Report on the Scottish Fire and Rescue Service's planning and preparedness for COVID-19 (Light Touch Review)
The main purpose of the SFRS is to work in partnership with communities and with others in the public, private and third sectors on prevention, protection and response to improve the safety and wellbeing of people throughout Scotland. In order to effectively support this strategy during the ongoing crisis, the SFRS has created a bespoke COVID-19 Tactical Action Group (COTAG).
The main purpose of the COTAG is to ensure that the SFRS continues to operate efficiently and effectively, whilst maintaining a high standard of Service Delivery during this period of uncertainty and potential disruption, through effective BCM plans. It is also responsible for ensuring that all areas of the Service are prepared and equipped to maintain service delivery safely, in challenging conditions that may be presented by COVID-19, in support of its aims and objectives.
A Senior Responsible Officer (SRO) at an Executive level has been appointed by the SFRS to chair the COTAG, routinely the ACO Service Delivery, which will convene on a daily basis during normal office hours, with the chair delegated to a duty officer outwith these times. The COTAG Chair will normally be the direct link to the Scottish Government Liaison Officer (SGLO) should there be a need to brief SG directly on behalf of the SFRS Gold Commander.
The COTAG is supported by two sub-groups:
Operational Availability Sub Group – Responsible for:
- Developing a range of scenarios on reduced staff availability
- Reviewing the effectiveness of the Appliance Withdrawal Strategy (AWS)
- Updating the appliance withdraw hierarchy in line with the current situation
- Developing staffing guidance for staff
- Monitoring staff attrition and recruitment scenarios.
Civil Contingencies Sub Group – Responsible for:
- Providing regular COVID-19 information updates to the COTAG
- Acting as conduit for all information supplied by partner agencies to the SFRS
- Providing information to local managers attending LRPs on the current SFRS position.
The COTAG will feed into and offer advice to SFRS Gold, Silver and Bronze Commanders, Operations Controls, Incident/Event Support Rooms, Multi-Agency Coordination Centres (MACCs) and internal Heads of Function. To ensure that all areas of the Service are prepared and equipped to maintain service delivery safely.
Any actions coming into the Service are recorded and actioned appropriately, with plans updated as required.
Reporting is carried out on a daily basis beginning with a Common Recognised Information Picture (CRIP) feeding into internal staff briefings culminating in a Scottish Government Submission at 14.30 hrs every day, giving a summary of the SFRS response readiness.
The SFRS has a robust Governance Structure and Reporting Protocol which is well developed, and has an appropriate weight of authority and support to play an accountable and leading role in mitigating the effects of the crisis.
3.2 Service Delivery
The SFRS has produced a comprehensive suite of documents in support of its COVID-19 response, which are continually being refined and updated as more intelligence is gathered, guidance produced or challenges emerge. At the time of writing, some of the finer detail was sparse but we are assured that documents are continually updated as guidance evolves.
It can be reasonably assumed that business as usual will be negatively impacted by potentially high levels of staff absence. Furthermore there exists a possibility of a significant and swift reduction in the Service's operational response. At the time of writing, the SFRS is reporting that the level of appliance availability is up to 96%, which considering the rate of national virus spread is a strong position, but may possibly be a consequence of increased availability of RDS pumps, due to restrictions placed on the normal primary employer work activity of crews.
In pre-planning for a reduction in operational response the SFRS has an Operations Control (OC) Resilience Strategy and an Appliance Withdrawal Strategy:
OC Resilience Strategy – The SFRS has OCs located in the North, East, and West of Scotland. For the duration of the crisis each is treated as an island site to prevent the possibility of cross contamination. The SFRS has mitigation strategies to improve staffing, if required in OCs, including re-engagement and the re-allocation of staff roles where skills allow.
An OC's operational capability is predicated on maintaining a minimum staffing number in order to carry out essential duties. In pre-planning for a reduction in normal staffing the Service has a three tiered response, based on crisis escalation. The SFRS has successfully tested its planning assumptions to prove resilience at all of its OCs.
