Inspection of the Scottish Fire and Rescue Service West Service Delivery Area

How effective is the Service in the WSDA at keeping people safe and secure?

33. To be effective the Fire and Rescue Service must identify and assess the full range of relevant and foreseeable fire and rescue risks its communities face. It should target its prevention activities to those who are at greatest risk and enable compliance with fire safety legislation through its protection work, carrying out enforcement action when required. The Scottish Fire and Rescue Service’s overall effectiveness within the WSDA is judged to be Satisfactory.

Governance

34. The FSA requires the SFRS to publish a LFRP for each Local Authority area. The plan sets out the SFRS’s priorities and objectives for that area; why they have been selected; how the SFRS intends to deliver them and (insofar as is practicable) outcomes by reference to which the SFRS’s service delivery in the local authority area can be measured. As per the SFRS Good Governance Framework 2023⁽¹⁾ these local plans link upward to the SFRS Strategic Plan and downward to Thematic Plans and ultimately into the employee Appraisal process. It is assumed that the reference to Thematic plans in the document equate loosely to Station plans and that this allows a strong planning process to run from the top of the organisation to each employee in the WSDA.

35. We examined all the LFRP in the WSDA and found that they have assessed a good range of risks and threats and were of a good quality. The plans give a description of the area, highlighting the various risks which may exist and where relevant, the actions of the SFRS and its partners to mitigate those risks. When assessing risk, each plan has considered relevant information from a broad range of internal and external sources and data. This includes data from other blue light organisations and resilience partners, historical incidents as well as social and economic information. As might be expected there were similarities in the content of the plans aligned to the LSO areas.

36. We were made aware that the SFRS has made the decision to postpone the development of new LFRPs and has directed LSOs to review all existing plans instead. It is acknowledged that this decision was taken by the SLT to ensure that the local plans were not being developed in bad faith, whilst a national consultation process with future organisational change implications at local level, was underway. That said, the local staff are acutely aware that there is a ‘business as usual’ workload that is present and needs to be planned for and delivered. The postponement of the development of new LFRPs is causing a degree of frustration at the local level and confusion as to how planning for new routine workload should be conducted.

37. We have also found evidence that some areas in the WSDA have developed Station Plans which give a more local context and direction for activities to be carried out, and in some cases targets to be achieved for local managers. However, this was not the practice in the majority of the area, where there is historic reliance on a localised seven- week planner system, albeit this planner had fallen into a degree of disuse due to not being refreshed. There also appeared to be a level of uncertainty amongst some staff regarding the processes of planning as opposed to reporting, with the latter being relied upon heavily. We found very little evidence that suggested targets and objectives borne from the LFRPs and Organisational Strategy formed part of the appraisal process as there was little appreciation of the link.

38. Much of the issues reported in the previous paragraphs were supported by our survey. In our survey we asked the question ‘Are you clear on your Department/Team’s priorities’? 84% of respondents said they were clear on their workplace priorities, very similar to the 85% reported during the ESDA survey. However, this indicated that approximately 1 in 7 employees were either not sure or unclear as to their workplace priorities. Some responses gave detail on what their priorities are, including delivering on LFRP priorities. A lesser number of respondents referred to there being unclear direction. Other reasons given for this included several priorities at any given time along with changing priorities as well as lack of communication around the priorities.

Recommendation 1: We recommend that the Service provides clarity on the expected business planning processes to be adopted in the coming years, and how they should align to the Good Governance Framework. All agreed processes should then be reinvigorated and clearly communicated across all SDAs.

Prevention and Engagement

39. Preventing incidents occurring in the first place is the most effective way of mitigating the impact of fire and other incidents. Prevention is focused on the people most at risk from fire and other hazards, such as road traffic collisions etc. Each LSO area has a LPDP, which outlines the work of the Local Authority Liaison Officer (LALO), Community Action Team (CAT) and front line firefighters that aligns with Service priorities and their local requirements. Prevention work, carried out by these staff groups seeks to improve the safety, health and wellbeing of communities leading to a reduction in incidents, injuries, and fatalities. The plan prepares staff to work efficiently and effectively to support the communities and partner agencies. The LALO and CAT are there to supplement, complement and enhance the work undertaken by frontline staff. Work undertaken is recorded on the Community Safety Engagement Tool (CSET).

40. There are many examples of personnel working to address social inequality and with vulnerable groups. We found evidence that staff in the WSDA were heavily involved with established methods such as Home Fire Safety Visits (HFSV), Post Domestic Incident Response (PDIR) visits, Vulnerable People referral pathways, seasonal Thematic Action Plans (TAP) and that these were used extensively. There was a general frustration from many staff groups with the HFSV process. There was a perception among many of those we interviewed that it was very target driven and not risk driven. Subsequently staff felt that the wrong demographic could be visited and that the scoring system didn’t necessarily allow flexibility to target the correct households within the limited capacity.

