Yet again I am bringing this one back to the top of the list.
SuDs and fire risks In a technical context, particularly in the UK, SuDs can be an acronym for Sustainable Drainage Systems which are methods to manage surface water runoff to mimic natural drainage.
My question: Is it possible that the use of plastic crates for SuDs installations has introduced a surprising and unanticipated fire risk?
After ‘firewater’ I have added some historical information on three major UK fire disasters and comments on the counter-intuitive nature of the problem.
The Northern Ireland Environment Agency working with the Scottish Environment Protection Agency – have published a document on Guidance for Pollution Prevention that refers to Suds (in section 4.5) that can be found in the document here
There is also the CIRIA SuDs Manual C753 (968 pages) available if you are really interested in SuDs but this does not refer to fire risk.
The use of the term ‘firewater’ is particularly interesting.
When not used to refer to alcoholic spirits like whiskey or moonshine, “firewater” primarily refers to two things: polluted water from firefighting operations and, less commonly, water used for wildfire suppression. The term “firewater” can also refer to a type of whisky-based liquor, but when not a drink, it is associated with the runoff of water from a fire, which can contain toxic contaminants and requires careful handling and disposal.
NEW Historical Fire Incidents and Material Risks
Three major UK fire disasters illustrate the critical importance of understanding how building materials behave under fire conditions: the Bradford City stadium fire (1985), the King’s Cross Underground fire (1987), and the Grenfell Tower fire (2017). While these incidents occurred in very different settings, they share common factors: the rapid fire spread was accelerated by combustible materials that were not originally considered high-risk – Bradford’s wooden stands and accumulated debris, King’s Cross’s wooden escalators and paint layers, and Grenfell’s external cladding system. In each case, materials that seemed appropriately specified for their primary function created unexpected fire hazards that had not been adequately assessed.
NEW The Counter-Intuitive Nature of SuDS Fire Risk
The concept of fire risk in water management systems appears paradoxical blind spot. These installations are designed to handle water, the primary firefighting medium. However, this counter-intuitive nature may be precisely why the fire risks associated with plastic SuDS components have received limited attention. Underground plastic crate systems, while effectively managing stormwater during normal operations, could potentially compromise both structural integrity and environmental safety during fire incidents – also then creating a “firewater” contamination pathway.
My original post starts here:
Is it possible that the use of plastic crates for SuDs installations has introduced a surprising and unanticipated fire risk? (link to previous post)
Emerging Fire Risks Associated with the use of Plastic Crates to create underground Storm water Detention Systems: An Assessment of Current Knowledge Gaps and Safety Implications.
## Abstract – Ewan Larcombe with the assistance of Claude (Ai)
The increasing adoption of plastic modular crate systems for underground storm water detention presents potential fire safety risks that have received insufficient attention in current design standards and emergency response protocols. This paper examines the fire behaviour characteristics of thermoplastic materials, documented challenges in suppressing underground plastic fires, and identifies critical knowledge gaps in the assessment and mitigation of fire risks associated with large-scale plastic infrastructure installations beneath car parks and roadways.
## 1. Introduction
Plastic modular crate systems have become increasingly popular for creating underground storm water detention and attenuation systems. These lightweight, cost-effective alternatives to traditional concrete systems offer significant hydraulic and installation advantages. However, the fire safety implications of installing large quantities of thermoplastic materials in confined underground spaces have not been adequately addressed in current design standards or emergency response planning.
This paper identifies an emerging risk that sits at the intersection of civil engineering, fire safety, and emergency response, where insufficient knowledge and documentation may be creating unrecognized hazards for both the built environment and emergency responders.
## 2. Background: Plastic Crate Storm water Systems
### 2.1 System Description
Plastic crate storm water detention systems consist of modular thermoplastic units, typically made from high-density polyethylene (HDPE) or polypropylene (PP), that are assembled to create void spaces for temporary water storage. These systems are commonly installed:
– Beneath car park slabs
– Under roadways and pavements
– In confined underground spaces with limited access
– Often adjacent to or integrated with building foundations
### 2.2 Installation Scale
Modern installations can involve:
– Hundreds to thousands of individual crate units
– Storage volumes ranging from hundreds to thousands of cubic meters
– Plastic material quantities measured in tons per installation
– Systems spanning large areas beneath critical infrastructure
## 3. Fire Behaviour Characteristics of Thermoplastics
### 3.1 Combustion Properties
Thermoplastic materials used in crate systems exhibit concerning fire behaviour characteristics:
**Melting and Flow Behaviour:**
– Materials melt and flow when heated, potentially spreading fire
– Molten plastic can create flowing fire hazards
– Surface re-solidification creates crusts that trap burning material beneath
**Heat Release Rates:**
– Thermoplastics can produce significant heat release rates when burning
– Large quantities represent substantial fuel loads in confined spaces
– Heat production can exceed the cooling capacity of conventional suppression systems
### 3.2 Documented Suppression Challenges
Research has identified specific difficulties in extinguishing plastic fires:
– Water application can cause surface crusting that prevents penetration to burning material beneath
– Some thermoplastics produce large fire balls when water is applied
– Foam application may be required but presents logistical challenges in underground confined spaces
– Re-ignition potential due to trapped burning material beneath solidified surfaces