Appliance Withdrawal Strategy – The SFRS has operational appliances at 356 Fire Stations across Scotland, some of which have multiple appliances. In order to pre-plan for a severe and prolonged staff reduction, it has categorised its pumping appliances into three priority bandings, which will drop off from operational response on a controlled basis. The SFRS is employing mitigation strategies in order to maintain appliance availability including reducing ridership factors from five to four Firefighters on a pump where practicable (this will be continuously reviewed), re-engagement of those operational staff recently retired and the re-allocation of staff roles where skills allow.
In order to carry out a phased reduction effectively the SFRS has produced a four tiered reduction in response based on crisis escalation, Tier 1 (100% - 96%), Tier 2 (95% - 80%), Tier 3 (80% - 60%) and Tier 4 (60% and below). At the time of writing, the SFRS is operating comfortably in Tier 2.
Should the Tier 3 level of attrition be reached the SFRS will introduce a temporary response reduction, according to incident type. Local officers are liaising with stakeholders as to what this reduction will look like in order to inform their risk assessments.
As the SFRS capacity diminishes it will undoubtedly have an impact on its ability to support large concurrent events. In consideration of this, the SFRS National Event Concurrency Risk Matrix has been reviewed and updated to fully assess reasonably foreseeable events, weighted against current mitigation policies, procedures and protocols utilising Reasonable Worst-Case Scenario (RWCS) of the effects of COVID-19.
We challenged senior managers in the SFRS on the evidence presented, to ensure the delivery of an effective operational response and were given assurances that the comprehensive planning and procedures produced are suitable and sufficient.
3.2.1 Training and Operational Competence
It is safe to say that mitigation strategies to limit the exposure to and spreading of COVID-19, will impact on training courses and training opportunities thus affecting competence levels of staff.
It is reported that all non-essential training has been cancelled and that risk critical training will go ahead based on a risk/benefit analysis.
Retained Duty System (RDS) training nights have been cancelled for a three week period, albeit staff will still be paid.
We feel that this is entirely appropriate in support of the Government strategy for social distancing, but feel that competence levels will have to be closely monitored, in order to reduce the likelihood of skills decay down to unacceptable levels. We are particularly concerned about the effects on RDS Firefighters who, as reported in our review of RDS Training are, under normal circumstances, severely limited in their ability to train for operational competence.
3.2.2 Partnership Working
The Civil Contingencies Act 2004 places a legal obligation upon emergency services and local authorities (defined as "Category 1 responders" under the Act) to assess the risk of, plan, and exercise for emergencies, as well as undertaking Business Continuity Management.
Historically, the SFRS has worked hard to build good relations with Regional (RRP) and Local Resilience Partners (LRP) (both category 1 and 2 responders) in order to work effectively and efficiently during difficult times. The SFRS, in its planning for a COVID-19 response is supporting these platforms at an appropriate level with DACOs attending RRPs and LSOs attending LRPs along with civil contingencies officers who add expertise and continuity to the process.
The Scottish Ambulance Service (SAS) in conjunction with all health sector workers is working incredibly hard in response to the demands of COVID-19. The SFRS is working closely with the SAS to mitigate any joint response issues with effective de-conflicting strategies working well to harmonise joint working in support of mutual aims and objectives.
The SFRS has recently reviewed the existing section 35 and 36 arrangements of the Fire (Scotland) Act 2005 for mutual aid and cross border assistance. The Service has a Memorandum of Understanding (MoU) with Northumberland and Cumbria Fire and Rescue Services and these are operating under 'business as usual' at present.
We consider these arrangements appropriate with the correct weight of authority and support to play an accountable and leading role in mitigating the effects of the crisis at a multi-agency platform.
