House of Commons - Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions

Select Committee on Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions Written Evidence

Memorandum by the Fire Brigades Union (FBU) (FRS 63)

The Fire Brigades Union (FBU) represents approximately 48,000 members covering all ranks and duty systems in the fire & rescue service including approximately 4,000 officers, 11,500 firefighters working the retained duty system and 1,500 firefighters (control). This represents over 85% of all uniformed operational personnel currently serving in the fire & rescue services. The FBU welcomes the opportunity to submit evidence both written and verbal to the Select Committee and this submission deals with some of the key issues. We would also welcome the opportunity to appear before the Members of the Select Committee to support our submission and to attempt to answer any questions they may have upon it.

1. A OVERVIEW

The FBU supports measures which genuinely improve the capacity of the fire service to deal with all types of incident and maintains or builds upon the high levels of resilience currently in place. Our members have a clear vested interest in measures which add to public protection and their own health and safety.

The fire & rescue service has undergone major change and is still undergoing further far reaching change. The FBU has played a direct and active role in the New Dimension Project and the FireLink Project. In our view, however, FiReControl is a belated attempt to re-hash and bolt-on an old idea without it being properly thought out.

FiReControl has no grounding in the New Dimension Project, the Bain Review, (December 2002), the Government's 2003 White Paper or the HM Fire Service Inspectorate's desk-based Analysis of the Best Value Reviews of Control and Communications (November 2003). We do not believe FiReControl improves the resilience of the fire service, and that its potential risks—both operationally and financially—greatly outweigh any potential rewards. We deal in Annexe 1 with what these various reports did say.

Two Government commissioned reports from consultants Mott MacDonald the first of which (The Future of Fire Service Control Rooms and Communications in England and Wales, April 2000) recommended a reduction from 49 controls to 21, the second (The Future of Fire & Rescue Service Control Rooms in England and Wales 2003) which recommended 9 new regional controls in England, one new control to serve London. The union produced a detailed response to both reports, the most relevant now being "Out of Control", published by the FBU in May 2004.

We believe FiReControl is also the blueprint—without any public debate—for the beginnings of regional fire services that are far closer to national Government than to local authorities. We have our own proposals for the creation of a UK-wide network of "Resilience Controls" which we supply as Annexe 2 prior its official public launch on 25 January.

The threat of terrorism is not new although its nature and the type of attack and the level of response needed may be. The fire service has dealt with the aftermath of major terrorist attacks for many, many years including the biggest ever loss of life—Lockerbie—and the biggest bomb ever used on mainland Britain—Manchester—and assisting in rescues from bomb damaged structures—Brighton. We have also dealt with a range of major environmental challenges caused by extreme weather conditions for many, many years.

A project described in the Fire Control Project Outline Business Case Volume 1 (Abridged Main Text) November 2004 (OBC p 52 paragraph 141) as having a "high risk" of "total project failure" with a "high impact" if it does fail could, in our view, only be given the go ahead if there were severe problems with the current arrangements alongside very high confidence any new system would be substantially and measurably better. No such problems have ever been identified and the question has to be if it ain't broke why is it being fixed so strenuously? The Government track record on technology/change projects does not suggest that it can do better than "excellent" (OBC page 11, paragraph 30). We provide at Annexe 3 FBU published in January 2004 into the Government's track record on technology/change projects.

There has also been recent and significant criticism of the operation of national Government helplines—and Mott MacDonald used a call centre model as the basis for both reports- where there were considerable problems even answering the telephone. Emergency fire controls are far more complex than the simple helplines which national Government continue to struggle to put right.

The FiReControl Project is one of the most technically demanding ever attempted by Government. The well publicised outcomes of far less complex IT/change Government projects is for them to be delivered late, over-budget or not functioning as originally planned. Sometimes all three.

The destruction of the existing "excellent" system would be a huge gamble with large amounts of public money, with FiReControl adding little additional measurable benefit in terms of lives saved even if it did work, with any failure resulting in a severe risk to public and firefighter safety. There is a real danger that runaway costs—possible with both FiReControl and FireLink—will mean that public money which is available to the fire & rescue service (from ODPM or from fire authorities) is siphoned off to pay for a very expensive communications system. With finite financial resources—either from the general taxpayer and business or council taxpayers—this could only result in a diminished frontline operational capability.

