored.
4. Heat detection systems: The guidance referred to heat detection systems and suppression equipment having to be
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