## 4. Underground Fire Suppression Complexities
### 4.1 Access Limitations
Underground plastic crate installations present unique challenges for fire suppression:
**Physical Access:**
– Limited entry points for firefighting personnel and equipment
– Restricted movement within void spaces
– Potential structural integrity concerns during fire conditions
**Equipment Deployment:**
– Difficulty positioning suppression equipment
– Limited hose deployment options
– Challenges in establishing adequate water supply
### 4.2 Ventilation Considerations
Underground fires involving plastic materials create additional complexities:
– Smoke and toxic gas accumulation in confined spaces
– Limited natural ventilation for heat and smoke removal
– Potential for creating adverse pressure conditions that affect fire behaviour
## 5. Current Knowledge Gaps
### 5.1 Lack of Specific Fire Safety Standards
Current design standards for plastic crate systems focus primarily on:
– Structural load-bearing capacity
– Hydraulic performance
– Installation procedures
Notable absence of:
– Fire safety performance criteria
– Emergency access requirements
– Suppression system design guidance
– Risk assessment methodologies
### 5.2 Limited Incident Documentation
Public documentation of fire incidents involving plastic stormuwater systems is notably sparse, potentially due to:
– Recent adoption of these systems
– Incident reporting gaps
– Industry reluctance to publicize failures
– Lack of systematic incident tracking
### 5.3 Emergency Response Protocol Deficiencies
Fire and emergency services may lack:
– Specific training for plastic infrastructure fires
– Pre-incident planning for underground plastic installations
– Specialized suppression techniques and equipment
– Understanding of unique hazards presented by these systems
## 6. Risk Assessment Considerations
### 6.1 Ignition Sources
Potential ignition sources in underground environments include:
– Electrical equipment and wiring
– Vehicle fires in overlying car parks
– Construction activities (welding, cutting)
– Adjacent building fires
– Utility infrastructure failures
### 6.2 Consequence Severity
The consequences of fires in plastic crate systems could include:
– Structural damage to overlying infrastructure
– Long-duration fires difficult to extinguish
– Toxic smoke production in confined spaces
– Risk to emergency responders
– Potential for fire spread to adjacent structures
### 6.3 Exposure Assessment
Factors affecting risk exposure:
– Proximity to occupied buildings
– Integration with critical infrastructure
– Location relative to emergency service access
– Local environmental conditions
## 7. Industry Perspectives and Bias Considerations
### 7.1 Commercial Interest Influences
Assessment of plastic crate fire risks must consider potential bias from:
**Concrete Industry Criticism:**
– Traditional concrete pipe and tank manufacturers may overstate plastic system risks
– Commercial interests in promoting alternative technologies
– Selective presentation of technical limitations
**Plastic Manufacturer Positions:**
– Potential understatement of fire risks
– Focus on installation and cost benefits
– Limited discussion of long-term safety implications
### 7.2 Need for Independent Assessment
Objective evaluation requires:
– Independent fire testing and research
– Unbiased risk assessment methodologies
– Transparent reporting of both benefits and limitations
– Input from fire safety professionals without commercial interests
## 8. Recommendations
### 8.1 Research and Testing Priorities
Immediate research needs include:
– Fire testing of plastic crate systems under realistic conditions
– Suppression effectiveness studies for underground plastic fires
– Toxic gas production assessment during combustion
– Structural behaviour analysis during fire exposure
### 8.2 Standards Development
Fire safety standards should be developed addressing:
– Design requirements for emergency access
– Suppression system specifications
– Installation location restrictions
– Risk assessment methodologies
### 8.3 Emergency Response Planning
Fire services should develop:
– Pre-incident planning procedures for plastic infrastructure
– Specialized training for underground plastic fires
– Equipment and tactics specific to thermoplastic suppression
– Coordination protocols with system designers and installers
### 8.4 Regulatory Considerations
Building codes and standards may require updates to address:
– Fire safety performance requirements
– Installation approval processes
– Ongoing inspection and maintenance protocols
– Emergency access and egress provisions
## 9. Conclusion
The widespread adoption of plastic crate systems for underground storm water detention represents an emerging fire safety challenge that has received insufficient attention from the fire protection community. The combination of large quantities of thermoplastic materials in confined underground spaces, limited emergency access, and documented difficulties in suppressing plastic fires creates a potentially significant risk that is not adequately addressed in current design standards or emergency response protocols.
The fire safety implications of these systems require immediate attention through independent research, standards development, and emergency response planning. While commercial interests may influence available information about system performance, the fundamental fire safety questions must be addressed through objective assessment and transparent documentation.
Failure to adequately address these emerging risks could result in significant consequences for both public safety and emergency responders. The time to address these knowledge gaps is before widespread adoption makes remediation more difficult and expensive.
## 10. Call to Action
This paper calls for:
– Immediate research into fire behaviour of plastic crate systems
– Development of fire safety standards specific to these installations
– Enhanced emergency response planning and training
– Greater transparency from manufacturers regarding fire safety limitations
– Regulatory review of approval processes for underground plastic infrastructure
The fire safety community must engage proactively with this emerging risk to ensure that the benefits of these systems do not come at the expense of public safety or emergency responder welfare.
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*This paper represents a preliminary assessment based on available information and professional experience. Comprehensive fire testing and research are needed to fully quantify the risks and develop appropriate mitigation strategies.*
https://claude.ai/public/artifacts/da7f98f3-ddaa-4654-bce0-5d3c33831535