Neither Project adequately tackles the desperate need for more up-to-date Fireground communications to replace the current antiquated radio systems used by individual firefighters. Next to nothing has been done to address what is a genuine and pressing issue of how to instantly communicate with personnel at small and large incidents, a central lesson of 9/11. Even if billions are spent on FiReControl and FireLink, firefighters at incidents will still be left with a whistle to signal the need to carry out an emergency evacuation rather than all being simultaneously sent a radio message.

This Project has already demoralised those working in Emergency Fire Controls and has already resulted in the loss of skilled and experienced personnel. A broad view is that ODPM is neither listening nor wants to address concerns of many "stakeholders", even those whom are nominally supportive or are resigned to having to support the Project. We attach at Annexe 4 sets of notes of meetings which highlight some of these issues.

We are not convinced that the location of many of the proposed controls are as resilient as claimed. Controls which are based in a mixture of retail and business parks, in some cases close to childcare nurseries or major retail outlets, some on known flood plains (while asserting they will deal with major flooding) and some very close to airports (post 9/11) do not, in our view, constitute an improvement in resilience. The proposed locations have the hallmarks of being chosen for cheapness and ease of gaining planning consent rather than the truly resilient locations they are claimed to be. "Finally, in the post-September 11 world our emergency control centres need to be resilient against attack or natural disaster" (Jim Fitzpatrick, 8th June Hansard Col 1234).

The situation and timing of the new London control is also unclear. London appeared at one stage to have negotiated its own "opt out" because it had all of the major concerns expressed by other fire & rescue authorities (see comments contained in Annexe 4 ). Its position is also being mis-represented. London is a single brigade control working to a single IRMP in a brigade with a relatively homogenous fire risk in a geographical area about a third of the size of Devon. It should not be mis-represented as a model for a regional control covering up to 9 brigades each with their own individual IRMPs, with more diverse risk patterns and more diverse duty systems covering areas perhaps fifteen times the geographical size of London. If London needs its own brigade control how can every other major conurbation in the UK (some of which have been terrorist targets in the past) do without theirs?

PROJECT MANAGEMENT AND SCOPE

Both the Mott MacDonald reports were flawed. The acceptance of the second report on which FiReControl was built meant the entire project process—and the costing and savings estimates which were at the heart of it- was fundamentally flawed from the beginning. Those who "signed up" did so, on the basis of the deeply flawed prospectus which defined the FiReControl Project from the very beginning.

Neither Mott MacDonald reports started with a proper understanding of the wide-ranging scope of the work of fire controls. Using a call-centre model typically used by roadside emergency organisations, both Mott MacDonald reports stripped down the work of future fire controls to call-taking, dispatch and incident monitoring roles.

In turn, this was used to justify cutting staffing numbers to levels which could manufacture the "savings" needed to underpin claims that the introduction of regional fire controls would produce savings. Cuts to staffing numbers are central to the national business case promoted by ODPM and we find it disingenuous of them to maintain that actual staffing numbers would be a matter for each control. If this were truly the case there could be no guarantee that regional controls would have sufficient staff to automatically back-up other controls and no grounds for their stated confidence that savings will be made.

Claims of "savings" based on staff cuts are at best precarious. Work arbitrarily missed from the list of the work considered "in scope" was—perversely—counted as a saving to the project. Everyone agrees this work still needs to be done. It is still unclear what mixture of incident-related work and core fire & rescue service related work is included beyond the basics outlined by Mott MacDonald.

The problem of what is in scope and out of scope was accepted by Fire Minister Jim Fitzpatrick in a written answer to a Parliamentary Question: as late as 2 December 2005 in which he said: "Some of the functions currently carried out by control room staff will remain elsewhere in Fire & Rescue Services." (Official Report, 2 December 2005, Col 797W). This lack of forethought and understanding has resulted in the recent circulation by ODPM officials—after they have announced the sites of the proposed new regional controls- of a questionnaire to find out what work their current fire controls actually do (Official Report, Written Answer 14 October Col 609W). South East RMB pointed out some of the problems in a letter to ODPM of 9th May 2005: "Many of these key activities must be maintained to ensure operational viability and yet have not been considered as part of any reliable cost comparison….What is not yet clear is the scope of work to be undertaken by the RCC, and what will be residual ie what will remain for Fire & Rescue Authorities to continue to undertake." We include this letter as part of Annexe 4.

