U.S. Fire Administration/Technical Report Series

Special Report: Scrap and 

Shredded Tire Fires

USFA-TR-093/December 1998

U.S. Fire Administration Fire Investigations Program

T

he U.S. Fire Administration develops reports on selected major fires throughout the country. 

The fires usually involve multiple deaths or a large loss of property. But the primary criterion 

for deciding to do a report is whether it will result in significant “lessons learned.” In some 

cases these lessons bring to light new knowledge about fire--the effect of building construction or 

contents, human behavior in fire, etc. In other cases, the lessons are not new but are serious enough 

to highlight once again, with yet another fire tragedy report. In some cases, special reports are developed to discuss events, drills, or new technologies which are of interest to the fire service.

The reports are sent to fire magazines and are distributed at National and Regional fire meetings. The 

International Association of Fire Chiefs assists the USFA in disseminating the findings throughout the 

fire service. On a continuing basis the reports are available on request from the USFA; announcements of their availability are published widely in fire journals and newsletters.

This body of work provides detailed information on the nature of the fire problem for policymakers 

who must decide on allocations of resources between fire and other pressing problems, and within 

the fire service to improve codes and code enforcement, training, public fire education, building 

technology, and other related areas.

The Fire Administration, which has no regulatory authority, sends an experienced fire investigator 

into a community after a major incident only after having conferred with the local fire authorities 

to insure that the assistance and presence of the USFA would be supportive and would in no way 

interfere with any review of the incident they are themselves conducting. The intent is not to arrive 

during the event or even immediately after, but rather after the dust settles, so that a complete and 

objective review of all the important aspects of the incident can be made. Local authorities review 

the USFA’s report while it is in draft. The USFA investigator or team is available to local authorities 

should they wish to request technical assistance for their own investigation.

For additional copies of this report write to the U.S. Fire Administration, 16825 South Seton Avenue, 

Emmitsburg, Maryland 21727. The report is available on the Administration’s Web site at http://

www.usfa.dhs.gov/

Special Report: 

Scrap and Shredded Tire Fires

Researched by: Stanley L. Poole, Jr.

Editors: Hollis Stambaugh

Peter Banks

 

This is Report 093 of the Major Fires Investigation Project conducted 

by Varley-Campbell and Associates, Inc./TriData Corporation under 

contract EMW-94-C-4423 to the United States Fire Administration, 

Federal Emergency Management Agency.

Department of Homeland Security

United States Fire Administration

National Fire Data Center

U.S. Fire Administration

Mission Statement

As an entity of the Department of Homeland 

Security, the mission of the USFA is to reduce life and economic losses due to fire 

and related emergencies, through leadership, advocacy, coordination, and support. 

We serve the Nation independently, in coordination with other Federal agencies, 

and in partnership with fire protection and 

emergency service communities. With a 

commitment to excellence, we provide public education, training, technology, and data 

initiatives.

ACKNOWLEDGMENTS

The USFA appreciates the help of the following persons who provided information or reviewed 

this report:

Edward E. Asper, Jr. Sales Representative/Volunteer Firefighter

Alban Tractor Company

Independent Hose Fire Department

Frederick, Maryland

Larry Burnette Assistant Director

Kentucky State Fire Marshal’s Office

Frankfort, Kentucky

Charles Cronauer Deputy Chief State Fire Marshal

Maryland State Fire Marshal’s Office

Towson, Maryland

Michael Hildebrand Hazardous Materials Author/Expert

Port Republic, Maryland

Douglas Howard Assistant Chief

Frankfort, Kentucky, Fire Department

Jack Manning Fire Chief

Washington Fire Department

Washington, Pennsylvania

John McGeary Fleet Maintenance Coordinator

Washington Fire Department

Washington, Pennsylvania

Daniel Madrzykowski Fire Protection Engineer

National Institute of Standards and Technology

Gaithersburg, Maryland

Mark Openshaw District Chief

Gila River Indian Reservation Fire Department

Gila River Indian Reservation, Arizona

John Serumgard Chairperson, Scrap Tire Management Council

Washington, DC

Ian Swisher Lieutenant

Maugonville Volunteer Fire Department

Maugonville, Maryland

TAbLE OF CONTENTS

OVERVIEW. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

SUMMARY OF KEY ISSUES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

SOURCES AND USAGE OF SCRAP AND SHREDDED TIRES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Intermodal Surface Transportation Efficiency Act of 1991. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Advances in Tire Recycling. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Barriers to Recycling. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

HAZARDS OF SCRAP AND SHREDDED TIRES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Fire and Environmental Hazards. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Hazards at Different Stages of Combustion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

THE FIRE INCIDENT CASE STUDIES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

PLANNING FOR TIRE FIRE PREVENTION AND EXTINGUISHMENT. . . . . . . . . . . . . . . . . . . 16

Fire Prevention Code Enforcement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Tire Fire Pre-Planning. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Excavation Equipment for Tire Fires. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Emergency Response. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

FIREFIGHTING STRATEGY AND TACTICS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Exposures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Containment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Extinguishment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Overhaul. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

ENVIRONMENTAL HAZARD CONTAINMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

SAFETY OF OPERATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

COST RECOVERY RESOURCES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

LESSONS LEARNED. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Bibliography. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

APPENDICES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

APPENDIX A: Large-Scale Test to Evaluate the Effectiveness of Various Fire Suppression 

Agents on Burning Stacked Tires. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

APPENDIX B: Reimbursement to Local Governments for Emergency Response to 

Hazmat Releases. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

APPENDIX C: House of Representatives Bill 104 Tire Pile Improvement and Remediation 

Effectiveness Act.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

APPENDIX D: Pennsylvania Waste Tire Remediation Act 190. . . . . . . . . . . . . . . . . . . . . . . . . . . 48

1

Special Report : 

Scrap And Shredded Tire Fires

December 1998

OVERVIEW

With the ongoing rise in use of motor vehicles, hundreds of millions of tires are discarded each year 

in the United States. Many are added to existing tire dumps or landfills, and a significant number 

are gathered for recycling. Stockpiles of scrap tires, whether in dumps or in recycling facilities, pose 

serious fire protection challenges to fire departments across the country.

Tires burn with a higher per-pound heat output than most coal1

, and the high heat production of 

tire rubber makes extinguishment very difficult. Tire fires yield large amounts of oil that are flammable and environmentally contaminating. Tire fires frequently become major hazardous materials 

(Hazmat) incidents affecting entire communities, often requiring neighborhood evacuations and 

protracted fire operations. These fires threaten pollution of the air, waterways, and water table.

This special report examines seven case studies of tire fires that have been typical of those in the United 

States. The case studies were selected because they occurred in varied circumstances and locations. 

However, they reveal a common pattern of challenges in tire fire prevention and extinguishment.

In many jurisdictions, fire codes and safety practices for scrap-tire operations are not adequately 

enforced. In fact, fire department personnel are often unaware of scrap tire operations in their 

response areas. Tire dumps and recycling operations are often overstocked and poorly maintained, 

without adequate separation of tire piles.

Pre-planning for tire fires is relatively uncommon. The lack of pre-planning compromises the efficiency and effectiveness of fire operations. Fire departments often try ineffective water or foam 

extinguishment strategies or attempt to locate needed excavation equipment after the incident begins. 

Effective and efficient extinguishment requires heavy equipment such as excavators, bulldozers, and 

front-end loaders specifically suited for piled tire product operations.

Despite these challenges, the incidence and impact of large tire pile fires can be reduced through 

strict code enforcement and appropriate fire safety practices. Standards for the storage of rubber 

tires should be rigidly enforced. A pre-plan utilizing the incident command system (ICS) should 

be established. The pre-plan should include development of maps, diagrams of the tire pile and 

surrounding areas, including water supply sources, and resource lists for needed equipment and 

personnel.

Extinguishment of tire pile fires is facilitated by the separation of unburned product from the fire 

to lessen the fuel load. Once adequate separation is accomplished, an earthen berm should be built 

1 Scrap Tire Management Council
2 U.S. Fire Administration/Technical Report Series

around the burning tire pile for containment. The burning material removed from the pile can be 

doused with water and submerged or buried to ensure extinguishment.

The direct application of water and/or foams generally does not provide effective extinguishment 

in tire fires. Rather, water is best used to keep the unburned tires from igniting. Class B foam is 

generally considered ineffective at extinguishing such fires, but can be used to prevent run-off oil 

from igniting. Class A foams and wetting agents are useful if applied in the ignition and propagation 

phases of the fire.

The environmental impact of tire fires on the air can often be minimized by letting the fire free 

burn, consuming most of the fuel. Generally, of greater concern, is the large volume of run-off oil 

produced by such fires. Run-off oil should be contained and collected to avoid contamination of 

ground and well water.

A potential for serious injury exists at tire fire incidents. The fire department should assume the role 

of safety coordinator for all agencies operating on the fire. In tire fires there is a particular need to 

maintain fireground security and to protect non fire department personnel, such as heavy equipment 

operators.

The costs associated with most tire pile fire incidents are generally very high. All legal remedies for 

obtaining cost reimbursement should be pursued, including funding available from State and Federal 

Environmental Protection Agencies (EPA). The Federal funding available would depend on the circumstances of the incident and usually cover reimbursement of local public expenditures.

SUMMARY OF KEY ISSUES

Issue Comments

1. Agency Coordination Fire departments and other government agencies are often unaware of scrap and shredded 

tire operations in their jurisdictions until a fire occurs. Multi-agency coordination is needed in 

pre-planning and emergency response.

2. Fire Prevention Tire recycling businesses are often deficient in fire prevention practices. The businesses 

Practices often operate out of converted industrial facilities, lack security, and use abandoned or rundown properties for storage. These properties often have poor access and become junkyards 

and disposal sites.

3. Code Enforcement Many scrap tire dumps and recycling operations do not comply with code provisions for tire 

storage and pile separation. Strict code enforcement is necessary to both help prevent the 

fires, and to make site operations more manageable when they do occur.

4. Pre-Planning Though necessary for efficient fire operations, pre-plans for tire facilities are rare. Pre-plans 

should consider methods of minimizing exposure of unburned tires, strategies for extinguishment, the organization of fire operations, and needs for equipment and personnel, including 

heavy equipment.

5. Excavation Equipment Recommended equipment for tire fires are excavators, bulldozers, front-end loaders, and 

Needs dump trucks.

6. Environmental Tire fires are Hazmat incidents. Smoke containing toxic products of combustion often necesHazards sitates evacuations, and run-off oil should be contained to minimize environmental damage.

7. Extinguishment Agents Applied water is not efficient at extinguishing deep-seated tire fires. Class B foams are not 

effective on tire fires, but may prevent fires in run-off oil. Class A foams and wetting agents 

appear effective only during the ignition and propagation stages of the fire.
USFA-TR-093/December 1998 3

8. Extinguishment Tactics Large tire pile fires are best extinguished by separating the burning tires with excavation 

equipment and extinguishing manageable amounts through submergence in water or burial in 

dirt.

9. Safety of Personnel These incidents will involve heavy equipment operators, personnel reclaiming run-off oil, and 

fire personnel. A unified safety operation is needed to monitor the safety of all personnel and 

to ensure that individuals have the proper personal protective equipment.

10. Lead Agency and 

Coordination

Although the fire department will probably be the first agency to respond, this type of incident 

quickly becomes a multi-agency operation. There should be a unified multi-agency incident 

command structure accommodating all participants.

11. Disposal Burned tires to be moved from the site must be totally extinguished before transport to landfill 

or other disposal areas to prevent a fire at another location. Tires should be relocated only to 

reputable recycling operations, or code compliant storage areas.

12. Costs Expenses for excavation equipment, repair and maintenance, and supplies will require 

significant funding. Some reimbursement may be available through Hazmat cleanup funds. 

Cost recoupment measures should be aggressively pursued.

SOURCES AND USAGE OF SCRAP AND SHREDDED TIRES

In the United States, 240 million tires are disposed of each year, and 75 percent of these are added 

to existing stockpiled tire dumps or discarded in landfills. The ever-increasing number of discarded 

tires poses serious problems, not only in land use, but also in environmental and fire protection.

In years past, tires were commonly buried in landfills, a practice that continues in some States. Tires 

are not desirable landfill material because tire casings trap air and buried tires often move, interfering 

with future landfill reclamation. Generally, the diminishing permitted landfill space is needed fore 

more suitable trash.

