FBU Response to the RBFA IRMP Action Plan 2012-13 Consultation

Introduction
The Fire Brigades Union (FBU) welcomes the opportunity to comment on the draft Royal Berkshire Fire Authority (RBFA) IRMP Action Plan for 2012/13. The FBU’s comments are intended to be constructive and based on the principles contained within its IRMP Framework document which has in the past; been distributed to RBFA Members and RBFRS Senior Management.   

The FBU firmly believes in and supports the process of IRMP as described in all of the current national guidance documents.

That said, the FBU fully recognises the current financial climate as imposed on RBFA by Central Government but does not support the approach taken thus far.

Last Year’s Action Plan
The Fire Minister Bob Neill indicated that efficiency savings could be achieved through a series of measures including the following which have not been, nor continue to be, adopted by RBFA:

• Shared services/back office functions
• Improved Procurement
• Sharing Chief Fire Officers and other senior staff
• Voluntary amalgamations

The result of the Authorities’ approach has been to implement hastily thought-out front line cuts and changes without them being thoroughly researched. This resulted in over £6M being ‘banked’ for capital projects at a time of austerity, pay freezes, pay cuts and actual and threatened redundancies.

The FBU fully recognises and supports the Prevention and Protection work which has assisted in the reduction of risk critical incidents however; it should also be recognised that incidents whether, preventable or not, will occur. To this end, it is the FBU’s professional opinion that the Authorities’ ‘rush for the cash’ in risk critical areas has exposed RBFA to an unprecedented risk in relation to Response activities that should, and could have been avoided.

Over the past twelve months we have witnessed a worsening service through:

• Increased attendance times
• Increased inability to deliver the required resources to the incident ground
• Increased risk to firefighter safety
• Increased risk to public safety.

The cuts already imposed and those being proposed are looked at in an insular and blinkered way and take no account of their consequential cost and impact on society and the wider economy.

If one fire could have been stopped from spreading or a casualty at an RTC extracted quicker and received earlier hospital medical intervention, all of these changes will cease to be cost effective.

What an IRMP should be
At its simplest level, Integrated Risk Management Planning (IRMP) is just taking a planned approach to delivering the business activities of Royal Berkshire Fire and Rescue Service (RBFRS). A true IRMP is therefore a process that, if done properly, leads to a risk assessed, performance driven, cost effective improvement in RBFRS’s provision delivered by a safe, well trained and motivated workforce.

The FBU fully supports and endorses RBFA’s stated aim that “The aim of the Service’s Integrated Risk Management Plan is to deliver the Right Resources at the Right Time, in the Right Place.”

The IRMP Action Plan for 2012-13, like its more recent predecessor continues to be based first and foremost on finance and it is therefore disingenuous to call it a risk management plan when in reality, it is about the management of money – not the management of risk.The proposed action plan will deliver Some Resources at Some Time, in Any Place.The following comments relate to the particular sections of the IRMP 2012/13 Action Plan (Consultation Document).

General Observations
The Fire Brigades Union general observations on the 2012/13 IRMP Action Plan for Royal Berkshire Fire Authority are:

• Overall, there is no plan to improve attendance times to dwelling fires and road traffic collisions
• Still no plan to set commercial and heritage response standards including weight of attack
• Fire cover in Newbury, Maidenhead, Windsor and Slough will continue to worsen.
• Wholetime fire engines will be crewing with four firefighters more often and subsequently will be able to achieve less at dynamic emergency incidents.
• The resilience for command and control of larger and protracted incidents is not being addressed.
• The IRMP is not a properly integrated plan. 
• The approach to IRMP and to managing the budgetary pressures does not adequately reflect national guidance leaving the Authority exposed to criticism and is now having an impact on the wellbeing of the general public as well as the firefighters.
• The plan implies that further front line posts will be removed, this against the continued expansion of support staff

Recommendations

• There should be a place in the IRMP documents to detail how performance is progressing against the baseline figures. 
• The Authority should be reporting each year in the IRMP documents whether the changes being made in IRMP are improving performance.
• The Authority should ensure that there is consistency in reporting the statistics from year to year and where there are anomalies, these should be explained.
• The Fire Authority should engage directly with the union to resolve issues in relation to solutions and improvements to firefighter and public safety

Observations

Chairman’s Foreword
The Chairman states that this plan highlights the key actions that RBFRS will be taking to ensure we continue to provide a good service for the public in Berkshire. The FBU is concerned at the perception that we are providing a good service as front-line services are, to a degree, being eroded such as increased switch-crewing, delayed attendances to higher risk incidents and delayed attendances to fires at commercial premises. 

