Standards and compliance guidelines

Storage of waste tyres in Victoria


Each year, the number of waste tyres generated in Victoria grows. In 2012–13, it’s believed that nearly 50,000 tonnes of waste tyres (approximately six million waste passenger car tyres) were stockpiled or dumped.

Waste tyres can create environmental and public health risks for Victoria. Whole tyres are flammable and when stored together in large volumes, can create a fire hazard. Once ignited, a tyre fire is difficult to extinguish and causes significant environmental, social and economic costs.

To protect Victorians against the fire risk associated with inappropriately managed waste tyre stockpiles, EPA has introduced new legal requirements for storing waste tyres. These requirements will also assist in supporting legitimate and sustainable waste tyre recycling opportunities in Victoria.

The information below was designed to help businesses that store waste tyres as part of their processing and/or recycling operations understand the new licensing requirements.

New legal requirements for storing waste tyres in Victoria

Waste tyres must be stored in a way that minimises fire risk and hazards to human health and the environment. The Country Fire Authority (CFA) and Metropolitan Fire Brigade (MFB) have published guidelines for the safe storage of waste tyres for both outdoor and indoor locations.

From 29 April 2015, premises in Victoria that will store more than 40 tonnes or 5000 equivalent passenger units (EPU) of whole tyres at any time require an EPA works approval before they are built or modified and an EPA licence to operate.

Existing businesses or sites storing 40 tonnes or 5,000 EPU of waste tyres have until 29 October 2015 to apply for an EPA licence to continue their waste tyre storage operations.

Unlicensed businesses face penalties up to $350,000 (2400 penalty units) under the Environment Protection Act 1970.

If you are legitimately reusing whole tyres (for example, as a safety barrier at a race track), then the EPA works approval and licensing requirements will not apply.

The burning and dumping of waste tyres is an offence under the Environment Protection Act and local laws. EPA can issue pollution abatement notices and take further legal action to require their removal and appropriate disposal.

How do I apply for an EPA licence if I have an existing business?

For existing businesses, a completed Licence application form and supporting information must be provided to EPA.

This should be emailed to approvals.applications@epa.vic.gov.au.

Please allow approximately 60 days for EPA to process your application. How long this takes will depend on whether all the necessary supporting information has been provided, the complexity of your operations and whether clarification or further information is required.

What supporting information will I need to submit as part of my licence application?

EPA’s Work approval application guideline (publication 1307) outlines the supporting information you must submit with your licence application form.

The sections below are a guide to the supporting information you should submit to EPA. This is based on relevant parts of the Works approval application guideline, but is a guide only.

Planning permit

If your operation is required to have a planning permit, then you must provide a copy of the permit to EPA.

Company contact details

To support your licence application, you need to provide the following:

  • CEO*: Name, phone (business hours), main work address, email etc
  • Signatory*: Name, phone (business hours), main work address, email etc
  • Key contact: Name, phone (business hours), main work address, email etc
  • Premises address
  • Postal address for correspondence
  • Billing address

* Highest officer in the company, such as the chief executive officer (CEO) or managing director.

Site plans

The following information must also be provided to EPA in JPEG format:

  • a premises plan clearly showing the site boundary
  • a general site layout plan showing details such as buildings, roadways, storage areas, activities, air stacks and wastewater outfalls
  • a tyre-specific layout plan showing configuration of tyre (and tyre-derived product if applicable) storage areas and separation distances to other tyre piles, buildings and boundaries, in accordance with the fire services guidelines
  • an aerial view showing separation distances from nearby sensitive premises (such as houses, hospitals or schools) and watercourses (rivers, streams, creeks etc).

Bushfire-prone area report

You should identify if your site operations are performed within a bushfire-prone area or bushfire management overlay. A bushfire-prone area report can be created from Planning Maps Online.

Operational activities

You must provide an overview of site operations for waste tyre management covering aspects such as:

  • transport
  • reception
  • storage
  • processing, treatment and technology
  • recovering resources from waste (recycling)
  • end product or use
  • disposal.

Processing and throughput capacity details (expressed on an annual and monthly basis) should also be specified.

Similarly, you should provide an overview of any other site operations that may have environmental aspects and impacts attached to them; for example, processing of other materials or waste streams.