Scrap-tire stockpiles, whether in tire dumps or in piles intended for recycling, create fire protection 

challenges for the fire service. Tires burn with a higher per-pound heat output than most coal, and 

the high heat production of tire rubber makes extinguishment difficult. Tire pile fires yield large 

amounts of oil that is both flammable and a threat to the environment. Such fires become Hazmat 

incidents that may affect entire communities, often requiring neighborhood evacuations, protracted 

fire operations, and causing contamination of the air, waterways, and water table.

To address the serious problems caused by stockpiling scrap tires, there have been both legislative 

pressures and technological advancements to promote tire recycling.

Intermodal Surface Transportation Efficiency Act of 1991

With special machinery, tires can be shredded into crumb rubber for use in paving road surfaces. 

The tire crumb rubber is mixed with asphalt cement binder to make a durable asphalt surface. The 

Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA) was expected to increase tire recycling by requiring States receiving Federal highway funds to use crumb rubber in asphalt paving.

ISTEA has not been fully implemented, however. Without the ISTEA mandate, the expected demand 

for 68 million scrap tires to be used in road surfacing has not materialized. Because the cost of 

crumb rubber asphalt is more expensive than asphalt made with natural materials, the market for 

crumb rubber asphalt has been weak.
4 U.S. Fire Administration/Technical Report Series

Entrepreneurs who anticipated implementation of the ISTEA mandate started collecting tires and 

intended to invest in tire-shredding machinery. When the legislation languished, many of these 

entrepreneurs went out of business, leaving large lots filled with scrap tires. Many of these failed 

enterprises subsequently experienced fires, as the case studies in this report demonstrate.

The limited implementation of ISTEA has created a business and regulatory climate that may promote tire fires through the following sequence of steps:

1. The growing environmental impact from the continual generation of scrap tires creates concern 

for tire disposal.

2. Increased regulation of landfills, coupled with limited landfill space, causes local government to 

encourage tire recycling.

3. Encouragement for tire recycling results in fast-track use and occupancy permits and flexible 

local zoning requirements.

4. Tire recycling firms begin operations often without the knowledge of local fire authorities.

5. Recycling facilities operate without pile separation required by fire codes and often with alarm 

and fire protection system deficiencies.

6. Because there are limited uses for shredded tire products, the supply of tires quickly overwhelms 

demand, the recycling plant’s land becomes full, tire collection fees fall, and the recycling firm 

goes out of business, leaving the tire piles in-place.

7. The burden for cleanup and disposal of tires falls to the property owners and local government, 

who begin legal action against the recycler to recover costs.

8. A tire pile fire begins, often of suspicious origin.

The warning signs of future tire pile fires are summarized in Table 1. According to data from the 

International Association of Fire Chiefs (IAFC), corroborated with the case studies presented in this 

report, tire pile tires often occur after fire code enforcement is initiated.

TABLE 1. WARNING INDICATORS FOR FUTURE TIRE PILE FIRES

•	 The tire operation changes from tire recycling to scrap-tire storage.

•	 The operation began as non-code-compliant.

•	 The State tire-fee-disposal program is not invoiced, and therefore not audited to ensure

proper tire disposal and ethical operations.

•	 The business owner resists compliance with code and fire safety practices.

•	 Business ownership changes.

•	 The business owner files for bankruptcy.

•	 The property owner and/or government pursue court action against the tire operation.
USFA-TR-093/December 1998 5

Advances in Tire Recycling

To address the problems caused by stockpiling scrap tires, tire-recycling technologies have advanced 

and positive alternatives are available. According to the Scrap Tire Management Council, common 

uses for tire reuse and recycling include:

Retreads. Tires can be reused by putting new rubber tread on reusable casings. Approximately 38 

million passenger cars and truck tires are retreaded.

Breakwaters. Whole scrap tires are used for breakwaters to reduce shoreline erosion by waves. 

Artificial reefs made of tires can create habitats for fish.

Crash barriers. Highway crash barriers can be constructed from whole tires.

Crumb rubber. Crumb rubber is made by finely shredding tires with the steel cords removed. As 

noted above, tires shredded into crumb rubber can be used in asphalt paving for road surfaces. 

Rubber crumb can also be formed into gymnasium floor mats, used to cover playgrounds and athletic fields, mixed with dirt as a playing surface, or used for running tracks.

Insulation and linings. Finely ground scrap-tire rubber can be used for sound insulation pads and 

truck and trailer cargo-compartment liners.

Fuel. The greatest use of old tires is the recovery of energy and conversion to fuel. Such tire-derived 

fuel is used in cement kilns, pulp paper mils, and electric utilities. An estimated 85 million dollar 

scrap tires are used as fuel annually. Emissions and heat output of tire-derived fuel are about the 

same as for coal.

Barriers to Recycling

Although efforts are underway to increase usage of scrap tires, several scientific and technological 

problems remain.

Pyrolysis. Tires can be subjected to pyrolysis to yield oil, gas, and carbon black. Pyrolysis is the 

process of thermally decomposing organic substances into less complex molecules. Pyrolysis of tires 

is extremely complex and costly. Tire pyrolysis plants are expensive to build, and the high capital 

investment has limited the use of pyrolysis for tire recycling.

Vulcanization. The rubber used in tire manufacturing is combined with sulfur under heat to thermoset, or cure, the tire into its shape. No technology is currently available to reverse this process 

and ‘devulcanize’ tire rubber. Because the sulfur cannot be removed, tire rubber cannot be used 

in processes such as producing plastics where chemical bonding with other polymers is needed. 

Vulcanization limits the reuse of tire rubber for manufacturing new products.

HAZARDS OF SCRAP AND SHREDDED TIRES

The composition and construction of tires and the operation of recycling facilities carry unique 

hazards.

Fire and Environmental Hazards

Rubber tires are made of very combustible compounds, including carbon, oil, benzene, toluene, 

rubber, and sulfur. Tires are not easy to ignite because they are designed to absorb the heat gener-
6 U.S. Fire Administration/Technical Report Series

ated by the friction of road contact. Once ignition takes place, however, this same ability of tires to 

absorb heat makes extinguishment difficult. The high carbon content and steel cords serve as a heat 

sink, absorbing and storing heat within the tire. Although extinguishment cools the tire from open 

flaming to a smoldering stage, the stored tire heat can re-ignite the tires.

Scrap-tire storage prevents environmental health risks. Standing water between tires is a breeding 

ground for mosquitoes. Tire piles are also an excellent rodent habitat, contributing another risk to 

public health.

The EPA does not consider scrap tires a hazardous waste. However, once there is a fire, the tire product breaks down into hazardous compounds including gases, heavy metals, and oil. Experience at 

large tire fires indicates for every million tires consumed by fire, about 55,000 gallons of unburned 

run-off oil can pollute the environment unless contained. The average passenger car tire is estimated 

to produce more than two gallons of oil. Tire fire run-off is a significant environmental pollutant 

that can get into ground water and contaminate well water. In addition to run-off oil, at least 32 

toxic gases are produced by tire fires.

Hazards at Different Stages of Combustion

There are three distinct stages of tire combustion Hazardous Materials – Managing the Incident, (1995) defines 

these as:

Ignition and Propagation Phase. Tires give off flammable vapors at approximately 1000 degrees Fahrenheit 

(538 degrees Celsius). However, once a flame front has developed and elevated temperatures are 

applied to a large area with a constant radiant heat flow, tires can decompose at as low as 410 degrees 

Fahrenheit (210 degree Celsius). Once ignited, a tire pile initially burns at a rate of two square 

feet every five minutes in the windward direction.

Compression Stage.. After the first several minutes of the fire, the top layers of tires will begin to collapse into strips. During this stage, heat and smoke levels increase dramatically. In large, high 

tire piles, the piles will start to collapse in on themselves within 30 to 60 minutes. Compression 

causes open flaming to slow down as the internal areas of tire pile receive less air. The pile continues 

to collapse, building downward pressure, and forms a semi-solid mass of rubber, tire cords, and 

steel. Equilibrium also starts to occur.

Equilibrium and Pyrolysis Stage.. At this point, the fire is a deep-seated internal fire with low open 

flames on the surface. The fire is in equilibrium when the level of fuel conversion is approximately 

equal to the amount of heat, fuel, and oxygen available. Internal temperatures are up to 2000 degrees 

Fahrenheit (1100 degrees Celsius). Tire fires in this stage consume the fuel much more slowly and 

completely. During this phase, downward pressure starts to push oil and water run-off into the 

ground, water, and other areas, depending upon the location of the fire.

The fire spread is influenced by the tire product configuration.. Whole tire piles burn down into the middle 

of the pile. The shape of the tire casings ensures a flow of cool air to provide oxygen from below as 

heat and gases rise vertically. The steel cords remaining from burned tires provide a covering that 

serves to break up water streams and produce steam before the water can reach the seat of the fire. 

Water run-off forms channels, which allow additional water to flow off without being converted to 

steam or absorbing the middle pile heat. Shredded tires and crumb rubber piles are similar to coal in 
USFA-TR-093/December 1998 7

that the fire spreads over the surface of the pile, forming a ceramic clay-like crust that deflects water 

and prevents penetration.

Smoldering Stage. . When tires burn in the hot, smoldering (stage) – common when water is being 

applied – vast amounts of smoke, products of combustion, and toxic chemicals are produced. When 

tire fires are allowed to free burn, fewer products of combustion are produced and most toxic chemicals are consumed. 

Source: Noll pg. 407

TABLE 2. TIRE PRODUCT COMBUSTION STAGES CHRONOLOGY

Stages of Tire 

Combustion Time Whole Tire Fire Progress Shredded Tires Action

Ignition/

Propagation 

Stage

0 to 5 

minutes

Active tire burning of 

individual tires but has not 

extended to the entire pile.

Tire shreds are readily 

ignited and involve the 

entire pile quickly.

Early extinguishment with water, 

class A foam or wetting agents 

may be possible.

15 to 30 

minutes

Once fire extends to the 

pile, the flame spread is 

two square feet every five 

minutes.

Fire spreads along 

surface of pile very 

quickly.

Separate unburned tire/product 

from the burning pile; downwind 

direction first.

Compression 

Stage

30 to 60 

minutes

The top layers of the tires will 

collapse on themselves. The 

visible flaming is reduced. 

The fire then is seated deep 

in the pile.

Burns like coal pile with 

hot coal bed in center 

and a clay-like ash 

crust on top of pile.

Focus efforts on separation; 

build containment berms and oil 

run-off collection ponds.

Equilibrium/

Pyrolysis and 

Smoldering 

Stages

60 minutes 

and beyond

Fuel consumption and 

heat production equalizes. 

Combustion is efficiently 

producing sufficient heat to 

consume most combustion 

products. Downward pressure of the encompassing 

pile causes the run-off oil flow 

to increase.

Clay-like ash crust 

protects burning core 

from water stream 

penetration.

Contain fire spread

Contain run-off oil

Option 1 – using the excavator 

separate burning debris into 

manageable piles and extinguish with fog streams.

Option 2 – allow tire/product 

fire to burn until the pile can be 

buried.

Storage and Recycling Operation Hazards

Tire entrepreneurs often use vacant industrial locations and buildings for their storage and shredding 

operations. It is enticing for governments to encourage the use of vacant properties because they 

can then be placed back on tax roles. However, these industrial properties are often not adequately 

evaluated for fire protection systems. Moreover, scrap-tire piles usually do not comply with National 

Fire Protection Association (NFPA) guidelines.

Tire shredding equipment may itself be a source of ignition if improperly maintained. The machinery is costly because of the wear and tear of cutting tires containing steel wire cords. This equipment 

requires maintenance and proper lubrication to avoid breakdowns and build-up of grease. This 

grease can cause a machinery fire, which in turn can spread to the shredded tire product. Sparks and 

friction of the shredder cutting through the steel cords are another potential source for fire. These 

machines should be protected from fire by automatic sprinkler systems.
8 U.S. Fire Administration/Technical Report Series

THE FIRE INCIDENT CASE STUDIES

Case 1. Falling Springs Road, Garfield County, Washington, 

October 1996

Situation Before The Fire: This fire involved shredded tire fill used in a civil engineering application of 

road construction. Falling Spring Road was built over a steep ravine. Instead of building a costly 

bridge, engineers decided to fill the ravine with shredded tire chips. They chose the chips rather 

than natural fill material because ravines filled with dirt and stone are susceptible to rock slides and 

avalanches that cause roadways to collapse. Previous success filling ravines with shredded tire chips 

justified this civil engineering technique on Falling Spring Road. Shredded tire chips are lighter 

than natural fill, making the fill more stable and reducing its tendency to slide out of the ravine and 

collapse the road.