If the Chairman’s comments in the foreword are to mean something then they should reflect the reality of the difficulties being faced by the Authority.

Our Performance
As stated last year, a lot of work was done in previous years in setting baseline figures for IRMP against the response standards. The idea was that there would be a rolling baseline figure that advanced by one year each year. At its inception the RBFA clearly stated that changes would result in a year on year improvement in performance yet again disappointedly, RBFRS’s own data demonstrates a clear decline in performance.

The FBU continues of the view that there should be a place in the IRMP documents to detail how performance is progressing against the baseline figures.  The Authority should be reporting each year in the IRMP documents whether the changes being made in IRMP are improving performance.   

Prevention
The Fire Brigades Union notes that the statements made are a matter of fact and are not measured against previous year’s performance or against the Strategic aims.

Protection
Again the FBU reiterates its previous statement and wishes to express its concerns that following the introduction of the new Officers Rota there will not be 100% availability of Fire Safety officers to carry out statutory duties as issues arise. 

RBFRS suggests that it reduced AFA’s by 20% when it fact it has taken the decision not to attend and there were occasions where a reduced attendance was sent which on arrival turned out to be a more serious incident.

It is also suggested that the department assisted in reducing fires in commercial properties by 3.6% – where is the evidence?

Emergency Response
The FBU cautiously welcomes the continued reduction in the overall numbers of incidents attended by RBFRS. The reason for this caution is based on the fact that RBFRS management make the decision not to attend when requested to do so by the very people we exist to serve – members of the community in distress. It could be argued that incidents are predominantly there, we choose not to respond.  The FBU’s opinion is therefore that the reduction is partly as result of previous years IRMP’s outcomes and preventative campaigns however, this reduction is primarily due to the non attendance which has been to the detriment of the members of the community who we exist to serve.

Initiatives introduced without public consultation and outside the scope of IRMP include the non attendance to Road Traffic Collisions where persons are not trapped, flooding incidents, persons shut in lifts to name but a few.

If we are an emergency service and members of the community we serve ask for our assistance do we not have a moral duty to assist them?

Response to Road Traffic Collisions
The 2002/3 is the Baseline against which the Authority measures its performance. Following the introduction of the IRMP process and despite assurances that it would demonstrate year on year improvement, it can clearly be seen that the opposite has been delivered.

The 84.4% shown in 2010/11 is a clear demonstration of ‘if it doesn’t fit – make it fit’. The criteria has been changed so that it only captures attendance at 11 minutes when persons are actually trapped – not against the 11 minute attendance. This practice was introduced last year following a ‘successful trial’ but this was at the expense of the depletion of fire cover in risk critical areas.

Response to Dwelling Fires
Again, the FBU reiterates its previous statement. Despite continuous upheaval, performance in this risk critical area continues to fall against both measuring criteria’s.

RBFRS states that “All failures to achieve the attendance times are thoroughly investigated by managers to identify the rationale and to establish where and how improvements can be made”. This is a misleading statement as RBFRS no longer measures against the 8 and 10 minute standards as evidenced in the Intranet Station pages.

This is of grave concern to the FBU as clearly the longer we take to get there, the higher the risk of injury and death to firefighters and members of community. It goes without saying that it also results in preventable losses.

The statement contained within the document that “The reason for this is the number of calls to dwelling fires has reduced over time, with some now occurring in more remote locations from fire stations, which has an affect on our attendance times” is not quantified and the plan no longer shows the baseline graph which indicated the levels of activity in this area year on year. In the absence of evidence, the FBU strongly challenges the accuracy of this statement.

Nothing in the action plan attempts to address this continuous failure and members of the community continue to be exposed to a higher than necessary risk of injury and death. The FBU would challenge the Chairman’s assertion that RBFRS is providing a good, efficient and effective service.

The FBU agrees that the availability of Retained appliances needs to be improved throughout the County and that Retained firefighters should be fully supported by RBFA’ The introduction of the Retained Support Unit is long overdue however; by RBFRS’s own admission risk critical incidents in areas covered by Retained appliances are very low, the FBU would challenge how that statement is quantified.

The rationale and evidence against which the Baselines were set, is clearly demonstrated in the following graphs.   

The following image clearly demonstrates that the rate at which the size of any fire increases itself increases with time. For example, between minutes 3 and 4, the fast-growing fire increases in size by about 12 units, but between minutes 9 and 10 it increases in size by over 40 units. If a person has survived near to a fire for nine minutes, one minute later the fire could have increased in size by such an extent that they will be killed.

Likewise, the longer we take to get there the more resources will be required to deal with the incident as demonstrated by the following graph.

