Waste recycling facilities are facing increasing regulatory and emergency service scrutiny due to the growing frequency and complexity of fire incidents across the sector. As a result, many operators and developers are being required to undertake a Fire Safety Study (FSS), a Fire Risk Assessment (FRA), or both, to demonstrate that fire-related risks have been appropriately identified and managed. Facilities handling combustible recyclable materials, construction and demolition (C&D) waste, lithium-ion batteries, tyre stockpiles, automobile scrap, mixed waste streams and hazardous materials can present significant fire and explosion risks that are often difficult to detect, control and extinguish.
Beyond property damage and operational disruption, fires at waste recycling facilities can also result in serious environmental impacts, including toxic smoke generation, contaminated firefighting water runoff, soil contamination and impacts on surrounding communities.
As a result, regulators, planning authorities and emergency services are increasingly seeking site-specific fire assessments rather than relying solely on prescriptive code compliance. Depending on the nature and scale of the operation, waste recycling facilities may be required to undertake an FRA, an FSS, or both.
For facility owners and developers, understanding when these assessments are required, how they differ, and what regulators expect is critical to supporting project approvals, demonstrating compliance and managing fire-related risks.
This article explains the key differences between Fire Risk Assessments (FRA) and Fire Safety Studies (FSS), the common triggers for each assessment, and the methodologies typically used for waste recycling facilities.

Do You Need a Fire Risk Assessment (FRA), a Fire Safety Study (FSS), or Both?

Although the terms are often used interchangeably, an FRA and an FSS serve different purposes and are often undertaken together for higher-risk waste recycling facilities.

Aspect	FRA	FSS
Primary Focus	Fire hazards, risk and consequences	Adequacy of fire safety systems and emergency response
Main Objective	Identify and reduce fire-related risk	Demonstrate a suitable fire safety strategy for site-specific hazards
Typical Basis	Risk assessment methodology	Performance-based fire safety analysis
Main Concern	Likelihood, escalation and consequence	Detection, suppression, protection and emergency response
Typical Trigger	Hazardous operations or elevated fire risk	Complex facilities with special fire hazards
Common References	HIPAP 3, dangerous goods guidance, EPA guidance	HIPAP 2, FRV GL-54, fire engineering principles
Typical Outputs	Hazard identification and mitigation measures	Fire safety strategy and fire protection basis

In simple terms, an FRA focuses on understanding the fire hazards, potential consequences and residual risks associated with a facility, while an FSS evaluates whether the proposed fire protection systems and emergency response arrangements are adequate to manage those risks.

When Is an FRA Required?

An FRA is commonly required where a waste facility involves elevated fire or explosion risks, such as:

• significant combustible material storage;
• hazardous waste handling;
• dangerous goods storage;
• lithium-ion battery processing or storage;
• combustible dust hazards; or
• significant off-site consequence potential

When Is an FSS Required?

An FSS is typically required where regulators, emergency services or planning authorities need assurance that the proposed fire safety strategy is appropriate for the site's specific hazards. This is often the case for facilities involving:

• large combustible stockpiles;
• battery recycling or energy storage systems;
• tyre recycling operations;
• hazardous waste facilities;
• dangerous goods storage; or
• non-standard fire protection arrangements.

Can a Facility Require Both an FRA and an FSS?

Yes. Many higher-risk waste recycling facilities require both assessments because they address different aspects of fire risk management.

In general, the FRA identifies and evaluates fire hazards, escalation scenarios and potential consequences, while the FSS demonstrates that the proposed fire protection systems, firefighting water supplies and emergency response arrangements are suitable for managing those risks.

For complex facilities, the findings of the FRA often form part of the design basis for the FSS.

What Is a Fire Safety Study (FSS)?

An FSS is a performance-based assessment that evaluates whether the proposed fire protection systems, firefighting resources and emergency response arrangements are suitable for the specific hazards present at a facility.
For waste recycling facilities, an FSS is typically required where standard fire protection approaches are considered insufficient to address complex fire, explosion or environmental risks. As noted by Fire Rescue Victoria (FRV), standard fire protection designs may not be adequate for facilities involving special hazards and site-specific fire scenarios.

When Is a Fire Safety Study Required?