Although tire fill had been used with some success in shallow- and moderate-depth ravines, the 

Falling Spring Road ravine was much deeper than others which had been filled with tire chips 

before.

Extent and Duration of Fire: After a wet winter and only a few months after its placement, the fill began 

to smolder. Cracks soon appeared in the pavement and the road surface failed. Finally, the flames 

flared through the road surface cracks and oil began to run off at the bottom of the ravine. The burning material was deep-seated and attempts at surface fire extinguishment were not successful. The 

only alternative was to excavate the roadway until the seat of the fire was reached, then to extinguish 

the fire. The extinguishment effort was protracted and required heavy equipment with a coordinated 

firefighting effort. The original road construction cost was 1 million dollars; 3 million dollars was 

required for fire extinguishment and cleanup.

Pre-Fire Planning: This fire was not anticipated and therefore not pre-planned.

Strategy Employed: The initial strategy was to allow the absence of oxygen to cause the smoldering 

fire to go out, but this did not work. Firefighters then attempted surface extinguishment; this was 

also unsuccessful. Excavation was the last resort and required full-depth excavation with equipment 

capable of very deep digging.

Problems Encountered During Fire Operations: When the tire chips were exposed to oxygen in the air 

during excavation, the fire flared up and engulfed the excavation equipment. These flare-ups necessitated training on and use of personal protective equipment for non-firefighters who were needed 

to undertake the operation.

The heavy equipment operators were provided breathing apparatus because of the volume of smoke 

production. The fire produced a light-grade run-off oil similar to 3-in-1 oil in a white soapy mixture. This run-off had to be contained. As the excavation reached the thermal center, the tire chips 

became tar-like clumps that were difficult to handle even with heavy equipment because the clumps 

adhered to the machinery.
USFA-TR-093/December 1998 9

Other Information: The cause of the fire was determined to be a pyrolytic decomposition of rubber 

material. This pyrolysis was associated with the rusting of steel tire cords, a high build-up of heat, 

but insufficient oxygen to cause flaming. The wet season contributed to the initial rusting. The 

pressure resulting from the depth of landfill in the ravine is theorized to have contributed to the 

pyrolysis.

After this fire, additional review will be undertaken before shredded tires will again be used for deep 

ravine fill.

Case 2. Washington, Pennsylvania, February 28, 1997

Situation Before The Fire: This fire involved shredded tires gathered by a recycling operation that had 

changed ownership several times. The most recent owners went out of business, leaving the property full of shredded tire product. The local government ordered the owners to bring the buildings 

into compliance with the fire code. The order included repairing the inoperative sprinkler system 

and central alarm system.

Extent and Duration of Fire: This fire involved 1.7 million tires in the tire shredding building and in four 

acres of shredded tire piles. The whole tire piles were stacked 50 feet high, with no separation. The 

fire burned for 14 days, required the evacuation of 500 residents, and closed two schools.

Pre-Fire Planning: This fire was not pre-planned.

Strategy Employed: The fire department initially used class B foam without success. The department 

then procured excavation equipment, first to separate unburned tires from the burning pile. Burning 

material was then excavated and submerged in trash containers filled with water for complete extinguishment. The trash containers filled with burned tires were trucked to the landfill for disposal. 

State contractors were used to contain and remove run-off oil.

Problems Encountered During Fire Operations: This tire operation was housed in a converted glass factory 

equipped with a fire sprinkler system and fire protection fire pump. The fire protection systems 

were disabled, and the electric power company had disconnected the power supply to the fire pump. 

When the fire department unit arrived they encountered a fire without separation and they had 

only a limited water supply for extinguishment. The electric power utility was called to connect the 

electric to the fire pump which improved the water supply. It took approximately 24 hours to get 

excavation equipment and State contractors on-site.

Other Information: This was a juvenile-set arson fire of a vacant but secured property. An environmental cleanup contractor, coordinated by the State and funded by the EPA Superfund, contained the 

run-off oil.
10 U.S. Fire Administration/Technical Report Series

Case 3. Cearfoss, Maryland, March 13, 1997

Situation Before The Fire: In this situation tires were used as planters and filled with topsoil that was 

sterilized with boiled water to kill unwanted weeds and bacteria. This use of tires was an agricultural 

experiment that was approved by the State EPA. The open-flame heater set up to boil the water for 

soil sterilization was too close to the combustible tires. Windy weather below the flames toward 

closely stacked tire piles.

Extent and Duration of Fire: The property owner had been collecting tires for five years. The fire 

involved 800 tire planters and approximately 4,800 whole tires. It took 100 firefighters from ten 

volunteer fire companies twelve hours to control the fire.

Pre-Fire Planning: Neither the fire department nor the State fire marshal had been notified that a permit for the operation had been issued by the State Department of the Environment. Therefore, the 

fire was not pre-planned.

Strategy Employed: The limited water supply was not considered sufficient for sustained extinguishment. Therefore, class B foam was used in an attempt to control the fire, but was not effective.

Problems Encountered During Fire Operations: This fire occurred on farmland in a rural area without a fire 

protection water supply.

Other Information: The tires were stored too close to combustibles and the owner publicly admitted 

he knew the tires were a hazard, but ignored the risk. The regional State fire marshal was not aware 

of the code violations until the fire occurred.

Case 4. Chautaugua County, New York, April 23, 1995

Situation Before The Fire: The most significant concern in this incident was the potential for run-off oil 

contamination of the aquifer which was located across the road from the fire. The area topography 

showed that any run-off from the area would travel toward the aquifer. This aquifer was of major 

importance to the entire county and several municipalities because it provided drinking water. Runoff threatened to pollute the area’s water supply.

Extent and Duration of Fire: A scrap tire pile consisting of five to six million tires caught fire. It covered 

seven areas, with tires stacked as high as 30 feet. Approximately two million tires caught fire, and 

flames threatened to spread through the remaining pile. A rural agricultural area surrounded the 

tires. Approximately 50 residences and a nearby school were evacuated because of smoke. The fire 

was declared out on May 1, 1995. However, many re-ignitions continued.

Pre-Fire Planning: The Sinclairville Fire Department was prepared with a pre-fire plan. The local officials also had an emergency plan.
USFA-TR-093/December 1998 11

Strategy Employed: State and Federal officials were called immediately and the EPA monitored the 

air quality. The State Department of Environmental Conservation constructed drainage ponds and 

systems for the collection of run-off oil. The oil was pumped into tankers and trucked to an oil 

recycling plant.

State and local highway crews using excavation equipment made a physical separation between the 

burning and unburned tires. They built an earthen berm around the burning tires to prevent the fire 

from spreading.

The fire department’s strategy was not to use water to extinguish the fire. Instead, the fire was permitted to burn and air samples were monitored. These samples indicated no significant readings a 

quarter-mile away from the fire. Once the fire burned to a manageable size, extinguishment began 

without water. The extinguishment efforts relied on smothering the tires with dirt. This tactic did 

result in numerous re-ignited fires in the following months. However, the re-ignited fires were of 

smaller magnitude and easily controlled.

Problems Encountered During Fire Operations: Chautaugua County believed that the threat of oil run-off 

could have a much more severe impact on the environment than the products of combustion of the 

burning tires. Although some citizens criticized the fire department for letting the fire burn rather 

than extinguishing it with water, the strategy was easily explained because the pre-plan research had 

been done.

Other Information: The fire was well controlled, as planned. Legal action by the town and county 

against the owner is underway for the recovery of expenses.

Case 5. Frankfort, Kentucky, August 15, 1995

Situation Before The Fire: At this location a limestone quarry mine had been converted into a tire 

recycling operation. The mine included a 300-foot single lane cave, which opened up into a large 

grotto. Several mine shafts opened into the grotto. The grotto was used as a whole-tire receiving area 

and the shredded product tire was piled in the other shafts. A previous fire damaged the shredding 

machinery and the shredding operation ended. As a result the property use changed from recycling 

to storage only. The tires were packed in the open shaft, which concerned authorities, and the tire 

salvage company was ordered not to receive anymore tires. The entrepreneurs went out of business 

rather than comply with fire safety practices, leaving the mine full of tires.

Extent and Duration of Fire: There were 100,000 tires in the caves when a second fire occurred. Since 

it was too dangerous to fight the fire in the caves, firefighters used positive pressure ventilation and 

heavy excavation machinery, to remove the tires from the caves and extinguish the fire. The fire 

required four days of around-the-clock operations to extinguish.

Pre-Fire Planning: After the first fire in the shredder machine, the fire department became aware of the 

scrap-tire operation. The department required that fire protection systems be installed.
12 U.S. Fire Administration/Technical Report Series

Strategies Employed: The strategy of positive pressure ventilation using a special fan unit was undertaken. The positive pressure ventilation was used to allow excavation equipment (track hoe) to enter 

the caves and pull out burning tires. Once removed, they were extinguished with hoselines, buried 

in moist dirt and sand until cool, then hauled away.

Problems Encountered During Fire Operations: The tire piles were not well-separated and there was limited 

access to the tires stored in the caves. The access problem hindered personnel, because their selfcontained air supply units did not have sufficient duration to enable them to enter the cave, find the 

fire, and exit before running out of air.

Other Information: A special unit on mutual aid from the Earlanger Fire Department provided the 

position pressure ventilation. This smoke removal unit was equipped with a 36-inch diameter fan 

permanently mounted on a one ton truck chassis. The air flow capacity is 80,000 cubic feet per 

minute and the air was directed using a 36-inch flexible hose. The excavation equipment operators 

were trained to use SCBA and were provided full-protective clothing.

In the face of this code requirement stipulated by the fire department, the owners of the tire operation went out of business and abandoned the tires in-place. The second fire occurred while legal 

action was being undertaken and before tires had been removed from the cave.

Case 6. District of Columbia, December 8, 1995

Situation Before The Fire: An entrepreneur stored old tires in a warehouse with the intent of making a 

profit transporting them to a tire recycler. When the warehouse lease was lost, the tires were abandoned in the vacant building which was then subjected to vandalism.

Extent and Duration of Fire: The fire occurred in a vacant two-story warehouse measuring 45 feet by 

105 feet that contained hundreds of thousands of scrap tires packed floor to ceiling. The fire took 

three days of around-the-clock operations before units could leave the scene. The resources committed were 125 firefighters, 14 engines, seven ladder trucks, two foam units, a rescue squad, a Hazmat 

unit, and an excavator.

Pre-Fire Planning: The fire department was not aware of the tires stored in the building and believed 

it to be vacant, so tire fire pre-planning was not completed.

Strategy Employed: The fire chief arrived at the scene 30 minutes after the initial alarm and met with 

incident commanders to review strategy and tactics. They undertook efforts to contain run-off oil.

Firefighters initially attempted water extinguishment. When no fire suppression headway was made with 

master streams, they used two foam units to apply AFFF class B foam. The foam had no effect and 

water streams were resumed.

Problems Encountered During Fire Operations: This vacant building filled with tires was in a mixed light 

industrial, residential area and access to the fire was limited. There were three overhead doors on 
USFA-TR-093/December 1998 13

the first floor. One was inoperable and framed for a three-foot passage door. The second floor had 

a loading dock access. The limited building entry made it difficult to apply a sufficient amount 

of water.

Other Information: The EPA and the U.S. Coast Guard were notified of the likelihood of contamination in the Anacostia River, and two fireboats monitored the river. Hazmat petroleum containment 

booms were placed in front of storm drains to contain and filter heavy deposits from the run-off 

water. The sewage treatment facility was notified to activate its scrubbers.

Case 7. Gila River Indian Reservation, Arizona, 

August 1, 1997

Situation Before The Fire: The Maricopa County Government entered into an agreement with a contractor to build a tire recycling plant and to dispose of the county’s scrap tires. In 1994 the contractor 

leased an area of an industrial park on Indian reservation land to shred three million tires and store 

the rubber chips. When the lease agreement lapsed, the contractor went out of business and abandoned the shredded tire piles.

