Best Practice Guidelines For Tyre Storage

BEST PRACTICE GUIDELINES
FOR TYRE STORAGE AND

FIRE AND EMERGENCY
PREPAREDNESS
MARCH 2019
Best practice guidelines for tyre storage and fire and emergency preparedness
CONTENTS
DISCLAIMER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
ACKNOWLEDGEMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
PARTICIPANT COMMITMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
ABBREVIATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
GLOSSARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
INTRODUCTION 11
1.1 CONTEXT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
1.2 BENEFITS OF IMPLEMENTING BEST PRACTICE. . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
1.3 GUIDELINE STRUCTURE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
UNDERSTANDING TYRE FIRES AND TYRE STORAGE REGULATIONS 15

2.1 OVERVIEW OF TYRE FIRES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
2.2 REGULATORY OVERVIEW. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
FACILITY LAYOUT 17
3.1 COMMON REQUIREMENTS FOR BOTH INTERNAL AND EXTERNAL STORAGE . . . 17
3.1.1 PLANNING YOUR FACILITY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
3.1.2 SECURITY AND MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
3.1.3 WATER ACCESS AND CONTAINMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
3.1.4 SITE SPECIFIC RISK ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
3.2 INTERNAL STORAGE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
3.2.1 SITE LAYOUT AND DESIGN. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
3.2.2 STACKING/STOCKPILE ARRANGEMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
3.2.3 STOCKPILE SIZE, DIMENSIONS AND CONFIGURATIONS . . . . . . . . . . . . . . . . 22
3.3 EXTERNAL STORAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
3.3.1 SITE LAYOUT AND DESIGN. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
3.3.2 SITE/FIRE ACCESS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
3.3.3 STACKING/STOCKPILE ARRANGEMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
3.3.4 CALCULATING TYRE STORAGE SPACE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
2 TSA_BPGL V1 MARCH 2019

FIRE & EMERGENCY PREPARATION 33

4.1 SITE EMERGENCY PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
4.2 EMERGENCY AND FIRE PROTECTION EQUIPMENT. . . . . . . . . . . . . . . . . . . . . . . . . 35
4.3 FIRE RISK ASSESSMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
4.4 SITE MANAGEMENT PLANS AND PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . 37
4.5 IGNITION SOURCE CONTROL. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
4.6 BUSINESS CONTINUITY PLANS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
4.7 SITE FAMILIARISATION FOR LOCAL EMERGENCY SERVICES . . . . . . . . . . . . . . . . . 39
4.8 FIRST RESPONSE TO FIRE INCIDENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
4.9 STAFF TRAINING. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41
FIRE SAFETY & EMERGENCY EQUIPMENT 42

5.1 COMMON REQUIREMENTS FOR BOTH INTERNAL AND EXTERNAL STORAGE . . . 42
5.1.1 EQUIPMENT FOR MOVING TYRES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
5.1.2 WATER SUPPLY AND ACCESSIBILITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
5.1.3 CONTAMINATED FIREWATER CONTAINMENT . . . . . . . . . . . . . . . . . . . . . . . . . 43
5.2 INTERNAL STORAGE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
5.2.1 BUILDING CODE/GENERAL REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . 45
5.2.2 FIRST RESPONSE EQUIPMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
5.2.3 FIRE HYDRANT SYSTEMS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
5.2.4 SPRINKLER SYSTEMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
5.2.5 SMOKE HAZARD MANAGEMENT SYSTEMS . . . . . . . . . . . . . . . . . . . . . . . . . . 47
5.2.6 MAINTENANCE OF FIRE PROTECTION SYSTEMS . . . . . . . . . . . . . . . . . . . . . . 48
5.3 EXTERNAL STORAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48
5.3.1 FIRST RESPONSE EQUIPMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48
5.3.2 FIRE HYDRANT SYSTEMS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48
5.3.3 MAINTENANCE OF FIRE PROTECTION SYSTEMS . . . . . . . . . . . . . . . . . . . . . . 49
TSA_BPGL V1 MARCH 2019 3

FACILITY MANAGEMENT 50
6.1 ONGOING FACILITY MANAGEMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
CONTACTS AND RESOURCES 51

7.1 STATE GUIDELINES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51
7.2 AUSTRALIAN CODES AND STANDARDS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51
7.3 INTERNATIONAL GUIDANCE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52
APPENDIX A
OVERVIEW OF TYRE STORAGE REGULATIONS IN AUSTRALIA 53
AUSTRALIA (FEDERAL). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53
TRANSPORT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53
STORAGE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53
WORK HEALTH AND SAFETY (WHS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53
STATE/TERRITORY BASED REGULATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
ACT 54
NEW SOUTH WALES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
NORTHERN TERRITORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57
QUEENSLAND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58
SOUTH AUSTRALIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61
TASMANIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64
VICTORIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65
WESTERN AUSTRALIA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67
APPENDIX B
CHECKLIST OF ESSENTIAL REQUIREMENTS 68

DISCLAIMER
This guideline has been developed to assist businesses understand the main regulations,
requirements and best practice methods that apply to the storage of tyres in Australia. The
guideline is intended to provide an easy-to-read summary of the key requirements that apply
to the storage of tyres nationally, and can be used to identify regulations that may apply to
you, your duties and areas where you can improve compliance.
Although the guideline has been written to help businesses understand the relevant
legislative and regulatory requirements, it is not a legal document nor a substitute for the
regulations. It should not be viewed as a definitive guide to the law; the guideline does not
cover every requirement relevant to businesses involved in tyre storage, and should not be
used as your only source of information on environmental or fire and emergency regulations.
Where there is variation between this guideline and any regulation then the applicable
regulation overrides this guideline.
Importantly, the guideline is not intended to replace proper occupational training, which is
a requirement under Workplace Health and Safety (WHS)/Occupational Health and Safety
(OHS) laws.
Whilst every effort has been made to ensure the accuracy of the information presented in
this guideline, the advice presented may not apply in every circumstance. Accordingly, Tyre
Stewardship Australia (TSA) cannot be held responsible, and extends no warranties as to:
• the suitability of the information for any particular purpose; and
• actions taken by third parties as a result of information contained in this guide.
If you need help with any of the contents of this guideline or have additional questions, refer
to the list of contacts and resources provided in section 7 of this guideline.
ACKNOWLEDGEMENTS
In order to harness existing knowledge and ensure that these guidelines are in line with
the expectations of key stakeholders, this guideline was developed in consultation with a
range of government and industry stakeholders; background research conducted as part
of this project included two workshops and a number of one-on-one consultations with
industry representatives (tyre recyclers and collectors), state-based environmental regulators
and state-based fire and emergency services (FES) departments. The authors and Tyre
Stewardship Australia (TSA) gratefully acknowledge the support and contributions to this
guideline from all those who participated in the consultation for this project.

ABOUT THE NATIONAL TYRE PRODUCT

STEWARDSHIP SCHEME
The National Tyre Product Stewardship Scheme (‘the Scheme’) is a voluntary scheme aimed
at improving the management of end-of-life tyres in Australia. Its objective is to:
• Increase resource recovery and recycling and minimise the environmental, health and
safety impacts of all end-of-life tyres generated in Australia.
• Develop Australia’s tyre recycling industry and markets for tyre derived products.
Tyre Stewardship Australia (TSA), is a not-for-profit company established to administer the

Scheme. It is funded by tyre importers at a rate proportional to the number of tyres they
import into Australia.
Participants in the Scheme commit to play their part in ensuring end-of-life tyres are
disposed of in a way that represents environmentally sound use.
There are a number of categories of Participants in the Scheme:

• Tyre importers and vehicle importers and manufacturers
• Retailers
• Fleet operators
• Local governments
• Collectors
• Recyclers
• Miners.
Businesses and organisations apply to become Participants in the Scheme. On becoming

Participants, they are required to meet the commitments that are relevant to them. These
commitments are set out in the Tyre Product Stewardship Scheme Guidelines.
PARTICIPANT COMMITMENTS
In order to participate in the scheme accredited participants commit to contribute to:
• the environmentally sound use of end-of-life tyres;
• elimination of the inappropriate export of baled tyres from Australia;
• elimination of the illegal dumping of end-of-life tyres;
• elimination of disposal of end-of-life tyres to landfill (except where no viable alternative is
available and subject to state and territory legislation; for example, in rural and remote
areas where appropriate recycling facilities are not available, or transportation costs are
prohibitive).

ABBREVIATIONS
ABBREVIATION DESCRIPTION
ACTRFS ACT Rural Fire Service
AS Australian Standard
BCA Building Code of Australia
BPA Bushfire Prone Area
CCTV Closed-Circuit Television
CFA Victorian Country Fire Authority
CFS South Australian Country Fire Service
DFES Western Australian Department of Fire and Emergency

Services
EPA Environment Protection Authority
EPL Environment Protection Licence
ERA Environmentally Relevant Activity
EPU Equivalent Passenger Unit
ESA ACT Emergency Services Agency
FRNSW Fire and Rescue NSW
MFB Victorian Metropolitan Fire Brigade
MFS South Australian Metropolitan Fire Service
NCC National Construction Code
NEPM National Environmental Protection Measure
NSW RFS New South Wales Rural Fire Service
NTFRS Northern Territory Fire and Rescue Service
OHS Occupational Health and Safety
PAH Polycyclic Aromatic Hydrocarbons
PPE Personal Protective Equipment
QFES Queensland Fire and Emergency Services

ABBREVIATION DESCRIPTION
RFSQ Rural Fire Service Queensland
SCBA Self-Contained Breathing Apparatus
SOP Safe Operating Procedures
TFS Tasmania Fire Service
TSA Tyre Stewardship Australia
TPSS Tyre Product Stewardship Scheme
UNEP United Nations Environment Programme
WHS Workplace Health and Safety
GLOSSARY
TERM DEFINITION
Access In the context of this guideline, access refers to provision of

space for safe entry point or a way in for emergency vehicles
and staff.
Best practice Best practice represents the current ‘state-of-the-art’; methods

or procedures which have consistently shown results superior
to other methods. An important aspect of best practice is
continuous improvement, as best practice can change and
evolve over time, for instance when there are improvements or
advances in technology.
Buffer zone An area of land designated for protection of the environment

or surrounding receptors, for instance to protect surrounding
residences and businesses from impacts from industrial
processes e.g. dust and noise.
Bunding A constructed retaining wall made from impervious material

designed to retain liquid to prevent the escape of potentially
polluting substances from that area.

TERM DEFINITION
Egress In the context of this guideline, egress refers the provision of

space for safe exit for emergency vehicles and staff from a
facility.
End-of-life tyres A tyre that is deemed no longer capable of performing the

function for which it was originally made.
Environmentally sound The Tyre Product Stewardship Scheme defines environmentally

use sound use as follows:
i. recycling into tyre crumb, shred, chips, granules, steel and
other tyre components;
ii. use as a fuel (other than direct incineration without effective
energy recovery and unsustainable burning for energy
recovery) or other means to generate energy;
iii. production of tyre derived products, including tyre derived
fuel;
iv. civil engineering.
Fire and emergency The process of planning, preparing and controlling risks for
preparedness potential fire and emergencies.
Fire risk assessment A process for:

i. Determining all possible fire hazards and scenarios at the
site, the likelihood that they will cause a fire and severity of
the potential fire;
ii. Determining all possible controls which can be implemented
to control the identified fire hazards and scenarios;
iii. Mitigating fire risks through the identified control measures
and by ensuring that all necessary fire safety and
emergency equipment is installed.
Hardstand A paved or stabilized area designed for storage of material or

parking for heavy vehicles.

TERM DEFINITION
Mutual aid In the context of emergency response, mutual aid is an

agreement to lend assistance across property boundaries.
For instance, this may occur due to an emergency requiring
additional resources, such as a tyre fire at a facility, which may
require assistance from neighbouring properties in addition to
emergency services.
Reticulated supply Town water supply or piped water network.
Stockpile In the context of this guideline, legitimate stockpiling is the

bulk storage of tyres on private land, with the permission of
the landowner, in compliance with the relevant state or local
government regulations and requirements, generally with
plans to process those tyres or transfer to another place for
environmentally sound use.
Tyre storage In the context of this guideline, tyre storage refers to the
temporary stockpiling or accumulation of tyres prior to
processing, or transfer to another place for further processing
or some other environmentally sound use. Long-term or
indefinite stockpiling of tyres is not supported by TSA.
Work Health and In the context of this guideline, this refers to the WHS
Safety (WHS) framework in Australia, which generally requires businesses to
ensure that they provide a safe work place. For tyre storage,
this relates to ensuring that all requirements are met so that
the health and safety of all stakeholders in the workplace are
protected from the exposure to potential hazards and risks
resulting from tyre storage activities.

INTRODUCTION 1
The Best Practice Guidelines on Tyre Storage and Fire and Emergency
INTRODUCTION
Preparedness (hereafter referred to as the Tyre Storage Guidelines) have been
developed to provide tyre collectors and recyclers with a roadmap to comply
UNDERSTANDING
TYRE FIRES AND TYRE with the regulations and requirements relevant to tyre storage and move
STORAGE REGULATIONS towards best practice methods for storage and fire and emergency preparation.
The guideline presents the Essential Requirements which have been deemed
FACILITY LAYOUT
to comply with regulatory requirements across each relevant Australian
jurisdiction, however implementation of these Essential Requirements should
FIRE & EMERGENCY
be undertaken with reference to the regulations and guidelines applicable
PREPARATION
to your state or territory (see Section 7 for a list of resources). The guideline
also presents best practice methods to help businesses reduce risks and be
FIRE SAFETY &
EMERGENCY EQUIPMENT best prepared for fire/emergencies, as far as practicable.
This guideline focusses mainly on the needs of tyre collectors and recyclers,
FACILITY MANAGEMENT as these businesses tend to store greater quantities of tyres and hence carry
more risk; however, the guideline may be used by any business which stores
CONTACTS AND a significant number of tyres on a temporary basis. Whilst the long term
RESOURCES
storage of end-of-life tyres is not supported by TSA, these Guidelines will
have application for those organisations that may be managing or monitoring
legacy stockpile sites.
This guideline will help you to:

• Understand Essential Requirements for complying with State or Territory
regulations relevant to tyre storage
• Understand environmental and OHS risks associated with tyre storage
and best practice mitigation measures
• Understand how to plan, design and operate facilities which incorporate
best practice tyre storage, fire and emergency preparation
1.1 CONTEXT
Australia suffers from a legacy of stockpiles of end-of-life tyres that have resulted
from the actions of unscrupulous operators and a number of other factors
including constrained local markets and highly volatile international markets.
These stockpiles have exposed whole communities to risks associated with
fire and vermin through the use of inappropriate storage arrangements.
A range of hazards and risks are associated with tyre stockpiles, which
increase in likelihood and impact with increasing storage quantities. The risk
associated with large stockpiles are such that most Australian jurisdictions
have imposed strict limits on the quantity of tyres stored and the manner in
which they must be stored at a facility.