A number of Fire & Rescue Authorities also have Service Level Agreements or contractual arrangements in place for work such as handling out of hours calls for other local authority providers such as Social Services Departments. These have been made on a best value procurement basis and are enthusiastically supported by all political parties as demonstrating flexibility while producing significant revenue streams for fire & rescue authorities. As a result of the ODPM's FiReControl proposal fire & rescue authorities will have to either negotiate themselves out of these contracts and lose revenue streams, or they will have to employ other staff to undertake the work. Both options are likely cost the business and council tax payer.

The amount of all "Out of Scope" work is difficult to quantify and cost but it is significant and substantial. Oral reports from ODPM representatives to Regional Management Board meetings suggests this work amounts to between 30% and 70% of the work currently undertaken in controls. Claims of cost savings—central to the Project—appear to be little more than cost- shifting by moving work and costs "out of scope" and hence off the Project's books.

The lack of understanding of the work of existing fire controls—which remained long after critical decisions had been made—has a significant effect even on the "Project Costs" estimates which are "in scope". The significant difference between the estimates contained in the Outline Business Case and the Strategic Outline Business Case which preceded it by a matter of months illustrates the link between poor project definition and rising project costs estimates. The result is that Mott MacDonald's original project cost estimate of £100 million had to be multiplied TENFOLD to £988 million and estimated savings have had to be HALVED from £155 million to around £80 million (written answer Official Report 27 October 2005 Column 486W).

To put these figures into some kind of context, the cost of the new Fortek mobilising system in Merseyside Fire & Rescue Authority, one of the larger brigades which covers a population of 1.5 million, cost £690,000. This project came in under budget. The ODPM uses Merseyside as an example of best practice. The costs of the Merseyside Fortek mobilising system provide an idea as to potential costs of rolling out this system to those brigades which do not yet have access to the very latest technology. It is an option certainly worth considering with some open-minded vigour in line with our own proposals for a UK-wide network of "Resilience Controls".

NOT TRIED AND TESTED

Technology which can work at brigade level cannot be assumed to be "tried and tested" at a regional level, never mind as part of a national network of control centres, and there are no obvious "models" to follow. In any event, national Government's known track record using genuinely tried and tested technology in a range of far less complex yet major IT/change projects does not fill us with confidence. As the OBC pointed out: "There is no precedent for a regional structure to deliver an operational function such as this." (page 79, paragraph 110). The risks outlined in the OBC are project specific and significant while "existing arrangements for delivering core services (including call-taking and dispatch functions) is perceived to be excellent." (OBC Page 11, paragraph 30). The OBC assesses the risk of "delay or even total project failure" as "high" with a "very high" impact if it does fail. The risk is so high, not simply because the project is unique, but because "the recent history of delivering IT/change projects in the public sector has demonstrated a less than 50% success rate." (OBC page 52 paragraph 141).

There is a high risk/high impact "that the current provisional timescales may not be achieved" which would "increase project cost". (OBC page 52, paragraph 142). There is a high risk/high impact that Council Tax may be pushed up as a result of cost overruns. The report says: "Failure to deliver economies would reduce the resources available to further service aims and objectives, and might impact on Council Tax" (page 52 paragraph 142). ODPM claims that there can be no financial impact on fire & rescue authorities or implications for council tax because "new burdens" funding will cover the payments are doubtful. In a letter to ODPM on 9th May 2005 the South East RMB (mentioned previously as Annexe 4) pointed out the weakness of this claim highlighting the fact there are currently additional costs which are already costs not being covered by "new burdens" funding. The costs of the Project are already beginning to bite into the funds of cash-strapped fire & rescue authorities and may have already contributed to some of the cuts in frontline services which have already taken place.