The county government had a performance bond with the contractor for 330,00 dollars, which 

was awarded to the county. After legal expenses the county collected 230,000 dollars. The county 

offered to share this payment with the reservation for tire disposal costs. Gila River Reservation 

officials refused the offer because the cost of tire removal was estimated at 1 to 2 million dollars. 

Reservation officials believed that the county should be responsible for the entire cost of the shredded tire removal. This controversy was at an impasse in May 1997 and was ongoing at the time of 

the fire.

Extent and Duration of Fire: There were 26 shredded tire piles, each 150 feet long, 60 feet wide, and 35 

feet high. A chain-link fence surrounded the property. The fire required that 150 people be evacuated from the area. It took seven days to extinguish the fire, with some continuing flare-ups. The 

cost of the fire was 2.2 million dollars.

Pre-Fire Planning: This shredded tire pile problem had been long identified, and in May 1997 the site 

was pre-planned for a potential fire. A tabletop training session to test the plan was scheduled for 

September 8, 1997, but the fire pre-empted the drill.

Strategy Employed: Pre-planning revealed that water was not sufficient to extinguish the fire, and 

that heavy equipment would be needed to separate the unburned tire rubber from burning rubber. 

Once the unburned tire shreds were moved away from the building piles, an earthen berm was built 

around the burning piles. The berm contained the run-off oil.

The fire chief, on behalf of the reservation officials, declared the incident a disaster. The declaration 

in turn permitted the State to declare a State of Emergency, providing State resources and Federal 

recoupment funding. These resources allowed the procurement of heavy equipment necessary to 

control the incident.
14 U.S. Fire Administration/Technical Report Series

The testing of a commercial wetting agent early in the incident appeared promising because it was 

able to knock the fire down and control re-ignition. A large quantity of the wetting agent was air 

shipped, but when applied, did not provide complete extinguishment. Use of the wetting agent was 

discontinued, and the tire piles were buried in dirt with two to three feet of cover on the top. Burial 

controlled the fire.

Problems Encountered During Fire Operations: The 26 piles were in four rows with six and seven piles 

to a row. The separation between piles was inadequate to prevent exposure fires to the other piles. 

Although there were fire hydrants, the water tower that supplied the hydrants had 300,000 gallons 

of water and a very slow resupply. On arrival, the fire had extended from one to two of the 26 piles. 

Efforts to control the fire were progressing, until a windstorm with 60-mile-per-hour winds spread 

the fire to 17 piles.

Other Information: As the dirt covering settled and the site experienced rain, the piles flared up again 

and had to be covered with truckloads of dirt. Nine bulldozers, nine front-end loaders, one gradeall, seven dump trucks, and fourteen water tank trucks were used. The EPA is monitoring the site for 

ground contamination.

The remaining tire piles are still in-place and the cleanup issue between the county and the reservation remains. The potential for a second fire exists. The August fire was believed to be intentionally 

set, and the investigation remained active at the time of this report.

These case studies are summarized in Table 3.
USFA-TR-093/December 1998 15

Y OF CASE STUDIES SUMMAR TABLE 3.

Incident Date Material Location Pre- Planning Source of Ignition Extinguishment Duration and Extent

Falling Spring Rd, Garfield County, Washington

February 16, 1996 Shredded tire

landfill 

Landfill in deep ravine

No Pyrolysis, possibly 

rusting of steel tire belts

Excavation of burning material

5 months total; digout started in May. Fire was out the last week of June, 1996

Washington, PA February 28, 1997 1.7 million tires in a 

tire shredding building and in four acres of shredded tire piles

 Abandoned recycling facility No Juvenile arson Class B foam inef- fective. Excavation of 

burning material with submergence

14 days, with evacuation of 500 residents and closing of 2 schools.

Cearfoss, MD March 13, 1997 800 tire planters and 

4,800 whole tires

Farm No Open-flame heater Water and class B 

foam ineffective 

12 Hours

Chautaugua County, NY

April 23, 1995 Scrap-tire pile 

consisting of 5 to 6 million tires

Scrap tire pile Yes Undetermined Fire was allowed to 

burn, then smothered with dirt.

9 days, with evacuation of 50 residences and one school

Frankfort, KY August 15, 1995 100,000 tires and 

shredded tire product

Limestone quarry mine converted to a tire recycling operation

No Suspicious Positive pressure 

ventilation and excavation followed by burial in dirt and sand.

4 days

District of Columbia December 8, 1995 Several hundred 

thousand tires

Vacant warehouse No Undetermined Water and class B foam 

ineffective.

3 days

Gila River Reservation, Arizona

August 1, 1997 3 million shredded tiresIndustrial park on 

Indian reservation

Yes, but fire 

occurred 

before drill

Suspicious Class A foam with 

wetting agent ineffective. Burial in dirt.

7 days
16 U.S. Fire Administration/Technical Report Series

PLANNING FOR TIRE FIRE PREVENTION AND EXTINGUISHMENT

Planning for tire fire prevention and extinguishment involves three major steps:

•	 Code enforcement, especially regarding tire pile separation;

•	 Pre-planning the scrap-tire operation as a potentially protracted target hazard; and,

•	 Identification of excavation equipment to minimize fire spread, coordinated with fire

suppression.

Fire Prevention Code Enforcement

Tire fires result in difficult challenges for governments and communities. The fires require extended 

operations that may involve evacuations of entire communities, severe property damage, the closing 

of schools, and contamination of air and water. Citizens may criticize fire department operations 

for not extinguishing the fire quickly, and local and State governments for allowing the scrap-tire 

operation to exist in their community. To minimize negative public relations the fire department 

public information officer (PIO) should be proactive in communicating the circumstances of tire 

piles and of any fires involving these operations. These efforts may include: education about the 

difficulty of tire fires, safety precautions to avoid breathing the smoke, the planned actions to control 

the incident, as well as progress updates. The PIO efforts should be aimed at developing support 

from the community.

Multi-agency coordination. The disruption to community life that tire fires cause is best minimized by 

ensuring compliance with fire prevention codes. Compliance helps reduce the risk of tire pile fires. 

Many of the case studies identified difficulties in fire prevention code enforcement typically due to 

a lack of multi-agency coordination. This was particularly apparent in the Cearfoss and Frankfort 

incidents.

•	 Cearfoss. The property owner requested and was issued a permit by the Maryland Department 

of the Environment to keep old tires. The tires he used as planters caught fire because of 

open-flame heater used to boil water for sterilizing the soil was too close. The property 

owner said in the Frederick Post, “For five years I’ve been building a fire trap.” He blamed 

the State for issuing him the permit. “I’m a good salesman and I sold the State a very bad 

idea.” Deputy State Fire Marshal Cronauer said “the fire could have been prevented or controlled if the NFPA tire storage code2 had been applied.”

The fire prevention efforts failed because the State Department of the Environment notified 

neither the fire marshal’s office nor the local fire department that a tire storage permit had 

been issued. Until they responded to the fire, the fire department had no idea that 5,000 

scrap tires were stored at the farm.

•	 Frankfort. The scrap tire facility was allowed to go into operation in an abandoned mine 

without notification to the fire department or local government. The fire department became 

aware of the operation after a fire damaged the shredding machinery. Tires were packed 

in the open shafts without proper separation. The fire department ordered the tire salvage 

company not to receive anymore tires. While the fire department and city researched the 

2NFPA Storage of Rubber Tires, 2310
USFA-TR-093/December 1998 17

appropriate code and ordinances with which the salvage company would have to comply, a 

second fire occurred.

As these cases demonstrate, fire prevention efforts will not be effective unless code enforcement 

agencies are made aware of tire operations during the use and occupancy and building permit processes. Government agencies at all levels must coordinate their efforts so that scrap-tire operations 

are in compliance with codes when they open for business.

Proper Tire Storage. The recommended guideline for tire-fire prevention is NFPA 231D “Standard for 

Storage of Rubber Tires”. Appendix C of that standard specifically addresses storage of scrap tires. 

The NFPA standard identifies the following requirements for tire pile separation:

•	 Fire lanes to provide access for effective firefighting operations.

•	 Clearance from buildings and other exposures.

•	 Should also be in accordance with NFPA 80A “Protection of Building from Exterior Fire

Exposures”. This standard is based on tire storage pile height and the width of piles facing 

exposures. The general guideline is 60-foot-wide separation, or more in windy conditions.

•	 Construction of an earthen berm 1-1/2 times the height of the tire pile if the recommended

separation distance cannot be achieved.

•	 Maximum pile size not greater than 20 feet in height and 250 feet in length and width.

•	 Distance of 50 feet maintained between tire piles and grass, weeds, and brush.

Other fire prevention maintenance programs should include:

•	 Eliminating weeds, grass, and combustible materials within the storage area.

•	 Situating tire storage on a relatively level area and providing for tire run-off oil at each tire

pile. Run-off oil should be contained so that it does not spread fire to other separated tire 

piles.

•	 Prohibiting heating devices and potential ignition sources such as smoking and devices that

produce welding sparks or open flames.

Tire recycling operations like those engaged in whole-tire shredding often have buildings that contain 

the shredding or tire rubber crumb machines. These buildings should be protected with automatic 

sprinkler systems, and the water supply should be adequate both to supply the sprinkler system and 

to provide water for fighting the tire fire piles.

Tire Fire Pre-Planning

Most fire departments routinely pre-plan fires and emergencies. Of the tire fires case studies examined 

for this report, however, only two were pre-planned. In the Chautaugua incident, the Sinclairville 

Fire Department had a pre-plan that included State and Federal assistance, the use of State and local 

highway personnel, and oil containment and transport to oil recyclers. A pre-plan was in-place at 

the Gila River Indian Reservation fire, but the fire occurred before training was complete and the 

pre-plan could be practiced.
18 U.S. Fire Administration/Technical Report Series

Responsibilities of Local Governments. Often the lack of pre-planning is a result of local governments 

and fire departments being unaware of stockpiled tires. This was the case in Washington, DC, where 

what appeared to be a vacant warehouse was found to be packed with used tires. A similar situation 

occurred in Frankfort, Kentucky, where the fire department became aware of tires stored in a limestone quarry mine only after an initial fire involving shredding machinery. Fire departments should 

be vigilant of tire operations in their areas. There also must be communication among government 

agencies so that fire departments become aware of these operations and can develop pre-plans. 

Scrap-tire operations and facilities should be considered high-risk target hazards because tire fires 

are Hazmat incidents and extremely challenging to extinguish. The fire department should start the 

pre-plan process by recognizing scrap-tire operations as potential Hazmat/fire incidents, not simply 

as refuse or trash fires. The challenge of tire fires warrants formal planning to minimize the impact 

on the community and the environment.

In addition to the traditional pre-planning for fire operations, local governments should be prepared 

to deal with the business owners who go out of business rather than comply with fire and safety 

codes. To prevent the local government and the property owner from being left with the cost of disposal when owners go bankrupt and abandon tire piles, tire recyclers and tire operations should be 

required to provide a performance bond with sufficient value to finance tire removal. The Maricopa 

County, Arizona, government officials did this when they entered into an agreement with a recycler. 

Unfortunately, the county received the performance bond of 230,000 dollars after legal expenses, 

while the estimated cost of tire removal was 2 million dollars. The performance bond should be 

enough to finance the tire product removal and legal expenses.

Pre-Planning Considerations. Several factors should be taken into account during pre-planning.

•	 Maps and Diagrams. There should be area maps showing not only the tire operation and 

piles but also potential areas and neighborhoods that may require evacuation. The available 

mapping should include topographical, aerial, water main, sewer, storm drainage, and soil 

composition diagrams. These maps help forecast run-off flows and potential containment 

sites. They also help predict whether the soil will hold the run-off, or whether run-off will 

be absorbed into the ground and possibly pollute water sources.

These maps also assist in planning where total extinguishment (submerging), truck loading, 

hauling, or tire product burying will be done. The use of water and heavy equipment will 

require access road management. Mud, deep ruts, and steel wire cords from burned tires can 

block or damage vehicles. To ensure that vehicles will have a suitable roadway to come and 

go from the fire site, stone, dirt, and a bulldozer are often needed to maintain site access.