Furthermore, when those risks are realised, for example through a major tyre fire, the image
and reputation of the entire tyre recycling industry can be adversely affected. Since early 2015,
there have been at least three major incidents: two fires in Victoria and one in Queensland,
which have brought the issue to the attention of the Australian media and community.
Tyre Stewardship Australia (TSA) does not support long-term or indefinite stockpiling of tyres,
however it recognises that temporary storage is a necessary and often unavoidable step in
the environmentally sound use of end-of-life tyres. To support industry to reduce the risks
associated with tyre storage, TSA engaged Arcadis to develop the Best Practice Guidelines
on Tyre Storage and Fire and Emergency Preparedness (Tyre Storage Guidelines). The
development and use of the Tyre Storage Guidelines will help tyre collectors, recyclers and
other businesses involved in tyre storage activities to significantly reduce the environmental
and occupational health and safety (OHS) risks associated with the management end-of-
life tyres. It is anticipated that uptake of the guideline by industry will help to lower the risk
across industry.
1.2 BENEFITS OF IMPLEMENTING BEST PRACTICE

Aside from managing and reducing the risk of fire at your facility, there are a number
of additional benefits to implementing best practice tyre storage, fire and emergency
preparation, including:
• Changes made to reduce your fire risk can help to reduce your insurance premiums
• Improve your workplace environment
• Lower your risk of liability (e.g. for pollution, non-compliance)
• Improve your relationship with neighbours and other stakeholders
• Assist with long term regulatory compliance
1.3 GUIDELINE STRUCTURE

The guideline is structured around seven key steps to achieving and maintaining best
practice tyre storage and fire and emergency preparedness. There are seven sections to
the guideline, as shown in the flowchart below. Each section includes a discussion of the
essential requirements, and guidance on best practice methods and procedures.
Best practice represents the current ‘up-to-date’, methods or procedures which have
consistently shown results superior to other methods. It is recognised that best practice
can change and evolve over time, for instance when there are improvements or advances in
technology. The methods presented in this guideline are considered best practice at the time
of writing.
12 1 INTRODUCTION TSA_BPGL V1 MARCH 2019

1. INTRODUCTION
What is this guideline about, why should you read it, how it is structured.
2. UNDERSTANDING TYRE FIRES AND

TYRE STORAGE REGULATIONS
The nature and behaviour of tyre fires, key fire risks at tyre storage facilities and methods for
reducing risks. Overview of relevant regulations (see also Appendix A).
3. FACILITY LAYOUT INCLUDING STACKING/ STOCKPILE ARRANGEMENTS

Planning your tyre facility for best practice tyre storage, site selection and layout,
site security, water access requirements, stacking and stockpile. Separate guidance for
internal/ external storage is provided.
4. FIRE & EMERGENCY PREPARATION

How to develop a best practice fire and emergency plan, conduct a fire risk assessment,
develop site management plans and procedures and implement ignition source controls.
How to engage with local fire services and provide best practice training for staff including
first response firefighting.
5. FIRE SAFETY & EMERGENCY EQUIPMENT

Guidance on the fire safety and emergency equipment that should be provided at tyre
storage facilities. Separate guidance for internal/ external storage is provided.
6. FACILITY MANAGEMENT
CONTINUOUS
Once all plans and procedures are in place, how to implement IMPROVEMENT
them into facility operations.
7. CONTACTS AND RESOURCES

Contacts and resources for further information.
TSA_BPGL V1 MARCH 2019 1 INTRODUCTION 13

An important aspect of best practice is incorporating continuous improvement into

operations and procedures; that is, taking steps to regularly improve management methods.
It is recommended that operators follow this approach to move toward best practice tyre
storage and fire and emergency preparedness and ensure that improvements continue into
the future.
14 1 INTRODUCTION TSA_BPGL V1 MARCH 2019

UNDERSTANDING TYRE FIRES AND

TYRE STORAGE REGULATIONS 2
INTRODUCTION 2.1 OVERVIEW OF TYRE FIRES

Although not easy to set alight, the nature and composition of tyres mean
UNDERSTANDING that once alight, tyre fires burn strongly, hot and fast and are extremely
TYRE FIRES AND TYRE
STORAGE REGULATIONS difficult to control. Since tyres are designed to absorb the heat generated
by friction with the road, they are not easy to ignite, however, they retain
FACILITY LAYOUT heat well and are composed of highly combustible materials – which means
that, once alight, they produce very high heat, which is further conducted by
FIRE & EMERGENCY
the high carbon content and steel reinforcement. This ability to absorb heat
PREPARATION makes it very difficult to extinguish tyre fires and they can burn for months,
generating smoke, oil and leaching toxic contaminants that affect the soil,
FIRE SAFETY & waterways and air.
EMERGENCY EQUIPMENT
Due to the shape of tyres, tyre piles contain many gaps, spaces and air
pockets which enable a continued supply of oxygen to fuel a tyre fire. Tyre
FACILITY MANAGEMENT
piles are difficult for firefighters to penetrate with water or foam; since tyres
are designed to repel water, and their hollow ‘doughnut’ shape traps oxygen
CONTACTS AND
RESOURCES and can form a barrier to firefighting water. This means that most traditional
firefighting agents including water and foam are less effective against a tyre fire.
The way that tyres are stored can produce further complications, as the tyre
pile continues to burn the shape of the pile can change, as tyres burn down
and compress, and flaming tyres can roll off the pile spreading the fire to
other piles or surrounding infrastructure. This creates an ideal fire that burns
extremely hot and fast in a manner that is difficult to predict and fight.
While they are inert and not hazardous in their original form, tyres contain a
number of hazardous chemicals including oil, benzene, toluene and sulphur.
This means that when burnt, tyre fires present significant risks to human
health and the environment, producing large volumes of thick and toxic
smoke. Eventually, tyres burn down to an oil (sometimes called pyrolytic oil)
which can pollute waterways and surrounding land. Water used in firefighting
operations also becomes contaminated, with runoff commonly seeping into
groundwater and surface water, presenting a serious risk to the surrounding
environment.
Tyre fires are commonly caused by arson or resulting from ignition in on-site
machinery, or from bush or grass fires in rural areas. Some of the key factors
that influence and increase the risk and impact of tyre fires are:
• How facilities on-site machinery are managed and operated
• The size of tyre stockpiles
• Where and how long tyres are stored
• How tyres are stacked, the amount of exposed surface area and air
pockets within stockpiles

For these reasons, methods for reducing the fire risk associated with tyre storage must
focus on:
• Effective fire prevention and site procedures to minimise the risk of fire occurring
• Limiting the size of tyre stockpiles as far as is practicable
• Maintaining adequate clearance between stockpiles and other infrastructure
• Configuring stockpiles in a way that ensures access for firefighting and maximises its
effectiveness
• Protection of human health and the environment in the event of a fire.
2.2 REGULATORY OVERVIEW

While interstate transport of tyres is regulated under the National Environmental Protection
(Movement of Controlled Waste between States and Territories) Measure 2004 (Controlled
Waste NEPM), there is no federal control over the storage of tyres. However, where tyres
are stored internally, buildings must be constructed in compliance with Volume 1 of the
National Construction Code (NCC), Building Code of Australia (BCA) (refer to Section 7 for
details on where to find this document). In addition, Australian businesses have obligations
under the harmonised Work Health and Safety (WHS) framework in Australia, which requires
businesses to ensure that they provide a safe work place.
Tyre storage in Australia is generally regulated at a state-level; an overview of the relevant

legislation for storage of waste tyres by jurisdiction is presented in Appendix A. In addition,
participants in the national Tyre Product Stewardship Scheme are required to meet the
commitments of the Scheme guidelines to ensure environmentally sound management of
end-of-life tyres.
ESSENTIAL REQUIREMENTS
A comprehensive review and comparison of the requirements in each jurisdiction was

undertaken as part of the background research for development of this guideline and,
where possible, essential requirements for tyre storage and fire risk management
have been identified which are considered to be applicable to most Australian
jurisdictions. These are included in boxes like this throughout the guideline.
Furthermore, a checklist which provides an overview of all essential requirements has
been provided in Appendix B.
This guideline does not seek to replace legislation or regulations. The regulations and
guidelines relevant to your state or territory should be considered in conjunction with
this guideline.
16 2 UNDERSTANDING TYRE FIRES AND TYRE STORAGE REGULATIONS TSA_BPGL V1 MARCH 2019
FACILITY LAYOUT 3
The prevention of a fire is the primary defence for any facility where tyres
INTRODUCTION
are temporarily stored, and therefore the layout of the facility is crucial. The
best fire and emergency preparation involves engaging with your local fire
UNDERSTANDING
TYRE FIRES AND TYRE authority, both at the outset and throughout continuing operations) and
STORAGE REGULATIONS collaborating with all relevant authorities and incorporating all possible fire
prevention methods into the layout and design of your facility. This section
FACILITY LAYOUT details the essential requirements and best practice layout of tyre storage
facilities, both for internal and external storage of tyres.
FIRE & EMERGENCY
PREPARATION
3.1 COMMON REQUIREMENTS FOR BOTH
FIRE SAFETY &
EMERGENCY EQUIPMENT
INTERNAL AND EXTERNAL STORAGE
FACILITY MANAGEMENT 3.1.1 PLANNING YOUR FACILITY

Whether designing a new facility, or upgrading an existing site, it is important
CONTACTS AND
RESOURCES to liaise with all relevant authorities to ensure that your facility meets the
requirements of all parties. These include:
• The local planning authority (usually the local council)
• The environmental regulator in your state or territory (e.g. Environment
Protection Authority)
• The workplace safety regulator in your state or territory (e.g. WorkSafe)
• The relevant State/Territory fire service.
Best practice is to plan, design or upgrade your facility in close collaboration

with the relevant authorities and especially the local fire authority, to ensure
that all relevant requirements are met and where possible exceeded and the
risk of fire at your facility is minimised as far as practicable.
Site selection
When selecting a site for tyre collection or processing activities, there are a
number of factors which should be considered in order to minimise the risk
of fire, and impacts to the environment and human health. The location and
size of a facility where tyres are stored should consider:
• Site area/size, and whether the site is large enough to accommodate
facility infrastructure, and allow access for firefighting vehicles in the event
of an incident (see Section 3.3.2) and whether the building can provide
adequate tyre storage area. Best practice is to allow for future expansion
of your facility.

• Zoning of the site – development of facilities in a Bushfire Prone Area (BPA) should be
avoided (note that there are additional requirements under Volume 1 of the NCC for
buildings located in a Bushfire Prone Area)
• The quantity of tyres that will need to be stored and whether required separation
distances and safe egress or pathways can be maintained (see Section 3.2.3)
• Sensitive receptors within the surrounding area i.e. avoid situating your site within 500m
of schools, residences, water bodies, major transportation routes and other sensitive
receptors.
• Provision of adequate buffer zones from neighbouring sites.
• Access to utilities, in particular water for firefighting purposes (see Section 5.1.2)
• Condition of adjacent roads and access points and whether these can accommodate
emergency services vehicles (see Section 3.2.1).
Best practice site selection would include consideration of smoke plume (smoke column)
behaviours, as the prevailing winds and their direction, and where any smoke produced
during a fire at the facility would travel should influence where a site is ideally situated. For
instance, if it is determined that the prevailing winds would carry the smoke plume from a fire
directly across a major transport route, or onto a sensitive receptor like a school or hospital,
then it would not be wise to place your site at that location.
3.1.1 ESSENTIAL REQUIREMENTS
Site selection for storage of tyres should include consideration of the following:
• impermeable soil, or addition of sealed surface
• site should be situated away from surface watercourses
• where tyres are stored outside, proximity to infrastructure and ensure site is large
enough to account for separation distances and allow for future expansion
• flat, level ground where possible.
Please note:
It is recognised that some of the measures recommended in the guideline
may not be immediately achievable by some existing and smaller sites. It is
recommended that all sites strive for best practice via continuous improvement,
which can be approached via your TSA Action Plan
18 3 FACILITY LAYOUT TSA_BPGL V1 MARCH 2019

Building Design and Upgrade

Buildings need to be designed and constructed in compliance with Volume 1 of the NCC.
Part E of Volume 1 of the NCC lists requirements and specifications for firefighting equipment
and smoke hazard management and, along with other requirements. Tyre storage facilities
are a special hazard requiring Clause E1.10 and E2.3 to be considered. An appropriately
qualified engineer should be engaged to design or upgrade the building and incorporate
all fire protection systems required under the Code. Further detail on building requirements
where tyres are stored inside are summarised in Section 3.2 and see Section 5 for further
details on fire and emergency equipment.
Tyre storage facilities should comply specifically with Clause E1.10 and E2.3, Part E
of Volume 1 of the NCC.
3.1.2 SECURITY AND MONITORING

Since many tyre fires are caused by arson, it is important to implement suitable security
arrangements, to prevent unauthorised access to your facility. At a minimum, all access
points should have security locks, which should be checked regularly to ensure they are in
good condition. Glass panels and windows should be minimised near entry points as these
present a weak point through which intruders might gain entry. Additional security measures
such as heavy duty security gates, alarms and CCTV cameras are strongly recommended to
prevent arson attempts.
In addition, early fire warning detection systems can also be installed to alert maintenance
staff and management, and provide sufficient time to contact emergency services and
deploy on-site firefighting equipment. This may include incorporation of thermal imaging or
smoke detectors at potential ignition sources.
External Storage
When tyres are stored outside, site security is even more important to preventing arson
attempts, particularly after hours. The essential requirements listed above meet the
requirements of most Australian States and territories, and the following best practice
methods are recommended:
• Install intruder controls, such as cyclone wire, at the top of security fences.
• Check security fences and access points regularly to ensure they are in good condition.
• Minimise glass panels and windows near entry points as these present a weak point
through which intruders might gain entry.
TSA_BPGL V1 MARCH 2019 3 FACILITY LAYOUT 19

• Implement additional security measures such as heavy duty security gates, alarms and
CCTV cameras.
• Implement a secure access card system to areas where tyres are stored and appoint
a qualified security guard to be on site during opening hours (or a staff member that is
trained and allocated this responsibility).
• Implement after hours security, such as alarms, CCTV cameras monitored by an external
security monitoring company.

