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EA’s proposed Fire Prevention Plan will inadvertently promote unregulated businesses and increase risk of site fires says TRA

The Tyre Recovery Association (TRA) is urging the Environment Agency (EA) to listen to the recycling industry to avoid the inadvertent promotion of unregulated businesses over reputable and regulated operations. While the TRA and other waste streams have repeatedly been calling for amendments to the EA’s proposed new Fire Prevention Plan over the past four years, especially to proposed stack heights and the fire breaks between them, the recommendations have, as yet, gone unheeded. The TRA believes that if due action is not taken, unregulated businesses will profit while those with a proven, professional and regulated background will rapidly be forced out of the industry.

Currently there are hundreds, if not thousands, of unregulated recycling sites across the UK operating under ‘Exemptions’. Should they choose not to adhere to the new requirement they are unlikely to fall foul of the new regulations nor face prosecution while reputable, regulated operations facing regular inspections will simply find it impossible to operate and close, with consequential job losses and increased safety risks.

“If put the good guys out of business you’ll end up with the vacuum filled by those operating on exemptions, which does not make sense,” said TRA Secretary General Peter Taylor OBE. “The proposed stack heights and separation dimensions are neither based on good science nor actual experience and if implemented would require the tripling or quadrupling of site area to accommodate the same capacity as currently accommodated at these site. Clearly, that is not viable for reputable businesses, which will simply fold if they try to conform.

“The TRA supports entirely the view expressed by other organisations, such as Hadfield Wood Recyclers, in urging the Environment Agency to take on board what the recycling industry needs to implement viable changes to the proposed new Fire Prevention Plan.

“The TRA believes that far from being ‘low risk’ exempt sites are actually more susceptible to both fires and rogue activities. And that is a key issue – the question of site exemption. Ideally there would be no exemptions and then we’d be in different territory. It seems in a bid to have ‘light touch regulation’, in other words reduced red tape, we have ended up with the creation of a grossly misused regulatory status which is not subject to proper regulation or enforcement.

Since 2011 the TRA has worked closely with the Environment Agency and others to produce a workable set of standards for safer storage of waste tyres. Initiated at the invitation of the EA and with a clear mandate from the EA in TGN7.01 (successor to PPG29) which ‘other trade associations such as the Tyre Recovery Association are producing sector specific guidance’, the TRA submitted its own proposals in late 2013. Having seen no direct action as a consequence, The TRA urges the EA to urgently revisit the approach and re-inject more transparency and genuine sector involvement into its proposals before reputable businesses are forced to close, jobs are lost and fire safety at recycling plants subsequently compromised.


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