The pre-plan should include a diagram of the tire pile site showing all buildings and utilities 

(gas, electric, heating oil, etc.), machinery controls, and fire protection systems.

•	 Command Post Organization. Tire fires may require evacuations, and planners need to identify 

evacuation sites, such as schools. Because these fire operations may continue for days or weeks, 

fire crew rehabilitation and rest areas will be needed. A command post of sufficient size to 

accommodate multiple agencies, including local, State, and Federal agency representatives, will 

also be required. The command post will probably be more effective if it is not at the fire site 

or too close to fire operations. The command post should not be shared with the rehabilitation 

area because such an arrangement will create distractions, interfere with public information, 

hinder coordination with news media, and make it harder to manage logistics and supply.
USFA-TR-093/December 1998 19

•	 Resource Lists. There should be a list of public and private resources and suppliers developed 

so that equipment and supplies can be requested without delay. This list should be current 

and updated frequently. Examples of equipment and resources are shown in Table 4.

TABLE 4. LISTING OF SOURCES OF EQUIPMENT AND PERSONNEL

Local and State government Heavy equipment and operators

School system/transportation agency Buses for personnel transport, evacuation

Rehabilitation shelters

Excavation/rigging contractors Large bulldozers and excavators (track hoes)

Contract suppliers Fill dirt and gravel

Food service

Sanitation and portable toilets

Universities and colleges Staff from ecology and environmental engineering departments

•	 ICS. The pre-plan should be established around the ICS. This type of incident benefits 

from an integrated multi-agency public and private operation. While the fire department is 

responsible for coordinating the fire control, it may necessitate reliance on other experts and 

contractors. Many responsibilities may be delegated, including operating heavy equipment 

to separate unburned product and move burned tires to be extinguished or buried.

Excavation Equipment for Tire Fires

In pre-planning for a tire fire, arranging for the proper excavation equipment is crucial. Tire piles 

fires typically meet the requirements for activation of State EPA assistance, and should be classified 

as a Hazmat incident. The State EPA will usually provide contractors familiar with hazardous waste 

cleanup, and who have expertise and knowledge of excavation equipment. However, fire department 

leaders should not depend totally on the State EPA or contractors for providing the correct excavation 

equipment. By pre-planning the tire fire incident, the necessary and optional equipment can be prearranged to ensure it will be available when needed.

Not all excavation equipment is intended for the same purpose. Many towns and cities have heavy 

equipment in their highway and road departments. Although readily available for fire emergencies, 

this equipment may not be suitable for tire fires. For example, the backhoes most highway departments possess do not have buckets with a sufficiently long reach. These backhoes also must be 

immobilized with support jacks, making it impossible to move the unit quickly if the tire pile collapses onto the machine. Moreover, these units are usually open and do not provide enough safety 

for the operators.

Three types of equipment are usually needed on tire fires. With these specialized machines, the 

operation can be more efficient and effective.

Excavator. The machine necessary for separating burning tire piles to allow extinguishment is the 

excavator with tracks. This is sometimes referred to as a track hoe (Figure 1). The excavator is also 

available with wheels, but track models are more suited to the muddy terrain that will result from a 

tire-fire incident.
20 U.S. Fire Administration/Technical Report Series

Excavators are rated by weight, the length of the bucket reach, and breakout power. Breakout power 

is the power of the machine to pull the bucket into undisturbed soil. Shorter reach and a heavier 

boom improve breakout power. However, for tire fires the important factor is the length of bucket 

reach. Fire departments should look for machines with the longest reach available that can still be 

transported on a flatbed trailer without disassembly. This is approximately a 23-ton machine with a 

reach of 30 feet. Larger excavators require disassembly for transport and reassembly on-site.

Figure 1. Excavator, or track hoe.

The excavator is a tracked vehicle with a wide stance that is stable without support jacks. It is 

important that this machinery remain mobile should it need to move out of the way of burning oil 

flare-ups or pile collapse. The excavator can rotate 360 degrees on a turntable. It has a fully enclosed 

cab, in which the operator is situated five to six feet above the ground. That position, combined with 

the long reach, provides the operator with sufficient safety to operate on tire fires. Although the cab 

of the machine is enclosed, operators should wear hard hats, appropriate protective clothing, and 

breathing apparatus if necessary. Excavators are usually equipped with a roof escape hatch should the 

machine overturn or the side door become blocked during tire fire operations. A firefighting crew 

with charged hoselines should always be available for rescue.

The most common attachment to the excavator is the digging bucket, which can be used on tires. 

Another is the grapple which is hydraulically operated and opens or closes so the tires can be gripped 

and lifted. While the grapple may work well for whole tires, it is 

not as effective for tire shreds or burned tire scraps.

The ideal attachment is a bucket used for digging combined 

with a mechanical thumb attachment (Figure 2). The thumb is a 

mechanical lever that is hydraulically operated and can close over 

the bucket as the thumb of the hand closes over cupped fingers. 

With the mechanical thumb open, the bucket can be used for 

digging (Figure 3). With the thumb closed over bulky material, 

it works similarly to a grapple.

Bulldozers. There is often a need to separate unburned from 

burning tires to prevent exposure fires and, as in the Chautaugua 

and Gila River Reservation incidents, to build berms around the 

burning tires for containment. Bulldozers are used both to push 

Figure 2. Hydraulic Thumb heavy loads of tires and dirt and to build berms. They can be 
USFA-TR-093/December 1998 21

used to dig and grade the run-off oil containment pond as well 

as to construct access roads or repair roads for heavy equipment. 

As tires burn the radial steel wire cords become personnel trip 

hazards that can also warp around mechanical equipment drive 

shafts and damage machinery. A bulldozer can maintain clear 

passable roadways for other vehicles at these incidents.

The burned tires separated from the pile by the excavator will 

need to be pushed to the extinguishment area; the bulldozer is 

the best machine for this task. It can dig the submergence pond 

in which to soak tires for complete extinguishment.

The key factors in selecting a bulldozer are weight and horsepower. A dozer can not push more than it weighs and has to have 

sufficient engine horsepower. The bulldozer selected for tire fires 

should be one of the larger units weighing 30 tons or more with 

a minimum of 230 horsepower. Dozers are designed specifically 

to push heavy loads with proportional weight when equipped 

with aggressive tracks called grouser cleats.

Dozers should not be confused with tracked front-end loaders. 

The loaders have the weight distributed to provide ballast for the 

bucket when raised in the air. There is some compromise for front-end loaders that makes them less 

efficient for pushing heavy weights than are bulldozers.

One manufacturer makes a high-sprocket dozer which is distinguished from oval-track machines 

(Figure 4) by the triangle-shaped track (Figure 5). The high-sprocket machine offers an advantage 

for tire fire applications because the hydraulic oil and drive sprocket are higher off the ground, 

minimizing exposure to flames and entanglement of steel tire cords.

Figure 3. Thumb open for 

digging

Figure 4. Oval sprocket design Figure 5. High sprocket design

Front End Loaders. The third type of heavy equipment that will be needed is the front-end loader. The 

loader is a tracked machine that looks similar to a dozer. A loader has a front bucket that can scoop 

up a load, raise it, and dump the load into a truck or other container (Figure 6). The loader will be 

needed to load the extinguished tires into trucks for hauling away. The loader can also be used to 

scoop dirt and dump it on tires to bury them until they cool.

In Washington, Pennsylvania, large construction refuse containers were loaded with tires by a frontend loader, then hauled away by trucks. In Frankfort, Kentucky, tires were pulled out of a cave, 

extinguished with water, and buried by the front-end loader until cool to prevent re-ignition.
22 U.S. Fire Administration/Technical Report Series

While the front-end loader cannot push as well as a dozer, 

it could substitute for one if a multi-purpose bucket were 

used. This bucket has a hydraulically operated bucket 

extension that converts the open-ended bull push plow 

for pushing into a bucket closed on the ends for lifting 

and loading. This multi-purpose bucket allows for pushing and loading.

The front-end loader needs to be a large machine with the 

weight of 21 tons or more and 160 to 220 horsepower. 

The bucket should have a capacity of approximately three 

cubic yards.

Efficient use of these machines requires a skilled operator. It is generally not advisable to attempt 

to use fire department personnel to operate rented machines. Even if fire department members 

are experienced with these specific machines, it is advisable to utilize their experience in safety officer assignments or coordinating with fire operations and the excavation equipment operation.

Trucks. Dump trucks to deliver dirt and stone for containment berms and access roads will be necessary. Dump trucks can also be used to remove totally extinguished burned tire product to other 

landfill or disposal sites.

If trash containers are used, as in the Washington, Pennsylvania, fire trucks designed to roll back 

the container on rails and pull the loaded container onto the truck chassis are preferred. Container 

contractors generally have the trucks to deliver and load these containers. The containers should be 

drained of water before being loaded on the truck.

Excavation equipment will generally require flatbed trailers for transport to the tire fire site. These 

tractors and trailers should be sent back to their equipment yard or parked away from the fire so they 

do not congest the tactical operation, or impede the access to the site.

Emergency Response

Major tire fire incidents are likely to involve State and Federal environmental agencies to coordinate 

safe removal of burned tire product. These fires frequently produce a multiple-agency response, 

including the State EPA for monitoring oil run-off containment and contracting for use of excavation 

equipment. The Federal EPA response center should be notified within 24 hours. Law enforcement 

is usually needed to help evacuate citizens, control unauthorized entry, and maintain security of 

evacuated areas. Mutual aid is often necessary for fire services because tire fires are usually protracted, around-the-clock events. Even fire departments with good resources need assistance to be 

able to respond to regular emergencies in addition to the ongoing tire fire.

Emergency management systems vary slights, and each fire agency should fully understand its local 

and State system. Agencies may include:

•	 Police and EPA enforcement officials

•	 State and local emergency management departments

•	 Highway and public works departments

Figure 6. Front-end loader. Shows 

limit of bucket elevation
USFA-TR-093/December 1998 23

•	 Regional Federal Emergency Management Agency (FEMA) office

•	 Regional Federal or State EPA office

•	 State fire marshal’s office

•	 State natural resources agency

•	 Procurement and finance agency

Procurement of Heavy Equipment. Experience shows that heavy equipment is often needed to supplement firefighting. Few fire agencies own such equipment, and the equipment itself, as well as trained 

operators, is usually procured through contractors. Local and State government highway departments usually have some heavy equipment and trucks that can support the fire department’s efforts. 

Moreover, when tire fires are classified by the State EPA as Hazmat incidents, State and Federal funds 

may become available to hire excavation contractors.

For example, the Gila River Reservation tire fire was pre-planned and one key element was the State 

government declaring a State of Emergency so that funding, State support, and mutual aid were 

immediately available. This support allowed the fire department to obtain water tankers and excavation equipment and to purchase wetting extinguishing agent. In the Garfield County fire, excavation 

equipment was needed to remove burning shredded tire landfill from a deep ravine.

•	 Fire departments should maintain lists of local and regional contractors that can be used for

support when necessary. Examples are:

•	 Excavation and building supply contractors

•	 Fire equipment suppliers

•	 Oil recyclers and hazardous waste contractors

•	 Food suppliers and portable sanitation contractors

•	 Apparatus and equipment repair contractors

•	 Fuel vendors for the on-site vehicles refueling

Safety Considerations. Precautions must be taken for ensuring safety of residents, including monitoring air quality, and coordinating evacuation if necessary. When residents are moved from their 

homes, overnight lodging in schools or community relocation facilities may be required. Medical 

and health care agencies should be involved to assist the elderly and those with respiratory ailments, 

which may be aggravated by the smoke of the fire.

There should be coordination with utilities because of the impact on water, sewers, and storm-water 

drainage. In some cases, power companies have been needed to reconnect electricity at closed tire 

recycling or storage facilities so that emergency operations could be supported.

