HM Fire Service Inspectorate – management of health and safety: an operational focus
About the Inspection
8. Her Majesty's Fire Service Inspectorate in Scotland (HMFSI) is a body that operates within, but independent of, the Scottish Government (SG). Inspectors have the scrutiny powers specified in section 43B of the Fire (Scotland) Act 2005.
9. This inspection is conducted under those powers conferred on the Chief Inspector under sections 43B and 43C of the Act and was initiated by the Chief Inspector on his own volition. Further information about HMFSI can be found in Appendix 1.
10. A draft outline was prepared which defined the scope of the inspection. This was consulted upon with the SFRS prior to fieldwork commencing.
11. The aim of this inspection is to assess the effectiveness and efficiency of the Service's governance and management, policy and planning, training and recording with an operational focus. We considered the extent of the following aspects of Health, Safety and Welfare as specified in the inspection outline:
- evidence exists of an embedded positive health and safety culture;
- that the SFRS meets identified legislative general duties and guidance document requirements;
- the organisation has a structure, is adequately resourced, has qualified people, is aware of its responsibilities, and adequate resources are made available to meet requirements;
- that there is active participation by an engaged workforce at all levels including the SFRS Board;
- there is an effective management and recording system; including evaluation and relevant performance and benchmarking measures;
- that proactive as well as reactive monitoring systems are in place;
- that sufficient resilience exists in systems and resources;
- there is an awareness of the organisation's risks and that they are managed effectively;
- suitable and effective operational training is in place;
- that the SFRS enables operational staff to remain effective and safe when responding to emergency incidents – demonstrating a 'Risks vs Benefits' culture;
- that the SFRS responds to operational and training accidents and incidents effectively and efficiently to assist learning, demonstrating how learning is shared and improvements monitored and managed;
- that the SFRS has suitable systems in place to support the workforce in managing their welfare; and
- to consider examples of how Operational Assurance has improved H&S and organisational learning to improve service response.
12. The intention of this report is to set out the facts and present the Chief Inspector's independent view of the current arrangements. Where appropriate, we will, make recommendations, identify areas for consideration and highlight good practice. Recommendations and any associated action plan developed by the Service will be monitored in line with existing arrangements.
13. In this report our findings include Recommendations, Areas for Consideration and Good Practice:
- Recommendations – these are areas that we believe will have a significant impact both within the scope of this report and will bring broader organisational benefits.
- Areas for Consideration – these may be delivered as described or in other ways as determined by the Service, they should deliver improvements to the organisation and staff over a given time period.
- Good Practice – activities raised by SFRS staff during interviews and supported by our professional judgement as having a positive impact on H&S within the Service.
14. There are occasions where our observations could be reported against more than one heading. Our aim is to ensure that our findings are allocated in the most appropriate place, or places, to give a comprehensive understanding of our investigations.
15. We acknowledge that due to the timescale for completing this work, which was partly affected by the impact of Covid-19, the SFRS may have already considered and addressed some of the issues identified.
16. The inspection methodology used is similar to our Local Area Inspections (LAIs) and previous Thematic Inspections. It provides a structure to our inspection which is risk-based and proportionate.
17. The inspection commenced with a desk-top review of the SFRS's policy, procedures and data in relation to how the Service complies with its H&S duties for operational response. This included interviews with:
- SFRS Board member
- Chief Officer
- Assistant Chief Officer (ACO) - Director of Service Delivery
- ACO – Director of Training, Safety and Assurance
- Service Delivery Area (SDA) Deputy Assistant Chief Officer (DACO) - North, East and West
- Head of Safety and Assurance
- Members of the Training, Safety and Assurance team
- Representative bodies and other staff groups
- Police Scotland
- The HSE
- Senior and Middle Managers (Directorate and SDA)
- Area Commanders
- SDA Group Commanders with Safety and Assurance Liaison Officer (SALO) reference
- Fire Station and Directorate based supervisory managers (Watch Commanders and Crew Commanders)
- Operational Crew (Watch Commanders, Crew Commanders and Firefighters)
18. We had intended to visit a number of Service premises across Scotland, including fire stations covering all duty systems, to analyse records and determine the understanding of the staff using H&S related systems. Unfortunately our planned programme had to be amended to ensure adequate Covid-19 control measures were in place. This was necessary to protect all those we needed to engage with and to comply with relevant restrictions in place at that time. Consequently we reduced the number of physical visits and introduced 'virtual' interviews using video technology. Despite these restrictions we undertook a sample of visits and engaged with an appropriate number of staff members to allow us to reach the conclusions within this report.
19. The data and information supplied to us was used to cross-reference the written policies, procedures, reports and used to triangulate information we received in our interviews. Performance data supplied to us in relation to H&S and other data taken from published sites is used, as necessary, to give context and inform the report.
20. This inspection was not intended to be a comprehensive in-depth audit, albeit it is sufficiently detailed in order for the Chief Inspector to give a professional judgement on the activity and suitability of the Service's H&S arrangements within an operational context. It has established, to the Chief Inspector's satisfaction, the facts needed to draw conclusions, make recommendations, identify areas for consideration and highlight good practice where appropriate.
21. The SFRS has a programme of internal audits, routine H&S inspections and fire station audits which involve a detailed inspection of aspects of its activities. We did not want to duplicate or encroach on that work. We did take these audits and inspections into consideration whilst carrying out our own work. Unfortunately, due to the Covid-19 pandemic and the restrictions imposed from March 2020, the SFRS had no choice but to cancel much of the work planned in this respect.
22. The sampling methodology that we adopt is not designed, nor guaranteed, to identify all potential areas for consideration or good practice; we intend that it is a proportionate activity that provides sufficient detail and engagement, comparable with other inspections that we have carried out.
23. Within this inspection, we also reviewed actions taken by the SFRS following previous inspection reports. These included H&S related themes that were identified during LAIs. The themes included:
- the use of the recording systems (previously RIVO and currently TASS (Think, Act, Stay, Safe);
- the level of understanding among personnel of the importance of 'near miss' reporting, that may be a factor in the low reporting of 'near miss' incidents. During previous LAIs we have noted that 'near miss' events are more often in non-operational or training environments and that 'near miss' reporting from the incident ground is less frequent;
- the limited amount of H&S input to new staff on courses such as Task and Task Management (TTM) which appear to be the only input given to a new entrant in relation to H&S;
- fire station facilities for cleaning and securing PPE;
- perceived inadequacy of torches and incidents of breathing apparatus radios being turned off accidentally;
- shortcomings regarding test records for equipment and the variances between records;
- an increase in the number of H&S events in some Local Senior Officer (LSO) areas which may not reflect the national position;
- Retained Duty System (RDS) staff desire to increase practical training, as they consider too much time is devoted to theoretical training, completing training records and other management activities;
- the volume of new information issued to station-based staff (including H&S issues), leading to concerns that safety-critical information could be missed; and
- a perceived lack of training among some staff on the process for carrying out Analytical Risk Assessments (ARA) or other H&S related duties.
24. Our report is the product of reviewing and analysing the current data, engaging with a wide range of SFRS staff and external stakeholders, and considering evidence from our previous Thematic Inspections, LAIs and other inspections. It is reflective of the circumstances at the time of our interviews and visits undertaken from April 2021 to January 2022.
25. During the inspection, HMFSI provided regular feedback to key SFRS staff including senior managers, so that any significant emerging issues and themes could be discussed and acted upon as required.