HM Fire Service Inspectorate: Assessing the Effectiveness of Inspection Activity

27. HMFSI has a process for following up on the SFRS's actions from our thematic inspection reports and for our LAI reports.

28. For the purpose of this inspection we selected some recommendations and comments from inspection reports to investigate. These are recommendations that are contained in reports^[3] that were issued prior to the introduction of our follow-up arrangements.

29. We are mindful that some of our recommendations can be time-limited in so far as they are relevant at the time of issue, but issues can change and the relevance, importance and currency of recommendations can change, particularly given the early evolution of the SFRS. We have taken this into account in selecting which recommendations to follow-up.

30. The sample of recommendations we selected for investigation relate to the following issues:

• the development of the Retained Duty System (RDS)
• pre-planning for flooding
• reducing unwanted fire alarm signals (UFAS)
• fire safety enforcement

31. RDS and UFAS were selected as important areas where there had been little movement because actions being taken in response to our recommendations are ongoing or long-term in nature, but where we hoped to keep a continuing focus on the subject.

32. We have listed these recommendations and considerations in tables 2 to 5 and after each table we provide a narrative.

The development of the RDS

33. It has been generally accepted that there are challenges to the viability of the RDS and that it is difficult to address these challenges and introduce change. Problems pre-date the creation of the SFRS and are not unique to Scotland. Recommendations on the development of the SFRS RDS have appeared in three of our reports as shown in table 2.

34. The SFRS fire cover model provides for RDS-crewed fire appliances to be available 24 hours a day, 7 days a week. In practice this was not being universally achieved. During the course of our inspection field visits, we were repeatedly advised by local staff of the fragility of many RDS (and Volunteer Duty System (VDS) crewed) appliances. Although there were examples of strong, viable units, many RDS units across the country had long‑term and growing difficulties in attracting and retaining staff and providing operational fire cover for 24 hours a day, 7 days a week.

35. Part of the background to our recommendations is that it was our view that protocols for station availability and appliance response were unnecessarily restrictive. Staff are required to book 'unavailable', potentially making a station or appliance unavailable, if they are more than six to eight minutes from the fire station. We suggested that a new category of 'delayed availability' could be introduced for staff and stations, to recognise that it may take an extended time to assemble a crew at some times of the day, but for many locations it may still be much quicker to do so than to wait for an appliance from another fire station to attend.

36. Another example of prescriptive rules is that staff who required only a short period of time off, for example a few hours, were required to make themselves unavailable for a longer period of time.

37. Additionally, we believe there was scope for the SFRS to consider how personnel from neighbouring fire stations might be aggregated to form a full crew and maintain a response capability, even when individually those stations are unable to muster a full crew. We were aware of a pilot that had been run on Islay where personnel from more than one station would be mobilised if there was insufficient numbers of personnel to crew an appliance at the fire station closest to the incident.

38. However, these are only specific examples of potential change and our recommendations were made to encourage and assist the Service with the review and on bringing about fundamental and innovative change and flexibility to the RDS.

39. The SFRS created an action plan for all the recommendations in the 'Equal Access' report. The action plan acknowledged the problem with RDS fire cover and proposed that the RDS and Volunteer project (which was then in place) would consider standardising and consolidating a sustainable RDS and Volunteer service in the short to medium-term, and to explore future options for medium to longer-term which will be visionary, bold and innovative. Progress on the action plan was reported to the Audit and Risk Assurance Committee (ARAC) meeting on a 6 monthly frequency commencing on 16 September 2014. The action plan proposed examination and review of personnel response times, recruitment, selection, contracts, promotion, annual leave, personnel development, integration opportunities, and greater resilience to appliance availability.

40. The SFRS action points relevant to this recommendation were signed off as complete in 2016. Although the actions were annotated as complete, the Service was unable to complete some actions at that time and those actions then became part of a further wider, later developed project, the Service Delivery Model Programme Framework.

41. The recommendation in the 'Planning and Defining' report was reported at ARAC as already complete with work ongoing as part of other workstreams.

42. The recommendation in the Western Isles LAI report is a national issue in a local report. We have not been able to find anything recorded about actions taken in relation to this recommendation. Though the Service identifies that it now has a procedure to consider such national issues referred to in LAI reports.

