Training Burns: A Guide to the Process of Fire Training

Originally published in the May 2003 Dispatcher

Inspect and notify are the two actions state asbestos regulations call for when your department has the opportunity to conduct a fire training burn. Planning ahead will keep you in compliance with the rules and make the burn go more smoothly -- and safely.

Practically speaking, fire departments should plan to have all the asbestos in a building removed (abated) well before the fire training. Otherwise, after the burn the ash and remaining debris must be disposed of as asbestos containing waste.

To do things properly, an inspection must be done before any asbestos is disturbed; and one cannot know what materials lurk in a building until it is thoroughly inspected.

Hire a licensed inspector

Since all asbestos should be removed from a structure before the fire training burn, a state licensed asbestos inspector must go through the building. The Wisconsin Department of Health and Family Services (DHFS) licenses inspectors in Wisconsin. Inspectors are listed in the "investigator" category on the DHFS web site, http://www.dhfs.state.wi.us/. Go to that web site; click on environmental; asbestos; certified professionals. Or call the DHFS asbestos office at (608) 261-6876 and an employee will fax or e-mail you a current list of inspectors.

Give your fire department enough lead time when calling an inspector: It might take from a few days to a couple weeks to conduct the inspection and receive materials sampling results. And that is just the first step of the process. Read on.

Wisconsin Department of Natural Resources (DNR) rules indicate who must hire (or schedule) the inspector: either the property's owner or its operator. The rules define owner/operator as "any person who owns, leases, operates, controls, or supervises the facility being demolished [burned] & or any person who owns, leases, operates, controls, or supervises the demolition & operation [burn], or both." Fire departments qualify as operators for fire training burns.

Local, regional, or county fire organizations might choose to send someone to a three-day asbestos inspection training course. This would save departments money, while allowing the fire organization to perform the inspection, including identification of all asbestos in the burn structure. Information on upcoming classes can be found on the DHFS web site listed above.

Inspection results

Whether or not the inspector finds asbestos, an asbestos notification must be filed with the DNR. Again, the "owner or operator" must do this using the inspection results. This can be done with DNR Form 4500-113, "Notification of Demolition and/or Renovation and Application for Permit Exemption" (see below). Two copies must be mailed in, not faxed: one to the DNR regional office and one to the DNR central office in Madison. Notification is free for stand-alone, residential structures with four or fewer dwelling units. But for other structures (e.g. commercial) a notification fee of $75 (and up to $750 for large amounts of asbestos) is due with notification.

If the inspector finds any asbestos, it should all be abated, but now the DHFS asbestos office must be notified in addition to the two DNR offices. DHFS is always notified when work with asbestos will be undertaken. The two departments have slightly different notification time requirements, but by mailing the notification two weeks or more before any asbestos work is planned on the structure, your fire department will be OK. Again, use Form 4500-113 to notify.

Asbestos abatement

On a stand-alone residential structure with four or fewer dwelling units, the owner can choose to remove the asbestos without an asbestos abatement license. However, licensed asbestos workers must be used in the following cases: owner chooses to hire out the abatement work; fire department hires out the work; building is other than the type of residential structure just described (such as commercial). The DHFS web site lists abatement companies with licensed workers.

Filling out form 4500-113

The current version of Form 4500-113 can be found on the DNR webpage Notification of Demolition and/or Renovation and Application for Permit Exemption. Print out the form, fill it out completely, and mail it in. The web page also contains a link to instructions for filling out the form and tells how to send copies to the DNR central and regional offices.

In box #6 of the form for Type of Project, check "Fire Training Burn." In box #10, for Dates of Renovation/Demolition, write the scheduled date of the burn; a range of dates up to a month long is acceptable if the burn is dependent on weather or other factors. Just be sure to give the DNR Asbestos Coordinator a "heads up" phone call at (608) 266-3658 a day before the actual burn day.

The notification form has spaces for abatement contractor, demolition contractor, facility owner, and waste disposal site/transporter. Usually, the fire department's name and contact information is written under "Demolition Contractor." Fill in the other information as completely as possible. Call the DNR Asbestos Coordinator if you have questions.

After the burn

Once the training burn is complete, cold ash and debris must be disposed of at a state-licensed landfill. For a list, see the DNR's web site under "Waste."

Fire training versus open burning

Fire training burns may only be conducted on a standing structure that offers some training value: Buildings may not be burned for the sole purpose of waste reduction; nor may they be burned by an entity other than a fire department. Open burning is strictly regulated by the state and usually by local governments, too.

NFPA regulations coincide

NFPA rules reinforce the thrust of the state's rules NFPA regulation 1403, "Standard On Live Fire Training Evolutions," Section 2-2.2, requires "permits required for the exercise, including permits for air quality &be researched thoroughly." Also, NFPA 1403 2-2.10(j) states, "All forms of asbestos deemed hazardous to personnel shall be removed by an approved asbestos removal contractor."

There are no known safe levels of asbestos exposure.

Why asbestos is regulated

Asbestos is regulated because it is a known human carcinogen and a cause of respiratory disease.

Most forms of asbestos burn at 2,732 degrees F (1500 degrees C). Therefore, asbestos will not burn during a training burn. If asbestos is not properly removed before the fire, some of it will contaminate the air and some of it will remain in the ash resulting from the fire.

Asbestos is classified into several categories: The two most basic are friable and non-friable. Friable means it crumbles when hand pressure is applied. Non-friable materials are further separated by whether or not they are resilient and pliable or rigid and brittle, and by whether they have the potential to become friable. In a fire, most materials that contain asbestos would combust, rendering the asbestos fiber content friable and causing it to release into the air.

Asbestos is found on and in boilers, heaters, piping, electrical equipment, flooring, and water heaters. It is also found in range hoods, roofing, siding, and many other building materials.

A popular misconception is that asbestos is not used in new construction. Actually, asbestos containing materials are still manufactured in the U.S., and they are imported -- though not always labeled.

Where can I find the DNR rules?

The two state agencies responsible for regulating fire training burns are the DNR and the DHFS. Within the DNR, training burns are covered under language for "intentional burning" [NR447, Control of Asbestos Emissions; see NR447.02(11) [exit DNR], and NR447.08(10) [PDF] [exit DNR]] and under language for "fire training burns" (NR502, Solid Waste rules; see NR 502.11(2)(c) [PDF] [exit DNR]]. This article does not account for County and Local ordinances.

For questions, please do not hesitate to phone the DNR's Asbestos Coordinator at (608) 266-3658.

Asbestos Program