High rise buildings - firefighting arrangements: report
Familiarisation and Risk Information
41. Information on building layout, active and passive fire systems, and the ability of residents to self-evacuate, may assist the SFRS in dealing with an incident.
42. Section 9 of the Fire (Scotland) Act 2005 (the 2005 Act) imposes a duty on the SFRS to make arrangements for obtaining information required for the purpose of extinguishing fires and protecting life and property. And section 27 provides power for authorised SFRS employees to gather this information.
43. Some domestic high rise buildings are fitted with on-site external indicator plates. Figures 3 and 4 show this type of indicator plate sited on the exterior of buildings. Indicator plates contain information on physical features of the building and firefighting facilities. This information provides firefighting crews in attendance with important detail in relation to the layout of the building and can influence the firefighting techniques employed.
44. The provision of indicator plates in Scotland initially occurred in the Strathclyde Fire Brigade area. After the formation of the SFRS in 2013 the plate was adopted as a standard by the new service. During our fieldwork, indicator plates are still in the process of being introduced in some parts of the country.
45. We approached this inspection with the inductive approach that mobile data was a more important aspect of risk information, but we have concluded that mobile data and indicator plates serve a separate but related purpose and we see the strong benefit for external marking. The feedback that we received from fire station-based personnel is that the external indicator plate is an extremely useful reference facility which can be easily and quickly consulted.
46. In some areas where indicator plates were not used in legacy Service areas, they have been purchased by the SFRS and provided to building owners to fit. There is a mixed picture in private sector blocks: in some areas there are no plates on private sector blocks. In some cases, there has been reluctance by private sector owners to fit plates.
47. We think that the responsibility to mark domestic high rise buildings should be a duty imposed on building owners, similar to the duty already imposed to maintain fixed firefighting equipment and facilities. There may also be scope to expand the marking system to non-domestic buildings.
Recommendation No. 2
We believe that it would improve safety if the external indicator plate used on domestic high rise buildings was adopted as a standard in Scotland and a mandatory requirement to install and maintain these plates was imposed on building owners.
We recommend that, if the SFRS shares our view, then the SFRS should work with Scottish Ministers to influence such a change to introduce a statutory duty (perhaps achievable by amending the Fire Safety (Scotland) Regulations 2006).
(This recommendation, albeit somewhat indirect, is made to the SFRS given that the statutory power of HMFSI facilitates the making of recommendations only to the SFRS).
48. In addition to external markings, those domestic buildings with wet risers have specific data sheets fitted by the Service within the riser inlet cabinet. This is useful information regarding operation of the system and particularly for crews who might not be otherwise familiar with the system or building.
49. Non-domestic high rise buildings containing fire engineering or complex arrangements may have diagrams, plans or instructions displayed internally. This provision might be ad-hoc and will not necessarily relate to the fact that a building is high rise.
Familiarisation (see also Building Inspections)
50. The Service's Standard Operating Procedure (SOP) for firefighting in high rise buildings (which we consider later in this report) includes information on familiarisation and visits to high rise buildings. There is reference to the following.
- Personnel should be familiar with high rise risks within the fire station area and neighbouring areas with regular visits for gathering and review of operational intelligence (OI)
- Quarterly inspection of multi-storey flats partly for familiarisation
- Periodic familiarisation visits to high rise buildings containing flats, which have features that may be unfamiliar to crews
- In relation to ventilation, carry out site specific visits to high rise buildings in the fire station area, as part of a training programme
- Regular visits and OI gathering are essential
- Imperative that site exercises are carried out
- Quarterly inspection schedule determined by Fire Safety Enforcement Officer (FSEO)
- Stations that have no high rise premises will undertake crossover visits to high rise buildings for which they are included on the first attendance.
51. The existence of this information sits awkwardly in the SOP when there are already separate documents covering familiarisation, visits and training, and there is overlap and potential for contradiction. We think that the SOP should contain only operational procedures and that other content about familiarisation and visits should be removed and dealt with in the existing documents that already cover these subjects. Our experience is that the familiarisation requirements contained in the SOP are inconsistently applied. (We have an overall recommendation relating to the SOP later in the report).
Operational Intelligence (OI) by mobile data
52. The SFRS has a standard procedure for OI. This includes gathering information, holding information for future reference and familiarisation visits by crews. The method of accessing information is by the use of mobile data using dedicated hand held tablets carried on each fire appliance or otherwise available. The OI system is used for holding site-specific information and for generic guidance.
53. This system is used by the SFRS for the provision of information on high rise buildings. In a few instances we noted that information is additionally carried as a laminated sheet in some SFRS fire appliance cabs.
54. There are two factors that we think are relevant. Firstly, this is not a new duty: gathering information on premises is a long standing duty on the Fire and Rescue Service so there could be an expectation that there will be legacy records available. Secondly, the SFRS OI procedure was introduced in 2018 as a new system with an associated workload, and implementation has been interrupted by Covid-19 restrictions.
55. The Grenfell Tower Inquiry (GTI) Phase 1 report contained recommendations on the storage and access to electronic plans.