Site security should include full enclosure of the site with fence or wall (non-
combustible materials) of adequate height to prevent unauthorised access.
3.1.3 WATER ACCESS AND CONTAINMENT

Operators should assess water access at the site and ensure that sufficient water supply
is available in the event of a fire. This can be undertaken at the design stage for new sites,
while existing sites may implement this as part of your TSA Action Plan.
See Section 5.1.2 for further details on water access and containment
Facilities should refer to both AS2419.1 (Fire hydrant installations) and AS2118.1
(Automatic fire sprinkler systems) for determining water supply requirements.
3.1.4 SITE SPECIFIC RISK ASSESSMENT

It is a requirement in some states (including Victoria and NSW) that a site-specific fire risk
assessment or fire safety study be conducted at all sites storing tyres. No one site is the
same, and tyre storage facilities vary significantly in the quantity and method of storage,
so regardless of your site’s location it is considered best practice to conduct a fire risk
assessment or fire safety study. The aim of the fire risk assessment is to determine all fire
hazards, the likelihood and consequence of these, and appropriate mitigation measures,
resources and equipment that should be provided at the site.
Refer to Section 4.3 for further information on how to complete a risk assessment.

All sites storing tyres, regardless of volume or size, should undertake a site-specific
fire risk assessment or fire safety study.
3.2 INTERNAL STORAGE

This section provides the minimum and best practice methods for a facility layout where
tyres will be stored inside a building.
3.2.1 SITE LAYOUT AND DESIGN

Operators should refer to Part E of Volume 1 of the NCC and the relevant standards
when designing their facility to determine fire protection system requirements including
fire hydrants, sprinkler systems, smoke hazard management systems and water supply
and containment requirements (see Section 5.2). When considering the number of tyres
which will be stored at your facility it may be worth considering Clause E1.10 of Volume 1
of the NCC, as storage in excess of certain quantities may trigger additional fire sprinkler
requirements. These are determined by the relevant fire authority. based on an assessment
of the likely fire scenarios and appropriate risk control measures implemented. Provision of
sprinkler systems can be costly, and may not be feasible depending on your circumstances
(for instance, where property is under a short-term lease arrangement). If tyre storage
requirements can be kept under these limits this may avoid the need for sprinkler systems,
although it is noted that some states may require this under state-specific regulations
or guidelines, even if the stored volume of tyres is less than the threshold defined for
combustible goods.
Site entry points should have at least 4m clearance with access roads designed for
large emergency vehicles and their weight limits. Large facilities should have at least
2 separate access points.
You should ensure that site access points, including gates and road surfaces are large
enough to allow access for emergency vehicles. See Section 3.3.2 for further detail on this.
Best practice is to determine site layout requirements and fire protection systems based on a
site-specific fire risk assessment (see Section 4.3).

Where tyres are stored internally, operators should ensure that they are in compliance
with the standards set out in the NCC, Volume 1, especially fire protection systems
which are pursuant to Clause E1.10 and E2.3.
3.2.2 STACKING/STOCKPILE ARRANGEMENTS

You should ensure that the storage areas are adequate to allow the required stockpile
sizes, and associated separation distances or clearances, either at the design stage or by
re-configuring your existing site (see Section 3.2.3 below). Importantly, there should never
be any obstruction of fire equipment systems as this will impede their use. The preferred
method for indoor storage is barrel stacking.
Best practice examples for tyre storage systems (i.e. pallet systems, portable racks) for
indoor, are illustrated in the National Fire Protection Association NFPA 231D Standard for
storage or rubber tyres.
Refer to Section 3.3.3 for a comparison of the advantages and disadvantages of each of the
stacking options for tyres.
Where tyres are stored internally, at a minimum the following is required:

• Portable storage systems that can be easily moved by forklift
• Horizontal systems using pallets or shelving racks for heights exceeding 1.5m
• No obstruction of fire equipment and storage.
3.2.3 STOCKPILE SIZE, DIMENSIONS AND CONFIGURATIONS

Tyres should be stored in accordance with the essential requirements in your State or
Territory, the stockpile configurations listed on p. 25 meet the requirements of most
Australian States and Territories. Best practice is to minimise the size of tyre stacks and
storage quantities as far as practicable. The site layout diagrams shown in Figure 1 on p.
26 demonstrate the clearance distances which should be maintained when tyres are stored
inside.

Tyre stacks within a building should not exceed 3.7m in height or 30m2 in area. The
following boundary perimeters are required (refer to Figure 1 overleaf):
• Building without sprinklers – minimum of 3m between stacks and building
structures
• Building with sprinklers – minimum of 2m between stacks and 1.5m between
stacks and building structures.
A minimum clearance of 1m should be maintained along paths of travel to exits

or firefighting equipment access and stored tyres must be 1m clear of roof or any
structures attached to the roof.

24
3 FACILITY LAYOUT
Figure 1 Stockpile configurations and clearance distances for indoor storage of tyres1
1 This diagram is indicative and alternative layouts may be deemed to be best practice in particular jurisdictions – check with your local authorities and regulations.
TSA_BPGL V1 MARCH 2019

3.3 EXTERNAL STORAGE

This section provides the essential requirements and best practice methods for facility layout
for storage of tyres outside.
3.3.1 SITE LAYOUT AND DESIGN

When tyres are stored externally, one of the key considerations is the quantity of tyres that
will need to be stored at any one time, how these will be stored and ensuring adequate
storage space at the site. If tyres are to be stored in stockpiles, there are restrictions on pile
sizes, how these are configured and separation distances from other piles, infrastructure
and boundaries (which are required by regulators in most Australian jurisdictions). These
restrictions have been based on previous research and knowledge of how tyres burn and
examination of optimal arrangements which allow firefighters best access to fight a fire.
While the preferred method for outdoor storage is laced stacking, it is important to consider
the following when considering your site’s layout regardless of the arrangement:
• The quantity of tyres expected to be stored under normal operating conditions
• Provision of adequate storage space to meet the required stockpile/stacking
arrangements (refer to Section 3.3.3)
• Control of runoff water in the event of a fire or incident, and whether adequate
containment can be provided on the site (see Section 5.1.3)
• Neighbouring sites/surroundings and their potential as ignition sources (i.e. if located
adjacent to an industrial facility, tyres should not be stored on the boundary shared with
that facility)
• Sealing surfaces at sites with permeable soils (permeable soils such as sand and gravel)
• Provision of hardstand designed for emergency vehicle weight limits
Best practice is to determine site layout requirements and fire protection systems based on a
site-specific fire risk assessment (see Section 4.3).
Questions to ask when designing site layout:
• How many stockpiles will there be?
• How much storage area is needed to maintain adequate separation

distances between the piles, site infrastructure and site boundaries?

3.3.2 SITE/FIRE ACCESS

You should ensure that site access points, including gates and road surfaces are large
enough to allow access for emergency vehicles, the essential requirements noted in the
box below meet the requirements of most Australian States and Territories. Best practice
methods include:
• Ensure that access points are provided on opposite ends of the site, ideally either side of
the likely path of a potential smoke plume.
• Incorporate a rapid entry feature to access points to allow quick access for emergency
services.
• Ensure adequate hardstand areas are provided at the site, to prevent emergency vehicles
becoming bogged and unable to access the site to fight a fire.
• Ensure vegetation within close proximity is managed on a regular basis.
• Consider the prevailing winds and potential direction of a smoke plume in the event of a
fire when designing access points, given that this may impede emergency services from
accessing the site.
Site entry points should have at least 4m clearance with access roads designed for
large emergency vehicles and their weight limits. Large facilities should have at least
2 separate access points.
3.3.3 STACKING/STOCKPILE ARRANGEMENTS

The various stacking options for tyres and commentary on associated fire risks are detailed
in the table on p. 29 and 30. The preferred method for indoor storage is barrel stacking and
laced stacking for outdoor situations.
Tyres should not be stacked on their treads unless there is some means of
containing/constraining the stacks.

METHOD DESCRIPTION ADVANTAGES DISADVANTAGES COMMENTS
Barrel stacking A fire in a barrel stack will Tyres can be unstable and This method is
reportedly burn with a can fall off when moving racks recommended for indoor
Whole tyres are stacked on
whirlpool effect sending flames or pallets. (applicable for outdoor as
their side, on top of each
straight up in the air, which well) storage and where
other in a uniform fashion.
may reduce the speed of the pallets or trolleys are
This method is typically used

fire spreading laterally (State of available.
for indoor storage on movable
California, 2004).
pallets or trolleys, or where
tyres may be sold for re-use.
Laced stacking Laced stacking minimises the This method most effective This is the preferred method
amount of space needed for for stacking tyres of the same of storage in outdoor
Whole tyres are stacked
storage, and also minimises size. Stacking takes more situations.
overlapping to create a woven
the amount of surface area time because tyres need to be
or laced arrangement.
exposed in a fire. Tyres are arranged in a laced pattern.
also more stable as they are
interlocked in a laced pattern.
Shredded or processed Reduces storage space and Shredding and crumbing is It is preferable to process
tyres reduces risks associated costly. tyres as soon as practicable
with water collecting in to reduce fire risks.
Shredding or crumbing tyres
tyres providing a breeding
reduces the volume of space
ground for mosquitos and
required for storage.
other vermin. Fires in piles of
shredded tyres are reportedly
less intense and produce less
smoke, since shredded piles
tend to burn at the surface
(IWMB, 2002).
3 FACILITY LAYOUT
27
28
METHOD DESCRIPTION ADVANTAGES DISADVANTAGES COMMENTS
Tread up Stacking It is easy to access and move In the event of a fire tyres can Tyres should not be stacked
tyres that are stacked on easily roll away and spread on their treads unless there is
Whole tyres are stacked on
their treads, and it is easier fire to nearby stockpiles or some means of containing/
3 FACILITY LAYOUT
their treads.
to organise tyres of different infrastructure. constraining the stacks,
sizes. given the containment/
constraint is fire resistant.
Baling Baling minimises the amount Research has indicated This method may be used
of storage space and tyres that even after 6 months’ for transport and export
Whole tyres are compressed
are effectively restrained in the compression, baled tyres will however it should not be
into a ‘bale’ and secured
bale. spring back to original shape used for long term storage.
(usually with steel wire) in
when released. In a fire the
preparation for storage,
steel wires are broken under
transport or export.
high temperatures and the
quick release of pressure
draws oxygen and fire into
the interior of tyres as they
return to their shape, which
can further fuel a fire. (IWMB,
2002).
Random stacking This method requires less This method takes up the This method of stacking
effort as tyres can be stacked most storage space. Due is not compliant in most
Whole tyres are tossed
quickly without considering to the random placement of Australian jurisdictions and
randomly into a pile.
where best they should be tyres more tyre surface area is is not in keeping with best
placed. exposed and greater amount practices. This method
of air between tyres, which will should not to be used.
further fuel and accelerate a
fire should one occur.

Tyres should be stored in accordance with the essential requirements in your state or
territory, the stockpile configurations listed on p. 32 meet the requirements of most Australian
States and territories. The site layout diagrams shown in Figure 1 on p. 16 demonstrate
the clearance distances which should be maintained when tyres are stored inside. It is
important that operators ensure that storage areas are large enough to comply with stockpile
size restrictions and separation distances (refer to Section 3.3.4 for further guidance on
calculating storage space).
Because of the risk of contaminating the surrounding environment in the event of a fire, tyres
should be stored on a sealed surface (e.g. concrete), with provisions for containing any runoff
or oil generated during firefighting (as detailed in Section 5.1.3).
The following best practice measures are recommended:

• Minimise the size of tyre stacks and storage quantities as far as practical. As a guide it is
considered that all tyres should be processed or transferred within 30 days, unless there
are extenuating circumstances preventing this.
• Provision of hardstand for storage areas.
• Provision of equipment which can quickly separate and move tyres in the event of an
incident (see Section 4.2).
• Ensure adequate clearance between the stockpiles to allow for 2 or more trucks to
access the tyre storage area in the event of a fire.
One method of storing tyres includes storage in a pit or contained area, which can be
filled with water to submerge and extinguish a fire. While this has been reported to be a
successful method of fire prevention (IWMB, 2002), this method may not be supported by
some state regulators. Any water used in this method would likely be contaminated and
therefore require testing and potential disposal as hazardous liquid waste. Contact your local
environmental regulator before implementing this at your site.

Acceptable tyre storage configurations/stacking (refer to Figure 2 on p. 34):
For outdoor storage, tyres should be stored on their sides or laced, with tyres
stacked overlapping to create a woven arrangement, unless they are restrained by
some means e.g. metal cages or portable systems.
Tyres should not be stacked on their treads unless they are contained by some
means.
Unless your licence or local regulator prescribe different requirements, tyre

stockpiles should:
• not exceed 3m in height due to potential for instability
• be no more than 6m wide and 20m in length (arrangement in long ‘thin’ piles will
assist firefighting operations)
• Alternatively, the total volume of tyres contained in a pile should not exceed
360m3.
Aisles between tyre stockpiles should remain clear from all combustible material
and allow for fire fighter access. Appropriate separation distances should be
determined based on the size of the pile, a minimum separation distance of 20m is
recommended between each tyre stockpile.
Differing requirements exist for NSW sites, refer to the NSW guidelines for further
detail (see Section 7).