SERVICE DELIVERY

Existing fire & rescue service controls have to comply with guidelines set out in GD92 (outlined in 1992 and evaluated a success in Specifications of a Communications Infrastructure for Fire Service Mobilising Systems GD-92/1003A/2.2, Home Office Fire Research and Development Group1/96 and Evaluation of GD92 Framework Summary Report, CFBAC Research Report Number 73, 1997) which sets down standards of, for example, resilience and fall-back. GD92 does not specify that all control systems are identical, but rather that they all must comply with key requirements. We are not aware—in the immediate wake of 9/11 or since—of any attempt by ODPM to change or amend those guidelines to set different criteria. We are not aware of any blanket failures identified by HMFI inspections. Challenged in a Parliamentary Question, ODPM was unable to produce details of any incidents where there were any failures involving emergency fire controls at any time in the last 30 years (Official Report, 12 December 2005, Col 1722W).

Many of the benefits claimed for the FiReControl project are supplied solely or largely by FireLink. This includes the re-establishment of interoperability with police and ambulance radio systems, Mobile Data Terminals in vehicles (for those brigades which do not already have them) and Automatic Vehicle Location (for those brigades which do not already have it). Taken on its own, there is little that FiReControl substantially adds of tangible or measurable benefit over and above that which already exists or will be provided by FireLink.

Claims about quicker response times as a result of FiReControl are unsustainable as the current system is already so fast any possible reduction could only be a matter of seconds. The basis for these claims appears to be Automatic Caller Location, which has been available for some time. It currently only works with BT lines; with mobiles it only gives a generalised radius of location and in any event the caller's location in most cases is not the actual location of the incident. ACL is only used for validation purposes, and in almost no circumstances as the primary source of information, and good call handling—the skill to elicit information from people who may be in panic—will still be essential.

In a Parliamentary Answer the Fire Minister claimed the RCCs would reduce the time from call-taking to arrival of an appliance or appliances at an incident. (Official Report 21 July Col 2089W). We welcome the acknowledgment that there is a link between savings lives and speed of response. But ODPM is fully aware that many fire & rescue authorities have actually significantly extended or are considering significantly extending the time between call-taking and arriving at incidents. We must challenge ODPM to detail the faster response times of the future, what response time targets they intend to set fire & rescue authorities, and how they intend to measure how these will be met. It seems unusual that ODPM are prepared to spend huge sums of money to possibly cut response times by a few seconds while fire & rescue authorities are extending those response times by several minutes with the net result being considerably slower response times than currently exist.

Regional and national co-operation at significant incidents has been a feature of the fire service for many, many years. The ODPM claim that FiReControl will improve firefighter safety because better information will be available to fire crews on the way to incidents is also unsustainable. Again, this is not new, and in any event this functionality will be either exclusively or largely provided by FireLink Mobile Data Terminals and not by the FiRe Control Project.

We understand the need to develop new practices to improve national resilience. But we believe a more cohesive approach which could command widespread support is contained in Annexe 2.

1. B FIRELINK

FireLink has always been a stand alone project and pre-dates FiReControl by many years. It is not dependent upon FiReControl although FiReControl is dependent upon FireLink. ODPM paints a picture of what regional controls will do without distinguishing between what is provided by FireLink and what will be added by FiReControl. FireLink will re-establish interoperability with police and ambulance radio systems although this appears to be restricted to "Gold" and "Silver" Command level (Written Answer, Official Report 13 October Col 553). It is unclear whether FireLink is intended to provide the facility for personnel in a fire appliance to "speak" to officers in a police car or paramedics in an ambulance. FireLink will provide Mobile Data Terminals in vehicles (for those brigades which do not already have them) as well as Automatic Vehicle Location (for those brigades which do not already have it).

In respect of FireLink there are two rival radio network systems; one a TETRA-based (O2) while the other is TETRAPOL-based (EADS). There are well-documented health & safety questions about TETRA based systems with the Home Office carrying out a 15-year £5 million pound research programme with the police service. We can find no documented concerns about TETRAPOL-based systems and it is of considerable concern that this issue appears to have played no part in the deliberations of the ODPM in relation to the fire & rescue service. It also needs to be established whether either or both bidders will need additional telecom masts to be added to secure sufficient radio coverage for the fire & rescue service. This is clearly an area of some public concern and may create a potential conflict of interest for ODPM in its planning role.

