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

Prevention and Protection – How effective is the Service in the East SDA at keeping communities safe and secure?

33. To be effective, the SFRS 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 North SDA is judged to be Satisfactory.

Governance

34. The Fire (Scotland) Act 2005 (the Act) requires the SFRS to publish a Local Fire and Rescue Plan (LFRP) for each Local Authority area. The plans set out the SFRS’s priorities and objectives for that area; why they have been selected; how the SFRS intends to deliver them and (as far as is practicable) outcomes by reference to which the SFRS’s service delivery in the LA area can be measured. We examined all the LFRP in the NSDA 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. 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.

35. In common with the East and West SDA reports, the decision to delay the development and publication of new LFRP for the North remains in place. The existing plans were reviewed as the SFRS charts its way forward for Service review and redesign. This approach has not stopped SFRS personnel in the North from continuing to achieve outputs and outcomes, but it is acknowledged that there is a drag in terms of strategic planning approaches. A number of SFRS LA partners admitted to a degree of frustration with the delay in the production of the new LFRP, but also voiced their understanding and acceptance that it would not be a worthwhile exercise to produce new plans in advance of any strategic or structural changes to the Service.

36. We were informed and found some evidence that the Service in the NSDA has developed Station Plans which give a local context and tie-in for activities that should align to the LFRP. We were advised by the NSDA management team that station plans had been developed and should be in place in the locations that we were scheduled to visit. While the plans were available or known about at some locations, disappointingly this was not the case in the majority of fire stations that were visited. Despite a lack of visibility of the formalised plans, our Inspection survey strongly indicated that personnel in the NSDA were aware of what the priorities were for their workplace.

37. In WT stations there was significant focus on a localised seven week planner system that guided much of the work undertaken by the station and its personnel. In the case of On Call stations there was a near universal use of the station practical training TFoC system to maximise the capacity that is available on station drill nights. Both WT and On Call personnel often cited outcome reports as their guide for planning work for upcoming periods of time, confusing planning with reporting. There appeared to be limited linkage, in most instances, between Strategic level plans, Station plans, and the appraisals of personnel, as is set out within the SFRS Good Governance Framework 2023.

38. Where we did find a station or a watch that could identify the Station Plan and clearly understand the linkages between strategic and station plans, station work outputs and outcomes as well as personnel appraisals, their understanding was to exceptionally high levels. Unfortunately, these exemplar level stations were the exception and not the rule.

Recommendation 1

The SFRS should engage with fire station staff to ensure that the importance of the Good Governance Framework, and how it should be used to guide their work at a local level (including appraisals) and also provide linkages to Service strategic plans, is understood by all staff. This is particularly important for Watch Officers who need to manage local work outputs and outcomes, and who will be the SFRS middle and strategic level managers of the future.

Prevention and Engagement

39. Preventing incidents occurring is accepted as the most effective way of mitigating the impact of fire and other incidents upon our communities. 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 Local Prevention Delivery Plan (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 SFRS works with a wide range of partners and the LPDP should guide and prepare staff to work efficiently and effectively to support the communities that the NSDA serves. The LALO and CAT are there to support, add capacity where it is needed, and to enhance the work undertaken by frontline operational staff. Work undertaken is recorded on the Community Safety Engagement Tool (CSET).

40. Across the NSDA we could evidence many examples of work where station personnel, LALOs and CAT personnel were actively engaged in a very wide range of activities that pushed the safety agenda that the Service is pursuing. We also came across many examples of initiatives that tied into the outcomes that were being pursued by LAs in line with their CPPs and LOIPs. LA partners that we spoke with held the SFRS contributions to their CPP and LOIP outcomes in the highest regard. Chief amongst the outcomes being pursued was to reduce poverty for members of the community, and there are numerous examples of this work being undertaken by watches across the NSDA e.g. Partnership Approach to Water Safety, breakfast clubs, Brew With the Crew, Food Poverty Initiatives, Youth Football, Fire Skills, School Competitions, Young Fire Setters intervention programme and hoarding interventions. This work is all commendable and clearly adds social value as well as allowing ample opportunity for early years engagement and interventions that align to fire safety strategies and outcomes that the SFRS will be pursuing.