41. We found that frontline staff were generally involved with traditional engagement activity such as Bonfire Night Initiatives, Schools, Fetes, Nurseries, Gala Days etc. It was clear that much of this historic activity had been curtailed during the COVID period, that recovery was still underway, and to some extent hadn’t been reinvigorated locally. We also found that the LALOs and CATs were extremely effective with engagement as well as developing innovative initiatives and that there was generally a productive, if not sometimes over reliant, relationship from frontline crews. Some good examples of community initiatives included community gardens with apiaries, Fire Reach programmes, Partnership Approach to Water Safety (PAWS), Fire Setters Interventions, Fire Skills course in His Majesty’s Prison Barlinnie, Water Safety Campaigns on the River Clyde, Mugdock Park and Loch Lomond, Hoarding Presentations, Fall Referral Project and the Wallacetown Initiative etc.

Good Practice 1: We were very pleased to observe innovative community safety initiatives. Staff in the WSDA should ensure that safety initiatives are recognised and that ideas are shared within the rest of the SDA and across the Service.

42. We found the LALOs and CATs to be very engaged, highly motivated and generally to be well staffed. It was clear that many of the CAT had been in post for a number of years, had very good knowledge of their role and were responsible for leading or delivery of an extensive element of the WSDA engagement activity. However, some staff within these groups were disappointed as they perceived that their access to opportunities for Continuous Professional Development (CPD) and formal development to a recognised qualification were extremely limited or non-existent. They felt this was out of balance with their LALO colleagues and other sections of the SFRS staff groups. It is acknowledged that there are established communication lines between the Function and the LSO area that ensure constant liaison. However, many staff were particularly frustrated by the lack of a day to day ‘go to’ person from within the National Prevention and Protection Function to help with engagement queries.

43. We also found that there was uncertainty regarding the removal of the Chief Officer’s Fund and the LSO’s ability to deliver discretionary spend on prevention resources such as safe letter boxes and fire retardant bedding thereafter. This was a source of concern to front line crews who felt they couldn’t intervene effectively when a risk to a vulnerable person had been identified. It should be noted that this fund is not a statutory requirement, however, the Service are aware of the issues and are working with local management teams to identify funding from other sources to meet local needs. There also seemed to be a great deal of frustration with CSET and that it didn’t allow for ‘double entries’. This meant that if two groups of staff were involved in an initiative, only one could record it for performance and reporting purposes, leading to a degree of frustration and low level anxiety between staff groups. The Service has acknowledged this as a known issue and is planning to resolve it following a review of CSET.

Recommendation 2: We recommend that the Service review the impact of the Chief Officer’s fund being removed within the WSDA and that guidance is provided to all staff as to how this resourcing should be replaced.

44. A natural part of a fire prevention strategy should be an understanding of how fires start in the first place. The SFRS has a fire investigation capability with a unit based within each SDA but considered to be a national resource. Although based within the WSDA, the DACO has no direct control over the operation of the Fire Investigation Team (FIT). However, significant findings from fire investigations should influence both prevention strategies, and where appropriate, efforts to improve firefighter and community safety. There should therefore be a direct link between fire investigation outcomes, incident debriefs, and operational assurance. The Service has detailed that a Fatal Fire Review Group meets nationally on a quarterly basis to review the findings of significant events. This then informs national changes to Prevention or Protection strategy. We understand that initial details of an incident of note are supplied to the LSO by the FIT and that all actions are then completed by the local management team thereafter. However, we found little evidence of a direct link between the FIT and local prevention teams in the WSDA, that had been used to develop or inform local activity or training.

Protection

45. The WSDA encompasses a diverse range of non-domestic premises including the care sector, businesses, heritage and industry which welcomes employees, residents, tourists and commuters alike. Such premises and workplaces can fall within the scope of the FSA and its associated Regulations and may be deemed “Relevant Premises”. Those responsible for such premises are termed “Duty holders” and are required to ensure adequate fire safety measures are provided within them. This process is normally achieved through the undertaking of an appropriate Fire Safety Risk Assessment (FSRA).

46. The SFRS is the enforcing authority for the majority of Relevant Premises within Scotland and has a legal responsibility to ensure advice and guidance is given to Duty holders and where required, enforce compliance with the legislation. Protection activity is the processes that involves the Service working with people who have duties under fire safety legislation to ensure the safety of employees, residents, visitors or customers in relevant premises.