43. A SFRS review of fire and rescue provision commenced in April 2014 with the aim of providing an accurate picture of fire station locations to identify obvious gaps, duplication or over-provision in service delivery, to inform a standard approach to all areas of emergency response.

44. More recently, in June 2019, the Service has created a Service Delivery Model Programme Framework, the work on this is ongoing which contains a RDS/VDS Strategy project. The declared purpose of this RDS/VDS Strategy project is to maximise the use and associated benefits of on-call firefighters, ensuring the provision of an appropriate balance of prevention and protection and emergency response services to communities across Scotland.

45. The project is being undertaken in three phases, phase one 'Research' was due to conclude in October 2019 (this was later changed to Q3 December 2019, with a report, taken in private, to the Transformation and Major Projects Committee in February 2020). The phase 1 report was considered in February 2020. SFRS Board Standing Orders enable the Board and its committees to discuss matters in private. HMFSI understands the need to be able to do this at times, however, our ability to track progress on actions when they are addressed in private is obviously restricted.

46. The RDS/VDS project will seek to create an overarching strategy to identify other initiatives and improvements that can be implemented to further support and strengthen the Retained and Volunteer duty systems. It is anticipated that the focus will be on but not limited to recruitment, retention, response models, station duties and enhanced engagement.

47. One change that has been implemented by the Service is the creation of the role of a RVDS support Watch Commander. In January 2019, SFRS appointed 18 staff to these posts to act as support officer for RDS and VDS fire stations. There has been a further appointment process which should lead to the appointment of a further 18 posts, at the time of writing a third phase is due to deliver 18 more posts in January 2021 in a number of areas across the country, giving a total of 54 posts. The posts are being allocated to geographic clusters of fire stations, with the type of support provided varying across the country as dictated by the LSOs.

48. The Service's assessment^[4] of these posts for the period 14 January to 30 June 2019 was that there were 254 instances of where appliances were enabled to turnout as a result of the post. During that period 5,668 hours of appliance availability were provided by these support Watch Commanders. Our limited assessment of these posts from an LAI perspective has been positive.

49. The positive impact of these officers goes beyond the simple increase of appliance availability into providing wider areas of support, such as administrative functions, gathering of risk data, training, etc. The creation of these posts has resulted in an increase in the establishment of the Service and therefore the employee and additional associated costs. The Service, however anticipates that the recruitment of these posts will be offset by the future rebalancing of existing wholetime resources, but that would be subject to the successful delivery of other Transformation projects.

50. The SFRS had the additional challenge of addressing different conditions of service between the predecessor organisations. But other than some standardisation and the creation of support posts, the position with the RDS in 2020 is not much different from when we issued our reports. While there has been a previous Service review and an ongoing review, there have been no fundamental changes to RDS conditions or to fire cover modelling affecting the RDS.

51. Our recommendations have offered external influence to highlight issues but cannot be seen as having brought about significant change. We do acknowledge the interdependency with other resource allocation issues and the difficulty in addressing the challenges that exist with RDS availability.

52. The issues surrounding the RDS are complex and connected to wider problems such as recruitment, retention and training, which have a link to crewing and availability. Through the earlier studies conducted, the Service has an awareness of the problems that need resolving. However, to an outside observer there appears to be inertia in implementing change given the Service's understanding of the problems that exist. This may be linked to ongoing negotiations involving changes to national conditions of service and national employment arrangements. We see the introduction of the RVDS support Watch Commanders as a welcome positive step. Given the relative importance of RDS and Volunteer firefighters, crewing almost 80% of SFRS fire stations, we continue to support efforts to create duty systems that can flexibly recognise the important role played by these firefighters in providing a service to their communities, while recognising that what will be a good solution for one community might not be appropriate for another.

Pre-planning for flooding

53. We commenced the inspection in May 2015. The purpose was to consider the way in which the SFRS had planned to carry out its functions under the Fire (Additional Function) (Scotland) Order 2005 in relation to serious flooding and, in particular in relation to our first recommendation above, we sought to establish, among other things:

How it has defined the limits of its responsibilities under legislation and secured a common understanding of them among other relevant agencies, including the definition of 'serious flooding'.