Unlike FiReControl, very little is known about the estimated costs of FireLink. The estimated cost—O2 is the ODPM's preferred bidder—has not been made public but FireLink was referred to in an ODPM press release as a "multi million" pound project. (ODPM press release 2005/0231, 11 November 2005). The charging structure is unclear; particularly what costs are "core" project costs carried by Government and what may be additional costs for airtime, data transfer, maintenance or other additional costs which may be carried by fire & rescue authorities. Any such additional costs, if borne by fire & rescue authorities, could amount to considerable revenue streams for either of the successful bidders and amount to a significant drain of fire & rescue authority funds.

In any event the costs of FireLink are likely to be significant as the police system in England—under a PFI contract—has been costed at £2.9 billion (O2 Airwave Press Release 1 April 2005) and the ambulance service in England have signed up to a project costing £390 million. (O2 Airwave Press Release 19 July 2005). If O2 subsequently secures the contract it would lead to the creation of a monopoly provider of radio networks to the three central 999 services in England. There is also an issue of resilience. O2 has recently announced the creation of a National Fallback System for the police although, interestingly, the cost of this additional contract is not mentioned (O2 Press Release 31 October 2005). It is unclear whether this is being offered to the fire & rescue service and if so at what, if any, additional cost and whether the Government or fire & rescue authorities would foot the bill. It is also unclear what will happen if, for example, the police seek changes to the system to suit their operational or other requirements which have a knock on effect for the fire & rescue service in terms of functionality and cost.

The lack of transparency over the cost, charging structure in the bidding and assessment process for FireLink only adds to our general concerns that the overall costs of this and FiReControl will lead to increased pressure for cuts in frontline services.

2. The FBU is currently engaged in surveying its membership seeking their views on a number of issues of interest to the Select Committee. This survey will be made available to the Select Committee as soon as it is available.

2(I) CIVIL RESILIENCE

The FBU has played an active and positive role in the change and modernisation of fire & rescue service for many years, before and since the publication of the White Paper in 2003. The Committee does have particular regard to civil resilience and we have prepared a separate Annexe 5 outlining some issues which are also touched upon in Annexe 2.

We have broader concerns about preparedness and planning for civil resilience and in particular whether lessons have been learned from the exercises carried out so far and from major incidents such as the 7 July London bombings and the major fire at Buncefield (where the available equipment was highly praised).

The fact that the London Fire & Emergency Planning Authority Commissioner has asked for significantly more mass-decontamination units supports our long-standing concerns about the amount of equipment available and the numbers of personnel trained to use it; both of these are very significant issues at all incidents and more so at protracted ones. If London needs a total of 16 Incident Response Units (plus the associated support crews of 40 firefighters per Unit) how many may the rest of the UK now need?

We face worse scenarios involving quite possibly several major incidents hundreds of miles apart. If we do not learn the lessons about the numbers of personnel and equipment needed for both the 7 July and the Buncefield incidents we risk being very thinly spread in dealing with the far worse scenarios which are all too foreseeable.

The public are repeatedly told of the risks now faced in the new and changed world; risks which have been transformed into reality and which have now arrived with a vengeance. We see no signs that ODPM has moved away from the cuts-based agenda which has driven it since the dispute and we strongly believe it has to re-assess its commitments to the cuts which have already started in a service which provides the frontline response to any major incident.

A central fault line in current national resilience planning is that IRMPs allow fire & rescue authorities to "manage" their local risks and in some instances contemplate and carry out significant cuts in personnel. We see little evidence that they are assessing risk and planning their levels of personnel with any view to the national need to be capable of responding to a series of protracted major incidents. And we see little evidence that ODPM is giving sufficient, if any, guidance on this matter; guidance that is urgently needed before the collective national response capability of the service is degraded any further.

2 (II) INTEGRATED RISK MANAGEMENT PLANNING (IRMP)

The Office of the Deputy Prime Minister introduced the system of local Integrated Risk Management Planning (IRMP) in England, Wales and Northern Ireland effective April 2004. The Scottish Executive introduced a similar system of IRMP for Scotland effective April 2005.

Section 62 of the Fire & Rescue Services Act 2004 devolved responsibility for the fire & rescue service in Wales to the Welsh Assembly Government, which is currently consulting on proposals to introduce a system of fire & rescue authority Risk Reduction Plans (RRPs) in place of Integrated Risk Management Plans (IRMPs). The final Welsh model is likely to focus on reducing risk rather than simply "managing" it.