47. The Service operates a system which includes carrying out proactive fire safety audits within premises, reactive post fire audits in premises and dealing with other complaints, enquiries and contraventions. Proactive audits are carried out using a risk based approach, following a national enforcement framework, which focuses on those premises which are considered to have the highest life risk from fire, such as care homes, hospitals and sleeping accommodation premises, for example hotels. Each LSO area has a LEDP, which outlines the work of the Local Managers, Fire Safety Enforcement Officers (FSEO) and Auditing Officers (AO) that aligns with these Service priorities and their local requirements.

48. We found these protection teams to be relatively well staffed with varying degrees of competence, knowledge and experience. It is clear that the recent increase in staff attrition rates within the Service has had a detrimental impact on these teams and that the Service is proactively building them back to strength with recruitment. In some cases, this has been inhibited and exacerbated by pension abatement issues, job evaluation process as well as limited development opportunities. Broadly speaking enforcement and audit staff interviewed reported they are finding it difficult to meet the nationally derived audit targets, beyond defined framework premises, in the WSDA. There is a general feeling that a lot of the capacity has been consumed by unplanned workload such as Short Term Let (STL) licensing, Aluminium Composite Cladding Material (ACCM) concerns, and/or non-mandatory and reactive workload such as complaints and enquiries. In respect of the STL issue, many staff were particularly frustrated by a perceived lack of guidance and direction from the National Prevention and Protection Function. The Service acknowledges that the STL Licensing regime has proven challenging for consistent application across Scotland. The Service continues to develop guidance, in liaison with partners, to ensure consistent standards can be applied by staff. We also found that there was no knowledge of the Fire Precautions (Sub-surface Railway Stations) Regulations and the potential implications, despite previous HMFSI observations on a probable policy void.

49. We have reported in previous inspection reports that enforcement staff have a generally poor opinion of the current SFRS national PPED, which is used to record premises and audit outcomes. Because of historical issues with PPED, such as losing records, many staff maintain their own separate record and find they are sometimes inputting in duplicate and triplicate. Staff in the WSDA were of the same opinion and some Enforcement and Auditing Officers we spoke to felt that if they were able to record fire safety audit findings on a mobile device, which was connected to a national recording system, whilst conducting the audit, it would release time and remove duplication of effort, thereby generating efficiencies and a faster completion of audits.

50. The Service has a quarterly Operational Assurance Visit (OAV) programme for high rise domestic buildings. The statutory purpose of these visits is to provide visiting crews with familiarisation of the premises and to check duty holder compliance with fire safety requirements. These visits are normally carried out by operational crews rather than fire safety enforcement staff. However, where there are a large number of residential high-rise buildings, enforcement staff are sometimes involved in compiling any required letters to duty holders, outlining deficiencies where these are found. This is an additional workload where enforcement resources are already stretched and is acknowledged by the Service.

51. Beyond the impact on enforcement staff there is also the scale of the task for operational crews conducting the visits. CoG fire stations are particularly affected because of the number of high-rise building premises within their areas. It is understood from a previous HMFSI thematic inspection (Arrangements for Firefighting in High Rise Buildings 2022)⁽²⁾ that the Service has considered the idea of a risk based OAV approach to this work. The Service informed us that the risk based approach pilot in Edinburgh has been paused and will be reconsidered upon the release of Phase 2 Grenfell report alongside an assessment of the impact that the Single Building Assessment may have upon SFRS. It is acknowledged that there is a degree of sensitivity surrounding the post Grenfell implications and that this may have legitimately inhibited development and change. That said, these visits continue to be a significant workload for certain operational crews and for some enforcement staff at a time of reduced resources.

Recommendation 3: We recommend that the Service reassess the impact of High Rise OAVs on capacity and explore the concept of a risk based inspection approach that embraces safety and assurance whilst not being overly burdensome.

Preparedness

52. The SFRS has a statutory duty to obtain information which may be required by its personnel in carrying out their operational role. When information is created, either by collection as part of that duty or through the writing of an operational policy, such as a Standard Operating Procedure (SOP) for an incident type, it is made available to firefighters through a demountable tablet device within the cab of the fire appliance.

53. The provision of up-to-date and accurate information to its firefighters is important in effectively responding to incidents when they do occur. We saw varying quantities of available information across the LSO areas. There are processes in place for firefighters to collect and review Operation Intelligence (OI); however we noted that in areas covered by On-Call appliances, firefighters from those stations were less likely to be involved in the process. There is also a heavy reliance on the On-Call Support Watch Commander to do this job in some areas, which was beneficial in respect of utilising the additional capacity but negated the positive benefits of crews collecting and understanding hazards and risk within their own station area.