54. At the time of our fieldwork the SFRS was working on the development of policy and procedures for flood response, which was to be completed by the end of 2015.

55. The initial SFRS action plan for this report was presented to the ARAC meeting in June 2016 in which it was detailed that the Service intended to carry out two actions to address this recommendation:

• to finalise the SOP 'Water Rescue Incidents', (which was in its consultation phase); and
• to carry out Water Rescue Training.

56. One item in the SFRS action plan, in response to our second recommendation in table 3, was marked as 'no longer pursuing', in relation to training, because the Maritime and Coastguard Agency wouldn't sign a Memorandum of Understanding (MOU). It is not clear to us now what the relevance of the proposed MOU was in response to our recommendation. However, we believe that this highlights that HMFSI missed an opportunity at the time to seek clarification from SFRS on its proposed course of action as it stated it was no longer pursuing. Had we done so, we would have been able to assess whether the SFRS had misinterpreted the intention of our recommendation or not, and to consider the appropriateness of the SFRS's intention to not pursue action.

57. A closure report of the actions taken for all the recommendations in the report was considered at the meeting of 3 July 2018. Although the action to carry out water rescue training was marked as complete, not all water rescue stations had concluded the training of personnel and it was reported that training was still on-going at four remaining fire stations.

58. As we have referenced earlier in this report, in other action plans, actions were marked as complete when in fact the action had been passed to another workstream to take forward. The new arrangements for monitoring action plans implemented by ARAC, mentioned earlier, allow for the recording of an action as being 'transferred', where it is managed and scrutinised through another forum, such as the Programme Office. This should ensure that a complete and auditable trail exists for our report recommendations.

Reducing UFAS

59. The SFRS attends a large number of calls which turn out to be false alarms. SFRS incident statistics show that in 2019/20, the Service attended a total of 91,971 incidents and that 57.8% (53,122) of these incidents were false alarms. A substantial proportion of these false alarm calls are designated by the Service as UFAS calls. SFRS performance reporting indicates attendance at 29,171 UFAS calls in 2019/2020. This represents around 32% of all calls attended by the Service.

60. Our report was issued at a time when the Service had standardised its UFAS policy, a change which in some cases, introduced an increased PDA to suspected UFAS calls in some parts of Scotland. At the time of the inspection we felt that although the intent of the SFRS policy was clear, in its aim to provide a single national framework to target demand reduction, we found it difficult to understand the detail as we felt it was overly complex. Through our interviews we found that staff were interpreting the policy differently.

61. One detail that was identified was that the policy allowed a reduction in attendance to an AFA in some circumstances, but not where a call was received through an Alarm Receiving Centre (ARC). HMFSI believed there was a 'conflict of logic' between two elements of the Service policy. An automatic fire alarm call received via an ARC (or auto-dialler) attracted a 'full fire PDA'; and a call received via a person calling from a premises where an automatic alarm has actuated, who cannot confirm whether or not there is actually a fire, results in the PDA with a reduction of one fire appliance being mobilised. These are essentially the same circumstances in both examples, but they were treated differently in the level of response.

62. However the recommendations contained a more general and fundamental challenge to SFRS policy. National reports had been published which identified the potential for 'Variable attendance by Time and Risk', where response is varied by time of day, and building and occupancy risk; and Call Challenge, where response is assumed to be delayed while the call is verified. There was no evidence of this national work having influenced SFRS policy.

63. There were also no targets set for the reduction in calls or 'blue light' journeys. The SFRS reported on the number of UFAS calls it responded to, but at that time did not set reduction targets for them. The Service did not report on the number of 'blue light' journeys undertaken as a result of responding to UFAS calls: this information could only be extracted manually, taking significant time to do so.

64. The action plan in response to our recommendations reported that the SFRS Prevention and Protection Directorate had carried out a review of its UFAS policy during 2015. The review included awareness and understanding of its policy intentions and direction. The findings of the review were then included in a wider action plan covering many areas of UFAS in the Service. The Directorate worked with Service Delivery and Response and Resilience to progress arrangements to automatically reduce the number of appliances sent to identified premises types on receipt of an automatic alarm to the SFRS.