3.3.4 CALCULATING TYRE STORAGE SPACE

For outdoor storage, the following calculations may assist in determining the amount of
space needed to store tyres at your facility.
Max. tyre pile size = 6m x 20m = 120m2
Incl. separation distance (20m) = 46m x 60m = 2760m2 per pile
Incl. max. height (3m) 6m x 20m x 3m = 360m3
Tyres2 per m3 = 12 EPUs per m3
Max tyres per stockpile 4,320 EPUs
This means that you should allow about 2760m2 storage area (including buffer zones) per
stockpile or 4,320 EPUs stored. This area may be reduced depending on how the piles
are configured – drawing up a site plan will help to determine the number of tyres which
can be stored at your site. Operators are encouraged to seek advice from the local fire
and emergency services and/or a specialist consultant in determining the amount of space
needed.
The following separation distances are recommended (refer to Figure 2 on p. 34):

• Non-combustible boundaries – at least 6m from perimeter
• Combustible boundaries or public roads – at least 20m from perimeter if the
stockpile’s long sides face the boundary and 12m from perimeter if the stockpile’s
narrow ends are facing the boundaries.
• If the building is protected with automatic fire sprinkler system that meets the
AS2118.1 standards, this distance may be reduced to 10m.
2 EPUs per metre is based on a maximum tyre pile of 3m, whole passenger/ light truck tyres, laced stacking, stored less than
15 years. This number has been converted to metric/ EPUs from information published by Cal Recycle (2015) on determining
the number of tyres in stockpiles. See the following link for further information: http://www.calrecycle.ca.gov/tires/enforcement/
inspections/NumberTires.htm#Volume

32
Figure 2 Stockpile configurations and clearance distances for outdoor storage of tyres3
3 This diagram is indicative and alternative layouts may be deemed to be best practice in particular jurisdictions – check with your local authorities and regulations.

FIRE & EMERGENCY PREPARATION 4
Fire and emergency planning and preparation is a vital step in the design and
INTRODUCTION
operation of your facility, as there are a number of measure which can be
implemented to first minimise the risk of fire and then optimise the success
UNDERSTANDING
TYRE FIRES AND TYRE of fighting a fire should one occur.
STORAGE REGULATIONS
Best practice emergency planning, establishment, validation and
implementation of an emergency plan should be done in accordance with
FACILITY LAYOUT
AS3745-2012 Planning for emergencies in facilities (Refer to Section 7 for
details on where to find this document). Considerations for emergency planning
FIRE & EMERGENCY
specific to tyre storage facilities are discussed in the following sections.
PREPARATION
FIRE SAFETY &

EMERGENCY EQUIPMENT 4.1 SITE EMERGENCY PLAN
An emergency plan should be developed for the site; this is a requirement
FACILITY MANAGEMENT for all businesses under the WHS/OHS laws. The emergency plan must be
documented and set out and expressed in a way that is readily accessible
CONTACTS AND and comprehensible to persons who use it.
RESOURCES
An emergency plan should address all aspects of emergency response
including:
• Emergency contact details for key personnel (e.g. fire wardens, floor
wardens, first aid officers) and local emergency services (e.g. police, fire
brigade)
• Appointment of organisation of fire wardens
• Site evacuation procedures
• The location of all fire safety and emergency equipment, and training of all
staff in their use
• Maintenance of fire safety and emergency equipment
• Procedures and schedule for regular emergency scenario training such as
evacuation drills, firefighting drills, spill response
The emergency plan should set out the management requirements and
processes to be followed in an emergency. In the case of a tyre storage
facility this should include determining the appropriate number of persons
trained in the use of on-site fire safety and emergency equipment and
processes for ensuring adequate staff are available at any time (either on-site
or on call). Some states (e.g. Victoria) require that the emergency plan is
prepared in consultation with the local fire service and this is considered to
be best practice.
Given the potential risks to both health and safety and the environment,
there are a number of additional items which should be considered when
developing your emergency plan, including:

• First attack firefighting/immediate response measures appropriate to the site and which
staff members should be trained in these (see Section 4.8)
• Locations of all drains at the site and procedures for ensuring any contaminated firewater
cannot enter drains (see Section 5.1.3)
• Locations of all hazardous materials at the site and procedures for ensuring these are
isolated and the risk of these.
• Prevailing winds and the direction a smoke plume may travel in the event of a fire as this
should be considered in evacuation plans (information on this can be obtained from the
Bureau of Meteorology)
A number of states (including NSW, Victoria, WA and South Australia) also require the
development of a Tactical Fire Plan as part of the emergency plan, and it is best practice to
develop this regardless of your site’s location. The main objective of a Tactical Fire Plan is to
provide detail of a site’s fire protection equipment and provide essential instructions for the
use of emergency services in the event of a fire. It is recommended that that Tactical Fire
Plans link with your local brigade’s fire pre-plans. These take the form of schematic drawings
which are colour coded to show locations of fire safety equipment. You should refer to your
state fire & emergency services department for guidance on how to develop a Tactical Fire
Plan, to ensure that they are consistent with the standards in your state or territory.
Significant publicity can be generated by a tyre fire, which can have a negative impact
of both your business and the wider industry. It is important to consider community
engagement at the planning stage, and you should develop a Communication Plan or
Protocol to ensure media releases/messages to community can be sent out quickly in the
event of an incident or fire. This can help to minimise damage to reputation and help allay
community fears (and also hasten responses to evacuation notices).
4.1 ESSENTIAL REQUIREMENTS
All sites should develop and document an emergency plan in accordance with
WHS/OHS laws that shows the location of all key fire equipment, site evacuation
procedures and other emergency services related information. This should include
appointment of a dedicated Site Safety Officer, and ensuring that all employees are
trained in the emergency procedures and that they are well rehearsed.
Best practice emergency planning, establishment, validation and implementation of

an emergency plan should be done in accordance with AS3745-2012 Planning for
emergencies in facilities.
34 4 FIRE & EMERGENCY PREPARATION TSA_BPGL V1 MARCH 2019

4.2 EMERGENCY AND FIRE PROTECTION

EQUIPMENT
Provision of fire safety and emergency equipment is a crucial aspect of fire and emergency
preparation. Operators should determine and document all site equipment requirements at
the planning/design stage or through development of the emergency plan, and best practice
is to determine these requirements as part of a fire risk assessment. Section 5 provides
greater detail on appropriate fire safety and emergency equipment for tyre storage sites.
4.3 FIRE RISK ASSESSMENTS

Some states have a requirement for a site-specific fire risk assessment (Victoria) or fire
safety study (NSW) to be conducted for sites storing tyres. It is considered best practice
that all sites complete a fire risk assessment or study as this will ensure that all fire risks can
be identified and controlled, and all resources and equipment required at the site can be
identified and provided.
The fire risk assessment should be conducted in consultation with your local fire authority
and, following a risk assessment method, you should consider all work areas, processes
and tasks undertaken at your facility to identify all possible fire hazards at the facility. This
might involve a walkthrough of the facility, you should involve employees and managers as
appropriate. For each fire hazard identified consider the following:
• Document all possible fire hazards and scenarios at the site, the likelihood that they will
cause a fire and severity of the potential fire
• Determine all possible controls which can be implemented to control the identified fire
hazards and scenarios
• Mitigate fire risks through the identified control measures and by ensuring that all necessary
fire safety and emergency equipment and other controls are installed and implemented.
An example risk matrix is provided overleaf, which can be used as a starting point for
conducting your fire risk assessment. As noted above, the fire risk assessment should be
conducted in consultation with your local fire authority or an appropriately qualified consultant.
All sites (new and existing) should undergo a fire risk assessment to identify fire
risks and document essential site equipment and resourcing requirements. Refer to
Section 5 for further information.
Where possible, this should be completed in consultation with your local fire authority.
TSA_BPGL V1 MARCH 2019 4 FIRE & EMERGENCY PREPARATION 35

36
Table 1 Example Fire Risk Assessment
FIRE HAZARD RISK INITIAL RISK CONTROLS RESIDUAL RISK

L X C = RR L X C = RR
L C RR L C RR
Example: Example: High Extreme Extreme Example: Low High Medium

Operation of tyre Loose, worn or broken Check electrical connections
shredder electrical components may regularly, repair and replace
heat up or arc, creating an as needed
ignition source
4 FIRE & EMERGENCY PREPARATION

Example: Example: Medium Extreme High Example: Low High Medium
Operation of Forklifts can generate sparks Only flameproof forklifts to be
forklifts from exhaust, brakes, tynes used in or near tyre storage
striking concrete area
Notes: L = Likelihood
C = Consequence
RR = Risk Rating
Scoring Matrix
Each risk is assigned a likelihood and consequence rating, ranging from low to extreme. The matrix below presents the resulting risk factor.
The residual risk is determined by considering the applied control and how this will either reduce the likelihood of the risk or minimise the resulting
consequences.
LOW MEDIUM HIGH EXTREME OVERALL RISK RATING
Low Extreme Significant or catastrophic impact
Medium High Major impact
High Medium Moderate impact
Extreme Low Insignificant or minor impacts

4.4 SITE MANAGEMENT PLANS AND PROCEDURES

Operators should have appropriate induction, training and operating procedures that
consider and minimise all possible hazards and risks at the site. The following procedures
should be documented and implemented:
• Site inductions, to ensure all personnel and visitors are familiar with site operations,
emergency procedures
• Hot work permitting, a permit system to ensure adequate controls are in place for all
cutting, welding, grinding and other activities which might cause a spark.
• First aid facilities, to ensure all personnel and visitors have access to first aid equipment.
• Staff training, operators should ensure their staff are trained in emergency site procedures
and that there are staff available on-site, at all times of operations, who are trained in the
use of firefighting equipment and initial response to fires. Best practice is to document a
Training Plan specific to your site (see Section 4.9).
• Housekeeping, to ensure that good housekeeping practices are in place, as poor
housekeeping can reduce the effectiveness of all other fire and emergency precautions.
• Equipment Maintenance Log, to ensure all electrical equipment, vehicles, machinery and
plant at the site are regularly inspected and maintained.
• Police checks of all staff, to reduce the risk of arson attempts by staff.
4.5 IGNITION SOURCE CONTROL

In order to minimise the likelihood of fires occurring, operators should develop, document
and implement procedures to control all possible ignition sources specific to your site. This
can be done as part of the Fire Risk Assessment, and you can refer to the Code of Practice
for the Storage and Handling of Dangerous Goods (Safe Work Australia) for assistance in
identifying potential ignition sources.
It is important to consider potential ignition sources, both on- and off-site. For instance, off-
site sources may include lightning strikes and grass fires at off-site locations.
Best practice ignition source control methods include:

• Incorporation of ignition source control measures into site emergency plans and
procedures
• Regular maintenance of all electrical equipment, vehicles and machinery at the site, which
is documented showing inspection dates and repairs undertaken.
• Restriction of smoking to designated areas away from hazards, with ‘No Smoking’ signs
clearly visible in appropriate locations.
• Installation of lightning rods in appropriate places, to reduce the risk of lightning strikes
causing a fire.

• Thermal imaging equipment and/or heat sensors to scan for heat and ignition sources,
particularly in tyre processing areas.
All potential ignition sources should be eliminated or controlled via reference to

Section 25.3 of the Code of Practice for the Storage and Handling of Dangerous
Goods (Safe Work Australia) in particular:
• Regular inspection of all electrical equipment and machinery
• Control of smoking at the site (i.e. only in designated areas away from hazards)
• Control/exclusion of open flames or hot work within 3m of tyre storage areas (via
hot work permitting)
• Keep site clear or minimise flammable material around tyre storage areas
• Ensuring that storage of flammable or combustible liquids are not within 30m of
any tyre storage.
4.6 BUSINESS CONTINUITY PLANS

As previously discussed, best practice is to avoid fires via minimising the size of tyre stacks
and storage quantities as far as practicable. However, failure of processing machinery and
equipment is not always avoidable (although this can be minimised with proper maintenance
and inspection procedures), and breakdowns or other external factors (such as breakdown
in a relationship with a major customer) may lead to a dramatic increase in stockpile size.
Since the likelihood and impact of fire increases with increasing storage quantities, it is
recommended that operators develop a Business Continuity Plan for managing overflow in
the event of a plant breakdown or other external factors.
A Business Continuity Plan is essentially a ‘backup plan’ which you can use to get your
business back on track after an incident or disaster (such as a fire). The plan should be well
thought out, documented and distributed to all key personnel in advance of any incidents. A
copy should be kept off-site to ensure it is not lost in the event of a fire. Typically, a Business
Continuity Plan includes:
• An introduction, with key business details and objectives of the plan
• A risk management plan, identifying business activities and potential risks of business
disruption
• An incident response plan, with information you will need to respond immediately before
and after an incident or crisis.

• A recovery plan, outlining the steps you will need to take to get your business running
again after an incident or crisis.
• A review schedule, to ensure the plan is tested and updated as needed.
For example, in the event of a lengthy machine breakdown, your Business Continuity Plan
could identify other businesses which have agreed to take on excess tyres until normal
operations are restored.
4.7 SITE FAMILIARISATION FOR LOCAL

EMERGENCY SERVICES
It is strongly recommended that facility operators liaise with the local fire authority and
arrange a site tour with your local fire brigade. This will allow local firefighters to familiarise
themselves with the site, operations and available on-site equipment, and allows those that
may respond to an incident to be best prepared prior to an incident occurring. The site tour
may include:
• Providing a rundown of operations and processes at the site
• Reviewing the location and condition of site entrances and access for emergency vehicles
• Reviewing the location and condition of on-site fire safety equipment and functionality
• Reviewing the location and condition of water access and flows
• Logistical matters such as mobile phone network coverage which will determine the need
for firefighters to bring radios to the site in an incident.
4.8 FIRST RESPONSE TO FIRE INCIDENTS
‘The first 5 minutes are worth the next 5 hours.’
Alan Brunacini, Retired Chief, http://bshifter.com/
The initial or immediate response can be crucial to averting a major incident. Always call 000
immediately to give the fire services time to arrive for on-site for intervention if it is required.
Research suggests that most tyre fires can be extinguished with water, Class A foam or
other wetting agents within the first 5 minutes of detection of a fire (MFB and CFA, 2014).
It is therefore important to ensure that adequate firefighting equipment is provided and site
staff are trained in first attack firefighting and the use of on-site firefighting equipment, where
safe to do so. Best practice is to develop a 5-minute initial response plan, to be incorporated
into your Site Emergency Plan, and conduct regular drills to ensure all staff are familiar and
capable of responding to an incident. 5 minutes can make a huge difference to the outcome
of the fire.