Tire fires should be managed like other Hazmat incidents. There should be documentation of all 

personnel who could be exposed to toxic materials. Safety procedures and operations should be in 

compliance with the appropriate EPA, Occupational Safety and Health Administration (OSHA), and 

applicable State regulations. 
24 U.S. Fire Administration/Technical Report Series

FIREFIGHTING STRATEGY AND TACTICS

The objectives for fighting tire and tire product fires should be prioritized in the same way as those 

for most fires, following time-tested basic steps:

•	 Rescue/Evacuation

•	 Exposure Protection

•	 Confinement

•	 Extinguishment

•	 Overhaul

With many fires, the exposure, confinement, and extinguishment phases can occur almost simultaneously with good tactics of hose line placement. With tire fires, however, each phase must be 

completed before the next is begun. Until the exposure of unburned tires is removed, the fire cannot 

be contained and until it is contained, it cannot be extinguished. Extinguishment must be complete 

before overhaul because of the tendency for tires to retain heat and re-ignite. The strategy and tactics 

of tire fires will be influenced by the application of fire code, tire pile separation, and pre-planning 

for resources such as heavy equipment.

Tire fires rarely involve life-threatening rescue challenges, but many require evacuation of residential 

areas around the site. The speed and direction of the wind will influence the extent of evacuation, 

and these may change during the days and weeks of fire operations. Evacuation efforts can often be 

delegated to police or other agencies.

Exposures

All of the tire fire case studies examined involved fire exposure problems, and this may be the most 

important and difficult challenge to address. The exposure priority of burning tire products is usually the surrounding unburned tire piles. If the fire can be stopped from spreading to unburned 

piles, then the fire department has protected the exposure and contained the scope of the incident.

Minimizing fire spread to unburned tires is difficult because:

•	 Most tire piles are not adequately separated.

•	 Fire apparatus and heavy equipment access roads may be inadequate.

•	 Tire pile separation requires heavy equipment that may take substantial time to get on-site

and in operation.

•	 Even with large amounts of water, it is difficult to keep deep-seated tire fires from re-igniting

and spreading from within the pile.

•	 In the first 30 minutes of the fire, the spread rate can be two square feet every five minutes.

In many of the case studies, fire departments attempted to use water to confine and extinguish the 

fires with surround-and-drown tactics because the heavy equipment needed to move unburned tires 

was not immediately available. In the Gila River Reservation incident, only two of 26 piles of tire 

shreds were on fire when the fire department arrived. A windstorm had spread the fire to 17 piles 

by the time excavation equipment arrived to move the unburned product exposures.
USFA-TR-093/December 1998 25

Therefore, the initial stages of the fire may best be spent planning how to effectively separate 

unburned tire exposures and how to contain run-off oil. Water is best used to keep unburned tires 

from burning rather than to extinguish the burning tires.

Containment

Once adequate separation is obtained with excavators and bulldozers, an earthen berm should be 

built around the burning tire pile. Berms at least one half the height of the tire pile should be sufficient, provided that the angle of repose of the pile is not such that material from the top can tumble 

out of the confining berm. With the berm complete, the tire fire can be considered contained and 

extinguishment can become the main focus.

A berm can also be used where adequate separation is not possible; NFPA recommends berms 1-1/2 

times the tire pile height. However, it is difficult to build berms when adequate separation is not 

available during a fire because heavy equipment and loads of earth must be moved into position.

Extinguishment

There are several strategic considerations and tactical options with tire fire extinguishment. One 

consideration is the threat to the community and pollution of the environment. Another is whether 

the tire product is stored inside or out. Depending on the pre-plan and nature of the fire, free burning, submersion or burial may be considered.

Letting the fire burn. The Sinclairville Fire Department used this strategy on the Chautaugua County 

fire. This was the pre-planned strategy because of concern that extinguishment water would cause 

ground water contamination and increase the spread of run-off oil. Allowing the fire to burn minimizes the impact on air pollution because the free-burning tire fire is the equilibrium and pyrolysis 

phase and will consume most of the fuel. Free burning therefore reduces toxic and carcinogenic 

combustion emissions such as benzo (a) pyrene and benzene, as well as toluene, chrysene, zinc 

oxide, titanium dioxide, carbon monoxide, sulfur dioxide, and hydrogen sulfide.

Burying the burning tires. In many cases the most effective means of managing major tire fires will be 

by smothering the burning material with dirt or fill. Though smothered, the fire will continue to 

smolder for weeks or months and will usually break out into open flaming periodically. This tactic 

was used in Chautaugua after the tire pile burned to a manageable size. This was also the primary 

extinguishment method used by the Gila River Indian Reservation Fire Department. Here, the tire 

pile was buried under three feet of dirt using bulldozers and heavy equipment. Flare-ups caused by 

settling and erosion were refilled with dirt.

Use of Water vs. Foam. Most firefighters have success using water on class A material fires. Class A 

materials such as wood, paper, and cloth absorb water, and this assists in cooling these burning 

materials. Bu contrast, tires and shredded tires do not absorb water, but instead repel it. Much of the 

water applied by master streams bounces or sprays off the tire ash crust and turns to steam before it 

reaches the seat of the fire.3

 Master streams produce greater run-off without significantly improving 

fire knock-down. Fog streams may be effective, for dousing separated burning product.

3 International Association of Fire Chiefs, Guidelines for the Prevention and Management of Scrap Tire Fires, pg. 24.
26 U.S. Fire Administration/Technical Report Series

In all the case studies where extinguishment used water successfully, the tactics employed used excavation equipment to first pull the burning material into small manageable piles. The fire was doused 

with handlines and a front-end loader was used to complete overhaul by moving the material to be 

submerged or buried until cool. In the Washington, Pennsylvania, fire, the burned rubber product 

was submerged in construction dumpsters filled with water. After the product was sufficiently 

cooled, the water was drained and the dumpster was trucked to the landfill. In Frankfort, burning 

tires were removed from caves and doused with hose lines. A loader then buried the tires in dirt until 

cool and they were trucked away for disposal.

Class B Foams. In some of the case studies, firefighters applied class B foam in a vain attempt to 

extinguish the fire in the ignition and propagation phase.

In such incidents, fire is spreading rapidly when the fire department arrives. Water is not maintaining extinguishment; the water streams knock down visible flames, but when the streams are directed 

on another area, the previously knocked-down fire area builds up heat and re-ignites.

This tendency of tire fires to revive with stored heat re-ignition is why many fire departments have used 

class B foams to attempt to smother the fires by starving them of oxygen. Class B foams are standard supplies on many fire pumpers, which are usually equipped with 10 to 15 gallons of foam concentrate.

In the case studies reviewed, the Washington, Pennsylvania, Washington, DC, Cearfoss, and Frankfort 

firefighters all used class B foam on the tire product pile, in each case without success. Firefighters at 

the Gila River Reservation fire used an A, B wetting agent, also without the desired results.

Using class B foams on tires is unsuccessful for three reasons. First, tires are a class A fuel and not 

extinguished by placing a foam layer between the fuel (tire) and oxygen (air) as is done with flammable liquids. With tire fires, it is not possible to separate the oxygen from the burning tire because 

the fire will continue to burn under the foam layer.

Second, the tire casing is formed with a built-in void space, which provides pockets of air to feed the 

fire. Thermal updrafts can also cause burning tire piles to draw air from within the pile. Whole tire 

piles create natural vertical and horizontal voids, which act as air vents to the burning material.

Third, foam is not useful on tire fires because run-off oil drains out of the pile below the flame and 

fire heat level. Run-off oil ignition occurs when the tire pile is disturbed and burning material falls 

to the lowest level, causing a flare-up.

Although generally ineffective for extinguishing tires, class B foam is important to use on run-off oil 

to prevent ignition and control any oil run-off fires. A class B foam layer should be maintained over 

the containment oil pond.

Class A Foams and Wetting Agents. Class A foams are made from a concentrate mixed with water and 

applied as an air bubble foam. This foam is effective on many class A fires. Class A foams usually 

include a surfactant which, when the foam breaks down, the liquid is easily absorbed or remains on 

the surface of the class A materials. This blanket of foam insulates unburned fuel from radiant heat 

or direct flame impingement.

Wetting agents are chemical compounds which include a surfactant and reduce the surface tension 

when mixed with water to improve penetration. This serves to improve the effectiveness of water 

in reducing run-off.
USFA-TR-093/December 1998 27

There is controversy over whether class A foams and wetting agents are useful on tire fires. On one 

hand, experiments with class A foams by members of the Phoenix Fire Department suggest that the 

class A foams provide a definite advantage, especially in deep-seated fires in wood or tires.4

 On the 

other hand, class A agents may have to be used earlier in the course of a fire (within the first 15 to 

30 minutes) than is commonly possible with tire fires.

The detergents in class A foams may help extinguish tire fires because the water-detergent mixture stays 

on the tire long enough to absorb heat. Moreover, the surfactant properties reduce surface tension and 

keep water from merely bouncing off tires. Many class A materials resist absorption of water because 

of surface tension. Wetting agents reduce surface tension, permitting water to flow and spread uniformly over solid surfaces. In theory, wetting agents improve adhesion of water to surfaces and increase 

absorptive speed. This allows the water to remain at the burning surface or to be absorbed into the 

burning fire seat where it can absorb heat and extinguish the fire. (See Appendix A, Large Scale Test to 

Evaluate the Effectiveness of Various Fire Suppression Agents on Burning Stacked Tires.)

There have been reports of limited success of wetting agents on tire fires. At the Gila River Reservation 

fire, these agents were tested in small quantities with some initial success. However, when additional 

quantities were delivered, it was not possible to get total extinguishment of the tire-shred piles.

Wetting agents and class A foams appear to have their best effect if used early in tire product fires. 

Their successful use seems to depend on delivery when the fire is in the ignition and propagation 

stages. Thus, the factor limiting the effectiveness of wetting agents and class A foams is having sufficient quantities available to use during the ignition and propagation phase of the fire and to start 

application then. Unfortunately, early application is often not practical because extinguishment 

should not begin until unburned tires are separated from burning piles and the pile fire is contained with berms. By the time those tasks are completed, the tire fire has usually reached advanced 

stages.

When used, class A foams change the capability of the fog nozzle by reducing stream reach, velocity, 

and spray coarseness. Compressed air systems may overcome the negative effects of class A foams on 

fog nozzles and improve foam delivery reach.

Overhaul

Water alone does not usually ensure total extinguishment because tire fires become deep-seated and 

must be dug out. Even when the fire can be knocked down, it is subject to re-ignition because the 

tires retain heat and decompose at relatively low temperatures.

To ensure extinguishment, the burned tire product should be buried in dirt or submerged until 

cooled below 200 degrees Fahrenheit. Burned tires may be submerged in construction dumpsters 

filled with water or in a three- to four-foot-deep water pond. Extinguished tire product is submerged in the pond until cool, then loaded into transport trucks with a front-end loader.

Tires must be completely extinguished before they can be transported to another site or landfill. If 

not extinguished, the tire remains can re-ignite at another location. It is dangerous to have a truckload of burned tire material re-ignite on the highway or to spread fire to a landfill. Regardless of 

how big the fire is, overhaul must ensure that the fire is totally extinguished before off-site disposal 

is attempted.

4 Stern, Jeff, and Routley, Gordon. Class A Foam For Structural Firefighting (U.S. Fire Administration Technical Report Series). 1996.
28 U.S. Fire Administration/Technical Report Series

ENVIRONMENTAL HAZARD CONTAINMENT

Preventing tire fire run-off oil from contaminating ground water and well water generally requires 

support from hazardous waste experts. Large tire product fires produce significant quantities of oil 

that usually are not consumed by the fire, but instead drain out the bottom of the burning tire pile. 

This draining run-off oil should be contained in a safe manner so that it does not contaminate the 

environment or become a secondary class B fire.

Controlling run-off oil spills should begin with pre-planning the tire fire incident. The tire pile 

topography is important so that natural drainage can be used to predict oil and water run-off. When 

constructing containment berms around the burning tire piles, drainage pipes should be placed at 

the bottom to provide for run-off drainage. All of the run-off should be directed into a drainage 

pond where the oil can be cooled and separated from the run-off firefighting water.

At one of the largest tire fires in U.S. history, 9 million tires in Winchester, Virginia, burned and produced 500,000 gallons of run-off oil. About 250,000 gallons of oil were recovered. This incident 

involved building dikes and a containment pond to control run-off. A secondary containment pond 

was used to hold oil separated from the run-off water. The run-off oil was pumped into tank trucks 

and recycled. The oil containment pond used on the Winchester fire was lined with rubber membrane material normally used for commercial roofing. This oil containment operation was critical 

because escaping oil of this volume threatened the Potomac River, the water supply for the cities of 

Hagerstown, Maryland, and Washington, DC.