An FSS may be required as a condition of planning approval or in response to requirements from regulators, emergency services or relevant standards.
Common triggers include:

1. planning permit conditions;
2. requirements from planning authorities or local councils;
3. advice from Fire Rescue Victoria (FRV), Country Fire Authority (CFA) or Fire and Rescue NSW;
4. WorkSafe requirements;
5. dangerous goods storage above regulatory thresholds; and
6. requirements arising from applicable AS/NZS standards.

In Victoria, FRV Guideline GL-54 is commonly referenced for facilities involving dangerous goods, hazardous substances, large-scale Battery Energy Storage Systems (BESS) and complex waste recycling operations. Across Australia, HIPAP 2 – FSS Guidelines is widely recognised as industry good practice for preparing FSS.
An FSS may also be recommended following a Preliminary Hazard Analysis (PHA), particularly where potential fire, explosion or off-site consequence scenarios require more detailed assessment.
From a technical perspective, an FSS is commonly expected for facilities involving:

• large combustible stockpiles;
• lithium-ion battery storage or recycling;
• hazardous waste processing;
• dangerous goods storage;
• tyre recycling;
• refuse-derived fuel (RDF) processing;
• significant environmental consequences from smoke or firewater runoff; or
• non-standard fire protection arrangements.

For new developments, FRV generally recommends undertaking an FSS during the detailed design stage, typically between 50% and 90% design completion. This allows sufficient design information to support meaningful analysis while retaining flexibility to address any deficiencies identified during the study. For existing facilities, an FSS may also be required where DG quantities change, storage arrangements are modified, or fire protection systems are upgraded or altered.

How Is a Fire Safety Study Prepared?

An FSS is generally prepared using a scenario-based and consequence-focused methodology. Rather than relying solely on prescriptive code requirements, the assessment evaluates how the facility would perform under credible fire and explosion scenarios.
HIPAP 2 and FRV GL-54 are commonly used references for developing Fire Safety Studies involving waste recycling facilities, dangerous goods and other complex industrial operations.

Methodology

Typical assessment elements include:

1. identification of fire hazards;
2. fire and explosion consequence analysis;
3. fire prevention measures;
4. assessment of fire detection and suppression systems;
5. determination of required fire protection measures;
6. firefighting water demand and supply analysis;
7. contaminated firewater containment assessment;
8. emergency response arrangements; and
9. assessment of environmental and off-site impacts.

The study is developed around realistic fire scenarios that reflect the specific hazards present at the facility. For waste recycling facilities, this assessment may encompass worst-case stockpile fires, lithium-ion battery thermal runaway events, and the potential for fire spread between storage areas. Additionally, it evaluates toxic smoke generation, suppression duration requirements, the risk of escalation to adjacent assets, and the resulting volumes of contaminated firefighting water runoff.

A key principle of modern Fire Safety Studies is that firefighting requirements should be based on credible fire scenarios rather than minimum prescriptive requirements alone. As a result, Fire Safety Studies typically look at the bigger picture, considering not only fire suppression requirements, but also environmental impacts, emergency response capability, and responder safety.

What Do Regulators Expect from an FSS?

Regulators and emergency services typically assess whether the proposed fire protection systems are fit for purpose and based on credible fire scenarios. Furthermore, they evaluate if these systems are functionally adequate, available when required, reliable during emergency conditions, and capable of operating throughout the entirety of an incident.

Importantly, an FSS extends beyond demonstrating adequate firefighting water supplies. A robust FSS should comprehensively address fire prevention measures, fire detection systems, and fire suppression systems, while also ensuring an effective emergency response capability, proper management of contaminated runoff, and the mitigation of risks to emergency responders.

What Is a Fire Risk Assessment (FRA)?

A Fire Risk Assessment (FRA) is a structured assessment used to identify, analyse and evaluate fire-related hazards, escalation scenarios and residual risk associated with a facility.
While an FSS focuses on the adequacy of fire protection systems and emergency response arrangements, an FRA focuses on understanding the likelihood and consequences of fire and explosion incidents, and determining whether the remaining risk is acceptable after mitigation measures have been implemented. For waste recycling facilities, an FRA is often undertaken as part of a broader risk management process to evaluate risks to workers, emergency responders, neighbouring properties and the environment.