The ODPM's 2003 White Paper set two "prevention-based" targets to drive IRMP. These targets now only apply to English brigades. Pages 26-31 of Annexe 9 (the FBU's 2004 National IRMP Document) gives further background to these targets, which are:

"To reduce the number of accidental fire related deaths in the home by 20% averaged over the 11 year period to 31 March 2010 compared with the average recorded in the five year period to 31 March 1999—with no local authority fire brigade having a fatality rate of more than 1.25 times the national average by 31 March 2010."

"To reduce by 10% the number of deliberate fires by 31 March 2010 from the 2001-02 baseline."

The FBU supports the general principles of prevention, protection and intervention which underpin IRMP; however we are concerned that the primary focus for IRMP in England appears to have become a reduction in accidental fire-related deaths in the home through preventative initiatives alone.

This preventative focus on direct life risk in the home effectively sidelines the intervention and rescue role of the service at dwelling fires, the wider emergency response and rescue role of the service at other fires and emergency incidents, and the positive effect of the protection afforded by legislative fire safety to UK businesses, their employees, the general public and the national building stock.

Additionally the FBU is concerned at a growing trend by senior managers within fire & rescue services to re-categorise fire deaths as either being "preventable" or "not preventable". Categorising fire deaths in this way essentially introduces a local "value judgement" into the IRMP process which is not found in any ODPM guidance on IRMP. The danger of this type of local "re-classification" is that these value judgements may then be relied upon by service managers to justify the use of resources in a particular way in a brigade.

Currently the ODPM classifies fire deaths as being either accidental (ie the fire which led to the fire death started accidentally) or not accidental (ie the fire which led to the fire death was started deliberately). The FBU recognises that this is the only valid classification which can be made of fire deaths and believes that the ODPM should issue clear guidance to fire & rescue authorities in this respect. Pages 29 and 30 of Annexe 9 refer.

To be robust and reliable, the Integrated Risk Management Planning process must consider all applicable risks and risk reduction measures available, ie prevention, protection and emergency response.

Whilst any reduction in fire deaths in the home which may be attributed to successful local preventative initiatives is welcomed by the FBU, the contribution of fire & rescue service emergency response to saving lives in England has been consistently demonstrated over the last 10 years.

Successful rescues by firefighters from fires in dwellings have risen from 2,716 in 1994 to 3,868 in 2003. Successful rescues by firefighters from all fires have risen from 3,222 in 1994 to 4,341 in 2003. These figures do not include persons who escape before the arrival of the service, or those who are evacuated as a result of a fire. The full 10 year rescue statistics were revealed in a written answer to Parliamentary Question on 16 June 2005 (House of Commons Fire [1632] 16 June 2005).

Jim Fitzpatrick: The number of people rescued alive from fires by fire & rescue service personnel in England are shown for each year 1994 to 2003 in the following table.

	Rescued casualties (9)		Rescued unharmed (10)		All people rescued alive
	All fires	Dwelling fires	All fires	Dwelling fires	All fires	Dwelling fires


1994	2,072	1,815	1,150	901	3,222	2,716
1995	2,317	2,034	1,155	918	3,472	2,952
1996	2,442	2,138	1,022	864	3,464	3,002
1997	2,684	2,347	889	701	3,573	3,048
1998	2,545	2,300	959	811	3,504	3,111
1999	2,511	2,252	1,413	1,043	3,924	3,295
2000	2,728	2,641	2,155	1,627	4,883	4,268
2001	2,671	2,412	1,409	1,176	4,080	3,588
2002 (11)	2,829	2,580	1,763	1,589	4,592	4,169
2003 (11)	2,735	2,441	1,606	1,427	4,341	3,868

(9) Based on all primary fires attended. Casualties include people who were injured or required a precautionary check-up.

(10) Based on a grossed up 20% sample of primary fires attended.

(11) Data include estimates for incidents not recorded during periods of national industrial action in 2002 and 2003.

Source: Fire & Rescue Service FDR1 returns to ODPM.