Undertaking first response to fire incidents includes:

• Identifying and assessing the fire
• Alerting all on-site personnel and implementing emergency response procedures
• Determining first attack or evacuation requirements
• Following OHS/WHS guidelines to ensure personal safety
• Using approved Personal Protective Equipment (PPE), including Self Contained Breathing
Apparatus (SCBA)
• Selecting the right extinguishing agent
• Operating on-site firefighting equipment
• Reducing the travel and growth of the fire e.g. by separating and reducing the size of
stockpiles using moving equipment
• Re-assessing the fire condition and behaviour and responding appropriately
• Seeking off-site support where necessary (i.e. mutual aid)
Personnel should be properly trained in these procedures before considering undertaking

first response firefighting. The safety of all people involved is paramount, and therefore it is
important that staff are trained to assess the safety of a situation and in first response to
fire incidents before undertaking any firefighting. Staff need to be able to assess an incident
quickly and understand if they are capable of safely dealing with a fire. Unless staff are
adequately trained and experienced, firefighting should be left to those who are qualified,
such as trained professionals.
An understanding of the complex behaviour of tyre fires is required to completely extinguish

a tyre fire, therefore beyond the first response any firefighting should always be left to
professional firefighters.
If possible, take all possible steps to ensure sites can be self-sufficient for firefighting
purposes, particularly where these are located at a distance from emergency services.
Operators may consider securing off-site support where possible (i.e. mutual aid/shared
resources supplied by neighbours) to assist in activities such as reducing the fuel source
through movement of tyres. Ensure any providers of mutual aid are properly trained in the
use of PPE and firefighting equipment, including SCBA.

4.9 STAFF TRAINING

Even the best fire and emergency preparation can be ineffective if site staff are not properly
trained. Minimum training requirements can be found below. It is considered best practice to
develop a Training Plan specific for your site which identifies and documents the fire safety
and emergency procedures and the training needs of all employees, contractors and visitors
to the site. Training should be practised and training refreshers provided. Training relevant to
fire and emergency preparation includes:
• Site induction
• Site emergency procedures
• Emergency scenario training such as evacuation drills, firefighting drills, spill response
• Use of fire safety equipment, first attack firefighting/immediate response
• Safe Work Procedures or Safe Operating Procedures (SOPs)
All staff should also be trained in implementation of the site emergency plan and
emergency response procedures, in accordance with the Work Health and Safety
Regulations.
It is recommended that all staff are trained in basic fire prevention methods and
operation of installed fire equipment.

5 FIRE SAFETY & EMERGENCY EQUIPMENT
Provision of fire safety and emergency equipment is a critical part of fire and
INTRODUCTION
emergency preparation. Providing inadequate or unsuitable equipment will
drastically reduce your chances of averting a disaster should an incident or
UNDERSTANDING
TYRE FIRES AND TYRE fire occur.
STORAGE REGULATIONS
Operators should determine and document all site equipment requirements
through design of the site and development of the emergency plan, with
FACILITY LAYOUT
reference to all relevant regulations, guidelines and standards (see Section
7 for a list of resources). Key requirements are summarised in this section,
FIRE & EMERGENCY
however since all sites are different, operators should familiarise themselves
PREPARATION
with these source documents. If you are at all unsure about what equipment
you need, contact your local fire authority for advice.
FIRE SAFETY &
EMERGENCY EQUIPMENT
Best practice is to determine fire safety and emergency equipment
requirements as part of a fire risk assessment (note that this is already a
FACILITY MANAGEMENT requirement in Victoria, see Section 4.3 for further details).
CONTACTS AND
RESOURCES 5.1 COMMON REQUIREMENTS FOR BOTH
INTERNAL AND EXTERNAL STORAGE
5.1.1 EQUIPMENT FOR MOVING TYRES

The ability to move tyres quickly and reduce the fuel source in the event of a
fire can be crucial in lessening the size and severity of an incident. For indoor
storage situations this may include use of forklifts. For outdoor storage
situations this may include use of forklifts, excavators, bulldozers, front-end
loaders or other earthmoving machinery. If such machinery is not available
at your facility, and the size of your facility does not warrant it, investigate the
option of mutual aid: a neighbouring facility may be able to provide moving
equipment in the event of a fire.
Tyres should only be moved if it is safe to do so. Ensure that personnel who
use moving equipment at your facility are trained in the use of Self Contained
Breathing Apparatus (SCBA), to protect their safety during a fire incident.
Firefighters may not be able to operate moving equipment or forklifts.
5.1.2 WATER SUPPLY AND ACCESSIBILITY

In most cases, firefighters are unable to bring water to the scene of a fire.
Operators therefore need to be able to provide adequate water supply in the
event of an incident.
42 5 FIRE SAFETY & EMERGENCY EQUIPMENT TSA_BPGL V1 MARCH 2019

Where tyres are stored in a building, most state guidelines (on tyre storage and fire safety)
require a water supply duration of 4 hours for fire hydrants and 90 minutes for sprinkler
systems, so water supply should be calculated based on the flow rate of both sprinklers and
hydrants at your facility.
If there is no reticulated supply in your area, as is the case in many regional areas, then water
tanks or some other form of water storage will be needed. Any fire water storage tank must
be served by two on-site fire pumps complying with AS2941. Pumps with a diesel backup
supply may be needed as well.
Where tyres are stored outside, the size of facilities varies to such a degree that it is not
possible to provide an all-encompassing requirement. It is therefore recommended that
the necessary water supply be determined by performing a site-specific assessment to
determine supply needs for the firefighting equipment provided.
Water provided for firefighting should be potable or Class A recycled water. Water with high
salt levels has been reported to produce dioxins in tyre fires (CFA, MFB, 2014). Dioxins are
highly toxic, are a known human carcinogen and if released are a serious and persistent
pollutant, and as such their production should be avoided.
Water provided for fire systems should be potable or Class A recycled water.
Internal storage: Operators need to be able to provide adequate water supply for
firefighting operations. Facilities should refer to both AS2419.1 and AS2118.1 for
determining water supply requirements.
External storage: A site-specific assessment should be undertaken to determine

water supply.
As an absolute minimum ensure that there is adequate water supply of 2 x 250,000 L

tanks where town water is insufficient.
5.1.3 CONTAMINATED FIREWATER CONTAINMENT

Water used to fight a fire will become contaminated through contact with oil, ash and the
smoke produced from the fire and in addition, tyre fires generate highly toxic run-off oil,
which is both highly polluting and flammable. Operators need to ensure that contaminated
firewater can be contained and not released to sewer, stormwater drains or the environment.
Containment should be provided in the form of bunds or catchment pits, which should have
a capacity large enough for a firefighting incident. The capacity can be calculated using
guidance provided in South Australia (South Australian Fire Authorities, 2014) and NSW (Fire
TSA_BPGL V1 MARCH 2019 5 FIRE SAFETY & EMERGENCY EQUIPMENT 43

& Rescue NSW, 2014), however best practice is to determine the capacity through a site-
specific fire risk assessment in consultation with the local fire authority.
Measures need to be implemented to prevent runoff of contaminated firewater to stormwater

or sewer, this may include installing a stormwater diversion system or stormwater
containment (including ‘penstock’ isolating valves for stormwater containment). Contact your
local authorities for advice about this.
For internal storage the NSW/SA method may be used to determining the required
containment capacity:
• Hydrant and sprinkler system – calculate containment capacity on the basis
of 2 hydrants operating simultaneously at 10L/sec each (no less than 20L/s
altogether) (in addition to the buildings maximum sprinkler design output
operating for period of 90 minutes).
• No sprinkler system – calculate containment capacity on basis of 3 hydrants
operating simultaneously at 10L/s each (no less than 30L/s altogether) for a
period of 90 minutes.
For external storage (and both situations in Victoria) the capacity should be
determined as part of a site-specific fire risk assessment.
You can refer to the NSW and SA guidelines (see Section 7) for guidance and refer to
your local regulator for advice specific to your jurisdiction.
5.2 INTERNAL STORAGE

Where tyres are stored internally, the NCC Volume 1, contains a uniform set of technical
provisions for the design and construction of buildings and other structures throughout
Australia (refer to Section 7). This includes standards for ensuring the fire resistance of a
building, the necessary firefighting services and equipment and smoke hazard management.
The building requirements are dependent on the classification of a building; generally

speaking a tyre recycling facility would be considered Class 8, while a storage facility (e.g.
tyre collector) would be considered Class 7b.
The following sections details some of the requirements specific to tyre storage facilities, however
this should not be considered an exhaustive list of requirements under the NCC, Volume 1.

5.2.1 BUILDING CODE/GENERAL REQUIREMENTS

Additional fire safety equipment is necessary for a building which stores tyres, due to the
increased hazard and fire risk. While an explanation of these requirements is provided in
the following sections, all facilities are different and it is not possible to cover all situations in
this guideline. The best way to ensure that your facility is compliant is to engage a qualified
engineer or fire safety consultant at the planning stage of your facility.
Tyre storage facilities should ensure that they are in compliance with the standards
set out in the National Construction Code (NCC), Volume 1, especially fire protection
systems which are pursuant to Clause E1.10 and E2.3.
Ref: National Construction Code Volume One, Building Code of Australia Class 2 to
Class 8 Buildings, 2014, Canberra ACT, Australia
5.2.2 FIRST RESPONSE EQUIPMENT

Under Volume 1 of the NCC, a building must be fitted with fire-fighting equipment to allow
occupants to respond to a fire and attempt to prevent fire spreading throughout the building.
Part E of Volume 1 of the NCC outlines the equipment required.
The equipment used for first response includes portable items designed for responding
to low level incidents, the response to such incidents can mean the difference between a
minor incident and a major disaster. Operators should refer to Volume 1 of the NCC and
seek advice from your local fire authority to determine the needs of your site, and consider
additional provisions where appropriate. Additional extinguishers may be required to cover
fire risks associated with tyre storage – refer to Clause E1.10 for further information.
Training staff in the use of this equipment is extremely important, and staff should be able to
assess a fire and be able to decide when it is appropriate to respond and when to evacuate
(see Section 4.8). First response equipment may include:
• portable water and foam fire extinguishers,
• water and foam hose reels
• moving equipment (see Section 5.1.1)
• other provisions as appropriate to your facility.
Best practice is to determine equipment based on a site-specific fire risk assessment.

5.2.3 FIRE HYDRANT SYSTEMS

Under Volume 1 of the NCC, a fire hydrant system must be provided for a building with a
footprint greater than 500m2 (and in a location where a fire brigade is available to attend
a fire). The fire hydrant system must be installed in accordance with AS2419.1. Where a
fire hydrant is not required it is recommended that you install one in any case, as this will
improve firefighting capacity in the event of a fire. Alternatively, a fire hose reel system should
be provided in accordance with AS2441.
Part E of Volume 1 of the NCC lists requirements and specifications for firefighting
equipment, and tyre storage facilities must comply specifically with Clause E1.10 (Provision
for special hazards, additional extinguishers). Operators should refer to the requirements
relevant to your state or territory to determine fire hydrant requirements.
Depending on your building size, a fire hydrant system complying with AS2419.1
(greater than 500m2) and a fire hose reel should be installed. The flow rate of each
hydrant should be based on a minimum flow rate of 10L/s per hydrant. The number
of hydrants required should be based on Standards Australia, 2004, AS 2419.1
(Amend Nos 1 and 2) Fire hydrant installations – Part 1: System design, installation
and commissioning
5.2.4 SPRINKLER SYSTEMS

Table E1.5 of Volume 1 of the NCC lists the conditions under which sprinklers are required.
There are additional fire sprinkler and smoke hazard management provisions for special
hazards, and sprinkler systems may be necessary due to the ‘nature or quantity or materials
stored’ e.g. additional fire sprinkler requirements where combustible goods exceed certain
limits (generally 1,000m3, with slightly differing limits for some states). Some states may
specify a requirement (under state-specific guidelines) even if the stored volume of tyres is
less than the threshold defined for combustible goods (such as Victoria – see Appendix A for
further details).
Research has shown that properly designed sprinkler systems can control a fire at a tyre
storage facility, therefore, whatever the quantity of tyre that are stored it is recommended that
a sprinkler system is installed.

Indoor tyre storage facilities storing in excess of the threshold defined for
combustible goods in Table E1.5 (relevant to your state/territory) of Volume 1 of the
NCC should have a sprinkler system complying with AS2118.1. In Victoria, this is
required regardless of the quantity stored.
Ref: Standards Australia, 2006, AS 2118.1 Automatic fire sprinkler systems – Part 1:
General systems
5.2.5 SMOKE HAZARD MANAGEMENT SYSTEMS

Part E of Volume 1 of the NCC lists requirements and specifications for smoke hazard
management, and tyre storage facilities must comply specifically with Clause E2.3 (Provision
for special hazards, additional smoke hazard management).
Tyre fires release a number of hazardous substances, including polycyclic aromatic

hydrocarbons (PAHs), dioxins, furans, hydrochloric acid, benzene, polychlorinated biphenyls
and heavy metals and these can be harmful to human health and the environment.
Studies have been conducted in France to test the composition of smoke generated by
tyres fires in warehouses, both with and without sprinklers (UNEP, 2013). Fires controlled
by sprinklers were shown to have higher emissions of carbon monoxide and unburned
organics. For this reason, it is recommended that smoke hazard management systems
should be installed regardless of whether they are required by the NCC.
In Victoria, where smoke and heat vents/exhaust are installed, the MFB and CFA recommend
they should be arranged for manual operation by the attending emergency services after
the fire is controlled by the sprinkler system. You should liaise with your local fire services to
ensure that the smoke hazard management system in your building is compliant with local
requirements.
All indoor tyre storage facilities should have smoke hazard management systems in
accordance with Clause E2.3 and Specification E2.2c of Volume 1 of the NCC or as
a minimum, provision of permanent natural ventilation in accordance with BCA Table
2.2a.

