Contingency Planning Arrangements for Industrial Action in the Scottish Fire and Rescue Service
6. On 1 December 2022, in line with Section 43B of the Act, the Minister for Community Safety directed HM Chief Inspector of the SFRS to conduct an inspection into the suitability of contingency planning arrangements in the event of IA in the SFRS. The role of HMFSI is set out in Appendix 1.
7. The SFRS has a duty under section 9(2a) of the Act, to "secure the provision of the personnel, services and equipment necessary to meet efficiently all normal requirements." The Service also has a duty under section 2 of the Civil Contingencies Act 2004 to "plan for emergencies, and to maintain plans for the purpose of ensuring, as far as is reasonably practicable, that if an emergency occurs, it is still able to continue to perform its functions".
8. The Inspection focused on business resilience and maintenance of service during periods of potential IA by operational firefighters and/or Operations Control firefighters. We considered a range of IA options open to FBU members, including withdrawal of labour for portions of the working day or for more prolonged periods.
9. During the Inspection, and taking account of our stated purpose, we focused on the following areas:
- Arrangements being considered for the maintenance of an effective operational response to emergencies across Scotland in the event of IA.
- Arrangements being considered for the ongoing receipt and processing of emergency calls to the SFRS Operations Control Centres.
- The development of safety advice for the public in the event of IA.
- The development of safety advice for business premises in the event of IA.
- Key SFRS business services and activities that must be maintained and arrangements in place to do so.
- Identification of significant risks that could result from interruption or reduction to SFRS services and arrangements in place to mitigate such risks.
10. We are committed to using the outcomes of our inspection to report assurance levels in Business Continuity Planning arrangements for IA and to highlight where these are considered appropriate or otherwise.
11. The SFRS provides a range of critical services across communities. These services include responding to fires, and to non-fire emergencies, such as road traffic collisions, rescue from water, incidents involving hazardous or toxic chemicals etc. Operational services provided by the SFRS during IA would be on a reduced emergency basis and not to the levels that the communities of Scotland would normally expect.
12. To ensure that service can continue to be provided in the event of IA, the SFRS has developed a range of Business Continuity Planning (BCP) arrangements. In light of the heightened potential for IA, the SFRS reviewed these arrangements to ensure, as far as is reasonably practicable, the safety of the communities it serves. At the same time, an Industrial Action Tactical Action Group (IATAG), chaired by the SFRS Deputy Chief Officer, was established. The group's aim was to list, track and quantify the risks posed by potential IA and to mitigate the effects of these risks while maintaining services where possible. The IATAG maintained a strategic control of SFRS work to prepare the organisation for potential IA. It put in place a wide range of plans and arrangements, aligned to its IA BCP, and ensured that these were tested and where appropriated, exercised. It should be noted that while the Service allocated significant resources, personnel and capacity to the planning phase for IA via the IATAG, it also maintained service delivery during this period.
13. While we acknowledge the work carried out in preparation for potential IA, we also note that exercising and testing was still ongoing in mid-January 2023. 'Business Rules' that SFRS officers would base appliance mobilisations and command and control decisions on, were still being developed and refined when this report was being drafted. We consider the publication and the testing of these business rules in an exercise environment to be extremely important. Given that the potential for IA is a reasonably foreseeable risk, we would encourage more active monitoring for future Service challenges and the regular updating of BCPs and their supporting processes upon which response plans will be based.
14. Recommendation 1 – The SFRS should ensure that BCP's are routinely updated and refreshed to ensure that it can respond to foreseeable risks. Regular training and exercising in relation to potential service interruption should be programmed into annual training programmes.