Similarly, the protection based fire safety enforcement activities of fire & rescue authorities since 1961 have led to a reduction in deaths and injuries from fires beyond the home. So much so that the significant majority of workplace injuries due to fire relate to process risks—the handling of flammable liquids or dangerous substances—which are not the responsibility of fire & rescue authorities. This success however is no reason for fire & rescue authorities to reduce their fire safety enforcement activities. The recent major incident at the Total Oil terminal in Hemel Hempstead has vividly demonstrated this.

Clearer ODPM guidance on risk-based response planning is needed to ensure that brigades are adopting a common emergency response methodology under IRMP. The FBU advocates the Critical Attendance STandard (CAST) methodology (pages 32-43 of Annexe 9) in this respect; a methodology which is based on risk & task analysis. However to date the ODPM has not issued an IRMP Guidance Note on the risk-based response planning process, despite this being an integral part of IRMP as demonstrated by the ODPM's rescue statistics.

The process of risk-based response planning is independent of, yet complimentary to, the use of computer risk modelling (such as the ODPM's Fire Service Emergency Cover [FSEC] model) which seeks to map areas of similar risk in brigades. The very brief reference to risk-based response planning (page 10 of ODPM document "Preparation for the FSEC Toolkit"—February 2004) must now form part of bespoke ODPM IRMP Guidance if it is Government's intention to demonstrate a real commitment to a truly integrated approach to IRMP.

Risk-based response planning methodology, and the system of measurement which underpins it, should be the same throughout England to allow valid comparisons between brigades on a like-for-like basis, and to satisfy communities that like-risk will receive a like-response irrespective of location in England.

Effective Integrated Risk Management Planning is potentially a detailed and complex process. A large number of apparently conflicting factors have to be taken into account. However as the IRMP process should essentially be about reducing risk, there is a simple formula that can be applied to each and every proposal in a local IRMP which will measure whether the proposed strategy increases risk or decreases risk. The FBU terms this the "Intervention Window" test. Pages 44-51 of Annexe 9 refer. The FBU commends this formula to the ODPM for a future IRMP Guidance Note to fire & rescue authorities.

2 (III) RETAINED

There is a UK-wide shortage of 3,000 firefighters working the retained duty system leaving many areas with a depleted service. It is a duty system misunderstood even within the fire & rescue service which has been historically undervalued.

The recruitment and retention problem must be addressed and we are disappointed that the ODPM has done little to address the problem which will get worse without long-term investment. Making do with inadequate resources and trading on the goodwill of an already over-stretched workforce and their main employers can only be short-term. This approach creates problems with retention and recruitment to a genuinely community-based service.

The union was disappointed that the ODPM's negative approach to the recruitment and retention problem was to see it as an opportunity to introduce slower response times and reduced levels of response. A more positive approach would include providing incentives to employers to release staff and building better links with business and the self employed; persuading public sector employers to encourage their workforce to work the retained duty system; recruitment underpinned by equal treatment, equal pay and equal rights; ending the current practice of using surplus money from retained budgets (because of lack of recruitment) for other purposes. The provision of proper pension rights, sick leave and training would also enhance recruitment.

2. A FIRE PREVENTION

We attach as Annexe 6 a fuller view on fire prevention. In summary we believe there needs to be a Best Value Performance Indicator (BVPI) underpinning a new PSA target relating to the fire protection role of the fire & rescue services based upon their statutory involvement with fire safety in non domestic buildings, the enforcement of fire safety legislation and in advising upon the fire safety elements of the design and construction of new or altered buildings.

There needs to be clear and strong guidance on the enforcement of the Regulatory Reform (Fire Safety) Order 2005 (FSO) which is due to come into force on 1 April 2006 to ensure the enforcement activities of fire & rescue authorities are properly carried out. We see little or no evidence that this will in fact be the case or that any targets are being set for them to do so. We have significant concerns over the near-ending in some brigades of the fire certification regime. The running down of this regime pre-dates even the introduction of the Order to the House.

There needs to be a meaningful review of the stakeholder consultation process. In its haste to rid itself of the national committee structure offered by the Central Fire Brigades Advisory Council, the ODPM had little or no idea of what it would do to replace the functions that the CFBAC offered, including the creation of policy documents that all organisations were signed up to. The national structure no longer exists leading to disputes which are breaking out across the fire & rescue services in England.