41. While we agree that there is significant social value to be gained through the community safety work that is undertaken in the NSDA, and indeed across the SFRS, we found that there was limited evaluation of the outputs or outcomes that these initiatives are seeking to achieve. As the Service considers options to realign its resources to meet the future risk demand across Scotland, the amount of capacity that will be available for utilisation on these initiatives will inevitably require to be considered. SFRS personnel use their capacity to deliver outputs, often to exemplary standards. To best target available resources to the point of greatest need in future, it would greatly assist the process if the outcomes from previous initiatives had been systematically evaluated. During this inspection process we found no LA partner of the SFRS who conducted what we would consider to be an effective evaluation process. With so much of the Services capacity aligned to LA partners efforts in tackling their top priority of poverty, the need for joined-up evaluation of initiatives is a pressing one.

Recommendation 2

The SFRS should work with partners to develop and implement an evaluation system that scores and grades the inputs, outputs and outcomes of the many Community Safety (CS) initiatives that it undertakes. This evaluation system should allow qualified decisions on where, and on what, initiatives to focus the resources of the Service.

42. We found that frontline crews continue to deliver a range of traditional fire and other safety related activities such as HFSV, vulnerable person referral pathways, SFRS Thematic Action Plans (TAPS) such as fireworks and bonfire initiatives, Gala day attendances, Cubs, Scouts and school visits to local fire station, safety talks to local Nurseries, local schools and local residential care homes and independent living facilities. While there is clearly activity ongoing, we often received comments that suggested the level of activity undertaken is not as high as it traditionally had been in the pre Covid pandemic period. Another common issue that was raised by both station personnel and CAT personnel was the challenge in gaining access to schools, and in particular secondary schools, curriculum time which was considered to be limited.

Good Practice 1

An example of the important and value adding work that is undertaken by CSA, CAT, and LALO teams was on an island that has no fire station (of which there are six within WIOS). One individual formed a partnership approach with the local GP to gain an insight to the people living within this community. Of the 94 properties on the island, 49 had elderly residents who had a range of vulnerabilities. Each elderly resident household on the island was subsequently visited and a HFSV carried out, with important safety messaging shared and vulnerabilities noted.

43. Across the NSDA we found CAT and LALO personnel engaged in a wide range of community safety engagement, education and prevention work and initiatives. In general, the CAT and LALO appear to have positive working relationships with station based operational personnel. We did however receive a number of comments from the operational crews who felt that the CAT/LALO personnel would often pass work onto them with little or no prior discussion and then leave them to produce the outcomes from community safety focused initiatives etc. Conversely, we also received comments from station based personnel who felt that their contact and support from CAT and LALO personnel was too limited.

44. While the CAT personnel that we spoke with were very clearly committed to their work, they voiced frustration at the lack of SFRS Continuous Professional Development (CPD) opportunities beyond mandatory training modules that must be completed every three years. A number of CAT personnel told us that LA and other partners offer more access to CPD events and training opportunities than the Service does. A similar finding appears in the East and West SDA reports.

45. It was clear from our interviews that the LALO and CAT roles work well together. However, there was frustration from CAT personnel about the perceived quick turnover of LALOs, who effectively function as their line management route. Allied to this was the ongoing frustration, also reported in the East and West SDA reports, about the lack of career opportunities or pathways to other roles for the CAT personnel. One solution suggested by the CAT personnel was for the SFRS to consider a non-uniformed role within their team to assume the managerial responsibilities that are currently undertaken by the LALOs.