3.2.3 Communication and Engagement
The SFRS recognises the changing way that people are living their lives during the COVID-19 pandemic, most particularly during the current lock-down. This change has resulted in a change in risk profile for communities. The SFRS is responding to this change through a targeted community engagement strategy focusing on supporting the public, relevant premises duty holders and partners.
a. Community Safety Engagement
- The SFRS has halted its Home Fire Safety Visit (HFSV) programme to prevent transmission of COVID 19, the Service is developing digital HFSV checklists
- In response to the lock-down the SFRS has developed COVID-19 specific home fire safety messaging, launching a TV advertising campaign on 28 March, running to 12 April. This includes a focus on five key elements; cooking, smoking, smoke and heat alarms, electrical safety and establishing a night time routine. Each of these messages is supported by specific social media campaigns
- The SFRS is also developing awareness campaigns to target emerging issues such as the accumulation of combustible materials. This message is also expanded to duty holders in non-domestic premises concerning the storage of goods and materials safely.
b. Fire Safety Enforcement
- The SFRS has ceased its routine fire safety audits although it is still has a response to high risk issues and complaints
- To support those vulnerable in the community during this difficult time, the Service is working with the relevant partners including the Care Inspectorate (CI) and Health Facilities Scotland (HFS)
- For both the CI and HFS, the way it operates within its MoU has been reviewed. It has developed Joint Working Agreements to support the streamlining of processes to open new facilities
- The Service has circulated guidance to its LSO areas, to engage with the duty holders for non-domestic premises regarding issues such as reviewing their Fire Risk Assessment (FRA), in light of any COVID-19 related changes and the safe storage of stock or materials.
c. Youth Volunteer Scheme
Youth Volunteer Schemes are a valued part of the SFRS. To ensure the continued engagement with these groups a digital strategy for communication is being developed. All training content is being reviewed with a view to supporting online delivery. Webinars for Youth Volunteers are being considered as part of this review.
d. Unwanted Fire Alarm Signals (UFAS) - The Service is reviewing its UFAS policy.
It is also reported that the Service has a process in place, which includes the consideration of requests for assistance from communities and partners. We would hope that there will be a consistent approach to all LSO areas of the Service
HMFSI is content that the SFRS is reportedly addressing the fact that people's lives may have significantly changed during this lockdown phase of the COVID-19 pandemic and is taking steps to mitigate associated factors and that these are suitable and sufficient.
3.3 Critical Support Functions
In line with the majority of organisations the SFRS has introduced homeworking for its non-operational staff where this is possible, which is reported to be operating well, with ICT structures coping with versatility and demand. The procurement department is reported to be operating efficiently under these constraints with no noticeable slow down or loss of normal provision.
There is however, concern over the ability to procure disposable PPE items such as latex gloves, disposable aprons and face masks following a NHS England communication to suppliers of these products to only supply the NHS. To mitigate this in the short term, the SFRS has alerted staff to use PPE appropriately as at present they have a finite stock. This issue has been escalated, see detail in risks and issues below.
3.3.2 Appliance and Equipment Testing and Maintenance
As is to be reasonably expected, a reduction in staff will cause a reduction in output or service. This will manifest in different ways depending on the issues at hand. The SFRS has reported that internally its fleet and equipment function is operating at normal levels with no noticeable reduction in output at this time. This will be monitored and contingency plans put in place as and when required.
Although RDS training nights are cancelled for three weeks, staff have been given authority to carry out critical maintenance which will include local based equipment inspection, testing and maintenance which will ensure, if carried out appropriately, that equipment remains ready for operational use.
An area of concern for the Service is the continual compliance with legislation such as the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER). The Health and Safety Executive (HSE) is not currently relaxing regulations during the crisis. Legislation requires the equipment to be tested against a standard by a specialist in a certain field. If the availability of specialist equipment inspectors' becomes compromised, it will become difficult to comply with current inspection regimes. The SFRS will have to carry out a risk based analysis when a piece of equipment falls outwith compliance as to whether or not it can remain in service. Further detail is noted in risks and issues below.
HMFSI is content that critical support functions within the SFRS are reported to be working well and we are given assurances that contingency planning is suitable and sufficient.