As containment ponds are built and receive run-off water and oil, firefighters must prevent oil from 

overflowing the ponds. Water usage should be controlled; firefighters should not continue applying 

large volumes of water on burning tires if it has no effect. The overuse of water will only increase 

run-off and cause overflow of containment ponds.

Public information efforts should be prompted and continual throughout the duration of the incident 

to avoid citizens’ criticism over extended operations coupled with a fire department’s difficulty in putting the fire out. Ineffective public information can influence fire commanders to needlessly flow large 

volumes of water to look good for public relations. This will likely overwhelm the ability to control 

run-off oil containment and result in a negative impact on the environment. Water is properly used in 

conjunction with digging out the piles with an excavator and extinguishing smaller piles.

In addition to all of the priorities of dealing with the tire fire and the collection of run-off oil, precautions should be taken to ensure that the run-off does not ignite and cause a flammable liquids 

fire. The containment of the oil pond should include security, such as a chain-link fence, to prevent 

construction vehicles from mistaking the oil pond for tire overhaul submergence ponds. With a hot 

oil pond near a raging tire fire, the potential for ignition of a flammable liquid is a real threat. To 

prevent ignition, the run-off pond should be covered with class B foam such as AFFF. The foam layer 

should be maintained over the ponds with oil on the surface. Most class B foams are designed to 

mend the foam blanket. This foam layer will prevent and extinguish an ignition of the run-off oil.

SAFETY OF OPERATIONS

As with all fires, potential for serious injury exists at tire fire incidents. With these fires, the safety 

issue goes beyond just fire department operations because of all the other public and private agencies 

also participating.
USFA-TR-093/December 1998 29

The fire department should assume the role of safety coordination for all the agencies operating on 

the fire. This is notwithstanding the fact that all contract personnel, as well as those operating under 

the control of other public agencies, should be monitored by their respective employers. Safety 

responsibilities should be handled per OSHA regulations, specifically 1910-120, paragraph Q.4, 

“Hazardous Waste Operations and Emergency Response,” and with EPA safety regulations. NFPA 

1500 standards also would apply. A designated safety officer should oversee the firefighting, run-off 

containment, and burned product overhaul and removal. The safety effort should be an aroundthe-clock operation and will require shifts. Many fire departments have shift coverage. However, 

to ensure accountability, shifts assigned for this fire may be covered with 12-hour shifts on and 

12-hour shifts off. Assistant safety officers may be needed to oversee personnel rehabilitation and 

to provide documentation of all personnel participating. They also would document injuries and 

subsequent medical treatments that occur at the incident.

These fires generally require the joint effort of many agencies and their respective personnel. 

Fireground security is necessary because day-to-day operations will involve working with personnel who do not know one another. Security and safety may be complicated if curiosity seekers and 

well-intentioned volunteers attempt to enter the fireground. Security should start with emphasis on 

requiring identification of all personnel cleared to work at these fires. Also important is personnel 

accountability, including accountability for non-fire-department personnel such as heavy equipment 

operators and environmental waste contractors.

All personnel operating in hazardous areas should have appropriate protective equipment, including 

SCBA, if indicated. Some non-fire personnel may need to have personal protective fire equipment 

provided. The fire department Incident Commander should assure that anyone with access to the 

site, including contractors, is made aware of the applicable safety requirements. Again, the fire 

department’s role here is not an exclusive one and non-fire personnel are ultimately the responsibility of their employers. At a minimum, the following steps should be taken:

1. Site briefing – All personnel entering the scene should be advised of the conditions, inherent 

dangers, and potential risks. Fire department safety procedures and personnel accountability 

rules should be covered at the briefing.

2. Communications – It should be verified that equipment operators have or are provided communications capabilities that are fully compatible with other fire department communications 

equipment.

3. Personal protection – Personal protective ensemble, including appropriate respiratory equipment, should be ensured for all fire ground personnel. Those not familiar with the use of respiratory equipment may need to be trained in how to wear and use this equipment properly.

4. Supervision and monitoring – The fire department should maintain close supervision of contractor personnel during operations, and provide on-going environmental monitoring.

Additional safety concerns include the following:

•	 The heavy equipment operators are at greatest risk because they will be working nearest to

the fire. Those especially at risk include bulldozer operators moving unburned tire product 

during the propagation phase of rapid-fire spread, and excavator operators who will be 

subject to fire flare-up when the burning tires are pulled from the pile. A Rapid Intervention 

Team of fire personnel should always be ready to move in with charged attack lines to protect 

or rescue heavy equipment operators.
30 U.S. Fire Administration/Technical Report Series

•	 Heavy equipment should not be driven over burned piles. The center of these piles can be

likened to volcano lava, and is very unstable.

•	 Because tire piles may be stacked very high, there is a threat that they may collapse or fall on

heavy equipment and personnel. Operators may become entrapped, injured, or killed. High 

stacked tire piles should be moved using tracked excavators with high reach to pull the fires 

down while bulldozers push the tires away for separation.

•	 Flare-ups of fire can occur by re-ignition, in run-off oil, and by air reaching the center of

the pile when the excavator pulls up burning material. Suppression crews with adequate 

hoselines must be available to extinguish small piles and keep class B foam on the run-off 

containment oil.

COST RECOVERY RESOURCES

The Winchester, Virginia, tire fire of 1983 was one of the largest in the United States. Like most 

scrap-tire product fires, it was very expensive. During the first week of the fire 330,000 dollars was 

spent on operations, with an average cost of 45,000 dollars per day. The cost to finally contain the 

fire and control the oil run-off was 1.2 million dollars.

The fires detailed in this report were similarly expensive. The cost estimate to remove the tire product before the Gila River Reservation fire occurred was 2 million dollars; the cost of the weeklong 

fire was 2.2 million dollars. The Falling Spring Road fire carried fire and cleanup costs of 3 million 

dollars.

In most cases local government alone cannot handle the costs involved in extinguishing tire fires 

and the ensuing reclamation tasks. These fires will require resources and funding from State and 

Federal government. Most of the funds available are from State EPAs in conjunction with the Federal 

EPA. The EPA may reimburse local fire departments up to 25,000 dollars for expenses related to 

emergency actions required to extinguish and control a tire fire. To access these funds, responders 

must contact the National Response Center within 24 hours of initiation of the response at 800-424-

8802. Also, assistance to support the containment, extinguishment and remediation of large tire fire 

incidents is available through the EPA as authorized by the Comprehensive Environmental Response 

and Liability Act of 1980 (CERCLA), as amended by the Superfund and Reauthorization Act (SARA) 

of 1986 (see Appendix B). Superfund assistance is managed by EPA officials who are deployed to the 

scene to help coordinate the resources.

At the Gila River Reservation fire, prior planning streamlined the approval and authorization process for assistance. The fire chief, on behalf of Indian reservation officials, made the initial request 

through the appropriate State and Federal government agencies. Local officials may also want to 

investigate whether State or Federal disaster relief monies would be available to offset the costs of 

response and recovery.

In most of the case studies, the costs went beyond the use of expended supplies. Usually, fire departments operating on tire fires will suffer damage and contamination to equipment, including personal protective gear, hoses, and tools that have to be replaced. It will be important to document all 

supply accounts with billing records, as well as with replacement equipment invoices. Because not 

all expenses may be reimbursed, it may be advantageous and necessary to pursue subsequent legal 

action against responsible parties, if practical.
USFA-TR-093/December 1998 31

Fire departments also can access cost recovery of emergency operations through the business and 

property owners. This process usually involves court-ordered fines and restitution procedures. 

Property owners also may be held liable through performance bonds and/or State environmental 

laws if compliance with appropriate regulations was derelict.

At the Federal level, legislative initiatives are progressing to help prevent scrap tire fires, and to assist 

communities that are confronted with a major tire fire. Congressman Kennedy of Rhode Island 

and Senator Chafee have introduced a bill to the House of Representatives and to the U.S. Senate, 

respectively, called the “Tire Pile Improvement and Remediation Effectiveness Act”. The Act would 

amend the Solid Waste Disposal Act to provide States with Federal grants for fire lane construction 

and removal of certain scrap tire piles. The proposed legislation gives priority to tire fires near community water systems, schools, and retirement communities. It also calls for grants to be provided 

when there are tire piles with one million tires or more (see Appendix C). This bill was under 

review by the House Committee on Commerce and was referred to the Subcommittee of Finance 

and Hazardous Materials.

In the Commonwealth of Pennsylvania, the State legislature passed Act 190, signed by the Governor 

in December 1996, which provides one million dollars a year to remediate waste tire piles across the 

State. The Act also provides two million dollars in tax credits for three years for companies or individuals which make capital improvements in equipment that processes waste tires (See Appendix D). 

The first round of grants of one million dollars is expected to clean up 800,000 tires at seven sites. 

The State Department of Environmental Protection has set aside 250,000 dollars for construction and 

renovation of public recreational areas utilizing scrap tires or tire rubber-derived materials.

Congressman McCain of Arizona introduced legislation in the Senate which requires that USFA report 

to Congress on the specific risks and associated issues pertaining to scrap tire piles and fires.

These positive efforts are viewed as models necessary to control the scrap tire problems before a fire 

makes it a Hazmat emergency.

LESSONS LEARNED

1. Strict fire code enforcement is necessary to keep tire product piles of manageable size so 

that fires can be prevented or quickly controlled.

Fire codes and safety practices for scrap-tire business operations must be aggressively enforced. 

Scrap-tire tire recycling, shredding, or storage businesses should not be allowed to start operations without the appropriate use and occupancy permit process. Firms should comply with 

NFPA’s Standard for Storage of Rubber Tires 231D to ensure the appropriate pile separation. 

Exceptions should not be made for firms claiming special circumstances, such as occupancy for 

outside storage or use of only unheated areas or temporary trailer office space. The substantial 

potential for major fires at such operations warrants treating tire recycling and storage business 

as a Hazmat facility. These operations tend to have lax security, become ill kept, over stocked, 

and in disrepair increasing fire hazards dramatically. Routine periodic inspections are necessary 

to ensure that these operations remain in compliance.

2. Fire departments should pre-fire plan all tire operations in detail and consider them substantial target hazards.

To prepare for fire, tire operations should be pre-planned and tires treated as a Hazmat risk. The 

pre-plan should detail the separation of unburned from burning tires and the containment of 
32 U.S. Fire Administration/Technical Report Series

run-off oil. It is also necessary to pre-plan major strategy decisions, such as whether the fire will 

first be allowed to burn (to minimize toxic products of combustion) or whether it will be extinguished by pulling the piles apart, then submerging tire products in water or burying them in 

dirt. The pre-planning should include development of a list of contractors to provide excavation 

equipment and estimates of how quickly the equipment can be deployed and become operational. Any unusual circumstances and special equipment requirements should be analyzed, and 

provided for in the plan.

3. Fire authorities need to emphasize multi-government agency cooperation so that State and 

local agencies are aware of the risks and share information on scrap tire operations.

Local fire departments, in conjunction with other State officials, should have identified risks 

and developed intervention and mitigation strategies to provide fire prevention and protection 

guidance on tire operations. Local governments should establish ordinances and require performance bonding to cover the cost of tire removal if the business goes bankrupt and abandons 

the tire product piles. Fire departments should always be aware of tire storage or recycling 

operations in their areas, and design and implement mutual aid agreements to address the risks. 

Illegal tire dumping or creation of unregulated tire piles should be stopped and corrected by the 

authorities having appropriate jurisdiction. These authorities should request support from other 

agencies, using resources such as community policing.

4. A multi-agency command post should be established on tire fire incidents so that the command-and-control system will be integrated, and authority and assignments can be effectively delegated.

Command post operations ideally should not be on the fireground, but instead, located away 

from the operations sector where it can better coordinate and support the incident. The fireground can become overwhelmed with news media and large numbers of citizen spectators, 

as well as with volunteers wishing to help extinguish these fires. The command post needs to 

coordinate the gathering of support, supplies, and resources and to oversee the security of the 

fireground and evacuation areas.

5. Tire fires are operationally demanding and technically challenging incidents that will 

involve all aspects of the ICS. Key functions include:

Staff functions

•	 Safety, public information, and liaison with private and public agencies will be crucial for

coordination of non-fire-department agencies and contractors.

