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Building Capacity in Fire Safety: Lessons for the Waste Industry

Building Capacity in Fire Safety: Lessons for the Waste Industry

In the early hours of the 24th September a fire broke out at a waste storage facility in Exeter. The fire quickly got out of control and required firefighters from the Devon & Somerset Fire and Rescue Service to work throughout the night to get the blaze under control.

Posted

25.09.2024

Written by

Richard Bowen

But this wasn’t the first major fire at a waste or recycling facility this year in the UK, it wasn’t even the first this month. The frequent occurrence of fires at UK recycling and waste facilities is extremely alarming, with five significant fires in September 2024 in addition to another four fires reported in August 2024 alone. This unsettling trend signals the urgent need for waste management operators to consider how they are managing the fire risk on their sites, and if they are using the best available risk management techniques available to them.

Waste and recycling facilities are particularly vulnerable to fires due to the highly combustible materials they store, such as paper, plastics, metals and rubber. According to the Environmental Services Association (ESA), waste fires cost the UK economy millions each year, with significant damage to property, loss of business, and environmental harm. Additionally, data from the National Fire Chiefs Council (NFCC) has identified that a substantial portion of fires are caused by the presence of hazardous materials, such as lithium-ion batteries, within the waste stream.

The Waste Industry Safety and Health Forum (WISH) works closely with the industry, regulators and experts and issues guidance on many topics of health and safety, including fire safety. It’s guidance document, Reducing Fire Risk at Waste Management Sites, identifies key fire risks and outlines preventative measures, including strict housekeeping practices, fire detection systems, and water supply management to combat fires. However, despite these recommendations, the industry continues to face high fire rates, indicating a gap between guidance and practice with many operators simply complying with the minimum legal requirements, and not taking a holistic approach to fire safety.

One of the key issues is that many operators approach fire safety as a compliance-driven exercise. Rather than developing a dynamic fire safety culture, the focus tends to be on meeting regulatory requirements and ticking boxes. The Regulatory Reform (Fire Safety) Order 2005, which mandates that all employers carry out fire risk assessments and ensure that adequate fire precautions are in place, often leads to superficial assessments rather than meaningful, ongoing safety improvements. Another issue is that fire safety often competes with operational priorities. For many operators, the drive to increase throughput and efficiency can lead to the neglect of housekeeping practices, inadequate staff training, and poor maintenance of fire detection systems. These operational pressures can leave sites vulnerable to fire risks, particularly in periods of high activity or staff turnover.

The focus of many waste facilities tends to be on preventing fires from starting, and while these prevention methods are important, they are inherently limited by the fact that fires can still occur due to unforeseen circumstances. For example, even the best housekeeping practices cannot fully prevent spontaneous combustion in waste piles, electrical faults in machinery, hot loads arriving on-site, or even a stray spark during processing, all well-known risks in the industry. While prevention is undeniably a crucial component of any fire safety strategy, it is insufficient on its own in the high-risk environments of waste and recycling facilities.

 

Anyone familiar with the Bowtie risk assessment methodology will understand that despite the best preventative controls, mitigation controls are equally, if not more, important. Building the ‘capacity’ to fail safely through mitigation, that is, implementing robust fire controls that can limit the spread and impact of a fire once it starts, is critical in ensuring that fires do not escalate into catastrophic events.

Building capacity, resilience, or as Finch Consultant Dr Stephen Cowley calls it elasticity, refers to an organisation’s ability to anticipate, prepare for, and recover from unexpected disruptions while maintaining operational functionality. In the context of fire safety and risk management, this means that when preventative measures fail, systems and structures are in place to mitigate the impact, prevent escalation and allow the organisation to seamlessly return to normal operations.

According to David Woods, a leading expert in resilience engineering, resilience is not only the ability to “bounce back” from disruptions, but more importantly, it is about “bouncing forward”, taking the learning from events to adapt and evolve so you are better prepared for future challenges. Another leading contributor to this topic, Erik Hollnagel, emphasises that organisations should focus not just on preventing things from going wrong (the traditional safety approach) but also understand why things go right.

In the context of fire safety and implementing effective mitigation strategies, site operators must think about how to build ‘capacity’ in , avoiding expensive clean-up costs and potential fines. Finch works with its clients to build capacity in their safety systems through the adoption of some practical techniques that will ensure your organisation is ready to mitigate risks when prevention fails. Our approach moves beyond traditional safety methods and focuses on continuous learning, adaptation, and resilience.

