EA provides guidance on FPP alternative measures
On 11th January, the Environment Agency published updated guidance on alternative measures under fire prevention plans (FPP). What constitutes alternative measures has been a hotly debated subject within the industry and we have previously written about the apparent difficulty officers on the ground have had in assessing the suitability of measures proposed by operators as satisfying the three objectives of the guidance.
The revised guidance provides some much-needed clarification on the issue, giving operators some reassurance that the measures they have put in place could meet the fire prevention objectives, where this may have previously been in question. Further, it gives operators the necessary reassurance that the EA can now properly consider the methods they have put forward.
The three objectives
The guidance sets out five case studies which give examples of some of the alternative measures proposed by operators, which meet the three objectives of the fire prevention plan guidance. The three objectives are to:
- Minimise the likelihood of a fire happening
- Aim for a fire to be extinguished within four hours
- Minimise the spread of fire within the site to neighbouring sites.
The wording of the objectives is deliberately broad to fit in with the EA’s renewed focus on outcomes-based enforcement. Operators are afforded the discretion to propose any methods they see fit, as long as these meet the objectives. It follows that the EA should assess and subsequently approve any measures proposed if the objectives are satisfied.
Alternative measures in the case studies
The five case studies included in the revised guidance cover a number of methods employed by operators which effectively achieve the objectives. These include the use of isothermal calorimetry testing to ascertain the ignition temperature and maximum storage period of materials before self-ignition would occur, the use of thermal imaging systems to detect hotspots within stacks and notify staff by text if the material reaches a certain temperature, robust security systems to deter arson, the installation of fire walls where separation distances of six metres are not possible, and confirmation from the local Fire and Rescue Service that measures are effective.
Impact of the guidance
The updated guidance provides some important and long-overdue clarification. Alternative measures play a crucial role in the operation of sites and many operators have been frustrated by the EA’s lack of flexibility in assessing proposed methods which they argue meet the three objectives. It has been apparent in some cases that officers have not had the knowledge or confidence to consider the efficacy of methods proposed by operators and have subsequently been reluctant to stray from the confines of the steps prescribed under the guidance.
It is encouraging to see that this has now been rectified and that the EA is committed to demonstrating that it is capable of adopting a more flexible approach. Whilst this should have been the case at the outset, the fact that there is now a written document confirming the types of measures which satisfy the objectives, gives some hope that lessons have been learnt and that alternative measures will no longer be the battle ground they were previously. This bodes well for other guidance which includes an alternative measures strategy, for example, the proposed enclosed building requirement for waste treatment sites.
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