Months before a massive fire swept through Baltimore’s Camp Small last year, a blaze that took days and multiple fire companies to extinguish, Baltimore was warned by state inspectors of a fire hazard on the site as well as conditions that could hamper an emergency response.

Maryland Department of the Environment records show that the city’s tree waste and recycling facility was cited in August and told to bar all dumping at its Old Cold Spring Lane site after repeated inspections found the facility was accepting fresh wood waste after it had been ordered not to.

The complaint, which is a public document, followed several inspection reports that found the facility was failing to process material within a year as required by state law. The complaint also notes that runoff water from Camp Small was likely leaching into a nearby wetland, a violation of state environmental protections.

Inspection reports dating back to at least 2023 also include warnings of a potential fire hazard at Camp Small, although the issues raised did not appear to have sparked or exacerbated December’s fire.

During multiple visits, inspectors found fire lanes in and around the site blocked or partially blocked due to fallen logs, stored equipment and other debris. Lanes were found to be blocked in October, just two months before the fire.

In May 2023, a state inspector found the site’s mulch pile registered between 140 and 164 degrees, making it potentially combustible. As mulch decomposes, it creates heat, making large quantities hazardous if not turned over for cooling.

Whipped by wind and fueled by acres of logs stacked as high as 15 feet, the Camp Small fire was one of the city’s largest in recent memory. Flames shooting dozens of feet into the air cast an orange glow visible for miles around the site, which is nestled along Interstate 83, and temporarily prompted the closure of the highway. City firefighters, with the help of crews from several surrounding counties, battled the blaze for days and did not officially declare it extinguished until three days after it started.

Initially feared lost, the city’s nationally heralded tree recycling program on the site was largely spared by the blaze. The small operation, which sells mulch, firewood, lumber and even some custom furniture, relies on a workshop full of expensive equipment and a stash of higher-value wood, both of which were untouched by the fire.

An investigation into the fire, completed in February, found the cause to be inconclusive. Investigators found no proof of malicious activity, said John Marsh, spokesman for the city Fire Department. However, the conditions at Camp Small after the fire made it difficult to investigate, he said.

“We have to understand the scale of the event, how big it was versus the thousands of gallons of water dropped on it,” Marsh said. “Now take excavators and heavy machinery and agitate the whole place; Talk about a crime scene that’s been compromised.”

Marsh said there were no logs or other debris blocking access for emergency crews at the time of the fire. The investigative report, obtained by The Baltimore Banner, notes that strong winds and intense flames made access to interior log piles “impossible.”

“Nothing impeded our progress,” Marsh said. “It was a challenge just by the design of the roads and where the fire was located.”

Witness accounts indicate that the site’s mulch pile was not involved in the fire. Shaun Preston, Camp Small’s yardmaster, told The Banner in December that he climbed atop the massive pile to get a better look at the blaze, which was then a small fire in the scrub beyond the site’s boundary. The fire, which consumed about two-thirds of the logs at Camp Small, did not burn the pile.

Alex Silverman, a spokesperson for the city’s Department of Recreation and Parks, the agency overseeing Camp Small, said the violations reported at the site are not a matter the city takes lightly. A cleanup operation for the facility was underway before the December fire, Silverman said. City records show a contractor was hired in August 2023 to remove logs and debris from the site, and the contract tripled in price in October 2024 as more work was requested.

Camp Small’s secondary fire lane was temporarily blocked, Silverman confirmed, due to dumping on the site. The city’s forestry division has been working to secure the site against illegal dumping and will train city staff on where to properly dispose of materials, she said.

Silverman noted that Camp Small’s mulch pile was not the source of the December blaze and said the city contracts to remove up to 7,000 tons of mulch annually. Recreation and Parks has been offering mulch giveaways to reduce the supply, and turning the mulch to manage the temperature, she said.

Mark Cochrane, a professor at the University of Maryland Center for Environmental Science, said space at a site like Camp Small could become very limited if the facility continues to accept wood waste but isn’t processing it in a timely fashion.

“You need access to ideally get to where the fire is and then be able to attack it,” Cochrane said. “If you can’t get to it, then it turns into one giant pile and in that case, it’s a much harder fire to fight.”

How the material is stored also matters, Cochrane said. Logs are difficult to burn, but if brush or smaller wood waste is stored nearby, that can increase a fire hazard, he said.

Camp Small’s hot mulch did not appear to reach temperatures needed to self-combust, but when stored in piles as high as 30 feet, as Camp Small has maintained in the past, it can be flammable under the right circumstances, Cochrane said. Mulch fires are smoky and difficult to extinguish, he said.

While the hazardous conditions cited didn’t appear to contribute to the fire, Camp Small remains in violation of state law. An inspection in January noted that the complaint filed against the site in August remained open and that the accumulation of logs on the property constituted open dumping.

“All natural wood waste must continue to be removed from the property,” the inspector wrote, echoing an order that has been made repeatedly by state officials since early 2024.

Silverman said the city has diverted wood waste dumping to locations in Druid Hill Park and Leakin Park since the fall due to delays in Camp Small’s processing material. She did not answer a question about why some waste was still reportedly dumped at Camp Small. No deliveries have been made to Camp Small since the fire other than materials needed to produce other products, she said.

“Addressing these violations to the fullest extent, which we intend to do, takes time and significant resources,” Silverman said. “The goal is to remove all excess material, which exceeded 30,000 tons before the fire.”

Cochrane said the fire presents an opportunity for Camp Small to get its site in better condition.

“I’m very supportive of what they’re doing there. That’s great that they’re recycling,” he said. “But it has to be managed.”

Correction: This article has been updated to correct references to Alex Silverman's gender.