5.2.6 MAINTENANCE OF FIRE PROTECTION SYSTEMS

All fire safety and emergency equipment should be maintained in accordance with AS1851
Routine Service of Fire Protection Systems and Equipment.
5.3 EXTERNAL STORAGE
5.3.1 FIRST RESPONSE EQUIPMENT

The equipment used for first response includes portable items designed for responding to
low level incidents, the response to such incidents can mean the difference between a minor
incident and a major disaster.
Training staff in the use of this equipment is extremely important, and staff should be able to
assess a fire and be able to decide when it is appropriate to respond and when to evacuate
(see Section 4.8). Refer to Volume 1 of the NCC and seek advice from your local fire
authority to determine the needs of your site. This may include:
• portable water and foam fire extinguishers,
• water and foam hose reels
• shovels for burying smouldering fires
• moving equipment (see Section 5.1.1)
• other provisions as appropriate to your facility
Operators should ensure that staff are available on-site at all operating times that are trained
in the use of the equipment provided.
Best practice is to determine equipment based on a site-specific fire risk assessment.
5.3.2 FIRE HYDRANT SYSTEMS

Operators should install a fire hydrant system complying with AS2419.1 Fire hydrant
installations – Part 1: System Design, Installation and Commissioning. Ideally this system (i.e.
size, storage volume, number of outlets) should be designed based on the outcomes of a fire
risk assessment, however SA guidelines may also be used, which provide recommendations
for small and large sites.

Sites should install a fire hydrant system complying with AS2419.1
Standards Australia, 2004, AS 2419.1 (Amend Nos 1 and 2) Fire hydrant installations –
Part 1: System design, installation and commissioning
5.3.3 MAINTENANCE OF FIRE PROTECTION SYSTEMS

All fire safety and emergency equipment should be maintained in accordance with AS1851
Routine Service of Fire Protection Systems and Equipment.

6 FACILITY MANAGEMENT
INTRODUCTION 6.1 ONGOING FACILITY MANAGEMENT

Once all plans and procedures for tyre storage, and fire and emergency
UNDERSTANDING preparation are in place, operators should ensure that these are
TYRE FIRES AND TYRE
STORAGE REGULATIONS implemented. Even best practice tyre storage and fire and emergency
preparation will be ineffective if it is not properly integrated into facility
FACILITY LAYOUT management and operations.
• Best practice management of tyre storage and fire and emergency
FIRE & EMERGENCY preparation means:
PREPARATION
• Developing and documenting plans and procedures in relation to tyre
storage and fire and emergency preparation
FIRE SAFETY &
EMERGENCY EQUIPMENT • Implementing all plans and procedures in relation to tyre storage and fire
and emergency preparation
FACILITY MANAGEMENT • Doing everything practicable to reduce and manage stockpile size
• Managing and controlling all possible ignition sources at the site, and
CONTACTS AND monitoring and controlling all identified off-site sources
RESOURCES
• Ensuring good housekeeping practices are in place at all times, because
poor housekeeping can counteract fire and emergency preparedness
• Regularly inspecting and maintaining all on-site electrical equipment,
machinery, plant and vehicles
Finally, an important aspect of best practice is incorporating continuous

improvement into operations and procedures and taking steps to regularly
improve management methods. It is recommended that operators
implement a regular review of tyre storage, fire and emergency planning
and procedures to ensure that site procedures are in line with current best
practices now and into the future.
TSA accredited participants should incorporate continuous improvement

actions relating to tyre storage and fire and emergency preparedness
outlined in this guideline in their annual Action Plan.

CONTACTS AND RESOURCES 7
Reference material has also been drawn and adapted from the following
INTRODUCTION
major resources (in addition to a wider range of resources as part of the
background research). These should be considered in conjunction to this
UNDERSTANDING
TYRE FIRES AND TYRE guideline.
STORAGE REGULATIONS
FACILITY LAYOUT FURTHER INFORMATION
http://www.tyrestewardship.org.au/
FIRE & EMERGENCY
PREPARATION http://www.safeworkaustralia.gov.au/sites/swa/contact/pages/
contact
FIRE SAFETY &
EMERGENCY EQUIPMENT Fire & Emergency Services, Environmental Regulator in your state or
territory
FACILITY MANAGEMENT
CONTACTS AND
RESOURCES 7.1 STATE GUIDELINES
Fire & Rescue NSW (2014), Fire Safety Guideline: Guidelines for Bulk Storage
of Rubber Tyres, December 2014.
Metropolitan Fire Brigade (MFB) and Country Fire Authority (CFA) (2014), Fire
Services Guideline Indoor Storage of New or Used tyres, March 2014.
MFB and CFA (2014), Fire Services Guideline Open Air Storage of New or
Used tyres, March 2014.
South Australian Fire Authorities (2014), Built Environs Section Guideline

No.13 General Guidelines for Rubber Tyre Storage, April 2014.
7.2 AUSTRALIAN CODES AND STANDARDS

Australian Standards: SAI Global https://infostore.saiglobal.com/
Australian Building Codes Board (2015), National Construction Code 2015

Volume One, Building Code of Australia, Class 2 to Class 9 Buildings.
Standards Australia (2012), AS1851-2012 Routine service of fire protection

systems and equipment.
Standards Australia (2004), AS2419.1-2005 (Amend Nos 1 and 2) Fire

hydrant installations – Part 1: System design, installation and commissioning.
Standards Australia (2006), AS2118.1-2006 (A4) Automatic fire sprinkler

systems – General system.

Standards Australia (2010), AS3745-2010 Planning for emergencies in facilities.
Safe Work Australia (2001), Code of Practice for the Storage and Handling of Dangerous Goods.
7.3 INTERNATIONAL GUIDANCE

International Association of Fire Chiefs (IAFC), Scrap Tyre Management Council (STMC) and
National Fire Protection Association (NFPA) (2000), The Prevention and Management of
Scrap Tire Fires.
Integrated Waste Management Board (IWMB) (2002), Tire Pile Fires: Prevention, Response,
Remediation.
United Nations Environment Programme (UNEP) (2013), Technical Working Group of the
Basel Convention, revised technical guidelines for the environmentally sound management of
used and waste pneumatic tyres.
U.S. State of California (2004), Rings of Fire: Revisited Fire Prevention and Suppression of
Outdoor Tire Storage.
52 7 CONTACTS AND RESOURCES TSA_BPGL V1 MARCH 2019

APPENDIX A
OVERVIEW OF TYRE STORAGE

REGULATIONS IN AUSTRALIA
AUSTRALIA (FEDERAL)
TRANSPORT
Nationally, tyres are listed as a ‘controlled waste’ in List 1 of Schedule A of the National Environmental
Protection (Movement of Controlled Waste between States and Territories) Measure 2004 (Controlled Waste
NEPM). The NEPM has established a national system to track the transport movements of controlled waste
between States and Territories and developed nationally recognised licences for interstate transporters.
While, the interstate transport of tyres is regulated via this legislation, there is no federal control over the
storage of tyres.
STORAGE
While there are no federal requirements on storage of tyres, where tyres are stored internally, buildings
must be constructed in compliance with Part E of Volume 1 of the National Construction Code (Building
Code of Australia)4, which lists requirements and specifications for firefighting equipment and smoke hazard
management, and tyre storage facilities must comply specifically with Clause E1.10 and E2.3. Clause E1.10.
Some states may specify a requirement (under state-specific guidelines) even if the stored volume of tyres is
less than the threshold defined for combustible goods (e.g. Victorian Fire Services Guideline – Indoor Storage
of New or Used Tyres, see below).
WORK HEALTH AND SAFETY (WHS)

In addition, Australian businesses have obligations under the harmonised Work Health and Safety (WHS)
framework in Australia, which generally requires businesses to ensure that they provide a safe work place.
However, there are no specific requirements under the WHS framework for tyre storage facilities.
4 Australian Building Codes Board (2015) National Construction Code Volume One, Building Code of Australia, Class 2 to Class 9 Buildings.

STATE/TERRITORY BASED REGULATIONS
ACT
Tyre storage In ACT, the Environment Protection Act 1997 defines the transportation of 2 tonnes
regulations or more of end-of-life tyres as a Class A activity and therefore requires the person
undertaking the transport to hold an environmental authorisation, however the
storage and processing of tyres is not a regulated or licenced activity.
Fire safety Storage and Disposal of Waste Tyres – Environmental Guidance Note
requirements
Brief guidance prepared via a joint initiative of the Motor Trades Association ACT
and ACT Environment Protection Agency refers operators to the South Australian
guidelines for guidance on tyre storage.
NEW SOUTH WALES
Tyre storage Protection of the Environment Operations (Waste) Regulation 2014

regulations
https://www.epa.nsw.gov.au/your-environment/waste/industrial-waste/tyres
A licence is required under the Protection of the Environment Operations Act 1997
to store more than 5 tonnes of waste tyres (being casings, seconds, shredded
tyres or tyre pieces) or 500 waste tyres at any time or a business involved in
processing more than 5,000 tonnes of waste tyres per year.
Licences require compliance with NSW Fire Brigade Storage Guidelines (see p. 59).
54 APPENDIX A TSA_BPGL V1 MARCH 2019

Fire safety The Fire & Rescue NSW Guideline for bulk storage of rubber tyres is a guideline
requirements that may be imposed in part or in full as a condition by the authority having
jurisdiction. This Guideline has minimum requirements for the storage of rubber
tyres, including those in an open yard or within buildings and structure.
https://www.fire.nsw.gov.au/gallery/files/pdf/guidelines/rubber_tyres.pdf
Acceptable rubber tyre storage:

• Bundled tyres – tyres strapped together in bundles and stacked together in a
system or on their sides
• Pallet system – a system containing a number of tyres which includes stringers
for material handling equipment
• Horizontal system – a system (pallets, shelving, racks) where tyres are stacked
upright along a horizontal length exceeding 1.5m
• Laced storage (outside only) – tyres which are stacked overlapping to create a
woven or laced arrangement
• Portable system – small portable systems that can be readily moved by fork lift.
External tyre storage:

• The site should be level, clear of all rubbish and combustible materials, and
enclosed by fences or walls constructed of non-combustible materials.
• A hydrant system complying with AS2419.1 should be provided when the total
quantity of outdoor storage will exceed 50 tonnes.
• Individual tyre stacks should not exceed 3.7m in height, 60m2 in area and 12.5
tonnes in weight.
• A maximum of four small individual tyre stacks can be grouped into a stack pile.
A minimum clear separation of 2.5m must be maintained between each stack.
• A minimum clear separation of 18m must be maintained between each stack
pile of four small stacks.
Small tyre facilities (less than 50 tonnes)

• Tyres should be stacked at least 6m from all non-combustible boundaries and
buildings, and 18m from combustible boundaries or buildings.
• Tyre stacks must be at least 6m from the site boundary facing the public road.
Large tyre facilities (50 tonnes or more):

• Tyre stacks should be at least 18m from any boundary or any building.
• Any external tyre storage facility should have at least two site access points
each being not less than 4m wide.
TSA_BPGL V1 MARCH 2019 APPENDIX A 55

Indoor tyre storage:

• Buildings with a floor area of 2,000m2 or more and containing more than 20
tonnes of tyres should have a sprinkler system complying with AS2118.1.
• Buildings with a floor area of 2,000m2 or more and containing more than 10
tonnes of tyres should have smoke and heat vents complying with specification
E2.2c Volume 1 of the NCC.
• Individual tyre stacks within buildings should not exceed 3.7m in height and
30m2 in area.
• Stored tyres must remain at least 1m clear in all directions from the underside
of the building’s roof or ceiling, roof structural members, lights (including light
fixtures), and sprinkler heads.
• A minimum clearance of 1m must be maintained along paths of travel to
required exits and firefighting equipment (e.g. hose reels, extinguishers,
hydrants). The paths of travel must be kept clear and unobstructed at all times.
Unsprinklered buildings:
• A minimum clearance of 3m should be provided between stacks.

NORTHERN TERRITORY
Tyre storage Waste Management and Pollution Control Act 1998

regulations
https://legislation.nt.gov.au/Legislation/WASTE-MANAGEMENT-AND-
POLLUTION-CONTROL-ACT-1998
Fire and Emergency Regulations 1996
https://legislation.nt.gov.au/Search/~/link.aspx?_
id=67B894390726410DBE22B12FE9A40D37&_z=z
In the Northern Territory the Waste Management and Pollution Control

Act 1998 is the governing legislation for the collection, transportation,
storing and processing of tyres and requires a licence if these activities are
undertaken on a commercial or fee basis. The NT EPA grants environment
protection approvals and licences for activities listed in Schedule 2 of the
Act.
Tyre storage is also regulated under the Northern Territory’s Fire and
Emergency Regulations 1996. Section 7A of the regulations contains specific
requirements for ‘stacked tyres’ requiring anyone storing any number of
tyres (new or used) to adhere to listed stockpile heights, dimensions and
separation distances. Government representatives consulted as part of this
project were uncertain whether reprocessors are aware of or following the
requirements under the regulations.
Fire safety Apart from the requirements under the Fire and Emergency Regulations
requirements 1996, there are no specific guidelines on tyre storage and fire/emergency
management published for NT, however a tyre recycling facility’s Environment
Protection Licence (EPL) generally contains licence conditions on tyre storage
requirements.

QUEENSLAND
Tyre storage In 2013, the Queensland environmental legislative framework underwent significant
regulations changes via the Greentape Reduction project (Department of Environment and
Heritage Protection (EHP), 2013). The Environmental Protection (Greentape
Reduction) and Other Legislation Amendment Act 2012, removed the threshold
for tyre storage as an environmentally relevant activity (ERA) under ERA 56 –
Regulated waste storage. This means that tyre storage in Queensland no longer
requires an environmental authority in relation to that activity.
ERA 56 previously mandated a licensing requirement for facilities receiving and

storing 5 tonnes or more, or 500 or more EPUs. Since removal of ERA 56, only
recycling, processing and transportation are under statutory regulation. (refer ERA
57 – Regulated waste transport and ERA 59 – Tyre recycling approval).
However, organisations and individuals storing tyres must comply with Fire
Services Requirements, which are enforced under their own legislation rather than
environmental protection legislation, as summarised below:
• The Fire and Rescue Service Act 1990, requires occupants of premises to
ensure the risk of a fire occurring at the premises is properly managed to
mitigate the risk. This is regulated under the Building Fire Safety Regulation
2008. There is a requisition under the Act (Fire and Rescue Service Act
Requisition (No. 1) 2011), this applies to external storage of more than 500
tyres. The requisition prescribes stockpile dimensions and configurations,
firefighting equipment, machinery for moving tyres and a number of other
requirements.
• The Public Health Act and more specifically the Public Health Regulation
2005, Division 2 prescribes mosquitos as a public health risk and requires all
persons to ensure that there is no breeding ground for mosquitos through the
accumulation of water.