When Is a Fire Risk Assessment Required?

An FRA may be required where a facility involves elevated fire or explosion risks. This typically includes facilities managing significant combustible material storage, dangerous goods storage, mixed dangerous goods classes, or incompatible material storage. It is also critical for hazardous waste processing, lithium-ion battery storage or recycling, elevated fire loads, combustible dust hazards, and facilities with significant off-site consequence potential or environmental impact concerns. Additionally, an FRA may be triggered by specific planning, regulatory, or insurance-related requirements.
Unlike prescriptive compliance assessments, FRAs are typically consequence-based studies that evaluate:

• • Hazard likelihood and exposure potential
• • Escalation pathways and off-site consequences
• • Environmental impacts and the effectiveness of proposed mitigation measures

For waste recycling facilities, the assessment commonly looks at ignition likelihood, fire propagation potential, consequence severity, incompatible material interactions, and the adequacy of proposed risk controls. In some developments, the FRA forms part of the technical basis for a subsequent FSS.

How Is a Fire Risk Assessment Prepared?

A Fire Risk Assessment is generally undertaken using a structured risk management process consistent with ISO 31000:2018 Risk Management – Guidelines. Depending on the project, the assessment may also draw upon HIPAP 3 – Risk Assessment, dangerous goods regulations, EPA guidance and fire engineering principles.
A typical FRA flows through a comprehensive analysis process, starting with hazard identification, ignition source analysis, and fire load assessment. From there, it moves into consequence analysis, fire spread and escalation assessment, and environmental impact evaluation. Finally, the process concludes with risk ranking, control measure assessment, and mitigation recommendations.
For waste recycling facilities, the assessment often includes development of a Hazard and Risk Register identifying:

• Ignition sources and incompatible materials
• Combustible stockpile and dust hazards
• Potential escalation pathways

For higher-risk developments, the FRA may also incorporate a thermal radiation assessment, explosion consequence analysis, toxic smoke dispersion assessment, and off-site consequence evaluation. The final outcome of the assessment is a clear understanding of the facility's fire-related risks and the measures required to reduce those risks to an acceptable level.

Why Waste Recycling Facilities Require Special Fire Assessment

Waste recycling facilities present a significantly different fire risk profile compared to conventional industrial developments. Unlike facilities with predictable fuel sources and controlled storage conditions, recycling operations often involve highly variable combustible materials, mixed waste streams, incompatible materials, dangerous goods, and constantly changing stockpile configurations. Consequently, facilities handling combustible recyclable materials, construction and demolition (C&D) waste, lithium-ion batteries, plastics, tyres, and hazardous waste may generate complex fire and explosion scenarios that can be difficult to detect, control, and extinguish.
In Victoria, EPA guidance for combustible recyclable and waste materials (CRWM), including EPA Publication 1667.3, places significant emphasis on fire prevention, stockpile management, firewater containment, and hazard identification within waste and resource recovery facilities. These strict regulatory frameworks reflect the unique challenges inherent to the industry.

Common Fire Risk Challenges

While traditional industrial sites deal with static risks, waste recycling operations face a dynamic set of hazards that complicate emergency response. These include:

• Stockpile and Material Hazards: Combustible stockpiles create exceptionally high fire loads, which are frequently worsened by hidden ignition sources buried deep within mixed waste streams. Furthermore, tyre and plastic fires produce significant radiant heat and toxic smoke, while specific processing areas face combustible dust explosion hazards.
• Suppression and Escalation Risks: Lithium-ion battery thermal runaway events present severe containment challenges, often leading to difficult fire suppression and high re-ignition risks. If uncontained, these incidents can result in fire spread between stockpiles or incompatible materials, creating rapid escalation to adjacent assets or off-site receptors.
• Environmental and Responder Safety: The intense nature of these incidents leads to significant volumes of contaminated firefighting water runoff that must be managed. Ultimately, these combined factors culminate in prolonged incidents that pose severe risks to emergency responders.

These hazards can create fire and explosion scenarios that are not adequately addressed through prescriptive code compliance alone. As a result, regulators, planning authorities, and emergency services increasingly expect site-specific fire hazard analysis, consequence-based risk evaluation, and performance-based fire safety assessments for complex waste recycling operations.