To date no standards have been set against commercial properties

What We Have Done in 2010/11Attendance at Road Traffic Collisions
The FBU welcomes the investment made in the new Heavy Rescue Unit which has undoubtedly improved our capability to deal with current and a wider variety of incidents. Having made such an investment, the Authority then ignored the professional concerns raised by its employees and the FBU as their representatives. We maintain that the HRU/RSV should attend all incidents thus ensuring that the appropriate resources are available if required and this will also assist in the maintenance of fire cover.

The FBU refutes the text contained in the IRMP action plan as being incorrect and misleading. FBU representatives fully participated in the review project and have always maintained that there should be two fully crewed units in the County.

The FBU representatives never agreed that the HRU Unit should be based at Dee Road Fire Station nor did they agree that the unit should loose its dedicated crewing.RBFRS management continuously challenge the mobilisation of the units and this has resulted in them not being mobilised when they were required. The removal of the HRU crewing now results in Newbury loosing its fire cover when the unit is requested.

More concerning is the fact that there will come a time when the HRU unit is required but it will not be mobilised until an appliance is in attendance resulting in an unacceptable delay, if we can find a crew to take it, and potentially will lead to more serious injuries than would have otherwise occurred and potential death through delay in extrication.

Additionally, by not mobilising the RSV at Slough the East of the County is regularly stripped of adequate fire cover which is recognised as the highest risk area within the County.

Using CLG’s Fire Service Emergency Cover (FSEC) formula would indicate that a 10% increase in RTC response times translates into a 7% increase in predicted fatalities at RTCs. It stated that an average response of eight minutes has a predicted fatality rate of 0.097 per life risk incident, versus 0.104 for an 8.8 minute response time. Previous work has estimated that there are about 1,000 fatal RTCs attended by UK FRSs. Therefore, a 7% increase would equate to about an extra 70 deaths in the UK per year, or about 65 for England.

The Authority failed to assess the financial benefits against the societal risks and the outcome of the implementation thus far is having an adverse effect in relation to the dwelling fire and RTC response standards.

Low Risk Call Attendance
A cost saving measure which; resulted in the resignation of Retained (RDS) firefighters from an already stretched service. This has led to a drop in confidence and morale of the RDS personnel and an increased exposure to a higher risk of accidents and injuries. A result of the introduction of this policy is that response standards for dwelling fires and road traffic collisions have been affected as high risk areas are left exposed.

Review Of Emergency Cover
Whilst welcoming the proposed move of Dee Road Fire Station to the Calcot area which will undoubtedly improve response times, the FBU is somewhat disappointed that this decision has come about due to the need to relocate the headquarters building and not based on the overwhelming evidence identified in 2007 and supported by the FBU at the time.

We do not support the decision of not going ahead with the proposed Twyford Fire Station as Wargrave Fire Station’s fabric is outdated and not fit for a 21^st Century service. The Twyford option would result is a building fit for the 21^st Century and ensures the long term presence of such a vital resource in the local community.

The figures quoted in the document are misleading and wide of the mark as they are taken from the work carried out in providing a full time station at Wokingham with accommodation for personnel providing 24 hour cover.

The proposed Twyford Fire Station would be of a much smaller scale therefore requiring a smaller plot of land and significantly lower building costs.

Training Review
This review has now been completed and the FBU urges the Authority to carefully consider its recommendations and look at ways of implementing them thus leading to a more competent, well trained workforce.

Officers Review 
In its response to the 2010/11 IRMP plan, the FBU encouraged the RBFA to engage directly with the union to resolve issues in relation to the Officers’ Cover Review. This request never came to fruition.

Interim arrangements have been implemented resulting in the loss of 5 Officers. This 10% reduction is now impacting on the ability of RBFRS to maintain a safe level of Officer cover and is impacting on workloads. In April a further 10% reduction is being introduced and the FBU has serious concerns that safety, operational resilience, managerial capacity and individuals’ health will be maintained and supported.

The FBU has always argued that the reduction now being implemented did not have any resilience and the number of Officers did not match the levels required to meet the workload demands. Following the internal re-structure consultation, RBFRS now proposes to employ a further (in addition to the two already employed) four non-uniformed project managers.

Given that the cuts were driven by the austerity measures resulting in significant savings, how are those savings being realised when you employ six new members of staff? The resilience issue continues to not being addressed.

Retained Review
The concerns raised at the last consultation in relation to the loss of the training reserve have become true even before the introduction of the Retained Support Units. We now see appliances crewing with four riders on a daily basis as opposed to the Authority’s policy aim of crewing with five. The document states that “The Retained Support Officers have been provided from existing resources, without affecting emergency cover to the community.” Although true, the removal of these existing resources are affecting our ability to deal with incidents in a safe and effective manner.

