Regulatory Decision 101.1: Using waste fire extinguishers for training

This Regulatory Decision (RD) is valid until 31 July 2028 by which time it will be reviewed. You should check back at that time to ensure the RD is still valid.

NRW can withdraw or amend this RD before the review date if we consider it necessary. This includes where the activity that this RD relates to has not changed.

Regulatory Decision

This RD is about when you can store and use waste fire extinguishers to train people to fight fires.

If you follow the conditions in this RD you can use waste fire extinguishers for training without an environmental permit for a waste activity If you cannot comply with the conditions in this RD, you need to apply for an environmental permit.

Conditions you must comply with 

You must:

• be a recognised training provider of firefighting services
• only store and use waste fire extinguishers for training exercises
• only use waste fire extinguishers that do not need any treatment or repair
• only use waste fire extinguishers that are accompanied by a material safety data sheet
• only store or use up to 100 waste fire extinguishers at any one time
• only store and use fire extinguishers classified as waste code 16 05 05
• store and use waste fire extinguishers on an impermeable surface with sealed drainage
• send any discharged foam offsite for appropriate treatment
• send used fire extinguishers for offsite treatment or disposal in accordance with current regulations
• keep records for 2 years to show that you have complied with this RD and make these records available to Natural Resources Wales on request

You must not use any waste fire extinguishers containing Perfluoro octane sulfonate (PFOS), Perfluorooctanoic acid (PFOA) or Perfluorohexanesulfonic acid (PFHxS). If you are unsure, check the material safety data sheet from your fire extinguisher supplier or directly with the supplier if the information is unclear before you use the extinguishers for training.

Enforcement

This RD does not change your legal requirement to have an environmental permit for a waste operation when you are using waste fire extinguishers for training purposes.

However, NRW will not normally take enforcement action if you do not comply with the need for an environmental permit if you meet the requirements in this RD.

In addition your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:

• cause a risk to water, air, soil, plants or animals
• cause a nuisance through noise or odours
• adversely affect the countryside or places of special interest