It comes amid widespread concern in the wood recycling industry about the impact of limits for maximum wood stack sizes outlined in current Environment Agency guidance – limits the WRA has described as “inoperable”.
The Agency issued TGN (technical guidance note) 7.01 on fire prevention at waste and recycling sites in October 2013 (see letsrecycle.com story), which includes the same standards set out in draft guidance currently being consulted on by the Environmental Services Association (ESA) in collaboration with the Waste Industry Safety & Health Forum (see letsrecycle.com story).
The guidance states that stacks of wood should be a maximum of 1,370 cubic metres in volume, 10 metres high and 20 metres wide or long, with a minimum of six metres separation between stacks – restrictions seen as too severe for many businesses by the WRA.
However, according to the Agency “incidents are much more likely to occur on sites which have not followed the minimum standards” and it therefore takes “a tough line on operators that do not follow these minimum standards”.
Wood recyclers can use alternatives to the TGN7.01 guidelines, the Agency said, but these have to be agreed with the Agency and they “must give equivalent or superior protection of the environment and local community to these minimum standards”.
And, these alternatives “can only be applied on a site-specific basis, and would be based on evidence from incident monitoring and modelling”.
Tests
But, newly-appointed WRA chief executive Simon Dowson said that the Fire Brigade is now planning to conduct practical fire tests to “try and establish empirically what stack sizes and separation distances should be”.
Mr Dowson told letsrecycle.com: “The desk top research has been completed and we are currently trying to identify a suitable site for the practical burns. The WRA board have agreed to give financial and technical support. The Fire Brigade have agreed that the WRA will be able to contribute to the methodology and also to observe the tests.”
The WRA has long been in discussions with the EA and Fire Brigade in order to reach a more acceptable compromise on waste wood storage limits. But, the Agency told letsrecycle.com that sector-specific guidance proposed by the WRA “would need to go beyond the minimum standards in TGN7.01 and provide best practice for the sector”.
Guidance
TGN 7.01 was expected to be replaced by sector-specific guidance and standards from various recycling trade associations, including the WRA, which had publication of its own document put on hold by the Agency in summer 2013 following a spate of fires at waste management sites.
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Then WRA chairman Peter Butt previously said that standards put forward in its own document had been broadly accepted by regulators and recyclers alike, and so it was “very frustrating” its publication had been put on hold (see letsrecycle.com story).
However, the Agency has now told letsrecycle.com that it is the regulator’s job to provide minimum standards, while trade associations may provide best practice and advice on these standards.
The Agency said: “We are working alongside government to implement the Smarter Environmental Regulation Review (SERR). This review has clarified that the role of a regulator is to provide operators with minimum standards in order to comply with relevant legislation. Regulators will no longer publish best practice, or guidance which goes beyond the minimum standards. Instead, trade associations, institutions and others will provide advice and guidance to cover best practice and this is where we would anticipate any future guidance produced by the Wood Recyclers Association to fit in.”
Market
A number of wood recyclers across the UK have expressed their strong concern to letsrecycle.com about the impact on their business of the TGN 7.01 limits as well as the current state of the waste wood market.
In a market prone to considerable seasonable fluctuations in supply and demand, wood recyclers often need to stockpile material before a customer for the wood can be found. Larger sites especially could therefore struggle to make enough money from recycling wood if restrictions on stack sizes and separation distances are too severe.
Several wood recyclers said the enforcement of current stack and separation limits in TGN 7.01 would be “devastating” for the industry, as the restrictions could make wood recycling economically unviable and potentially force some in the sector out of business.
The announcement of WRA-funded fire tests also come amid a difficult seasonal period for the sector, with very few outlets for waste wood fuel at home and abroad in warmer temperatures, which is forcing a number of recyclers to close their gates entirely to the spot market.
And, with so many sites – especially in the south of England where there are even fewer outlets – stockpiling material, one recycler told letsrecycle.com that anxiety and pessimism about TGN 7.01 stack size limits meant his firm was currently reticent to take in spot market material “perhaps for at least another two months or more”.
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