Fire detection for paper and card recycling sites

Last updated 30 October 2026. Paper and cardboard look like a low-risk waste. They are clean, dry and mostly arrive flattened or baled. But a stack of card bales is a large block of tightly packed fuel, and the most common way it catches fire today is from something hidden inside it: a lithium-ion battery or disposable vape that was crushed in the baler. The bale can smoulder for hours before anyone sees smoke, often after the site has closed. This page explains what the Environment Agency (EA), Natural Resources Wales (NRW) and the WISH Forum ask of paper and card recycling sites, and how camera smoke and fire detection fits into your fire prevention plan (FPP).

Which paper and card sites need a fire prevention plan?

Section 4 of the EA’s fire prevention plans guidance puts “paper or cardboard” first in its list of combustible wastes. If your environmental permit lets you store combustible waste, the EA expects an FPP, and it will ask to see and approve it if your permit requires one or if it has concerns about your site. The guidance only partly applies to the paper and pulp manufacturing sector, which should contact the EA. For recycling and transfer sites that take in, sort, bale and store paper and card, the full guidance applies.

Paper and card turn up at several kinds of site:

• Paper and card merchants and baling sites, which take in old corrugated cardboard (OCC), mixed paper and office paper, bale it and ship it to mills.
• Material recovery facilities, where card and paper are sorted from mixed recycling. Our page on recycling plants and MRFs covers the sorting side.
• Confidential shredding sites, which hold large amounts of fine shredded paper before baling.
• Waste transfer stations that bulk up commercial cardboard. See our page on waste transfer stations.

In Wales, NRW’s fire prevention and mitigation plan guidance covers the same ground. It names paper and paper products among the materials at risk of self-combustion if they are stored for more than 3 months. Our NRW fire prevention plan guide explains the Welsh rules on detection.

Why do paper and card bales catch fire?

Your FPP needs a control for each likely cause of fire. At a paper and card site, these are the ones that come up again and again:

• Batteries hidden in the load. Lithium-ion cells in vapes, phones, toys and power tools get mixed into commercial and household paper and card. A cell crushed in a baler or shredder can go into thermal runaway, a chemical reaction that produces intense heat. Packed paper round it starts to char and smoulder.
• Hot plant and friction. Balers, conveyors and shredders run in dusty conditions. WISH asks sites to keep dust, loose fibre and paper to a minimum and to clean at least once a day while the site is operating.
• Smoulders left at the end of the day. WISH warns that fires may smoulder undetected after the end of a shift, and suggests a formal close-down procedure that includes inspecting the site after work stops.
• Long storage. Paper bales held for months while markets are slow can heat up in the middle of a stack. The EA has specific rules for bales kept longer than 3 months, set out below.
• Arson. Open yards of dry card are an easy target. Your FPP has to show how you will prevent arson and vandalism.

Hidden battery

Most of these causes leave a gap between the start of the fire and the moment someone sees it. A bale that left the baler at four o’clock can be smoking by midnight, deep inside a stack, with nobody on site. Our waste site fire risk assessment guide shows how to work through each area of your site, and our UK waste battery fire statistics page sets out the wider battery problem.

What happens when a paper or card site catches fire?

On 22 June 2026, Cheshire Fire and Rescue Service declared a major incident at a recycling site in Widnes, letsrecycle.com reported. Fire spread through a large stockpile of baled cardboard inside a single-storey building of about 50 metres by 50 metres. Around 450 tonnes of an estimated 550 tonnes of waste on site were involved. By 6pm there were 20 fire engines in attendance, with crews from Lancashire, Merseyside, North Wales and Greater Manchester. Firefighters had to fight the fire from outside because of the risk that the building would collapse. The response was scaled back at around 4am, but crews stayed for days to damp down hotspots. No one was hurt. A week later the service said the most likely cause was a damaged lithium-ion battery, possibly a disposable vape, that went into thermal runaway and set light to the cardboard; strong winds then spread the fire, letsrecycle.com reported on 1 July 2026.

On 6 March 2025, West Midlands Fire Service sent six fire engines and 42 firefighters to a fire at a paper recycling plant in Nechells, Birmingham, called at about 3.45pm. A stack of paper of about 20 metres by 16 metres was alight. An aerial platform and a drone were used, crews worked through the night, and firefighters went back the next day to check for hotspots.

