Government & Politics
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Framing the future of fire reform
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FIRE Correspondent Catherine Levin says the Fire and Rescue National Framework is timely and needed and reflects the breadth of fire reform in England
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he Fire and Rescue National Framework may appear to be just a load of policy wonkery, but in reality it is a set of requirements and ideals that frame the entire service and give it direction. It provides the legal basis for Integrated Risk Management Plans that underpin the approach taken by each and every fire and rescue service in England. So much has happened in fire lately that the Framework has a lot to cover, a great deal to embrace anew. It acknowledges the context of the Grenfell Tower fire and the work of the Hackitt review into building regulations and the need to be flexible to further change the Framework based on evidence emerging from that work. By Valentine’s Day the consultation will be pretty much done. All fire and rescue services will have pored over it and worked out what they want to say in a formal consultation response that will be made public at some stage. It might have got through a fire authority meeting if timetables allow, but in the main they will be mechanistic responses. It is good that the Home Office brought together an external working group to gauge views from the fire sector, although the list of members does not include any representative bodies. National Fire Chiefs Council A notable new inclusion in the Framework is a section devoted to the National Fire Chiefs Council as well as other references. It sets out an expectation that every fire and rescue service in England should consult and engage with the NFCC. It provides a more solid basis for the organisation representing the professional voice of the Service than CFOA could when DCLG was responsible for fire. A quick comparison between the 2012 Framework and this new draft shows that three of the priorities remain the same: identifying risk; provision for prevention and protection; and accountability to local communities. The 2018 consultation draft includes an additional two objectives: collaboration (replacing references to partnership, which
is now out of vogue) and the development of a resilient, skilled, flexible and diverse workforce. There is a distinct change in tone and emphasis in the 2018 Framework. It is particularly stark in the prevention and protection section. The expectation about prevention is framed around vulnerability. There is a balance to be had between helping other agencies and delivering core functions while trying to reduce burdens on the overall public purse. Acknowledging the need for staff to be trained and supported in this work, the Framework is much more people focused in its approach than its predecessor. This draft reduces the requirements in the 2004 Act to respond to fires and to road traffic accidents, to a passing reference. It is all very well saying that prevention and protection are the first line, but the response is surely worth more than a single short paragraph? National Resilience By way of contrast, the National Resilience section has doubled in size. It includes, for the first time, references to Marauding Terrorist Firearms Attacks (MTFA). It notes: ‘The Government has committed significant financial resources to develop an MTFA capability, with the support of fire and rescue services’. The Framework goes on to say: ‘Where they [the FRA] have an MTFA capability, [they] must put in place arrangements to ensure their teams are fully available at all times’. It sounds like this is going to be achieved through existing budgets, but a quick look at the Report on Proceedings from the FBU’s 2017 conference reveals an instruction to its Executive Council to submit a pay claim, ‘To address any broadening of role maps… which may include emerging potential new areas of work such as EMR and MTFA’. (p70) There seems to be a disconnect here. Both the Opposition and the FBU have long called for a new statutory duty for the Fire and Rescue Service to respond to flooding so that the new burden can be financially recognised. Is MTFA the new flooding? www.fire–magazine.com | February 2018 | 19
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That will keep everyone busy. Collaboration has replaced partnership as word of the moment with 12 mentions; in 2012 partnership appeared 11 times in the Framework and now it is a mere three. It is probably not a surprise given the duty is to collaborate, not to partner, but it is an interesting observation on the popularity of language waning over time. Collaboration is extended to embrace the provisions about inter and intra operability that appeared in the response section in 2012. It is updated with references to JESIP to reflect the enormous investment made to improve working between emergency services. In the Workforce section, fire and rescue services, ‘Should have in place a people strategy’. Making direct reference to the principles set out in the NFCC’s People Strategy (and further cementing the position of the NFCC), the Framework lists out a minimum requirement including: improving diversity, recruitment, health and wellbeing as well as tackling bullying and harassment.
