Using waste tyres in escape ladders in water storage reservoirs

The Environment Agency for England has issued a new regulatory position statement (RPS 139) applies to businesses who to use waste tyres in escape ladders in water storage reservoirs.

This RPS will have limited application as it may only impact upon companies within the water sector but will have wider application for businesses with stocks of waste tyres.

RPS 139 Conditions
You must:

  1. have written confirmation from the Environment Agency that you can use waste tyres in this way
  2. make sure the tyres in the ladder are at least 10 metres apart
  3. store the tyres with a 10 metre fire break between piles
  4. already have an abstraction licence for the reservoir
  5. already have planning permission

You must not:

  • use more than 1,000 tyres
  • store more than 500 tyres in a pile
  • bring tyres to the site before the project starts
  • store the tyres for more than 3 months before they’re used

You must make sure the tyres do not endanger human health or the environment. You must not:

  • cause a risk to water, air, soil, plants or animals
  • cause a nuisance through noise or odours
  • adversely affect the countryside or places of special interest

An RPS means that the Environment Agency will not normally take enforcement action against you provided:

  1. your activity meets the description set out in this RPS
  2. you comply with the conditions set out in this RPS
  3. your activity does not (and is not likely to) cause environmental pollution or harm human health

Time Expiry of RPS
RPS 139 is time-limited and is proposed to be reviewed on 31 January 2021.

A copy of the Environment Agency’s Regulatory Position Statement 139 is freely available here


  1. Review your current activities as either a waste tyre supplier or operator of a water reservoir to understand whether the Environment Agency’s RPS 139 applies to your organisation and activities as a compliance obligation.
  2. If RPS 139 applies to your activities in the use of waste tyres for use as escape ladders in water storage reservoirs follow the conditions of the RPS.
  3. Check back for any revised guidance with the Environment Agency no later than 31 January 2021
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