SMS Projects Limited

Fire is the single most destructive event a waste or recycling site can face. Unlike most industrial fire risks, waste fires often can’t be tackled head-on by the Fire and Rescue Service – mixed, combustible, hard-to-access material means your own suppression system is frequently the only thing standing between a contained incident and the total loss of your site. For operators across the UK and Ireland, that makes fire suppression a frontline safety system, not a box-ticking exercise.

At SMS Projects Limited, we design, specify, and oversee the installation of fire suppression systems for waste management operators across the United Kingdom and Ireland. What we see time and again is that fire risk on waste sites is rising – driven by growing volumes of lithium-ion batteries in the waste stream, larger stockpiles, and increasingly complex material mixes – while suppression provision hasn’t always kept pace. This article sets out why suppression deserves board-level attention, what UK and Irish legislation demands, and how the right technology, properly specified, protects your people, your permit, and your site.

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The Scale of the Problem

Waste and recycling sites are, by their nature, high fire-risk environments. Mixed combustible materials, spontaneous combustion in organic stockpiles, and an escalating volume of lithium-ion batteries entering the waste stream through incorrect disposal all combine to create ignition risks that don’t exist in most other industrial settings.

In a single month in 2024, UK waste sites recorded more than 37 significant fires. Battery-related fires alone have surged, with incidents driven by lithium-ion cells entering general waste and recycling streams increasing sharply year on year. Ireland’s waste sector has faced the same pattern – the EPA has recorded several high-profile facility fires in recent years, prompting tighter licence conditions and dedicated fire safety guidance for operators. Every one of these incidents carries the same set of risks: injury to staff and firefighters, environmental contamination from fire-fighting run-off, smoke pollution affecting neighbouring communities, and – in the worst cases – total loss of infrastructure, stock, and the licence or permit to operate.

Unlike a typical commercial premises fire, the Fire and Rescue Service often cannot safely enter a burning waste building. Stockpiled material, uncertain structural integrity, and the presence of hazardous or reactive substances mean firefighting activity is frequently limited to external, defensive tactics. That reality places the burden of active intervention squarely on the site’s own suppression system, deployed automatically, in the critical minutes before a small fire becomes an unrecoverable one.

UK Legislation: What the Law Requires

Fire suppression at waste sites in England, Scotland, and Wales sits under a web of overlapping legislation, permitting conditions, and technical standards. Non-compliance doesn’t just risk enforcement action – it can suspend your environmental permit or invalidate your insurance entirely.

Regulation / Standard	What It Requires	Consequence of Breach
EA Fire Prevention Plan	Operators holding an environmental permit must submit a Fire Prevention Plan. Where waste is stored in a building, a fire suppression system proportionate to the scale and risk of the activity is mandatory.	Permit refusal or suspension
UKAS Certification	Design, installation, and maintenance of all automated suppression equipment must be covered by a UKAS-accredited third-party certification scheme, evidenced in the fire prevention plan.	Failed EA inspection, invalid permit evidence
Fire Safety Order 2005	Places duties on the “Responsible Person” to carry out and review fire risk assessments and implement appropriate fire safety measures, including suppression where risk warrants it.	Enforcement notices, prosecution
Approved Document B (ADB)	Sets fire safety provisions for building design based on use, occupancy, and height. Transitioning to align with BS EN 13501 European classification.	Building control rejection
BS EN 12845	The primary British Standard governing design, installation, and maintenance of automatic sprinkler systems – typically required by insurers.	Invalidated insurance cover
POPs Regulations 2019	Persistent organic pollutants present in mixed waste require fire-fighting water residue to be treated as contaminated and segregated – suppression design must account for this.	Environmental contamination liability

The Environment Agency’s fire prevention plan guidance is explicit: if waste is stored in a building, a fire suppression system is not discretionary. The system specified must be proportionate to pile sizes, fire load, and the nature of the material being processed – and every part of that specification needs to be evidenced, auditable, and certified by a UKAS-accredited third party.

Irish Legislation: The Republic of Ireland Framework

Operators in the Republic of Ireland face a parallel – though distinct – set of obligations, enforced principally by the Environmental Protection Agency (EPA), the Health and Safety Authority (HSA), and local fire authorities. The underlying principle is the same as in the UK: suppression provision must be proportionate to risk, evidenced, and maintained.

Regulation / Standard	What It Requires	Consequence of Breach
Waste Management Act 1996 (as amended)	Governs EPA waste licensing and local authority waste permits. Fire Risk Assessment (FRA) conditions are now routinely inserted into EPA licences for large-scale non-hazardous waste facilities.	Licence refusal, suspension, or enforcement action
EPA Fire Safety & FRA Guidance	EPA guidance on fire risk assessment and fire safety at waste transfer stations sets out the scope of the FRA — prevention, early detection, and intervention must be the primary focus, with sprinkler systems designed to IS EN 12845.	Licence non-compliance, remediation notice
Firewater Retention Requirements	EPA guidance requires a firewater risk assessment to determine if a retention facility is needed. Contaminated fire-fighting water must be characterised and its disposal route agreed with the EPA before release.	Environmental pollution liability, licence breach
Fire Services Act 1981 & 2003	Places a duty on the “person having control” of a premises to provide reasonable fire safety measures and procedures and ensure the safety of persons in the event of fire. Enforced by local Fire Authorities.	Dangerous building notice, prosecution
Building Control Regulations	S.I. No. 496/1997 and the Part B / BCAR updates taking effect from May 2025 set fire safety design standards for new and altered buildings, including sprinkler and suppression provision.	Building control rejection, invalid Fire Safety Certificate
PFAS / AFFF Foam Restrictions	EPA restrictions on PFOA and PFAS-containing firefighting foams require a phased move to fluorine-free alternatives, with strict rules on storage, labelling, and disposal of legacy stock.	Waste licence breach, disposal liability