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Inspectorate A big change that needs to be reflected in the 2018 Framework is the fire-related provisions in the Policing and Crime Act 2017. The Act led to the reincarnation of the fire inspectorate; gave police and crime commissioners locus of control over fire; and created a new duty to collaborate. For the first time, the Protocol on Government Intervention Action is also updated by way of the National Framework and again reflects the changes wrought by the 2017 Act. Much of the inspection section is a rehash of existing information and a confirmation that fire and rescue authorities, ‘must cooperate with the inspectorate’. There will be a collective sigh of relief when fire and rescue authorities learn that the Home Office and HMICFRS will be working together to align data and information collection. Let us hope that in turn is aligned with the requirement to feed the DCLG Single Data List. Police fire and crime commissioners feature in the Framework even though there is currently only one; the list is likely to grow a bit more during 2018. Like fire and rescue authorities, the PFCC will have to produce an IRMP; but unlike fire and rescue authorities the PFCC will have to prepare and publish a fire and rescue plan. ‘The plan should set out the strategic vision, priorities and objectives for the fire and rescue service’. It makes sense to have a fire equivalent of the existing police and crime plan and even more so to combine the two, but given the Framework goes on to say in paragraph 4.10 that the IRMP can include the same detail as the fire and rescue plan, it begs the question, why even ask for it separately?
PFCCs are also asked to prepare and publish a fire and rescue statement: ‘[It] should outline the way in which the authority has had regard to [the] National Framework’. They also have to publish an annual statement of assurance which also shows ‘Due regard to their priorities and expectations set out in their IRMP and the requirements in the National framework’. Why both? It all seems a bit over the top. It is all about the plans in this Framework. • Integrated Risk Management Plan (refreshed every three years) • Annual statement of Assurance of compliance with the Framework • Efficiency Plan (with annual report on progress against the plan) • Medium Term Financial Strategy (with a funding and spending plan) • Business Continuity Plan • Post inspection improvement plans and action plans (where required) • Fire and Rescue Plan (with a Fire and Rescue Statement about the plan for the PFCCs but not anyone else).
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Professional Standards The nascent Professional Standards Body is here; with a clear direction of travel that the Home Office expects fire and rescue authorities to implement the standards through this work. The added reference to the inspectorate will give this body added clout. There is no explicit reference to National Operational Guidance. In the six years since the last National Framework was published, the NOG Programme has turned guidance upside down, reformed it and brought it into a digital age. It is a critical part of the infrastructure of the Fire and Rescue Service and should be in the Framework. The inclusion of references to sharing intelligence, data and research and development as well as encouraging evaluation is a marked departure from 2012. What is needed of course is a platform for the sharing to take place and bodes well for the introduction of a fire.gov.uk-type resource, which was hinted at last year but has not yet been revealed. Later in paragraph 5.20, the Framework refers to engagement with national research and development programmes, giving the impression there are lots. It is the paucity of national research and development and a strategic framework for it that is the problem, not the lack of engagement.
Thomas Review This builds nicely on recommendation 35 of the Thomas Review, where fire and rescue services are encouraged ‘To maintain an up to date strategic workforce plan’. The Thomas Review includes references to firefighter fitness and acknowledges work being carried out by the NJC in this area. In 2016, the NJC/Home Office published the Firefighter Fitness Best Practice Guide. It is fitting then that fire and rescue authorities are now mandated to follow the Fitness Principles in the Framework. It is useful to return more widely to the Thomas Review. It was finally published in November 2016 having been finished in 2015 and trailed at the LGA Fire Conference in March that year. The Review is littered with references
“It does reflect how much has been going on in the fire sector and the breadth of fire reform in England” 20 | February 2018 | www.fire–magazine.com
Government & Politics
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pretty much the same job for a better deal was not acceptable. Taking the opportunity to firm this up, the Framework now tells fire and rescue authorities that they must not re-appoint principal fire officers after retirement. But, just in case, the Framework does allow a little wriggle room for exceptions. This draft Framework leaves a gaping hole where fire protection is concerned and while it refers to the Fire Safety Order, it really should do more to set out expectations in a post-Grenfell world once the Hackitt report is published in the spring. This omission is acknowledged in the Foreword, but the timing may not quite work out, so the version of the Framework that emerges post consultation is likely to be temporary or very delayed. On balance, it would be better to have the temporary version and a fully considered post Hackitt addendum to complete it later in the year. This Framework is timely and needed; although it is not perfect and in places, the emphasis is not quite right. It does reflect how much has been going on in the fire sector and the breadth of fire reform in England. The building blocks that came out of the Policing and Crime Act 2017 provide the basis for much of that reform: inspection, governance changes and collaboration all need time to bed in and some stability will be needed to ensure it will be a success.