46. In the early years of the SFRS, local area teams could bid for and utilise finance for local initiatives from a ring-fenced budget known as ‘the Chief Officer’s Fund’. The removal of this fund continues to be a source of concern and frustration for the CAT. Discretionary spend on a wide range of safety products such as deaf alarm pillows, fire retardant bedding etc., that could previously be targeted at vulnerable or high-risk members of the community is generally not now achievable without externally sourced funding. CAT personnel have undertaken work and invested significant team capacity into sourcing and securing external funding via charities that could be used to purchase a range of products used for the achievement of community safety outcomes. They described the process for them to have external funding accepted into the Service as “administratively tough” and more difficult than it possibly should be. The final consideration for the utilisation of any secured external funding was that it can only be spent on SFRS central contracts, which the CAT do not consider, in the circumstances in which they wish to spend this finance, to offer good value as the cost of goods appears higher than it would be on the open market.

Recommendation 3

The SFRS should consider the current arrangements that allows external funding for initiatives to be brought into the Service with a view to streamlining them to facilitate these financial inflows. These processes should consider the entry of external funding as well as the most appropriate value for money route to spending which maximises outcomes.

In Focus: HFSV’s Risk Critical Information

47. Home Fire Safety Visits (HFSVS) are a cornerstone in the SFRS strategy to keep members of Scotland’s communities safe in their homes. HMFSI understand that a new policy on the delivery of HFSVs is planned, and that it will lead to a stronger focus on high-risk households. During our fieldwork in the East and West SDAs it became noticeable that there may be some inconsistencies about how the information gained from a household could be used and who should be informed of it. This issue affected mostly On Call stations, where a number of reasons exist for HFSVs not being conducted by the crew members themselves but by the CAT members.

48. When conducting the NSDA fieldwork, specific questions were asked to allow the Inspection team to probe this issue further. While the practices we were informed of were not universal across the North, the information that was uncovered and triangulated across multiple interviews was significant enough that it was considered as a suitable ‘In Focus’ topic for this report. At the root of this issue is not just the safety of members of the public, but also of the firefighters who may be called to their homes in response to an emergency call.

49. While interviewing CAT personnel, we were informed on a number of occasions that high risk HFSVs had been marked on CSET as “leave for CAT team”. This was to ensure that a timeous visit could be undertaken to a household when there may not be the personnel resources available at On Call stations to do so or, in the opinion of the CAT, a higher level of CS knowledge may be required to make the HFSV as effective as It could be. HMFSI fully understand and appreciate this approach. The concern that we have, and which was borne out during our field work, is that firefighter safety critical information that is identified during the visit is often not made available to the home station personnel. This in our view presents a level of avoidable risk that could lead to negative operational outcomes.

50. The issue was crystalised during a visit to an On Call station who had attended a household several times for secondary fires and who had offered a HFSV on multiple occasions, all of which were refused. The crew subsequently attended a serious housefire at the premises, which was caused by misuse of matches by children, and which led to the family being rehomed in temporary accommodation in a neighbouring town. Following this incident the WC contacted CAT to discuss the premises in question and was informed that the household was indeed known to them, and that a HFSV had been conducted by them. The CAT confirmed that no information that had been gained during the HFSV had been passed to the On Call station.

51. This outcome was a concern to the WC who subsequently set up a local intelligence gathering group that consisted of the SFRS, police, local NHS partners, local social housing partners and local elected members of the Council. The meetings for this group are hosted at the fire station and intelligence is shared that could impact the safety of the community or of the public services who may attend any household locally.

52. This group shared intelligence about the temporary and then permanent rehousing of the family into their original home following its repair. At that time the crew offered a HFSV to the householder which was again refused. A subsequent offer was made and accepted by another member of the household and it was promptly undertaken. On entering the home, they found and noted a number of causes of concern, which given the previous history of the household could impact firefighter safety in future.

