Climate Change: managing the operational impact on fires and other weather-related emergencies
Our Inspection Findings - 4.1 Response to Flooding
“Since the early 20th century, rainfall levels have increased in Scotland by around 11% and on a shorter timescale, since the early 1960s, by around 27%. We expect these changes to continue and intensify. 1 in 11 homes and 1 in 7 businesses in Scotland are already at risk of flooding and, on average, around 2000 more properties will be at risk every year due to climate change”.
Ministerial foreword extract
Second Scottish Climate Change Adaptation Programme 2019-2024
Climate Ready Scotland
14. Area flooding can involve:
- coastal flooding, caused by extreme weather including storm conditions combined with high tides
- river flooding, usually caused by periods of heavy rain
- flash surface flooding caused by periods of heavy rain
- groundwater flooding, which occurs when the levels of water below ground rise above normal levels
- damage to water mains or failure of physical structures.
15. Scotland has been exposed to wide area flooding events such as during Storm Franklin. More recently, in November 2022, the east of Scotland was impacted by heavy rainfall and a number of flooding incidents occurred in the north east of the country due to events such as watercourses overtopping.
16. The SFRS’s Operational Strategy acknowledges the challenge that climate change presents. It includes the aim of “enhancing partnership working and responding to the increasing climate change emergency” and acknowledges emerging risks by highlighting the “estimated 284,000 homes and premises at risk of flooding in Scotland”.8
17. While there is a perception within the Service that there is increased SFRS incident activity, the SFRS is unable to provide statistics on the number, location and consequence of widespread flooding incidents that it attends. This is due to limitations in the UK Incident Recording System (IRS) used to record incident data. The reporting tools used to analyse this information do not allow managers to differentiate between wide area flooding and localised flooding incidents, for example those affecting a single property or not caused by a weather event. We have included a recommendation relative to this issue later in the report.
SFRS Planning and preparation
National Framework and Legal duties
18. The SFRS has a legal duty to prepare and provide for the rescue of persons and for protecting persons from serious harm where there is serious flooding9. The Service also has a duty to provide its staff with appropriate training and for obtaining relevant information likely to be required for the purpose of responding to this type of incident. The attendance of the SFRS at flooding incidents more generally is within the scope of its power to undertake ancillary provisions within the Fire (Scotland) Act 2005.
19. While the rescue of persons at flooding is a statutory duty, the Service also routinely, uses its resources for water rescue at non-flooding incidents such as loch and river incidents.
20. The statutory function is supplemented by guidance in the Fire and Rescue Framework ‘SFRSshould continue to strategically place specialist resources in areas where there is a greater risk of flooding (that is flood response stations, swift water rescue units, high volume pumping appliances which divert huge volumes of flood water), and ensure firefighters are prepared, fully equipped and ready to support and protect communities, whatever the weather.’
21. The SFRS standard operating procedure (SOP) acknowledges that HM Coastguard is responsible for the initiation and co-ordination of maritime search and rescue operations in the United Kingdom.
22. It is generally held that the SFRS does not have any specific statutory duty to carry out publicity or prevention work in relation to its water rescue and flooding activities.
Strategy, Policies and Procedures
23. The SFRS operates a tiered capability and resource system for attendance at water related incidents;
- Level 1 water awareness
- Level 2 flood first responder (FFR)
- Level 3 swift-water rescue technician (SRT)
- Level 4 boat operator
- Level 5 water incident manager (WIM).
24. Level 1 is a training provision standard for all firefighting staff. This level of training is designed to give personnel an understanding of the hazards and risks associated with water and know how to carry out shore-based rescues utilising equipment, such as hose inflation kit and throwlines, and to work safely near water. Level 1 trained personnel are not permitted to enter water.
25. Level 2 is training for staff at a declared water rescue or flood response station who will be expected to provide a wading response to water rescue or flood related incidents. During the course of our inspection, the number of FFR fire stations increased from 66 to 78.
26. Level 3 trains personnel in swimming and rescue techniques and develops them to water rescue technician standard which includes training on how to interpret water conditions and to perform in-water rescues as part of a rescue team. This is for personnel who work at declared water rescue stations, to enable them to carry out flood and water rescues safely, on, in, or near inland water. There are 20 fire stations in Scotland with a swift-water rescue capability.
27. Level 4 is for personnel who are already Level 3 qualified and who may be required to operate a powered rescue craft.
28. Level 5 is for personnel who may be required to manage or advise at a water incident at tactical or operational level. At the time of writing, the SFRS does not have any Level 5 qualified personnel, although it is planned to train a number of Flexi Duty Officers (FDOs) to this level.
29. There is also a Level 6 tier. This is flood rescue tactical advisor level, for those who may be required to provide operational and tactical advice in relation to major or wide-spread flood or water rescue incidents. The SFRS does not have any Level 6 qualified personnel. A prerequisite of this course is to be Level 4 and Level 5 qualified and, as detailed above, there are no personnel who have met this standard. The SFRS intends to train some FDOs to Level 5 and utilise this cadre as a tactical advisor role for attending water and flooding incidents, but there are no plans in place to train personnel to level 6.