65. The progress of the SFRS action plan was reported to the SDC and all recommendations signed off as complete in 2018.

66. A further paper was presented to the SDC meeting of 4 December 2018. This paper set out to provide an update on UFAS response strategy currently under consideration which is predicated on time and risk factors. The paper stated that 'Following the submission of a UFAS response options paper to the Board in March 2018, it has been agreed that the SFRS should adopt a time and risk response model to AFA calls from non-domestic premises.' The paper concluded with next steps, and set out that 'a further paper will be produced detailing an implementation strategy alongside timescales and any impact or benefits on service delivery.' The work and research to provide a response based on risk and time was on-going and not complete.

67. In February 2018, a 15% reduction over a three year period was set as a Service wide target. According to the closure report on 13 September 2018, the Service do not report on the number of 'blue light' journeys undertaken as a result of responding to UFAS calls. This work has been highlighted as an area to be explored as part of the Command Control Futures project, which is implementing a new single system across the three SFRS control rooms. This is done with a view to simplifying the process by which individual 'blue light' journeys can be recorded.

68. It is still the case that the Service doesn't report the number of 'blue light' journeys and the counting of journeys isn't included in the Performance Management Framework.

69. At a meeting of the SDC on 12 March 2020, a paper was brought forward outlining plans for reducing UFAS demand. The plans provided the basis of a project, upon which the following priorities would be delivered:

• mainstreaming best practice UFAS initiatives across the country; and
• consolidating the SFRS's overall approach to managing UFAS.

70. In consolidating the SFRS's overall approach to managing UFAS, the Prevention and Protection function committed to conducting a UFAS Stocktake Review – a detailed examination of the effectiveness of the SFRS's UFAS arrangements, and a key action within the SFRS's Annual Operating Plan 2020/21.

71. At a meeting of the SLT on 23 June 2020, a report outlining the findings and recommendations of the UFAS Stocktake Review were presented and subsequently approved by the SLT. A Board Strategy Day was held on 30 July 2020 where the highlights of the Review and next steps were set out.

72. A total of 20 recommendations were proposed by the UFAS Working Group as part of the Stocktake Review, subdivided into 'Improvement', 'Change' and 'Implementing Change'. The Stocktake report highlights that, of themselves, the 13 recommendations for improvement are unlikely to address the longer-term challenges of tackling UFAS demand.

73. The SLT approved the recommendations and gave the UFAS Working Group direction to develop a plan that prioritised implementing the recommendations for improvement over the short-term and in parallel with that, take forward the recommendations for change by starting to evaluate potential policy changes.

74. Although work on this is continuing, in May 2020, influenced by the impact of the Covid-19 pandemic, the Service announced that it was changing its response at AFA actuations to a single pumping appliance, with the exception of sleeping accommodation and other specific high-risk premises which will continue to receive either a full or appropriately modified PDA. Premises such as hospitals and care homes will not see any change, as will premises that already have a single pump strategy under the previous policy.

75. The Service intends to evaluate the outcome of the overall impact of this change of policy as a result of the pandemic. The results of this evaluation would then be fed into the UFAS Stocktake Review Project mentioned above. We consider that the implementation, in May 2020, of the revised mobilisation policy should provide a sizable data source to analyse and reach robust conclusions which ultimately could result in a long-term decline in the number of UFAS mobilisations.

76. The HMFSI recommendations comprised two specific and two general recommendations. While general recommendations can be useful at times to allow the Service flexibility in the action it may take to respond to a recommendation, there may be times when flexibility in response may not be appropriate.

77. Although HMFSI has limited knowledge of the detailed work of the Stocktake review of UFAS, we are supportive of activity taken to reduce the negative impact of UFAS calls on the Service. We would encourage the Service to use the opportunity presented by the response to the pandemic and, using this experience, implement changes, such as those identified in the Stocktake review, that will lead to long-term and sustainable reductions in the number of UFAS calls and mobilisations.

Fire safety enforcement

Conditions of service

78. Two of our reports contained a recommendation on the increased use of Auditing Officer posts within fire safety enforcement. These reports were issued by different Chief Inspectors.