53. Subsequent interviews for this inspection confirmed that the practice of not sharing safety critical information with local stations, although not universal, was worryingly widespread across some areas. When questioned directly about the practice, CAT members advised that they did not share the information to ensure that the SFRS complied with GDPR and data protection regulations. One long serving CAT member told us that they were “limited in what they could tell crews (post HFSV), we haven’t been told definitively what we can share, we just don’t do it”. A senior NSDA FDO advised us that the view that HFSV information should not be shared was a commonly held one in areas of the North and that Information Governance instructed this.

54. To pursue the perception that data protection is a more paramount concern in relation to firefighter safety critical post-HFSV, the inspection team conducted an interview with a member of the SFRS Information Governance team. They informed us that safety of firefighters would be the paramount concern, but that data and information must also be dealt with confidentially and sensitively. It also transpired that following a previous but unrelated significant data issue for the SFRS that specific training regarding data protection had been delivered to personnel from P&P, including SCs, CAT, and LALOs. This training was described as “directive” and was firmly delivered following what was a serious incident for the SFRS. It appears that this directive training to address a data protection incident in the Service has led to a conflation of what HFSV information should be treated in strict confidence and not openly shared, even when it appears to be potentially risk-critical for firefighters in an operational context.

55.It is our view that there are restrictions on the sharing of safety critical information following HFSVs being conducted by CAT members in some areas of the North. It is also clear that this has the potential to lead to serious negative outcomes for attending fire crews at operational incidents who may not be in possession of the full intelligence picture that could be available. These gaps in operational intelligence are avoidable.

Recommendation 4

The SFRS should engage with Information Governance, CAT, LALO, Prevention, Protection and Preparedness (PPP) and operational personnel to review how Firefighter safety critical Information should be recorded and then disseminated following HFSVs. This should be done as a matter of urgency.

Protection

56. The NSDA contains a very wide range of non-domestic properties including those in the health and care sector, industry, tourism and hospitality sector etc. For most non-domestic buildings in Scotland the SFRS is the enforcing authority for fire safety as set out In the Fire (Scotland) Act 2005. Many of these premises are deemed ‘relevant premises’ by the Act and as such will have ‘duty holders’, responsible for ensuring that suitable and adequate fire safety measures are in place within them. As the enforcing authority, the SFRS has a legal duty to ensure that advice and guidance is given to duty holders and to ensure enforcement of the Act.

57. The SFRS PPP Directorate operates a system of proactive fire safety audits within premises, reactive audits in premises where fires have occurred, and dealing with complaints, enquiries and contraventions. This system is functional in support of the SDAs and should ensure a consistent approach across Scotland. Proactive audits are conducted using a risk-based approach, following a national enforcement framework, which focuses on those premises which are considered to represent the highest life risk from fire. These premises include care homes, hospitals and sleeping accommodation premises such as hotels.

58. Each LSO has a LEDP which sets out the work priorities for the PPP local FDO managers, Fire Safety Enforcement Officers (FSEO) and Auditing Officers (AO). Across the NSDA we were informed that the LEDP is a valuable governance tool as it details local priorities for framework premises. These are then placed onto a risk-based register for the audits to be undertaken by the FSEO and AO personnel as part of a structured work plan. Each FSEO has a work target of 122 audits that require to be undertaken each year. Audit targets are generally considered by the FSEOs to be achievable. We were advised however, that they can be impacted by unplanned work, such as reactive audit inspections, dealing with complaints from the public, and most notably by the ongoing volume of STL licencing applications. The achievement of the 122 annual audit target can also be impacted by capacity being lost to dealing with compliments, complaints and enquiries that are received by the FSEO team. There was a systematic approach to dealing with this work, and it is dealt with in a consistent manner across the NSDA. The work generated by complaints and enquiries, however, is often uncredited and it can impact available audit capacity. Similarly, there have been prohibition and enforcement notices served on duty holders of premises within the NSDA. These notices attract high levels of media, legal and LA scrutiny and as such they are dealt with as a priority and require significant resources and time to be expended on them. One other significant factor that can impact upon the achievement of the audit target, is the geography of the NSDA and the travel distances and planning that may be required to reach any relevant premises for audits to be undertaken.