Attendance At Automatic Fire Alarm Incidents
Following the challenge to last years IRMP report, it was recommended to and agree by the Authority to introduce a one appliance attendance to domestic alarms between the hours of 09:00 and 18:00. Is the Authority aware that this was subsequently changed to between 0800 and 2100 hours? 

The plan only indicates a reduction of calls attended but does not state how many of those alarms were in fact fires, of which there have been a few, leading to an unnecessary risk to the health and safety of responding firefighters and increased losses to the owners/occupiers.

Action Plan 2012/13 – What We Are Going To Do This YearReview Of Specialist Appliances
If it is proposed to carry out the reviews during 2012/13 why is it that some have already started and must be completed by April 2012 when the document is still under consultation? Yet again the FBU is seeing a ‘rush for the cash’ and a consultation process being undertaken when the decisions have already been made. This demonstrates contempt for the professional opinion of firefighters and the valuable engagement with the community we serve.

The FBU proposes that these appliances are required and form an integral part of our response effectiveness and as such we urge the Authority to include within this review crewing methods. Today, our ability to deliver these units to the incident ground is being seriously challenged as we do not have the personnel to deliver them to critical incidents without undue pressure on our ability to deal with the incident and provide fire cover.

Aerial Ladder Platform (high reach appliance) at Slough
It is widely known that RBFRS management wish to remove this appliance from its fleet. It has been previously stated that this appliance is not often used, and when it is used, its not very often for rescues, so therefore it doesn’t matter if there is a delay getting it there as most of the time it is only used for firefighter safety or putting water onto a big fire.

However, aerial appliances are a critical tool in maintaining firefighter safety, affect rescues on a regular basis and are regularly used at medium and large incidents in Berkshire.

The removal of this appliance will lead to a lack of resilience and since the only aerial appliance will be based at Whitley Wood fire station, it will have an impact on RBFRS’s ability to crew the OSU and HERU. Additionally should it be needed to carry out rescues, any delay in is arrival could seriously affect the outcome of a potentially successful rescue.

Replacement For Dee Road Fire Station
In addition to the comments already made under the “Review of Emergency Cover” the FBU urges the Authority to consider locating the fire station within the new headquarters complex. This would lead to a considerable capital expenditure saving and ongoing capital and revenue savings for the life of the building.

In line with the areas identified in the risk map, this location would deliver the desirable increased performance in response times.

Windsor Fire Station
The FBU continues to have grave doubts about the proposal to respond to incidents in the Windsor area with the L4P van crewed by 3 fire-fighters. The Fire Authority has been unable to demonstrate that this will provide a safe and effective service to the residents of Windsor. It is important to note that no other UK fire and rescue service has adopted a similar provision in respect of primary fires. This fact alone should encourage the Authority to be cautious.

The L4P was brought into service on a risk-assessed basis to provide fire cover to the CockMarsh area of Maidenhead, which has proved difficult to access in the past. It does not hold that this minimal level of service provision can then be transferred to a major town without any detriment to the residents it is there to protect – Windsor’s built environment presents no problems with access that would justify the use of this vehicle; rather Windsor lends itself to the need for a standard-sized fire appliance that can respond to all the incidents that an urban area generates.

The introduction of a non standard unit to a high risk area will also deprive that area of fire cover at times when the unit is not available due to mechanical defects/servicing. The reserve fleet is one of standard full size fire appliances.

The proposed introduction of co-responding in Windsor will be vigorously opposed by the FBU as it is non-contractual and outside our Role Maps as supported by the outcomes of the High Courts. 

The FBU is also concerned to hear that the existing Windsor Fire Station will close and cannot see how this benefits the residents of the town. Will the site of the new ‘fire station’ be risk-assessed to provide the best performance in respect of the response standards?

Road Traffic Collisions
The FBU is unclear on what this is trying to achieve. Team members are already disseminating their expertise and experiences to all firefighters and Officers who form part of the team already attend more difficult entrapments at the request of the Incident Commanders.

Wildfire/Forest Fires
It is regrettable that the Fire Authority has still not published the findings of its review into the Swinley Forest incident although many months have elapsed since the fire occurred. This report would provide a powerful learning opportunity for all the Authority’s partners and the wider fire and rescue service.

The FBU urges the Fire Authority to work with it and the South East of England Wildfire Group to refine its wildfire response policy so that this varies according to the risk posed by factors including the location of the fire (accessibility, vegetation, slope, exposure to solar radiation etc) and weather conditions (temperature, humidity, wind strength and direction etc).

© Fire Brigades Union – December 2011

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