79. With regard to the Planning and Defining report, the Service had in 2013, a Prevention and Protection Directorate Working Structure which outlined the number of Fire Safety Enforcement Officers (FSEOs) and Auditing Officers (AOs) that were notionally allocated to each LSO area. The split between FSEOs and AOs was based on legacy FRS arrangements. The Service then developed an options paper with options to blend these roles to varying percentages of balance. Work commenced to move towards the blended structure. Local structures were to be further reviewed to ensure resources were in place to match available budgets.

80. AOs made up 17% of FSE staff as at May 2017, the majority of enforcement staff being uniformed FSEOs, working to 'Grey Book' conditions of service, and Auditing Officers working to 'Green Book'. This was the position at the time of our fieldwork for the FSE report.

81. Although the Service accepted all the FSE report recommendations during our informal consultation, the Service subsequently adopted a position that it would not have a programme for converting FSEO posts to AO posts. Career progression and Incident Command resourcing were seen as factors influencing Service policy. However the Service did support the further blend of FSEOs and AOs in response to recruitment challenges.

Other issues

82. Our FSE report on the inspection of fire safety enforcement contained a number of other recommendations to the Service. We have selected two of these other recommendations for follow-up, though one of the selected recommendations has four separate elements to it. These recommendations refer to increased transparency, communication and quality.

83. An action plan for the FSE inspection was first presented to the SDC meeting of 3 July 2018.

Transparency

84. There was no information or guidance on the SFRS website about the fire safety audit process even though it is a requirement of the SCOP to publish risk methodology and risk ratings (our report made other comments on risk methodology and risk ratings, which are not considered here).

85. The Service undertook to develop a webpage with a specific information page to dutyholders within the "For Businesses" section on how enforcement activities are delivered.

86. Standardised templates were created for Local Enforcement Delivery Plans laying out the process and methodology for fire safety audits. All plans to be accessible via the "For Businesses" section on the SFRS website.

87. Guidance on the SFRS audit process has been incorporated into the Local Enforcement Delivery Plans for LSO Areas which will be published on the SFRS internet site in due course. Further guidance is also provided in a pre-audit letter sent to dutyholders at the time an audit is confirmed.

88. The Prevention and Protection Directorate was unable to directly access the SFRS website to make quick changes and relies on SFRS communications staff to amend the website. A review of the business page for fire safety is being undertaken centrally which will incorporate all appropriate and linked documents alongside the Local Enforcement Delivery Plans.

89. We have seen local enforcement plans during our LAIs which explain the LSO area strategy for targeting audits, which generally reflect the SFRS Enforcement Framework. There is no information on the risk assessment methodology and risk ratings.

90. The Service's action plan considers the fire safety audit process and priorities but does not consider implementing the recommendation about risk assessment methodology and risk ratings.

91. It is still the position that there is nothing relevant on the SFRS website explaining risk assessment methodology and ratings. And the Service reports that it is involved in national developments that may see changes to risk rating systems.

Communication quality

92. Although we had come across some evidence of excellent communication, the general standard was below this. For example, it was commonplace for letters sent to dutyholders to contain general recommendations which do not relate to any deficiency, prescriptive requirements with no accompanying descriptive explanation or rationale for the action; and the distinction between mandatory and non-mandatory was blurred.

93. The SFRS has recently changed its standard paragraphs which are used by enforcement staff in drafting reports and letters to dutyholders. However, we have received negative comments, from enforcement personnel, during LAI's that the revised paragraphs are poor.

Targets

94. At the time of inspection there was an emphasis on numbers with a personal audit target of 132 audits per person per year.

95. The Directorate stated it has continued as part of its training events and quality assurance processes, to promote detail and quality whilst undertaking audits and demonstrate full reasoning for comments made. The Directorate also stated it has little concern regarding this recommendation, however it will look to improve upon performance in conjunction with the Fire Safety Enforcement Policy Framework and Local Enforcement Delivery Plans. The SFRS comments in its action plan about targets being too onerous and quality of the completion of audit paperwork appear to miss the point of the recommendation 5 above.