59. During our inspection, PPP personnel reported that STL licencing applications have placed a very high demand upon the capacity of the enforcement team. The SFRS is a consultee for these licence applications. Across the four LSO Areas that make up the NSDA there is an ongoing STL application backlog that collectively numbers in the hundreds. The number of licences applied for remains consistently high due to the volume of new applications that are made; this is despite the efforts of the SFRS to reduce them. There was a similar picture for STL applications within the East and West SDAs. STL licencing is a challenge for the SDAs as each LA has a slightly different approach and there remains a lack of guidance from the PPP Directorate on how these should be processed. This has led to LSO areas applying different approaches. The duty for the issuing of STL licences lies with the LA, who will issue a licence to the applicant. One NSDA LSO has introduced a change to correspondence letters to emphasise the ‘advisory’ role played by SFRS and to free up auditor capacity. It is hoped that this approach, which we are told has reduced demand, will place the workload back onto the LA which both issues the licence and charges a fee for doing so. This should hopefully allow the enforcement team to focus on high-risk premises when their expertise may be required. STL demands are a large drain on the NSDA enforcement teams’ capacity, for which there is no facility for recharge of service back to the issuing LA, who charge circa £600 per licence. In recognition of the lack of capacity to deal with STL applications, several contracts for three hours per week have recently been issued to On Call staff within the SDA. This will clearly assist in alleviating some of the work pressure, but it is another financial cost that is being borne by the SFRS.

Good Practice 2

The Service recently introduced a change to its STL licencing paperwork to emphasise the ‘advisory’ role played by the SFRS in the process. This is a positive move that should reduce the capacity that is required for this function.

Recommendation 5

The SFRS should produce national STL guidance for use across the Service SDAs. They should produce national STL governance documents for issue to licence applicants that makes clear the role of the SFRS and the primary role of the LA issuer. The SFRS should engage LAs to allow a common understanding of the role that both parties play in the issuing of STL licences.

60. Like other groups of personnel across the SFRS in recent times, the enforcement team has lost staff to retirement ahead of projected leaving dates. This is due in part to changes in pension regulations. We understand that the gaps in the team have been addressed but that there is now a significant number who are not yet classed as being experienced or competent in role, which is estimated to take two years to achieve. This has been ameliorated to some degree by the recent employment of two former experienced FSEOs as support staff AOs. These two AOs operate on a peripatetic basis across the NSDA. We are told that their previous skills and experience have been a welcome addition, and that they are effective mentors for the new enforcement team members as they work towards competence status. To assist with the challenges of geography, training for local training officers and On Call Support Watch Commanders (OCSWC) within WIOS is to be undertaken to establish a cadre of auditors. While we welcome initiatives such as this, it must be tempered by the expectations that might be placed upon these personnel and the level of audit that they should be expected to undertake, as well as the level of support that they will need from PPP, as they work towards achieving competence in this role.

Good Practice 3

Personnel have been placed on training courses to allow them to gain Fire Safety modules qualifications in advance of them joining PPP as FSEOs. This learning is supported by time allowances by the Service.

61. The SFRS utilises the IT-based PPED to record premises audit outcomes. In keeping with the findings of the East and West SDA reports, we received a number of comments regarding PPED. The most positive comment we received was that “it works to a certain degree”, but in the main it was not viewed positively. The system can be frustrating and challenging to use for those who are required to enter audit data into it. We were advised that loss of data is a frequent occurrence and has led to FSEOs maintaining their own records of audit outcomes and PDF captures of inputs to PPED to mitigate this. FSEOs told us that the duplication of data input and capture impacts their efficiency and leaves them concerned that important audit information could be lost due to the inherent operating flaws of PPED. Within the NSDA a workplan approach has been created which allows FSEOs and AOs to view the audit workload, which is categorised by risk, and to tackle it on that basis. This has not been Service-driven, but was developed locally as the PPED system does not have this level of functionality.