The Health and Safety Authority and local authorities are the primary enforcement bodies for workplace fire safety duties in Ireland, while the EPA regulates fire risk and firewater management as a condition of waste licensing. For any facility holding an EPA waste licence, the Fire Risk Assessment isn’t a one-off exercise – it’s a live licence condition that must be reviewed whenever site operations change.

Voice from the Industry

Adie Mason brings extensive operational experience gained from a career spanning waste and recycling operations, including wood disposal and global waste management companies – experience that shapes how SMS Projects approaches every fire risk assessment.

Helen Sinton brings over 20 years of experience in the wood recycling and chipboard manufacturing industries, with deep hands-on knowledge of fire prevention, suppression, and site safety procedures across waste and recycling operations.

Fire Suppression for Waste Sites: One Size Never Fits All

Waste management sites present a unique and elevated fire risk profile. The combination of mixed combustible materials, lithium-ion batteries, spontaneous combustion in organic stockpiles, and large open-air or enclosed storage areas requires specialist suppression approaches that differ significantly from standard commercial or industrial applications.

⚠️ Battery fires at UK waste facilities increased by 71% in a single year, driven by incorrectly disposed lithium-ion batteries entering general waste streams. Specialist high-pressure water suppression is now considered essential at any site receiving mixed household or commercial waste.

Suppression Technologies: Matching System to Risk

SMS Projects Ltd is an independent specialist – we are not tied to any single manufacturer or product range. We select technology based on your site’s specific fire risk, permit conditions, building layout, and insurer requirements, working with leading certified manufacturers to specify and oversee installation.

Beyond Compliance: The Business Case for Fire Suppression

Compliance is the floor, not the ceiling. The business case for a properly specified suppression system extends well beyond satisfying the Environment Agency.

Asset and infrastructure protection. A well-designed system can mean the difference between a contained incident and the total loss of infrastructure, permits, and material stock worth millions of pounds. Uninsured or under-suppressed sites face an existential risk from a single serious fire.

Insurance and permit continuity. BS EN 12845 compliance is typically a condition of insurance cover, and UKAS-certified installation evidence is required for environmental permit inspection. Getting the specification wrong risks both simultaneously.

Worker and community safety. Waste fires generate toxic smoke and contaminated fire-fighting run-off that can affect neighbouring communities and watercourses for years. Effective suppression limits both the immediate danger and the longer-term environmental liability.

Operational continuity. A serious fire doesn’t just destroy stock – it can shut a site down for months while investigation, clean-up, and rebuilding take place. For many operators, that downtime is more commercially damaging than the physical loss itself.

Our Approach

Every fire suppression project we undertake follows a structured, evidence-based process, working closely with site operators, environmental consultants, and insurers to ensure the final system is genuinely protective – not just compliant on paper.

SMS Projects Ltd is also part of the Ciqurix Video Flame Detection Partner Program, pairing suppression specification with early-warning video fire detection that recognises a fire at inception – unaffected by dust, dirt, fumes, moisture, light levels, or temperature – and integrates directly into suppression and alarm systems.

Serving the UK and Ireland

SMS Projects Ltd specifies and oversees fire suppression systems for waste operators on both sides of the Irish Sea. Whether you hold an Environment Agency permit in England, a SEPA authorisation in Scotland, or an EPA waste licence in the Republic of Ireland, the underlying discipline is the same – a proportionate, evidenced, properly certified system matched to your site’s actual fire risk.

For Irish operators, that means working within the EPA’s Fire Risk Assessment framework, coordinating firewater retention where a facility’s licence requires it, and specifying sprinkler and suppression systems to IS EN 12845 – the Irish equivalent of the British Standard. For UK operators, it means UKAS-certified installation evidenced against the Environment Agency’s fire prevention plan guidance. In both jurisdictions, we work directly with your licence or permit conditions rather than a generic template.

Taking Action: Where to Start

If you’re not yet confident that your fire prevention plan or EPA licence conditions, suppression provision, and third-party certification evidence meet the requirements of the Environment Agency, EPA, BS/IS EN 12845, and the Fire Safety Order 2005 or Fire Services Act 1981 & 2003, the starting point is a formal fire risk assessment. This should identify every significant ignition and fuel source on site, evaluate whether existing suppression is proportionate, and confirm that certification documentation is inspection-ready.

From there, SMS Projects can assist with specifying the right suppression technology, coordinating certified installation, and providing the documentation and evidence you need to satisfy regulatory requirements and licence or permit conditions – in the UK and in Ireland.

📋 SMS Projects Limited offers no-obligation site assessments for waste operators across the UK and Ireland. Contact us to arrange a visit from one of our fire suppression specialists.