Fire safety Queensland Government Gazette No. 78 (1 April 2011) pages 539 – 544
requirements
Fire and Rescue Service Act 1990
Fire and Rescue Service Act Requisition No. 1 2011
https://publications.qld.gov.au/dataset/gazettes-april-2011/resource/bb4a2a9c-
c60c-4062-a4ea-85fc264703dd
The requisition applies to any person who stores or stockpiles in excess of 500
tyres of any type and in any condition (new, second-hand, re-conditioned, scrap,
shredded or crumbed) or their equivalent parts with a dimension exceeding 100
mm in the open.
• Single stack tyre dimensions must not exceed the following:
-- Maximum width of base – 5m
-- Maximum length of base – 45m
-- Maximum height – 3m
-- Maximum distance between stacks – 10m
-- Average side slope – 1:1.
• The longest dimension of a stack must be at right angles to the direction of the
prevailing winds
• Multiple stacks may be separated by a protective wall with a fire rating of 4
hours provided that:
-- the protective wall protrudes 1.5 meters above the highest point and 1.5
meters beyond the widest point to each side
-- only two stacks abut on the longest axis and two stacks on the shortest axis
(i.e. four individual stacks in any one group)
-- any individual stack must not exceed the dimensions specified above
(except that tyres may be stacked against such wall with a side slope batter
only on the exposed sides)
-- such groups of stacks do not exceed an aggregate width of 10 meters and
an aggregate length of 90 meters
-- such groups of stacks are separated from any other group of stacks,
individual stacks of tyres or any combustible or flammable material including
grass and weeds by a distance of 10 meters or more.
• Machinery capable of creating a break 10 metres wide between burning and
unburnt tyres must be kept on site 24 hours a day. A competent operator for
this equipment must be available 24 hours a day.

• A system to have the operator on site within 20 minutes must be in place 24

hours a day. This system must be approved by the Commissioner, Queensland
Fire and Rescue Service.
• A stockpile of sand or soil and the resources to load and transport it to the tyre
storage site, and to place it on the tyre stacks must be readily available. The
volume of sand or soil must be sufficient to completely cover the largest stack
to a depth of 1 metre over the entire exposed surface area of the stack.
• A water supply system capable of delivering high volumes of water with
minimum delay is required. The source may be reticulated town water or a dam.
• The on-site water reticulation system is to have the following characteristics:
-- A minimum of three standpipes with fittings approved by the Commissioner,
Queensland Fire and Rescue Service are to be located so that at least one is
no closer than 50 metres and no further than 90 metres from any part of any
stack and is up-wind or cross-wind no matter what the wind direction.
-- Each standpipe is to be able to deliver 1,800 litres/minute when any two are
operating. This flow rate must be able to be continuously maintained for a
minimum of 3 hours.
-- Three 30 metre lengths of 64-millimetre hose and fittings, one branch and
one nozzle must be kept readily available at a specified Fire Point.
-- This equipment is to be maintained in accordance with AS1851 and to
meet the specifications of the Commissioner, Queensland Fire and Rescue
Service.
-- If water is to be drawn from a dam, a volume of 648,000 litres must always
be available for pumping.
-- Provision should be made to contain firewater runoff.
• More than one access point to the storage area shall be available to allow for
varying wind directions. A perimeter road shall be developed to aid security
and access. All roads to, and lanes between stacks, shall be maintained in a
condition suitable for Queensland Fire and Rescue Service vehicles.
• If water is to be drawn from a dam, a hard standing area of a design and location
approved by the Commissioner, Queensland Fire and Rescue Service must be
provided adjacent to the dam for the sole use of a Queensland Fire and Rescue
Service pumping unit.
• A security system meeting the approval of the Commissioner, Queensland Fire
and Rescue Service is to be provided.
A plan of action for a fire emergency must be developed. This plan must be
approved by the Commissioner, Queensland Fire and Rescue Service.

SOUTH AUSTRALIA
Tyre storage Environment Protection Act 1993

regulations
https://www.legislation.sa.gov.au/LZ/C/A/ENVIRONMENT%20PROTECTION%20
ACT%201993.aspx
In South Australia, the Environment Protection Act 1993, governs the licensing
requirements regarding the transportation, storage and processing of waste tyres.
Key storage requirements are summarised as follows:

• The reception, storage, treatment and disposal of waste tyres (greater than 250
millimetres in size) is listed as a Prescribed Activity of Environmental Significance
and therefore requires a licence, unless the amount in question is below 5
tonnes and being used solely for the purpose of recycling, reuse, or if it is
conditionally approved by the Authority.
• Used tyres should be stored in a manner that minimises risks to the
environment, human health and therefore minimising the risk of fire. Businesses
are considered to be compliant if they operate in accordance with the following
guidelines:
-- General Guidelines for the Outdoor Storage of Used Tyres issued by the
South Australian Fire Service Fire Safety Department
Some general storage requirements are listed under the EPA 183/10: Waste
guidelines – Waste tyres, updated September 2010, such as secure fencing and
access for emergency vehicles, and there is a specific requirement that all tyre
facilities comply with the guidelines issued by the South Australian Fire Service Fire
Safety Department.
http://www.epa.sa.gov.au/page/view_by_id/4285

Fire safety General Guidelines for Rubber Tyre Storage (Guideline 013) issued by the South
requirements Australian Fire Authorities
http://www.mfs.sa.gov.au/site/community_safety/commercial/guidelines.jsp
Used tyres should be stored in a manner that minimises risks to the environment
and human health, therefore minimising the risk of fire.
Tyre storage in buildings must comply with the Part E of Volume 1 of the NCC.
Outdoor tyre storage must be arranged as piles of tyres or contained in metal

cages, in rows not exceeding the dimensions set out below:
• Storage heights should be determined by the stability of the pile and must not
exceed 3 metres high due to the potential for instability.
• ‘on-flat’ or ‘laced’ tyre storage will be employed for all outdoor tyre piles
• Tyre piles shall be arranged in ‘thin’ rows to assist firefighting operations and
shall be no more than 6 metres wide.
• Tyre pile rows shall be no more than 20 metres in length to limit the total volume
of tyres contained in a pile to a maximum of 360m3.
• Tyre piles shall be arranged to provide suitable aisle separation in order to
reduce the risk of fire spread between piles, and allow safe travel of fire
appliances through the site. These aisles must remain clear at all times, be free
from combustible materials and tyre scraps, and shall have a minimum width of
20 metres.
• Tyre piles shall be kept from allotment boundaries as follows:
-- Where the pile narrow ends face the boundary – 12 metres, and where the
long sides face the boundary – 20 metres.
-- Where the allotment boundary adjoins a public road affording perimeter fire
appliance access, the total applicable distance may include the far boundary
of the roadway and should be not less than 3 metres.
-- Where the allotment boundary is of fire resisting construction to a minimum
height of 3 metres, the boundary distance may be reduced to a minimum of
6 metres.
-- Separation distances of tyre piles from buildings on the same allotment shall
be 12/20 metres (as applicable from above) where the building’s exposed
facade is not protected.
-- Where the building’s exposed facade is protected with an automatic fire
sprinkler system in accordance with AS2118.1, or a wall wetting sprinkler
system in accordance with AS2118.2, the separation distance may be
reduced to 10 metres.

-- Notwithstanding the requirements of AS2419.1, where the total storage

volume on site is less than or equal to 750m3 (up to two piles as defined
above), the facility shall have a hydrant system capable of providing
simultaneous hydrant flows of two outlets (10L/s each).
-- Large storage facilities where the total tyre storage volume on site is greater
than 750m3, the facility shall have a hydrant system capable of providing
minimum simultaneous hydrant flows of three outlets (10L/s each).
• Indoor storage:
-- Storage of tyres indoors shall be within open framed fixed or portable
racking systems, or palletised, and shall be arranged to prevent tyres from
becoming dislodged and falling/rolling from the storage system.
-- Buildings of greater than 500m2 floor area used as tyre storage facilities
should be provided with the following fixed fire suppression/smoke hazard
management provisions in addition to any other fire and life safety measures
required by Volume 1 of the NCC.
-- Tyre storage >10 tonnes or 1000 tyres (whichever is the lesser)
• permanent natural ventilation or automatic smoke hazard management
systems or automatic smoke and heat vents
-- Tyre storage >20 tonnes or 2000 tyres (whichever is the lesser)
• automatic fire sprinkler protection and automatic smoke hazard
management systems or automatic smoke and heat vents
• Bund walls, sealed kerbing and blind sumps/catchment pits should be provided
to contain water run-off from the site during firefighting activities.
-- Non-sprinkler protected premises
• The bunded capacity shall be designed to cater for a run off of not less
than 30 litres a second (fire hydrant flows) for 90 minutes, which equates
to 162,000 litres (162kl).
-- Sprinkler protected premises
• The bunded capacity shall be designed to cater for a run off of not less
than the combined volume of 20 litres a second (fire hydrant flows) for 90
minutes (108kl) AND the design sprinkler system flow rate for 20 minutes.

TASMANIA
Tyre storage Environmental Management and Pollution Control (Waste Management)

regulations Regulations 2010
https://epa.tas.gov.au/policy/acts-regulations/empca/waste-management-
regulations
In Tasmania waste tyres are classified as a controlled waste under section 3 of the
Environmental Management and Pollution Control Act 1994 and under regulation
5 of the Environmental Management and Pollution Control (Waste Management)
Regulations 2010. This Regulation requires the registration of handlers of
controlled waste and therefore this regulation applies to all parties involved with the
production, transportation and receiving of tyres.
An Approved Management Method (AMM) for the Storage and Reuse of Waste
Tyres 2017 has been developed under the Waste Management Regulations.
Key storage requirements are summarised as follows:

• Except where approved or provided for in accordance with the Waste
Management Regulations, no more than 6,250 EPUs of waste tyres may be
stored on any premises.
• Waste tyres stored either indoors or outdoors must be stored in accordance
with all of the guidelines contained in the Guidelines for Bulk Storage of Rubber
Tyres published by Fire & Rescue NSW in 2014.
A Companion Document has been developed to assist relevant site operators to

comply with the requirements for tyre storage and reuse set out in the AMM. Refer
to Storage and Reuse of Waste Tyres:
https://epa.tas.gov.au/regulation/waste-management/controlled-waste/handling-
controlled-waste-in-tasmania/approved-management-methods/storage-and-
reuse-of-waste-tyres
Fire safety General Fire Regulations 2010

requirements
https://www.legislation.tas.gov.au/view/whole/html/inforce/current/sr-2010-136
No specific guidelines on tyre storage and fire/emergency management have been

published for Tasmania. The Tasmanian Government refers to the NSW guidelines
where guidance is needed.

VICTORIA
Tyre storage Environment Protection (Scheduled Premises and Exemptions) Regulations 2015
regulations
http://www.legislation.vic.gov.au/Domino/Web_Notes/LDMS/PubStatbook.
nsf/93eb987ebadd283dca256e92000e4069/C729EEA6CD963AF7CA257E27001
D2AA8/$FILE/15-025sra%20authorised.pdf
Storage of waste tyres in Victoria
In 2015, the Victorian EPA introduced tighter controls for waste tyre storage to
protect Victorians against the fire risk from inappropriately managed waste tyre
stockpiles.
Premises that store more than 40 tonnes or 5,000 waste tyres are required to
obtain a works approval and/or licence from EPA Victoria.
http://www.epa.vic.gov.au/business-and-industry/guidelines/waste-guidance/
storage-of-waste-tyres-in-victoria
Waste Management Policy (Combustible Recyclable and Waste Materials) (the

policy) 2018
The Policy came into effect on 28 August 2018, replacing the interim Waste
Management Policy (Resource Recovery Facilities). Compliance with the policy
requires combustible recyclable and waste materials (CRWM) at waste and
resource recovery facilities (WRRF) to be managed and stored in a manner that
minimises risk of harm to human health and the environment from fire.
For waste tyre storage premises, the policy applies to unlicensed facilities only.
https://www.gazette.vic.gov.au/gazette/Gazettes2018/GG2018S397.pdf
To support compliance with the policy, an updated Management and storage of

combustible recyclable and waste materials – guideline (publication 1667.2) was
developed.
https://www.epa.vic.gov.au/business-and-industry/guidelines/waste-guidance/
combustible-recyclable-and-waste-materials

Fire safety The Country Fire Authority (CFA) and Metropolitan Fire Brigade (MFB) have published
requirements guidelines for the safe storage of tyres for both outdoor and indoor locations.
https://www.cfa.vic.gov.au/documents/20143/202133/Fire_Services_Guideline_
Open_Air_Storage_of_New_or_Used_Tyres.pdf/a3f43247-d643-9b03-4843-
2e28f53711be
https://www.cfa.vic.gov.au/documents/20143/202133/Fire_Services_Guideline_
Indoor_Storage_of_New_or_Used_Tyres.pdf/b70a3a23-10b0-dbad-0105-
8ca4f57e3549
Operators are required to undertake a fire risk assessment which will determine all
fire hazards at the site, determine the likelihood that a fire will occur, and then
determine the consequences of a fire incident in terms of fire safety, property
protection and the environment.
The tyre storage area must be adequately bunded or contained so that, in the event of
a fire, no contaminated water is allowed to escape beyond the property boundaries.
Operators should develop and document an emergency plan and tactical fire plan
in addition to emergency procedures.
Operators are required to ensure equipment is maintained or easily accessible to

contain and manage emergency incidents.
Operators of fork lift equipment should be trained in the use of Self Contained
Breathing Apparatus (SCBA) and appropriately trained in the site emergency plan
and emergency response procedures.
Storage pile sizes should be minimised to restrict the available fuel in the event of
a fire:
• Maximum pile dimensions of 20m long x 6m wide x 3m high is recommended.
• A minimum separation distance of 20m between piles is recommended, but is
not guaranteed to prevent fire spread.
• Storage pile heights should be determined by the stability of the pile and must
not exceed 3m.
• Separation distance of storage piles to buildings will depend on the building
construction. For buildings without appropriate fire resistant construction, this
distance should not be less than 20m.
• Separation distance to boundaries facing public roads should be not less than
6m, and not less than 20m to the far boundary of the public road.
• Separation distance between the edges of storage piles to other boundaries
should be no less than 20m.