62. PPP staff working in the NSDA informed us of consistently positive and professional working relationships with a range of external partners in the NHS, LA licencing and building control teams. Engagement and information exchange with these partners is conducted on a near daily basis to ensure that the highest priority cases for licencing and audits are promptly dealt with.

Preparedness- Operational Intelligence

63.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 Getac tablet device within the cab of the fire appliance.

64. The provision of up-to-date and accurate information to firefighters is important in effectively responding to incidents when they occur. We saw varying quantities of available information across the NSDA LSO areas. There are processes in place for firefighters to collect OI. However, we noted that in areas covered by On Call appliances, firefighters from those stations were often less likely to be involved in the collection process. The reasons for this were varied, but in the main it was due to their non availability in relation to their primary employment responsibilities. A number of stations did have an On Call firefighter with the work reference for the collation of OI, and these individuals would often work with the local OCSWC to ensure that the relevant data was collected and input to the OI system. Where this system is in place there is the obvious advantage of collation by a member of the local personnel. However, we did not find a consistent level of assurance that the information was then fully imparted to the remainder of the On Call crew. We found that the maintenance of OI knowledge for an On Call crew was one of a number of items that were subject to the time pressures of the weekly training night.

65. During this inspection we received many affirmations that the OI system, and the demountable tablet that holds it, is used in an operational capacity. We found that this use was in the main to confirm hydrant locations, occasionally to check details of SOPs and unfortunately in rarer instances, “where time allowed”, at or enroute to an operational incident, to check the OI information of a site or premises. The use of the system on the islands was deemed to be less effective due to the Getac tablet requiring, for update purposes, to be located off the fire appliances and thus needing to be physically gathered as part of a station mobilisation.

66. The OI system is being used in an innovative way across the NSDA to ensure that site-specific information (SSI) that has been gathered from HFSVs can be accessed by operational crews. This information would normally be logged by the OC team on the SFRS mobilising system and be automatically generated for responding operational crews when an emergency call is received. The Service has recently announced the procurement of a new mobilising system. The existing system is now aged and cannot have significant amounts of new data input to it. In the intervening period before the new system comes live, the use of the OI system to log SSI is an approach that allows firefighters to have a fuller picture of the vulnerabilities that may be relevant to persons who reside in locations that they are mobilising to.

Good Practice 4

The use of the Operational Intelligence System to log and make Site-Specific Information that is gathered during HFSVs accessible to operational crews via appliance Getac tablets is a good example of innovation.

67. As has been previously reported in the 2019 HMFSI Thematic Inspection report of the management and provision of risk information, and the East and West SDA reports, there remains issues with the automatic up-dating of the Getac tablet device. This is a national problem and one that the Service has been trying to address. It is disappointing 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. HMFSI has also had a demonstration of the new system and hardware that will replace the current OI arrangements, and we are encouraged with the potential that it appears to have.

Business Continuity Plans

68. Business Continuity Planning (BCP) within the NSDA is based on guidance in line with the Civil Contingencies Act 2004 (CCA). The Act requires the SFRS to plan and to consider foreseeable hazards and threats to the ongoing business of the Service, and to put in place mitigation for any impact from these. Within the NSDA, the Civil Contingencies Officer (CCO) cadre have received formal training on the formulation of BCPs and support the local LSOs in developing and reviewing plans for their stations and sites. For this report we sampled existing NSDA BCPs and found them to be complete, correctly detailed, current and within their review cycle. There was recent support provided by NSDA CCOs for a review of fallback sites that would be used should fire stations be rendered unusable for any reason; these details are include within exiting BCPs. The CCOs deliver local BCP training to the LSO teams and their officers who will have responsibility for the compilation and review of the local plans. We are content that BCPs have been developed and are in place for the NSDA and that these are reviewed on a sampling basis with the support of the CCO group.