54. We also note that the procedures for collecting and reviewing information on OI were a mixture of proactive and reactive processes which ranged from informal drive-by to formal liaison and communication with Council Planning officers. The processes seemed to be suffering post Covid, much like community safety engagement. We were not convinced that any system employed throughout the WSDA was infallible and that all relevant OI had been collected and reviewed.

55. We are also aware of continued ongoing issues with the automatic updating of the demountable tablet device and the ability to create new OI records. This would seem to be a national problem and one that the Service has been trying to resolve, with a twice weekly manual update process in place as an interim solution. In 2019, HMFSI published a Thematic Inspection report of the management and provision of risk information. In that report we highlighted that there were issues about the updating of the information on the tablet. We are disappointed that these issues have not been resolved and it is of concern that firefighters may not have ready access to the most up-to-date information.

56. In addition to the updating issues, we found that in general, the device was underused by firefighters mainly due to the problems associated in using it, which we also highlighted in our 2019 report. We found that the tablet is mostly being used for its map capability to locate hydrants rather than for its OI content. However, the mapping function does not have traditional ‘Sat Nav’ capability to plot a route to the incident, which is something that front line firefighters said they would find useful. We found that crews tend to use their own personal mobile phones for plotting a route to a location. We did find evidence that the Service has started to issue new mobile phones for appliances which have data access and OI information such as Road Traffic Collision (RTC) vehicle data.

57. Notwithstanding the issues detailed previously, we are aware, through a project demonstration, that the Service is currently developing and rolling out a new demountable tablet system, with new hardware and software, that will enhance and replace the current systems. There is a clearly defined plan for this project, which is scrutinised through the change committee. The SFRS is a pathfinder Service for the UK FRS, having secured significant funding to support this technological advance. Current estimates within the project timeline, are that the replacement of mobile data terminals and demountable tablets across all response vehicles, will take approximately three years to complete. We see this project as an extremely positive improvement but concerns regarding the current processes, systems and hardware remain extant.

58. Business Continuity Planning (BCP) is based on best practice and guidance under the Civil Contingencies Act 2004 (CCA). The CCA requires an organisation to make arrangements and take cognisance of potential and foreseeable hazards and threats to business and that arrangements are in place to mitigate any impact. It is the responsibility of the WSDA DACO (Head of Function) to maintain, audit and exercise individual Business Continuity Management Plans (BCMPs), in conjunction with other functions whose plans may have an interdependent impact. We found strong evidence that BCMPs have been developed for each workplace within the WSDA and that these have been reviewed within a reasonable timeframe. The standard of these plans was very consistent and thorough. We were assured by the Service that these plans are exercised within all LSO areas on a regular basis.

Good Practice 2: We were very pleased to observe proactive management and development of BCMPs for each of the workplaces within the WSDA.

59. SOPs are generic operating procedures, mainly developed from National Operational Guidance (NOG). We found staff were aware of SOPs, as well as other operational guidance, and understood where they could be accessed either within the workplace or on the incident ground. Most staff seemed very comfortable with the format and content as an aid to strong incident command, whilst others found them a bit cumbersome. Some staff were particularly frustrated by the consultation and implementation change process of these documents. They intimated that change could often happen whilst they were on leave and that refamiliarising themselves quickly could be difficult, considering the changes were often not highlighted and that there was a need sometimes to reread the whole procedure. This was particularly pronounced within Johnstone Operations Control (JOC). The Service have subsequently detailed that changes to SOPs are highlighted in red and sent out for a period of 28 days familiarisation negating these concerns, however, it would appear that staff awareness of this process is limited.

60. In addition, we found little evidence of the development of Site Specific Operational Procedures (SSOP) of known hazards and threats that were specific to the area. The lack of specific guidance for dealing with incidents in the Clyde Tunnel and Glasgow Underground were cited as examples, as historically there had been an ‘Operations Technical Note’ in the legacy service. The Service confirmed that SSOP’s are no longer being developed and informed us that the Operations Function are currently developing a new document strategy, which will include operating procedures supported by manuals. We are also aware that the Service has developed enhanced incident response plans and OI for some specific hazards. However, we are still unsure whether all hazards within the WSDA that may require specific operating procedures outwith generic standard operational guidance have them in place.

Recommendation 4: We recommend that the WSDA review the hazards within their area and confirm that specific operational procedures have been developed, if it is deemed that they are not covered entirely by generic standard operational procedures.