Fire risk assessment

A site fire risk assessment must be completed by an appropriately qualified and/or experienced consultant and submitted to EPA. This assessment should cover the requirements listed in the respective fire services guidelines for indoor and outdoor storage of new or used tyres.

In completing the fire risk assessment, the local fire authority should also be consulted. Queries should be directed to the District Operations Manager at the respective District Office.

The fire risk assessment should also assess the maximum storage capacity (expressed as EPU or tonnes) of waste tyres that can be safely stored on the premises at any given time. The maximum storage capacity will be driven by the applicant’s ability to contain contaminated firewater, oil and liquid by-products of combustion generated as part of fire fighting activities in the event of a fire.

For further information, refer to the fire services guidelines:

Management plan

You will also be required to submit a management plan that explains how the site will implement the necessary fire hazard controls, including:

  • identification of site fire hazards and how all other possible ignition or fuel sources have been minimised
  • quantity of fire water and foam required, and the equipment necessary to deliver it to a potential fire.

A management plan for the reuse or disposal of the waste tyres should also be developed and implemented by site owners and occupiers to ensure that excessive numbers of waste tyres are not accumulated. This should include a description of the inventory process used to track the incoming and outgoing waste tyres.

Environmental information

This section of the submission should identify the environmental aspects and impacts associated with site operations and provide details on the types of procedures and controls that are in place to manage those risks.

You should ensure you provide information across all environmental segments relevant to the activities performed on your site, including:

  • energy and water resources
  • air and noise emissions
  • water discharges
  • waste generations
  • land and groundwater contamination.

For further information, refer to EPA’s Works approval application guideline (publication 1307). (Environmental considerations that may be applicable to waste tyre storage are summarised in the prompt sheet Appendix C-8.)

Licence conditions for waste tyre storage

If you’ve been successful in applying for an EPA licence to store waste tyres, your licence will feature a number of conditions.

These conditions may include the following:

General conditions
LI_G3 By 30 September each year you must submit an annual performance statement to EPA for the previous financial year in accordance with the Annual performance statement guidelines (publication 1320).
LI_G4 Documents and monitoring records used for preparation of the annual performance statement must be retained at the premises for seven years from the date of each statement.
LI_G5 You must implement a monitoring program that enables you and EPA to determine compliance with this licence.
Amenity conditions
LI_A1 Offensive odours must not be discharged beyond the boundaries of the premises.
LI_A2 Unacceptable noise (including vibration) must not be emitted beyond the boundaries of the premises.
LI_A3 Nuisance dust must not be discharged beyond the boundaries of the premises.
Discharges to water
LI_DW1 Stormwater discharged from the premises must not be contaminated with waste.
Discharges to land
LI_DL1 You must not contaminate land or groundwater.
Waste management
LI_WM1.5 You must not have more than [x EPU OR tonnes of] waste tyres on the premises at any time.
LI_WM1.6 The maximum size of a pile of tyres stored outdoors does not exceed 20m long, by 6m wide, by 3m high.
LI_WM1.7 All waste tyres must be contained within the building for storage of tyres on the premises at all times.
LI_WM4 You must ensure that waste does not burn at the premises.
LI_WM4.1 You must maintain onsite fire fighting equipment and access to water supplies that are capable of controlling and extinguishing a tyre fire at the premises.
LI_WM4.2 You must maintain clear access for emergency and fire services vehicles, and fire protection equipment (including fire hydrants and fire hoses) or related signage.
LI_WM4.3 You must implement a management plan to prevent fire and minimise potential ignition and fuel sources.
LI_WM4.4 You must maintain bund walls or catchment pits sufficient to contain surface run-off from the site during fire fighting activities.
LI_WM7 You must maintain an effective method of security which prevents unauthorised access.

More information on specific licence conditions is available in the Licence management guideline (publication 1322). This guideline is designed to assist you understand and manage your licence.

The Environment Protection Act specifies penalties for breach of licence conditions, and for operating a site without a licence. Penalties for operating without a licence may be up to $350,000 (2400 penalty units).

For more information relating to the waste tyre storage (A09) licence application process, contact EPA’s Licensing Team Leader on 1300 372 842 (1300 EPA VIC).