The premises fire service is required to comply with Australian Standard (AS2419.1)
or be in accordance with the requirements of the CFA or MFB.
WESTERN AUSTRALIA
Tyre storage Environmental Protection Regulations 1987

regulations
https://www.legislation.wa.gov.au/legislation/statutes.nsf/main_mrtitle_1400_
homepage.html
Environmental Protection (Controlled Waste) Regulations 2004
https://www.legislation.wa.gov.au/legislation/statutes.nsf/main_mrtitle_1387_
homepage.html
Both the Environmental Protection Act 1986 and the Waste Avoidance and
Resource Recovery Act 2007 have provisions that can be relevant to the control of
used tyre waste.
Up to 500 tyres can be stored at a tyre fitting business (or at a place connected
with one) or up to 100 tyres can be stored in any other place.
Any premises storing more than 500 tyres per year are required to obtain a licence.
The permitted quantity of used tyre storage is stipulated on a site’s licence (under
category 56 or 57 in Schedule 1 of the Environmental Protection Regulations
1987).
Refer to Tyres Legislation:
http://www.wasteauthority.wa.gov.au/publications/tyres-legislation
Fire safety In Western Australia, there are no prescribed Essential Fire Safety Measures
requirements provisions other than those outlined in Part 1 of Volume 1 of the NCC for new
buildings.
While WA does not have any specific guidance/fire standards, licences issued
by DER contain specific tyre storage conditions such as stockpile heights and
separation distances. It is understood this is done on a case by case basis.

APPENDIX B
CHECKLIST OF ESSENTIAL
REQUIREMENTS
ASPECT ESSENTIAL REQUIREMENT REFERENCE
SECTION
Site selection Site selection for storage of tyres should include 3.1.1
consideration of the following;
• impermeable soil, or addition of sealed surface
• site should be situated away from surface
watercourses
• where tyres are stored outside, proximity to
infrastructure and ensure site is large enough to
account for separation distances and allow for
future expansion
• flat, level ground where possible.
Building design Tyre storage facilities must comply specifically with 3.1.1
Clause E1.10 and E2.3 of Part E, Volume 1 of the NCC.
Security and Site security should include full enclosure of the site 3.1.2
monitoring with fence or wall (non-combustible materials) of
adequate height to prevent unauthorised access.
Fire retardant access Facilities should refer to both AS2419.1 (Fire hydrant 3.1.3
and containment installations) and AS2118.1 (Automatic fire sprinkler
systems) for determining water supply requirements.
Site specific risk All sites storing tyres, regardless of volume or size, 3.1.4
assessment should undertake a site-specific fire risk assessment
or fire safety study.


SECTION
Internal storage Where tyres are stored internally, operators should 3.2
general requirements ensure that they are in compliance with the
standards set out in Volume 1 of the NCC, especially
fire protection systems which are pursuant to Clause
E1.10 and E2.3.
Internal storage – site Site entry points should have at least 4m clearance 3.2.1
layout and design with access roads designed for large emergency
vehicles and their weight limits. Large facilities
should have at least 2 separate access points.
Internal storage – Where tyres are stored internally, at a minimum the 3.2.2
stacking/stockpile following is required:
arrangements • Portable storage systems that can be easily
moved by forklift
• Horizontal systems using pallets or shelving racks
for heights exceeding 1.5 m
• No obstruction of fire equipment and storage.
Internal storage Tyre stacks within a building should not exceed 3.7m 3.2.3
– stockpile size, in height or 30m2 in area. The following boundary
dimensions and perimeters are required:
configurations • Building without sprinklers – minimum of 3m
between stacks and building structures
• Building with sprinklers – minimum of 2m
between stacks and 1.5m between stacks and
building structures.
A minimum clearance of 1m should be maintained

along paths of travel to exits or firefighting equipment
access and stored tyres must be 1m clear of roof or
any structures attached to the roof.


SECTION
External storage – site/ Site entry points should have at least 4m clearance 3.3.2
fire access with access roads designed for large emergency
vehicles and their weight limits. Large facilities
should have at least 2 separate access points.
External storage – Tyres should not be stacked on their treads unless 3.3.3
stacking/stockpile there is some means of containing/constraining the
arrangements stacks. This containment/constraint should be fire
resistant.


SECTION
External storage – Acceptable tyre storage configurations/ 3.3.3

stacking/stockpile stacking (to be used in absence of local jurisdiction
arrangements regulations):
For outdoor storage, tyres should be stored on

their sides or laced, with tyres stacked overlapping
to create a woven arrangement, unless they are
restrained by some means e.g. metal cages or
portable systems.
Tyres should not be stacked on their treads

unless they are contained by some means. This
containment/constraint should be fire resistant.
Unless your licence or local regulator prescribe

different requirements, tyre stockpiles should:
• not exceed 3m in height due to potential for
instability
• be no more than 6m wide and 20m in length
(arrangement in long ‘thin’ piles will assist
firefighting operations)
• Alternatively, the total volume of tyres contained
in a pile should not exceed 360m3.
Aisles between tyre stockpiles should remain clear

from all combustible material and allow for fire fighter
access. Appropriate separation distances should be
determined based on the size of the pile, a minimum
separation distance of 20m is recommended
between each tyre stockpile.
Differing requirements exist for NSW sites, refer to

the NSW guidelines for further detail (see Section 7).


SECTION
External storage – The following separation distances are 3.3.3

Separation distances recommended:
• Non-combustible boundaries – at least 6m from
perimeter
• Combustible boundaries or public roads – at
least 20m from perimeter if the stockpile’s long
sides face the boundary and 12m from perimeter
if the stockpile’s narrow ends are facing the
boundaries.
If the building is protected with automatic fire

sprinkler system that meets the AS2118.1
standards, this distance may be reduced to 10m.
Site Emergency Plan All sites should develop and document an 4.1
emergency plan in accordance with WHS/OHS laws
and meeting Australian Standard AS3745-2010
that shows the location of all key fire equipment,
site evacuation procedures and other emergency
services related information. This should include
appointment of an Emergency Control Organisation
and a dedicated Site Safety Officer, and ensuring
that all employees are trained in the emergency
procedures and that they are well rehearsed.
Fire Risk Assessment All sites (new and existing) should undergo a 4.3
fire risk assessment to identify fire risks and
document essential site equipment and resourcing
requirements.
Where possible, this should be completed in

consultation with your local fire authority.


SECTION
Ignition source control All potential ignition sources should be eliminated 4.5
or controlled via reference to Section 25.3 of the
Code of Practice for the Storage and Handling of
Dangerous Goods (Safe Work Australia) in particular:
• Regular inspection of all electrical equipment and
machinery
• Control of smoking at the site (i.e. only in
designated areas away from hazards)
• Control/exclusion of open flames or hot work
within 3m of tyre storage areas (via hot work
permitting)
• Keep site clear or minimise flammable material
around tyre storage areas
• Ensuring that storage of flammable or
combustible liquids are not within 30m of any tyre
storage.
Staff training All staff should also be trained in implementation of 4.9

the site emergency plan and emergency response
procedures, in accordance with the Work Health and
Safety Regulations.
It is recommended that all staff are trained in basic

fire prevention methods and operation of installed
fire equipment.


SECTION
Fire safety and Water provided for fire systems should be potable or 5.1.2
emergency equipment Class A recycled water.
– general water supply
Internal storage: Operators need to be able to
and accessibility
provide adequate water supply for firefighting
operations. Facilities should refer to both AS2419.1
and AS2118.1 for determining water supply
requirements.
External storage: A site-specific assessment should

be undertaken to determine capacity.
As an absolute minimum ensure that there is

adequate water supply of 2 x 250,000 L tanks where
town water is insufficient.
Fire safety and For best practice internal storage, the NSW/SA 5.1.3
emergency method may be used to determining the required
equipment – firewater containment capacity:
containment capacity • Hydrant and sprinkler system – calculate
containment capacity on basis of 2 hydrants
operating simultaneously at 10L/s each (no less
than 20L/s altogether) (in addition to the buildings
maximum sprinkler design output operating for
period of 90 minutes).
• No sprinkler system – calculate containment
capacity on basis of 3 hydrants operating
simultaneously at 10L/s each (no less than 30L/s
altogether) for a period of 90 minutes.
For external storage (and both situations in Victoria)

the capacity should be determined as part of a site-
specific fire risk assessment.
You can refer to the NSW and SA guidelines (see

Section 7) for guidance and refer to your local
regulator for advice specific to your jurisdiction.


SECTION
Internal storage – fire Depending on your building size, a fire hydrant 5.2.3
hydrant systems system complying with AS2419.1 (greater than
500m2 ) and a fire hose reel should be installed.
The flow rate of each hydrant should be based on a
minimum flow rate of 10L/s per hydrant. The number
of hydrants required should be based on Standards
Australia, 2004, AS2419.1 (Amend Nos 1 and 2)
Fire hydrant installations – Part 1: System design,
installation and commissioning
Internal storage – Tyre storage facilities should ensure that they are in 5.2.1
building compliance compliance with the standards set out in Volume 1
of the NCC, especially fire protection systems which
are pursuant to Clause E1.10 and E2.3.
Ref: National Construction Code Volume One,

Building Code of Australia Class 2 to Class 8
Buildings, 2014, Canberra ACT, Australia
Internal storage All indoor tyre storage facilities should have a smoke 5.2.5
– smoke hazard hazard management system in accordance with
management system Clause E2.3 and Specification E2.2c of Volume 1 of
the NCC or as a minimum, provision of permanent
natural ventilation in accordance with Table 2.2a,
Volume 1 of the NCC
Internal storage – Indoor tyre storage facilities storing in excess of the 5.2.4
sprinkler systems threshold defined for combustible goods in Table
E1.5 (relevant to your state/territory) of Volume 1 of
the NCC should have sprinkler system complying
with AS2118.1 be installed. In Victoria, this is
required regardless of the quantity stored.
Ref: Standards Australia, 2006, AS2118.1 Automatic

fire sprinkler systems – Part 1: General systems


SECTION
External storage – fire Sites should install a fire hydrant system complying 5.3.2
hydrants with AS2419.1;
Standards Australia, 2004, AS2419.1 (Amend Nos

1 and 2) Fire hydrant installations – Part 1: System
design, installation and commissioning



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BEST PRACTICE GUIDELINES

FOR TYRE STORAGE AND

1.2 BENEFITS OF IMPLEMENTING BEST PRACTICE. . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

1.3 GUIDELINE STRUCTURE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

UNDERSTANDING TYRE FIRES AND TYRE STORAGE REGULATIONS 15

2.2 REGULATORY OVERVIEW. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

3.1.1 PLANNING YOUR FACILITY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

3.1.2 SECURITY AND MONITORING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

3.1.3 WATER ACCESS AND CONTAINMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

3.1.4 SITE SPECIFIC RISK ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

3.2 INTERNAL STORAGE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

3.2.1 SITE LAYOUT AND DESIGN. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

3.2.2 STACKING/STOCKPILE ARRANGEMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

3.2.3 STOCKPILE SIZE, DIMENSIONS AND CONFIGURATIONS . . . . . . . . . . . . . . . . 22

3.3 EXTERNAL STORAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

3.3.1 SITE LAYOUT AND DESIGN. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

3.3.2 SITE/FIRE ACCESS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

3.3.3 STACKING/STOCKPILE ARRANGEMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

3.3.4 CALCULATING TYRE STORAGE SPACE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

2 TSA_BPGL V1 MARCH 2019

FIRE & EMERGENCY PREPARATION 33

4.2 EMERGENCY AND FIRE PROTECTION EQUIPMENT. . . . . . . . . . . . . . . . . . . . . . . . . 35

4.3 FIRE RISK ASSESSMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

4.4 SITE MANAGEMENT PLANS AND PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . 37

4.5 IGNITION SOURCE CONTROL. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

4.6 BUSINESS CONTINUITY PLANS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

4.7 SITE FAMILIARISATION FOR LOCAL EMERGENCY SERVICES . . . . . . . . . . . . . . . . . 39

4.8 FIRST RESPONSE TO FIRE INCIDENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

4.9 STAFF TRAINING. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

FIRE SAFETY & EMERGENCY EQUIPMENT 42

5.1.1 EQUIPMENT FOR MOVING TYRES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

5.1.2 WATER SUPPLY AND ACCESSIBILITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

5.1.3 CONTAMINATED FIREWATER CONTAINMENT . . . . . . . . . . . . . . . . . . . . . . . . . 43

5.2 INTERNAL STORAGE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

5.2.1 BUILDING CODE/GENERAL REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . 45

5.2.2 FIRST RESPONSE EQUIPMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

5.2.3 FIRE HYDRANT SYSTEMS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

5.2.4 SPRINKLER SYSTEMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

5.2.5 SMOKE HAZARD MANAGEMENT SYSTEMS . . . . . . . . . . . . . . . . . . . . . . . . . . 47

5.2.6 MAINTENANCE OF FIRE PROTECTION SYSTEMS . . . . . . . . . . . . . . . . . . . . . . 48

5.3 EXTERNAL STORAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

5.3.1 FIRST RESPONSE EQUIPMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

5.3.2 FIRE HYDRANT SYSTEMS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

5.3.3 MAINTENANCE OF FIRE PROTECTION SYSTEMS . . . . . . . . . . . . . . . . . . . . . . 49

TSA_BPGL V1 MARCH 2019 3

CONTACTS AND RESOURCES 51

7.2 AUSTRALIAN CODES AND STANDARDS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

7.3 INTERNATIONAL GUIDANCE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

WORK HEALTH AND SAFETY (WHS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

STATE/TERRITORY BASED REGULATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

NEW SOUTH WALES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

4 TSA_BPGL V1 MARCH 2019

TSA_BPGL V1 MARCH 2019 5

ABOUT THE NATIONAL TYRE PRODUCT

Tyre Stewardship Australia (TSA), is a not-for-profit company established to administer the

There are a number of categories of Participants in the Scheme:

Businesses and organisations apply to become Participants in the Scheme. On becoming

6 TSA_BPGL V1 MARCH 2019

ACTRFS ACT Rural Fire Service