Learning Teams

When fires or other safety incidents occur, traditional investigation methods like root-cause analysis tend to focus on identifying a single cause, often overlooking the complex interactions between people, processes, and systems. Instead, a technique developed by Ivan Pupulidy, known as ‘Learning Teams’ provides a more nuanced and learning-centred approach to investigating incidents.

In a Learning Team, frontline workers, supervisors, and safety professionals come together after an incident or near miss to analyse what happened. The goal is not to assign blame, so participants must feel safe to discuss all elements of their work without fear of punishment or reprisal, and to understand the complexities of the system and how processes function in practice. Workers share their first-hand experiences and provide insight into how they have to adapt to manage risks on a daily basis.

To take the Learning Team approach to the team would form not just when things went wrong, but also when things go right. Learning from success as well as failure is a powerful way to continuously improve your systems and processes. For example, Learning Teams could be especially valuable in addressing the frequent fire risks associated with materials handling and machinery operations. By forming a Learning Team following a fire, frontline staff would be brought together to analyse how the incident unfolded. Instead of focusing solely on what went wrong, the team would discuss operational challenges like fluctuating waste streams, human fatigue, or equipment maintenance issues. Workers could share how they adapt to varying material compositions or the speed at which they need to work, providing insight into how these factors contribute to fire risks.

Similarly, when a facility operates for a period without incidents, a Learning Team could examine what has contributed to this period with no fire incidents, considering factors such as how teams managed safe waste separation, efficient machinery handling, and fire prevention protocols, all offering valuable lessons to reinforce successful practices across the site.

Work as Done vs Work as Imagined

Not appreciating the difference between the way we think work is being performed versus how it’s actually being performed is often one of the biggest failings in risk assessments and operating procedures. Traditional risk assessments and procedures are often based on our perceptions of work, where everything happens in an expected order, without deviation (Work As Imagined), whereas in reality work is seldom that predictable, and rarely do things always go according to plan.

The reality of everyday work is that it’s often messy, and this is especially true when processing waste due to its innate variability with issues appearing suddenly and having to be resolved dynamically. Workers are skilled at adapting to unforeseen circumstances, making small adjustments as required to keep things running safely and efficiently (Work As Done). The gap between Work As Imagined and Work Is Done is often where things go wrong, as these small adjustments our workers have to do are seldom risk assessed or considered in the task design. For example, a risk assessment might “imagine” that waste piles are always stored according to exact protocols, however, workers may routinely adapt to operational pressures by stacking waste .

This may not be their fault as operating conditions or tight budgets might prevent them from strictly following the rules, but it’s these messy realities of work, and understanding how employees are adjusting to daily challenges that can reveal important safety gaps.

Ensuring workers are consulted throughout the risk assessment process, and they can share their experiences of how work is done, you can build capacity by closing these gaps and designing procedures that are more meaningful to what’s happening at the sharp end.

The 4D’s- Dumb, Dangerous, Different, Difficult

The 4D’s, a technique with origins in the US Air Force but further developed by Jeffrey Lyth provides a practical way to identify what challenges your workers are facing in their everyday work. The 4D’s provides a simple framework to encourage more meaningful conversations with those working at the sharp end, and can identify tasks or conditions that are:

  • Dumb: Processes that seem unnecessary or overly complex, leading workers to bypass safety steps.
  • Dangerous: Tasks that workers perceive to involve high risk or serious consequences.
  • Different: Situations workers consider to be unexpected or not normal.
  • Difficult: Tasks that workers find physically or mentally demanding or overly complicated, increasing the likelihood of errors.

Applying the 4D’s has a number of direct and indirect benefits, including the ability to spot emerging issues before they escalate into serious problems, but also making your worker’s feel heard about their concerns, which can have a very positive impact on worker engagement and your company’s safety culture.

Bringing it All Together

For the waste and recycling industry, building capacity through robust fire mitigation controls is essential. The reality is that fires will happen, even with the best prevention strategies in place. Therefore, by adopting a resilient approach to fire safety, waste and recycling facilities can ensure that fires are contained, controlled, and mitigated as quickly as possible. Prevention and mitigation are not mutually exclusive but should work together to create a comprehensive fire safety , which should include suitable process safety and asset management. By looking beyond prevention and focusing on capacity-building and mitigation, the waste sector can enjoy the benefits of fewer incidents, less downtime and improved operational continuity, not to mention building trust amongst its stakeholders such as regulators, councils and the local community.

The techniques presented in this article are just a few of the ways that Finch consultants apply their knowledge and expertise across the spectrum of capabilities we offer, including Asset Management, Process Safety and Health and Safety. For more information, please contact [email protected]

 

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