30. The equipment available includes lifejackets for all personnel responding to flooding incidents, flood suits and safety helmets, wading poles for gauging depth of flood waters and highlighting hazards therein are provided as appropriate to personnel depending on role.
31. There is a greater provision for SRT crews. This includes water rescue boats, water sledges, marker buoys, reach poles, personal flotation devices for personnel and other ancillary equipment to assist in rescue operations.
Good Practice 1
The standard of equipment and capability, demonstrates that the Service operates a good level of preparedness for communities in discharging its statutory duty of rescue at flooding incidents and its activity at other water rescues.
32. High Volume Pumps (HVPs) were provided as part of the government’s national resilience programme and can be used to mitigate the effects of flooding by allowing crews to pump large volumes of water away from impacted areas. The SFRS has four HVPs placed strategically across the country situated at fire stations in Cambuslang, Falkirk, Dundee and Elgin. These resources are mobilised on request from an incident by incident commanders.
33. There is a Service lead for the HVP capability, who co-ordinates meetings with representation from the fire stations where HVPs are placed. That person acts as a conduit to a UK national user group to share issues, improve knowledge base and share good practice.
34. A Scottish water national users group (SNUG) has been established within the SFRS. The group meets on a quarterly basis and involves representation from all Local Senior Officer (LSO) areas. The purpose of the group is to identify and resolve issues and ultimately make improvements. The Water SNUG feeds into a UK National User Group through attendance by the subject lead, who is a flexi-duty officer responsible for coordinating the group. There is evidence of good end user engagement at fire station level. A number of staff we spoke to knew of the group and how to raise issues with this group and provide feedback. The water SNUG has been consulted during a SFRS process to standardise equipment and water related PPE used across the Service.
Good Practice 2
The water national users group within the Service works well as a forum for raising and resolving issues. Watch based personnel have good levels of awareness of the Water SNUG and the identity of their representative on the group.
35. The SFRS has a Standard Operating Procedure (SOP) for ‘Water Rescue and Flooding’. The terminology and guidance in the SOP indicates that it is written principally for operating at a water rescue response at an established body of water, rather than for flooding incidents. One consequence of this is that some firefighting personnel can be unsure how the guidance applies at a flooding incident.
36. The SOP states that personnel trained to level 1 ‘cannot enter the water’. This guidance is unqualified. While there is a need to have tasks undertaken by appropriately trained personnel and have in place instructions which impose or reinforce this, an absolute restriction when applied for example to minor flooding on level ground or in a low risk environment, seems impractical.
37. The reality is that level 1 trained personnel can be at minor incidents with low water levels and may be required to walk through some water and that they will often use a risk-based common sense approach to decision making. We think that the instruction ‘cannot enter the water’ has introduced uncertainty, rather than offer meaningful guidance to personnel.
The Service should consider whether there is potential to amend the guidance in the Water Rescue and Flooding SOP, so that the application of the ‘cannot enter the water’ rule is explained and qualified, with a view to including more definitive guidance for personnel at incidents where there is a very low water, low risk environment.
38. The SOP contains procedural guidance on what the action of an incident commander or team leader of a water rescue team should be at an incident, but there is no similar guidance for FFR teams.
39. There is no clear procedural guidance available on the response to wide area flooding. The SOP lacks detail on strategy such as how SFRS priorities might be determined, or how multi agency working would operate at a serious flooding incident.
40. When the SFRS mobilises a response to a weather related flooding incident affecting multiple properties, two fire appliances with crews, along with two swift water rescue teams and two inflatable rescue boats are mobilised. The two appliance crews may be level 1 trained crews. The level 1 crews will be available to provide land-based support and logistics, but otherwise, since they cannot enter the water, their contribution at some incidents will be limited.
41. The SFRS’s Water and Flooding SOP recognises that as a Category 1 responder10, the Service participates in multi-agency planning for, and in response to, all types of civil emergencies, and it includes the type of information that should be collated for its operational intelligence system in relation to identified water risks. This includes specific hazards, access points, and physical features. These plans include imagery and site plans to assist responders.
42. A number of “Water Incident Response Plans” (also referred to as ‘water OIs’), have been added to the Operational Intelligence (OI) system11 and the information is available to crews responding to incidents. However, the evidence of this varied by location. Some areas do not have any ‘water OIs’ and some have created plans but these haven’t been added to the OI system due to technical issues.
43. While ‘water OIs’ are envisaged for rivers and bodies of water, rather than flooding sites, these locations are also impacted by weather events or could be the source of flooding and the existence of OI information may be useful and relevant at flooding or weather related events.
44. We examined some examples of water OIs on the OI system. We found the information to be well constructed and useful. This was borne out by our fieldwork experience when there were positive examples of how crews had utilised information on ‘water OIs’ to assist in safely progressing incidents, sometimes working in areas which were not familiar to the crews.