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to improving equality and diversity. He writes: “There is much re-building to be done around culture and trust, including addressing the concerns around bullying and harassment. This also has an obvious relationship with equality and diversity.” Aside from the Thomas Review, the trail had been laid back in May 2016 by Theresa May in her much quoted ‘96 per cent white and 95 per cent male’ reference to the demographics of the firefighter workforce. It led the one o’clock news that day. In May 2017, Brandon Lewis got his headline by saying that “there’s more diversity in the range of fire hoses than firefighters”. “A culture shift is needed”, he said, echoing the Thomas Review. Well if that is the case, then the National Framework has to do more to help that happen. Saying it is part of workforce or people planning is all very well, but the lack of emphasis is disappointing and not in line with the rhetoric. While Adrian Thomas did not explicitly include the re-engagement of principal officers in his report, it could well have fitted in to his review of conditions of service. The government has had a bee in its bonnet about this for some time, with Theresa May criticising the practice in her May 2016 speech. “It looks wrong; it erodes public confidence; it undermines the respect of firefighters and staff in their leadership. It must stop.” The consultation during 2017 made it clear that retiring and returning to the same place of work doing
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Pete Murphy and Russ Glennon, members of the Joint Universities’ Emergency Services Research Team, respond to the new National Framework having failed to be impressed by the document, highlighting a “surprising number of inconsistencies”
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Governance reforms go off the boil
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ecember 2017 finally saw proposals for operationalising key parts of the 2017 Crime and Policing Act that affect the Fire and Rescue Service. The Act made a new National Framework inevitable. The previous Framework from 2012, lamentably unfit for purpose from day one, has effectively become obsolete. The Home Office have finally issued a consultation on a new Fire and Rescue Framework, and the rebranded HMICFRS issued more detailed proposals for the inspection framework and programme for 2018/19. And yet, these two documents fail to impress. The
surprising number of inconsistencies between them adds to the impression that their release owes more to a communication strategy or timetable for ‘bad news’ than a desire to create a new, more efficient and effective policy and delivery regime. By the time you read this article, we hope to have published our detailed response to both consultations through the Fire Sector Federation. Our response to the Framework is informed by our response to the HMICFRS consultation, although in view of the inconsistencies, differences in content, level of detail and even dissonant tone of the two documents, we intend to provide parallel responses to the two documents for members of the FSF to consider. A Reinterpretation of the Current Context The new draft Framework, like its predecessor, is a model of brevity. So far, so good. Unfortunately, the Minister’s Foreword and the subsequent introduction raise immediate concerns. The consultation feels ‘stage managed’ through a series of omissions, implicit assumptions, and questionable interpretations. These primarily concern funding, inspection, core responsibilities and the workforce. The first paragraph of the Minister’s foreword refers to the long-term significant decrease in the number of fires, and later suggests this may be partially due to successful fire protection and prevention. Yet it fails to acknowledge that while the numbers of fires are reducing, the losses from fires are up over fourfold per incident, reflecting increasing complexity in modern construction and occupation. It ignores widespread evidence that, while funding for public services is being universally reduced, this has been disproportionately www.fire–magazine.com | February 2018 | 21