Operational functions

•	 Rapid Intervention Teams for the protection of excavation equipment operators and other

fireground units.

•	 Extinguishment team to douse the burning tire product extracted from the pile by the excavator and moved by the front-end loader.

•	 Class B foam team(s) to protect and prevent run-off oil ignitions.

•	 Emergency medical services on-site.

•	 Hazmat team to monitor personnel exposures, physical effects.
USFA-TR-093/December 1998 33

Planning functions

•	 Coordination of tire pile separation

•	 Containment berm construction

•	 Extinguishment strategy

•	 Overhaul and burn product disposal

•	 Contingencies planning for variables as change of wind and weather, or oil ignition

•	 Consultation with technical specialists

•	 Resource research and service and support logistics

•	 Personnel support for around-the-clock operations

•	 Mutual aid for other emergency incidents

•	 Supplies including food, fuel, and rehabilitation supplies

•	 Replacement equipment

Finance functions

•	 Timely procurement of contractors and special equipment resources

•	 Coordination of local, State, and Federal government expense reimbursements

•	 Incident documentation and accounting

•	 Cost recoupment efforts from owner operators

6. The availability of the appropriate number and type of excavation equipment is absolutely 

essential for these fires. Excavation equipment must be large enough to do the job effectively and used within the manufacturer’s design limits by skilled operators.

The most desirable equipment for tire product fires are large excavators, bulldozers, and frontend loaders. These machines should be tracked units rather than tire units for increased traction 

in the muddy conditions typical of tire fires operations. Each of these machines has a specific 

and necessary purpose. The excavator has the long boom and bucket to pull the unburned pile 

away from the fire, or reach into the burning tire product and pull the burning material out of 

deep-seated piles so they can be doused. Bulldozers are needed to push tire product away from 

the fire to provide exposure separation. The dozers are also useful in constructing earthen berms 

and containment ponds. Front-end loaders are needed to move tire product from the excavator 

to the submergence or burial area and to load transport trucks. The loaders are also used to load 

and move earth for berms and burying tires.

7. Tire product fires generally will be protracted and the sequence of fire operations is 

important. The priority of actions should be rescue/evacuation, exposure, confinement, 

extinguishment, and overhaul. Exposure and confinement should be completed before 

attempting extinguishment.

•	 Rescue/evacuation. Rescue problems are uncommon, but the toxic smoke plume may warrant 

evacuation of area residents. Wider evacuation may become necessary if the weather or wind 

direction changes.
34 U.S. Fire Administration/Technical Report Series

•	 Exposures. Unless the tire fire is small and likely to be extinguished in the incipient, the separation of unburned tires must be accomplished to limit the full load.

•	 Containment. The next priority is to contain the fire to the burning pile(s) and to contain the 

run-off oil. Proper containment tactics will prevent burning run-off oil to extend the fire. 

Attempts to flood the fire with water before containment will cause increased run-off 

and environmental damage.

•	 Extinguishment. After the fire and runoff containment has been accomplished the fire may be 

allowed to burn to a manageable size until the burning material can be excavated, doused, 

and then submerged or buried for extinguishment.

•	 Overhaul. This operation ensure the fire is completely out. Because of the tendency of tire fires 

to retain heat and re-ignite, the burned tire product should be cooled below 200 degrees 

Fahrenheit before transport to a landfill or other location.

8. Class B foams should be used for preventing run-off oil fires and extinguishing oil fires. 

Class A foams may be effective if applied early in the incipient stage of the fire.

Class B foams are effective for flammable liquid fuels like run-off tire oil and should be used in 

conjunction with tire pile fire operations. Class B foams should generally not be used on burning tires because they are relatively ineffective on deep-seated class A fires.

Class A foams and wetting agents can be used to extinguish burning tires with success when 

the fire is in the ignition and propagation stages. This opportunity is most likely to occur when 

there are no exposure piles, the burning pile is contained, and class A foams are readily available. 

Most large tire product fires are in the compression or equilibrium and pyrolysis stages before 

fire operations can begin extinguishment. Class A foams and wetting agents are no more successful than water at extinguishing large tire fires in these later stages. However, wetting agents 

suggest some advantages over water if the pile is pulled apart and doused, prior to exiting.

9. Officials should be alert for the warning signs and profiles of future tire fires and be proactive in working with fire investigation and arson units to prevent major incidents.

The potential warning signs of future tire pile fires are:

•	 The operation was allowed to begin non-code-compliant.

•	 The tire operation changes from tire recycling to scrap-tire storage.

•	 The State tire fee disposal program is not invoiced, therefore is not audited to ensure proper

tire disposal and to identify unethical operations.

•	 The business owner resists compliance with code and fire safety practices.

•	 The business owner files for bankruptcy.

•	 The property owner and/or government pursues court action against the tire operation.

When these warning signs are apparent, fire and arson units should help develop and devise 

preemptive strategies such as increased facility security and visible police patrols.
USFA-TR-093/December 1998 35

10. Tire fires are extremely costly and all laws and legal avenues of expense reimbursement 

should be researched before a fire.

Major tire pile fires will likely require resources and funding from other sources. Most of the 

funds available are from State EPAs in conjunction with the Federal EPA and FEMA. For incidents 

of the magnitude that pose a threat to the environment, funding may be available through the 

SARA. These funds must be coordinated through the Federal government. Other methods for 

recouping funds may include researching all State and local laws that allow replacement of 

equipment and supplies. Such laws may permit the cost of emergency operations to be passed 

on to property owners through fines and restitution. Because not all expenses may be reimbursed, it may be advantageous and necessary to pursue legal action against responsible parties. 

Performance bonding is one important precaution that can be taken to reduce local government 

costs.

11. Safety coordination of the overall incident should be the responsibility of the fire 

department.

While the fire department usually operates under various safety requirements and standards, as 

well as OSHA and EPA regulations, other agency personnel may have limited experience operating under these requirements. The fire department safety officer should take the lead to ensure 

that all private and public personnel work in accordance with fire department safety standards. 

The fire department may need to review safe use procedures for personal protection equipment 

for excavation equipment operators. Personnel accountability should be stressed.
36 U.S. Fire Administration/Technical Report Series

Bi

Baker, Jeff. “Tribe Fears Fire in Black Hills.” The Arizona Republic, May 26, 1997

Brown, Ken. Garfield Colorado Falling Springs Site Remediation Project Report. October 23, 1996. http://www.

wsdot.wagov/transaid/tirefir4.htm

Caterpillar, Inc. Caterpillar Performance Handbook Ed. 26, Peoria, Illinois: Caterpillar, Inc., October 1995.

Duncan, Samuel. Evaluation of NDI Compressed Air Foam Systems (CAFS) Applied as a Retrofit. Warren, Michigan: 

U.S. Army Tank-Automotive Command Research, Development and Engineering, August 1994. 

#13606

International Association of Fire Chiefs and The Scrap Tire Management Council. Guidelines For Prevention

and Management of Scrap Tire Fires. Washington, DC

Hasegawz, H.K., and Staggs, K.J. “Large-scale Tests to Evaluate the Effectiveness of Various Fire 

Suppression Agents on Burning Stacked Tires (Draft Report).” Livermore, California: Lawrence 

Livermore National Laboratory, October 5, 1990.

King, Alan P.E. Shredded Rubber Tire Fills On Fire. Washington State Department of Transportation, 

September 1996. www/wsdot.wagov/transaid/fir4.htm

National Fire Protection Association. Standard for Storage of RubberTires NFPA 231D. Quincy, Mass: NFPA, 

1989

Noll, Gregory, Hildebrand, Michael, and Yvorra, James. Hazardous Materials: Managing The Incident, 2nd ed. 

Fire Prevention Publications, Stillwater, Oklahoma, 1995

Scrap Tire Management Council. Questions and Answers about Scrap Tire Management. Washington, DC: Scrap 

Tire Management Council, 1995 

Department of the Army Belvoir Research, Development and Engineering Center, Report of Class A Foam 

Tests (Underwriters Laboratories Project 93NK24320). February 1994. Northbrook, Illinois Underwriters 

Laboratories.

Routley, Gordon, and Boston Fire Department. Compressed Air Foam for Structural Fire Fighting: A Field Test 

(United States Fire Administration Technical Report Series). Boston: United States Fire Administration, 1993.

Roy, Darmstadt, Benallal, Chaala, Schwerdtfeger. “Vacuum Pyrolysis of Used Tires” Universite’ Laval, 

Quebec Canada, May 1995.

Scrap Tire Management Council. ScrapTire Use/Disposal Study. Washington, DC: Scrap Tire Management 

Council: February 1995.

Stern, Jeff, and Routley, Gordon. Class A Foam For Structural Firefighting (U.S. Fire Administration Technical Report 

Series), 1996.

“Stubborn Fires of Junk Tires Under Control” New York Times, August 3, 1997. Scrap Tire Management 

Council, Technical Briefings of Scrap Tire Utilization Technologies. Washington, DC: Scrap Tire Management 

Council, 1992.

“Tire fires ends man’s garden dream,” Frederick Post (Frederick, Maryland), March 14, 1997. 

Wilk, Damion. “On The Job Washington, DC”. Firehouse Magazine, February 1997, 30-33.
37

APPENDICES

Appendix A Large-Scale Test to Evaluate the Effectiveness of Various Fire Suppression Agents 

on Burning Stacked Tires

Appendix B Reimbursement to Local Governments for Emergency Response to Hazmat 

Releases

Appendix C House of Representatives Bill 104 Tire Pile Improvement and Remediation 

Effectiveness Act.

Appendix D Pennsylvania Waste Tire Remediation Act 190
38

APPENDIX A

Large-Scale Test to Evaluate the Effectiveness of Various 

Fire Suppression Agents on Burning Stacked Tires

by H.K. Hasegawz and K.J. Staggs

SUMMARY OF TEST RESULTS

Oxford Energy Tire Fires

Test TFFT# Product Concentration 

(%)

Extinguished? 

No. of 

Applications

Weight 

Loss (lbs.) Comments

9 Ansulite 3.0 Yes: 1 5.29 Allowed to sit for 15 min. to ensure it 

was out.

12 Ansulite Test 2 3.0 Yes: 1 5.51 Allowed to sit for 15 min. to ensure it 

was out.

5 VoeFoam 6.0 Yes: 2 6.17 5 min. interval before second 

application

13 VoeFoam Test 2 0.6 No 5.1 Put out with sprinklers.

6 Silver 0.3 Yes: 3 5.07 May have been out before the 3rd. 

application.

14 Silver Test 2 0.6 No 9.04 Fire appeared to be out, but after 4:00 

minutes (3rd application)

11 Pine Tar 6.0 Yes: 3 6.62 Flame height down to 8 inches after 

1st. application.

3 Pyrocap 6.0 Yes: 3 6.61 Flame height down to 1 inch after 1st. 

application.

1 Firetrol 0.3 Yes: 3 8.16 Flame height 3 inches after 1st. 

application.

15 Firetrol Test 2 0.6 Yes: 3 6.82 Out at end of 3rd. application.

2 Phinex+ 3.0 Yes: 3 6.4 Flame height 3 inches after 1st. 

application.

4 3M AFFF 6.0 No 7.5 1 inch flames after 3rd. application.

10 Wetting Agent 0.1 No 15.21 1 inch flames after 3rd. application.

7 Flouropolidol 3.0 No 18.3 Intense 2 inch flames after 3rd. 

application.

8 Polyfoam 8.0 No 16.32 3 inch flames after 3rd. application.
39

APPENDIX b

Reimbursement to Local Governments for Emergency 

Response to Hazmat Releases
40 U.S. Fire Administration/Technical Report Series

Appendix B (continued)
USFA-TR-093/December 1998 41

Appendix B (continued)
42 U.S. Fire Administration/Technical Report Series

Appendix B (continued)
USFA-TR-093/December 1998 43

Appendix B (continued)
44 U.S. Fire Administration/Technical Report Series

Appendix B (continued)
USFA-TR-093/December 1998 45

Appendix B (continued)
46

APPENDIX C

House of Representatives Bill 104 Tire Pile Improvement 

and Remediation Effectiveness Act.
USFA-TR-093/December 1998 47

Appendix C (continued)
48

APPENDIX D

Pennsylvania Waste Tire Remediation Act 190
USFA-TR-093/December 1998 49

Appendix D (continued)