The ability to retrieve important information on specific hazards at water-related incidents can aid with the tactics adopted, inform the crews and incident commander of hazards to assist in their risk assessment process and is ultimately a commitment to firefighter safety. The SFRS holds good information but the provision is inconsistent across the Service.
The SFRS should progress consistently the completion of water incident response plans and make them available on the OI system.
45. While flood-prone areas are known and mapped and the risk of occurrence is assessed, the extent of any single flooding event may be unpredictable. Accordingly it is not straightforward to determine what level of OI it might be of use for the SFRS to hold. There are no flood response plans available on the OI system for known flood risk areas.
46. Personnel we engaged with had a general awareness of flooding risk as a consequence of historical events, but did not have detailed knowledge of which properties are at risk of flooding in their local area. This is despite the SFRS Operational Strategy 2022-2032 committing to responding to the increasing climate emergency whilst referencing their awareness of an estimated 284,000 homes and premises in Scotland being at risk of flooding.
Training and exercising
47. The SFRS is registered with Rescue 3 Europe, an international accrediting body for technical rescue courses. Rescue 3 Europe develop training courses used by organisations and individuals operating in high risk environments, including water rescue courses for emergency responders and rescue teams. In addition to registration, where appropriate the SFRS maps high-level outcomes to national occupational standards which are incorporated into the design and development of water rescue course programmes.
48. An overview of the accredited training courses is contained in Appendix A.
49. There are some good examples of fire station personnel having water training embedded as part of their work routines. Though personnel at some water rescue fire stations find it difficult to undertake the required level of water training. The ‘on water’ element of training should be carried out on suitable and appropriate bodies of water. Training involves using class II water conditions which are described as being rapids of moderate difficulty with passages clear. Water training requires a crew to be unavailable for fire cover and there can be availability pressures that make this difficult to achieve for some.
50. There is no clearly understood method for recording and monitoring maintenance of competence training hours. PDR Pro is the SFRS system for recording training, however, the system does not have the flexibility to be used to log water rescue training hours. This can impact on individuals’ ability to demonstrate maintenance of competence and managers’ ability to monitor actual training achieved against requirements.
The SFRS should firm up its guidance and requirements for the recording of maintenance training, carried out by level 3 and 4 personnel in line with its national policy standards on water and flood rescue training to improve accountability and monitoring.
51. Exercises – particularly multi-agency exercises dealing with issues of mobilising, command and co-ordination – are a valuable way of testing existing plans, identifying improvement, and offering learning opportunity. The SFRS has competing priorities in respect of exercising and there is little evidence of physical exercising with partners by fire station crews for wide area flooding incidents. There is little evidence of Level 1 crews training with Level 2 and Level 3 crews on water-based scenarios.
52. The SFRS is not the lead body in co-ordinating a wide-area flooding response. There are a number of agencies involved in flood related prevention and response work.
53. The Scottish Environment Protection Agency (SEPA) and Scottish Government approach is that the creation of flood defences alone will not be sufficient to protect homes and businesses from flooding. The need for communities to increase resilience and preparedness is important in order to support those most likely to be affected.
54. The SFRS utilises SEPA’s Flood Guidance Service to understand the likelihood of flooding in particular areas. This information is communicated internally to raise awareness and takes the form of a daily flood guidance statement. When appropriate, this flood risk information is shared externally through relevant media channels.
55. The SFRS has representation on Local Resilience Partnerships (LRPs) and has an involvement in planning for flooding through these partnerships. There are 12 LRPs in Scotland, six feed into the West of Scotland Regional Resilience Partnership (RRP), three into the North of Scotland RRP and three into the East of Scotland RRP. This structured partnership approach, consisting primarily of Category 1 and Category 2 responders, is designed to ensure preparedness to respond to an emergency situation. Each RRP produces a Community Risk Register (CRR) which highlights the risks which have the highest likelihood of occurring with potential to have significant impact. Each of the three RRP’s published CRRs recognise flooding as a potential risk within their region and refer to multi-agency plans which are in place to support response to this type of emergency.
56. Fire Service managers generally have an awareness of the SFRS’s involvement in developing plans at Local Resilience Partnership level. A consistent outcome from interviews is that fire station personnel have a limited knowledge of what flood plans exist within the Service.
57. Although information may be available from local authorities to help identify priorities on those needing evacuation during a wide area flooding incident, there is a limited understanding amongst flexi-duty officers on how this would operate.
58. Our 2015 report considered the situation regarding site-specific planning for flooding and contained a recommendation for the SFRS to compile a list of flood plans and to make them available for incident command and planning purposes. There is little evidence that the Service has been able to develop this. The arrangements that exist for multi-agency planning for wide area flooding are not well communicated within the Service.
The SFRS should review its approach to planning for wide-area flooding, both generally and also where appropriate on a site-specific basis, and take steps to assess or develop plans, and determine how information can be shared with operational personnel to assist with planning, procedures and incident command at potential flooding events.