The following are guidelines to allow beneficial live burn training while taking every precaution to minimize the impact on the environment.
Live burn situations where structures or flammable liquids are burned as part of a supervised fire training exercise are invaluable to fire department personnel. However, this real-life fire fighting experience does adversely affect the environment. The purpose of these guidelines is to allow beneficial live burn training while taking every precaution to minimize the impact on the environment.
The environmental concerns relating to air quality include the toxic emissions from the combustion of asphaltic shingles, insulation on wiring, synthetic materials such as carpeting, carpet pads, upholstery; lead from lead-based painted materials; and asbestos emissions from pipe lagging, transite siding shingles or asbestos contained in asphalt roofing shingles. Applicable air quality regulations include and can be found within the link below:
Kentucky Administrative Regulations Title 401
- 401 KAR 63:005 Open burning.
- 401 KAR 63:020 Potentially hazardous matter or toxic substances.
- 401 KAR 63:021 Existing sources emitting toxic air pollutants.
- 401 KAR 58:025 Asbestos standards--National Emission Standards for Hazard Air Pollutants (NESHAP).
- 401 KAR 58:040 Requirements for asbestos abatement entities.
Proper fire fighting techniques, when applied to a burning structure of flammable liquid, serve to extinguish the fire in as efficient a manner and in as short a time as possible. The result is the saving of many structures, lives and the reduction in the amount of pollutants emitted to the air compared with a fire that burns out of control. Similar reductions in toxic or harmful air pollution emissions may be accomplished during live burn training exercises if certain precautions are taken before the fire is ignited. These precautions include the removal, to the extent practical, of materials in or on a structure that are likely to produce toxic or harmful emissions. Specifically, all asphaltic roofing shingles (whether or not they contain asbestos) must be removed down to, but not including, the tar paper covering, prior to burning.
A point of emphasis is necessary concerning asbestos in or on acquired buildings that will be used by fire fighting entities in a live burn training exercise. These structures are not exempt from Kentucky or federal asbestos regulations. Kentucky Administrative Regulation 401 KAR 58:025 Asbestos Standards adopts by reference the federal requirements contained in 40 CFR 61, Subpart M. The following requirement is contained in 40 CFR 61.145 dated Nov. 20, 1990: If a facility (structure) is demolished by intentional burning, all regulated asbestos containing material (RACM) including Category I and Category II nonfriable asbestos containing materials (ACM) must be removed in accordance with the NESHAP before burning.
The Kentucky Division for Air Quality recognizes the standards set forth in the National Fire Protection Association's publication "NFPA 1403 Live Fire Training Evolutions in Structures 1986" as representing a bona fide fire training. The burning of structures where the NFPA 1403 standards are not followed, burning for purposes of urban renewal or inexpensive disposal are not considered bona fide fire training and would be in violation of 401 KAR 63:005. The use of flammable liquids, as defined in NFPA 30, 1990 Edition, "Flammable and Combustible Liquids Code" shall be prohibited in live fire training exercises except as follows:
- Small amounts of clean diesel fuel or kerosene, not to exceed a total of five gallons, may be used to aid ignition of a structure.
- A mixture of 50 percent diesel fuel and 50 percent gasoline by volume may be burned in a properly designed and constructed pit for purposes of fire training involving flammable liquids. These fuels must be free of contaminants. Properly designed props such as flanges and valves may be used provided any unburned liquid fuel is contained to prevent soil or water contamination.
The number of live burn exercises involving either structures or liquids, needed for various fire departments and industry will vary depending on the number of personnel to be trained. For purposes of these guidelines, one live burn of a structure per 10 firefighters per year is considered acceptable and adequate. In the event more than 10 firefighters are to be trained in one exercise, multiple structures may be burned provided the fire department can demonstrate that the burning is not associated with an urban renewal project, and provided not more than one structure is burned per day of training. Liquid burns may be conducted on an as needed basis.
Bonafide fire training is defined by the Division for Air Quality as only those training events where the following completed application forms have been submitted. These forms must be submitted at least 15 business days prior to the proposed training date to both the Division for Air Quality and the Kentucky Fire Training Commission. Both agencies will review the submitted applications for approval:
Please submit the application forms to the Division for Air Quality regional office in your area and the Kentucky Fire Commission.
Applicants will be notified whether the application has been approved or denied.
Please note that fire training originally sponsored by the Kentucky Fire Commission, State Fire Marshal, Division of Forestry or other recognized state/federal agencies do not have to obtain prior approval for legitimate open burning activities.
Any requests for exceptions to these guidelines shall be submitted in writing to the Division for Air Quality at the address below. Exceptions shall be in writing and shall be issued prior to the burning exercise.
If you would like to file a complaint or would like more information on open burning call Diana Davidson at 502-782-6592 or e-mail: firstname.lastname@example.org