ASBG's submission calls for NSW Fire and Rescue's document Fire Safety in Waste Facilities (FSWF) to firstly recommend the use of a fire study and provide area topics in which such a study can be made. There are many issues and recommendations on FSWS, but the most glaring is the excessive separation distances required for combustible waste. It is around 3 times larger than used for diesel storage. These distances were taken out of context from a UK document which based its distances on the premise there were no other fire controls used.
Application of FSWF can also apply to existing sites, but there is no consideration of issues affecting existing sites such as land surface available. Retrospective application of new standards to old sites is also poorly addressed and requires a reassessment of how new fire controls can in part be applied to existing sites, like with older buildings. EPA has also included its own requirement for a minimum of 4 hours of fire water storage in worst case scenario. This again is excessive and requires reconsideration and justification based on evidence this will provide a cost effective solution.
 ASBG's Submission on Fire Safety in Waste Facilities 2019 | 1028 kB |