56. HMFSI carried out a thematic inspection on operational risk information in 2018 and subsequently issued a report containing a number of recommendations for the SFRS.
57. The SFRS OI system is contained in a number of different documents. The OI framework document identifies the types of record that might be held in terms of graphics and contains an inspection frequency based on risk level. Frequency of visit is 1/2/3 or 5-yearly. However an OI record is mandatory for 'high rises'. We think the use of the generic term 'high rises' in the document lacks some definition.
58. One of the graphics categories in the OI framework is called a 'Fire Service Response Plan' (FSRP) – this is a 3-dimensional image of premises and is standard for premises within an OI inspection programme.
59. Given that the SFRS standard is for OI to be recorded for all 'high rises', coupled with the focus on high rise information which followed the Grenfell Inquiry report, we were surprised to find that the SFRS does not have all the domestic high rise buildings recorded on its OI system. There are different interpretations in place. Our experience is of course a sampling exercise, but there is an inconsistency and differences between Local Senior Officer (LSO) areas. Some areas have no information recorded, others have good information, and in one case the information is available, but not on the OI system.
60. We examined some of the risk information recorded on the OI system for a number of domestic and non-domestic high rise buildings at each LSO area that we visited, where they were available:
- the records commonly comprise two dimensional layout plans and associated information
- a small number of layout representations are difficult to understand and are suited to interpretation by persons with an existing awareness of building layout
- some OI records are well structured and contained good information
- some records contain legacy TIPs (Tactical Incident Plans).
61. We are impressed by the records available in one LSO area (a city with a challenging portfolio of property types) and the work that was underway there to develop and record suitable OI records. However the provision of OI records on the tablet device is inconsistently applied throughout the Service.
62. Generally, fire station-based personnel have a good level of knowledge of local domestic high rise buildings as a consequence of the visit frequency and there is less importance placed locally on the information available on OI records. In practice, the usefulness of OI information may be greater to incident commanders and attending crews that are unfamiliar with the building.
63. Where there is information regarding cladding systems, this can be recorded on the OI system and we saw examples where this type of information was in place. The Service has placed the information on cladding systems available from the Scottish Government's high rise inventory, onto the emergency notes page of relevant OI records.
64. Where the SOP cannot be followed at a particular domestic high rise building, a summary of the variation has been placed on the emergency notes page of relevant records.
Recommendation No. 3
The SFRS should review its expectation regarding the recording and use of OI for high rise buildings and take steps to implement a standard approach.
Other record keeping
65. The GTI Phase 1 report contains recommendations related to the provision of an external Premises Information Box (PIB) containing relevant information on the building and occupants.
66. In Scotland there has not been a strong tradition on the use of PIBs. There are other requirements and recommendations to provide plans contained in legislation and guidance such as:
- the requirement for underground railway stations to have an accessible plan
- the recommendations in British Standards for layout and similar information for large or complex or underground buildings
- the display of zone plans in buildings with fire warning systems.
67. We came across situations where housing authorities in Scotland are considering whether PIBs should be located on their housing blocks. And the Service's guidance for OAVs includes checking any plans and information in a PIB (if available).
68. The provision of paper plans could in some ways be seen as a low-tech approach, when every SFRS fire appliance in Scotland is equipped with a tablet to hold mobile data. Of course paper plans could be seen as a back-up arrangement in the event of equipment failure.
69. One of the more difficult aspects of the GTI recommendation is for owners and managers of high rise residential buildings to provide Personal Emergency Evacuation Plans (PEEPs) for occupants with reduced mobility.
70. It is difficult to see how a system of PEEPs could be effectively put in place, resourced, and maintained accurately due to the number of practical difficulties involved in domestic blocks.
71. A PEEP is a formal process normally applied in respect of non-domestic premises where a person's assistance needs are assessed and arrangements put in place, often by an employer. However the situation in a domestic environment is different. In most domestic settings there is no assistance immediately available. The equivalent of a PEEP in a domestic situation has been described as producing a 'rescue plan' rather than an 'evacuation plan'.
72. While this recommendation was not directed at the FRS, a PEEP scheme could have major issues for the SFRS. If this type of information was available, how would it be accessed and used by the SFRS? Traditionally, the SFRS has held information on personal risk factors such as where there is a hoarding risk or medical oxygen is in use; when it becomes aware of these, the information would be available to the incident commander at a fire.
73. The UK Government issued a consultation on the provision of PEEPs in high rise buildings and it has been a complex and controversial issue. In June 2022 subsequent consultation was issued under the description 'Emergency Evacuation Information Sharing'.
74. The SFRS is a joint contributor to research work being undertaken by a contractor which may impact on high rise. This is a project examining the potential for a technological recording system for recognising whether persons who have previously been identified as in need of assistance, are present in a domestic building. The proposal is to use time and presence technology to display on a screen, accessible only to the fire and rescue service, information on whether these residents had left the building or are still within the block. The contractor is hoping to carry out trials of the system in some existing buildings.
Recommendation No. 4
The SFRS should develop its own policy on the suitability of 'Premises Information Boxes' for high rise domestic blocks so that a standard approach can be taken where housing providers may propose to introduce these boxes for their buildings