Further information

Sustainability Victoria is supporting EPA and other organisations by providing information, investment support and brokerage initiatives with waste tyre recyclers.

For general information or to report illegal dumping of waste tyres please contact:

EPA Victoria
GPO Box 4395
Melbourne, Victoria 3001

Phone: 1300 372 842 (1300 EPA VIC)
Email: contact@epa.vic.gov.au

 

Q&A on storage of waste tyres in Victoria + Expand all Collapse all

  • What is the problem with waste tyres?

    The risk posed by tyre stockpiles has been demonstrated by a number of tyre fires in Australia and around the world.

    Tyre fires are very difficult to control and generate hazardous smoke, which can cause a health risk through the inhalation of particles and chemicals.

    The number, size, location and poor management of tyre stockpiles pose a hazard to the Victorian community and environment.

  • Can I reuse tyres on my property?

    Waste tyres can be reused in other applications, including, in an acceptable manner:

    • as safety barriers at racing venues and similar activities
    • by farmers to weigh down covers on silage stacks
    • as a second-hand tyre where safe to do so.

    Otherwise, waste tyres should be reprocessed at suitable facilities or be shredded before they can be disposed to landfill.

    Unacceptable reuse or disposal of used tyres include:

    • erosion control works
    • fences
    • artificial reefs
    • to assist burning of other wastes (e.g., stumps, dead stock)
    • drains constructed from half-tyres
    • dumping or burial at unlicensed premises.

    If you are reusing tyres in an acceptable manner, then the EPA works approval and licensing requirements will not apply. In some cases, planning approvals may still be required.

  • I store tyres – what should I do and what EPA approvals do I need?

    Used tyres must be stored in a way that minimises fire risk and hazards to human health and the environment. The Country Fire Authority (CFA) and Metropolitan Fire Brigade (MFB) have published guidelines for the safe storage of tyres for both outdoor (PDF 115KB) and indoor(PDF 119KB) locations.

    EPA recommends that a management plan for the reuse or disposal of the tyres be developed and implemented to ensure that that excessive numbers of used tyres are not accumulated.

    Existing businesses

    Businesses already storing more than 40 tonnes or 5000 EPU of waste tyres (prior to 29 April 2015) have until 29 October 2015 to apply to EPA Victoria for a licence to continue their waste tyre storage operations. A completed licence application form and supporting information must be provided to EPA as part of your licence application. The supporting information requirements are consistent with those outlined in EPA's Works Approval Guidelines. 

    New businesses

    Businesses that do not currently store waste tyres but that are proposing to store more than 40 tonnes or 5000 EPU of them after 29 April 2015 will need to apply to EPA Victoria for a works approval (to build the site), prior to applying for a licence (to operate). The works approval guidelines outline the assessment process and how to prepare your application. 

    The Environment Protection Act 1970 specifies penalties for breach of licence conditions, and for operating a site without a licence. Penalties for operating without a licence may be up to $350,000 (2400 penalty units).

  • What are the new Regulations?

    The objective of the Environment Protection (Scheduled Premises and Exemptions), (Industrial Waste Resource) and (Fees) Amendment Regulations 2015 is to minimise the environmental and public health impacts (particularly those as a result of fire) from inappropriate storage of waste tyres in Victoria. They provide an ongoing legislative basis for the management of fire risks from the storage of waste tyres following the expiry of the Interim Waste Management Policy (Storage of Waste Tyres).

    The regulatory impact statement found that the preferred option was to make premises storing more than 40 tonnes or 5000 equivalent passenger units (EPU) of whole waste tyres at any time subject to EPA works approval and licensing requirements.

    EPA will be responsible for administration and enforcement of the proposed Regulations, as part of its works approval and licensing regime, and more broadly as part of its focus on teh illegal dumping of wastes.

    The Regulations took effect on 29 April 2015. Occupiers of affected premises have a transitional period of six months – until 29 October 2015 – to apply for an EPA licence.

  • What should members of the public do if they’re concerned about a site that is or may be storing lots of waste tyres?

    If you are unsure about stockpiling operations of a site, you can report it to EPA on 1300 372 842 (1300 EPA VIC). The dumping of tyres is also an offence under the Environment Protection Act 1970, and can attract significant penalties.

Page last updated on 6 Oct 2015