2. B NJC

On the 14 October 1999 the then Secretary of State to the Home Department, Jack Straw instituted, at the request of the Local Government Association, an independent inquiry into the future arrangements for determining firefighters' conditions of service. Frank Burchill, Professor of Industrial Relations, Keele University, was appointed by Mr Mike O'Brien MP on 25 November 1999 to undertake the Inquiry. His report was submitted in March 2000.

The National Joint Council agreed to work together to act upon the recommendations contained within the report. The Fire Brigades Union played an active and constructive role in the implementation of the recommendations.

Although there remained areas of disagreement between the Local Government Employers and the FBU, it was felt that the new machinery would assist in resolving these. The Union then tabled a claim for an increase in pay in May 2002. What resulted has been referred to as the Fire Service Pay Dispute.

Prolonged negotiations followed, which led directly to government intervention and the Fire & Rescue Services Act 2004. This act came into force after the resolution to the dispute which was in accordance with an agreement in June 2003 between the Employers and the Employees side of the National Joint Council. This agreement included in Paragraph 7.1 "By 30 November 2003 a working group representative of fire service stakeholders will propose revision to the constitution of the NJC. The report of this working group will be presented to the appropriate fire service stakeholders for ratification during December 2003." Rita Donaghy, Chair of ACAS, was appointed to convene and chair the working party. By agreement the deadline for the completion of the report was extended to 31 January 2004.

Rita Donaghy submitted her report in January 2004 (attached as Annexe 7). It was ratified by the Fire Brigades Union national executive at a meeting in January 2004. The Employers side of the NJC however asked to continue working with ACAS to clarify some points surrounding the proposed Middle Managers" negotiating body.

The Employers side of the NJC agreed to consider the proposals at a meeting on 17 February 2004 at which they could not come to an agreement. Brendan Barber, General Secretary of the TUC, wrote to the Chair of the Local Government Association on 21 February in the hope that Sir Sandy Bruce Lockhart might bring some influence to bear on the Employers side to resolve the situation. Sir Sandy Bruce Lockhart replied on 4 March stating "Employers were now making proposals which they believe will help to establish permanently the more settled relations in the service". He concluded that it was his view that "these discussions should be pursued further within the joint machinery."

The FBU remains committed to the recommendations made by Rita Donaghy and have recently agreed to have further discussions with the Employers on the Constitution of the NJC. It should however be pointed out that it has taken almost 9 months for the Employers to make any formal approach to the union regarding the constitution of the NJC.

It is our strong view that the Negotiating Machinery for Local Authority Fire Brigades should, as Sandy Bruce Lockhart previously stated, remain "within the joint machinery".

2. C DIVERSITY

The FBU's women representatives, gay & lesbian representatives and black & ethnic minority representatives have each provided their own detailed submission which is included at Annexe 8. These representatives have been recognised as the most important and most effective advocates of equality and diversity within the UK fire & rescue service for many years. It is of deep regret, and appears particularly perverse, that FBU representatives have been excluded from the equality debate at the "Diversity Happens" Programme Board.

3. COOPERATION

3.1 The FBU supports greater cooperation and collaboration between the fire & rescue service and other agencies; this already occurs on a regular basis. There is significant joint-working with the police, ambulance and coastguard including joint exercises. We welcome collaboration with social services and voluntary organisations to assist in identifying vulnerable groups. There is considerable joint working with organisations which deal with young offenders and there are several LIFE projects aimed at helping young offenders break the cycle of offending and re-offending.

3.2 There is a big difference between cooperation and collaboration and taking on the work of other emergency services as demonstrated by the different variations of "co-responding". Co-responding in practice places the fire & rescue service in a position where it is taking over the role of the ambulance service in attending what are major medical emergencies. In practice it is often driven by the inability of ambulance services (some of them regional ambulance services) to hit target response times for major emergencies. In those areas where co-responding does take place or is being piloted, the fire & rescue service is sometimes sent alone and the incidents can involve anything from serious medical emergencies to members of the public who have collapsed drunk in the street. The FBU has never been presented with any proposals at a national level on co-responding, and any that were presented would need to address our serious concerns. These would include the additional burden of significant extra work for those working the retained duty system which is currently drastically under-strength, and the overall impact on a public service which the ODPM remains firmly intent on cutting.