Role of Different Authorities

Different authorities typically assess different aspects of fire risk and fire safety performance.

Authority	Primary Focus
Planning Authorities / Consent Authorities/Councils (e.g. DPIE, DTP, DEECA)	Land-use compatibility, permit conditions and off-site risk considerations
Environment Protection Agency (EPA)	Environmental impacts, combustible recyclable waste management, smoke and contaminated runoff
WorkSafe, SafeWork	Dangerous goods, hazardous materials and worker safety
Emergency Services	Emergency response capability, firefighting access, suppression adequacy and escalation management

Understanding these overlapping regulatory expectations is important during the early planning and design stages of waste recycling developments.

Common Deficiencies Identified in FSS and FRA Submission

FRV has identified several recurring deficiencies in fire safety submissions that frequently hinder the approval process. These often begin with weak fire hazard identification and insufficient consequence analysis, which fail to capture the true scale of potential incidents. Furthermore, submissions frequently demonstrate inadequate firefighting water determination and a poor assessment of contaminated firewater containment.

Technical gaps are also common regarding the chemical nature of the risk, such as insufficient toxicity and combustion product analysis. These data gaps are often accompanied by generalized or unsupported justifications that lack the necessary site-specific evidence. Finally, a significant issue remains the poor alignment between the FSS and actual emergency response plans, a disconnect that can result in major delays during planning approval, regulatory review, or emergency service assessment processes.

Conclusion

Waste recycling facilities present unique fire, explosion and environmental risks that often require more than prescriptive code compliance. Depending on the nature of the operation, a Fire Risk Assessment (FRA), a Fire Safety Study (FSS), or both may be required to demonstrate that fire-related risks have been appropriately identified, assessed and managed.

While an FRA focuses on understanding fire hazards, consequences and residual risk, an FSS evaluates whether the proposed fire protection systems and emergency response arrangements are suitable for those risks. Together, these assessments provide a structured basis for improving fire safety, supporting regulatory approvals and protecting people, property and the environment.

Understanding when these assessments are required, how they are prepared and what regulators expect can help waste facility owners and developers reduce approval delays, improve emergency preparedness and achieve more robust fire safety outcomes.

Need a Fire Risk Assessment or Fire Safety Study for Your Waste Facility?

Fire Risk Assessments (FRA), Fire Safety Studies (FSS) and dangerous goods compliance assessments require specialist expertise across fire engineering, hazardous materials, emergency response, environmental protection and regulatory compliance. Engaging experienced consultants early in the planning or design process can help identify potential issues, reduce redesign costs and support smoother approval pathways.

Risk and Safety Solutions Melbourne (RSSM) provides independent risk engineering and fire safety consulting services across Australia, including:

• Fire Risk Assessments (FRA);
• Fire Safety Studies (FSS);
• Dangerous Goods Assessments;
• Preliminary Hazard Analyses (PHA);
• Hazard and Risk Assessments; and
• Regulatory and planning approval support.

Our team has extensive experience supporting waste recycling, resource recovery and hazardous materials facilities across Australia.

If you require a Fire Risk Assessment (FRA), Fire Safety Study (FSS), Dangerous Goods Assessment or other risk engineering support, contact Risk and Safety Solutions Melbourne (RSSM) to discuss your project requirements.

Phone: +61 (03) 9804 8571
Mobile: +61 4680 032 922
Email: info@riskandsafetysolutions.au
Address: PO Box 6111, Point Cook, Victoria 3030
Website: www.riskandsafetysolutions.au

References and Guidance Documents

This article draws upon the following industry guidance and regulatory publications:

• Fire Rescue Victoria (FRV) Guideline GL-54 – Fire Safety Study
• Fire and Rescue NSW – Fire Safety in Waste Facilities Guideline
• ISO 31000:2018 Risk Management – Guidelines
• HIPAP No. 2 – Fire Safety Study Guidelines
• HIPAP No. 6 – Guidelines for Hazard Analysis
• EPA Victoria Publication 1667 – Management and Storage of Combustible Recyclable and Waste Materials
• Fire and Rescue NSW – Guidelines for Bulk Storage of Rubber Tyres