Not every story ends that way. On 21 August 2025, Shropshire Fire and Rescue Service was called at 07:36 to a paper recycling site in Oswestry, the BBC reported. One bale of compacted paper was smouldering inside a machine, with a small fire in the base of the equipment. A lithium battery pack had been damaged during compaction. The service said cameras on site that analyse images for signs of fire meant the incident was caught early.

Tipping floor

The pattern is the same in all three. Paper and card fires grow fast once flame takes hold, and a fire in a stack or a building is hard to reach. Catching it at one bale is what keeps it small.

What are the pile size limits for paper and card?

Section 9.2 of the EA FPP guidance sets maximum pile volumes by material and particle size. For paper and cardboard they are:

• Loose and larger than 150mm: 750 cubic metres.
• 30 to 150mm, or baled: 750 cubic metres.
• Smaller than 30mm: 450 cubic metres.

That makes paper and card one of the few materials where baled stock gets the same allowance as loose material. Fine material such as confidential shred has the smallest limit, because smaller pieces are more prone to self-heating. The EA also asks you to store waste in its largest form for as long as you can.

Maximum volumes

The general limits apply on top. No pile may be more than 4 metres high or more than 20 metres long or wide. Piles must be at least 6 metres apart and 6 metres from the site boundary, buildings and other combustible material, unless you separate them with a fire wall that has at least 120 minutes of fire resistance. You must keep a quarantine area that can hold at least 50% of your largest pile, with 6 metres of clear space around it, and you must be able to move burning waste there within 1 hour. Our guide to EA fire prevention plan detection requirements covers the detection side of the same guidance.

How should paper and card bales be stacked?

WISH’s WASTE 28 guidance (issue 3, March 2020) is based on large burn tests, and baled paper and cardboard were among the materials tested. WISH groups paper with wood and RDF as general wastes, which burned at surface temperatures of about 850 to 950°C in those tests, lower than plastics and rubber at up to about 1,200°C. That is why paper and card can use the general waste separation distances.

WASTE 28 gives a worked example for open stacks of paper and card bales using free-air separation. With four stacks each 20 metres square, the separation distance is 17 metres on each side. Leaving out the access gaps between bale lines, each stack holds about 850 cubic metres, so about 3,400 cubic metres across the four. If you choose free-air separation rather than the EA’s 6 metres plus fire walls, your plan needs to show the working.

Stack layout

WISH has three other practical points for paper and card sites:

• Do not build walls out of paper bales. Using bales of paper to enclose loose stored paper is unlikely to stop fire spreading. If you use bales to separate wastes, use non-combustible ones such as metal, and even then a gap-free fit is hard to achieve, so permanent walls or tight interlocking blocks are better.
• Mark the stacks on the ground. Yellow road markings around each stack boundary help operatives keep to the plan, and make it easy to see when a stack has grown past its line.
• Clean every day. Keep dust, loose fibre and stray paper to a minimum, and clean at least once a day while the site is operating.

Bale blocks

How long can paper and card bales be stored?

Section 8 of the EA guidance says combustible waste must normally be stored for less than 6 months, and you must follow the first in, first out principle and show how you record what is stored and for how long. If you keep any combustible waste at the maximum pile size for more than 3 months, you must show what extra measures you will take to prevent self-combustion.

Section 8.3 is aimed squarely at bales. If you store bales (it names RDF, cardboard and paper) on site for more than 3 months, your plan must show:

• the sampling and testing protocol you will use, covering a representative number of bales, with a minimum of 10%;
• that you take temperature readings from the centre of bales, and from bales in the centre of a pile;
• that you turn the bales to reduce the risk of heating.

Long storage

Paper markets move, and in a slow month bales can build up quickly. Plan for it. The EA asks you to consider seasonal changes in supply and demand, and a stack that has to be sampled, probed and turned is also a stack that takes longer to move in an emergency.

What fire detection does a paper and card site need?

Section 13 of the EA FPP guidance says you must have procedures to detect a fire in its early stages, and your plan must show how the detection system raises the alarm both during working hours and when the site is closed. The system must suit your activities and risks, and it can be automated or manual. The examples of suitable automated systems are smoke and heat detectors including temperature probes, CCTV visual flame detection systems, and spark, infrared and ultraviolet detection. Design, installation and maintenance must be covered by an appropriate third-party certification scheme or meet a recognised standard; if neither applies, you must show you can still meet the three objectives of the plan.

Paper and card sites bring two practical problems for any detector. Indoors, paper dust hangs in the air round the baler and can drift past a camera. Outdoors, bale yards are lit by floodlights that flare at night and are open to rain, wind and low winter sun. A system that cannot tell dust or glare from smoke will either raise false alarms or be switched off. So ask how a camera system learns the normal look of your site, and whether each alert comes with a clip so the keyholder can check it before they set off.

Zones on a site plan

How do you protect a paper and card site at night?

Most paper and card sites are busy in the day and empty at night and over weekends. That is when a smoulder from the last bales of the shift has time to grow, and when an intruder can reach a yard of dry card. WISH’s close-down advice deals with the first risk: inspect the baler, the floor and the stacks after work stops. Cameras deal with what happens after the last person leaves.

Perimeter after dark

With camera detection, each stack, bay and machine can be its own detection zone. When smoke or flame appears in a zone, the alert goes to the duty keyholder’s phone with a short clip, so they can see what is happening before they drive out. Email alerts go to the wider duty list, and an alarm receiving centre (ARC) or call alerts can be added for sites where nobody is on call overnight. Fence and gate alerts after closing give you a chance to act before anything is lit. Our out-of-hours site security checklist covers the security side of a closed site.

Evening routine

How quickly do you need to respond?

The EA guidance says you must be able to move waste into the quarantine area as soon as possible or, at most, within 1 hour of a fire starting. At a paper site, the usual first response is to get a loading shovel or telehandler to pull the burning bales away from the stack and break them open so they can be damped down. Smouldering paper bales are hard to put out from the outside; the fire is in the middle. That needs a driver, a machine and water, and it all starts with somebody knowing there is a fire.

Write the response into the plan with names, roles and travel times. Say who receives the alert, who goes to site and how they get in. Name the plant they will use, say where the water comes from and explain how firewater run-off will be contained. Keep watching burnt bales for many hours after the fire appears to be out. Our FPP detection template and fire prevention plan checklist help you set this out.

Where does Woodcock AI fit at a paper and card site?

Woodcock AI turns the CCTV you already have into AI smoke and fire detection. It connects to your existing cameras or recorder over ONVIF or RTSP, so cameras that already overlook your tipping floor, baler, bale yard and gates can start watching for smoke and flame without being replaced.

• Polygon detection areas. Draw a shape that follows the edge of each bale stack, bay or machine, so every alert names the area on your FPP site plan. See polygon detection zones.
• Self-learning, fitted to each scene. Each camera’s model is fitted to its own view and learns from that site’s normal footage, including dust round the baler and floodlights on wet concrete. Read about our self-learning AI.
• Years of development, in use today. Woodcock AI has been developed over several years and runs on real UK waste and industrial sites.
• Alerts that reach a keyholder. App alerts with a clip and email come as standard, with an alarm receiving centre (ARC) and call alerts as optional add-ons. Per-camera schedules keep smoke and fire detection on around the clock, with intrusion or line-crossing alerts on the fence and gate once the site is closed.
• Records for your plan. Each alert keeps its time, area and clip. We run smoke tests on site at commissioning, so you have evidence that the system works on your cameras.

Camera detection does not replace load checks, daily cleaning, bale sampling or a life-safety fire alarm. It adds a layer that watches the surface of every stack and bay, all night, and tells someone straight away. For how it works in detail, see our AI smoke and fire detection camera page, our guide to thermal cameras and AI CCTV for an FPP, and video smoke detection on existing CCTV. For other waste sites, see AI CCTV for waste and recycling, RDF and SRF bale storage, plastics recycling sites and lithium-ion battery fires in waste.

Which sources is this page based on?

• GOV.UK, Environment Agency, Fire prevention plans: environmental permits (last updated 11 January 2021; checked 30 October 2026).
• Natural Resources Wales, Fire prevention and mitigation plans (checked 30 October 2026).
• WISH Forum, WASTE 28: Reducing fire risk at waste management sites (issue 3, March 2020).
• letsrecycle.com, Cardboard fire at Widnes waste site sees 20 engines deployed (23 June 2026) and Disposable vape battery likely caused Widnes recycling fire (1 July 2026).
• West Midlands Fire Service, Fire at paper recycling plant, Nechells (6 March 2025).
• BBC News, Plea to separate household waste after fire (August 2025).

We have summarised these documents in our own words. Always read the current versions and follow your permit. This page is general guidance, not legal or regulatory advice; your regulator decides what is acceptable for your site.

Frequently asked questions

Last reviewed 30 October 2026