LGA and NFCC Bespoke Peer Challenge: States of Jersey Fire and Rescue Service

LGA and NFCC Bespoke Peer Challenge

States of Jersey

Fire and Rescue Service

4th – 7th April 2022

Feedback report

R.155/2022

1. Executive summary .............................................................................................. 3
2. Key recommendations ......................................................................................... 6
3. Summary of the peer challenge approach ........................................................... 9
4. Feedback ........................................................................................................... 10
5. Next steps .......................................................................................................... 16

1. Executive summary

The States of Jersey Fire and Rescue Service (SJFRS) invited the peer review to help it explore the concerns it has for maintaining a high quality and safe service for the island. This is outside of any existing Local Government Association (LGA) or National Fire Chiefs' Council (NFCC) offer and so is entirely voluntary. This demonstrates SJFRS's openness, transparency and desire to improve, by requesting a recognised critical support product - the LGA Peer Review. As such, this is a pilot process, demonstrating a possible model for further joint working between the LGA and NFCC.

SJFRS has committed and passionate staff at all levels of the organisation who want to keep the residents of Jersey safe. There is no question about the levels of dedication of fire fighters and officers. The Service, led by the Chief Fire Officer, is dedicated to keeping the residents, visitors and businesses in Jersey safe through an increase in training, adherence to UK National Operational Guidance (NOG) where possible, and improved Fire Safety.

Partners see the Service, led by the credibility of the Chief Fire Officer, as a very good organisation to work with. The peer team discussed options for expanding partnership working to maximise the benefits for the Service, partners, and residents.

The "Prevention, Protection and Response" approach looks to align with best practice in the UK. However, the Service is unable to deliver effectively across all three of these functions. This is due to the reduced resources, in particularly in the last two years as the new structure has been implemented, taking out several senior officer posts (such as the Deputy Chief Fire Officer and Group Manager levels), and reducing the numbers covering roles such as Fire Safety, Policy Development and Training. This has placed multiple demands on operational staff, which in turn reduces the time available for operational staff to keep up to date with their operational training.

Fire fighters and officers reported equipment to be of good quality, with new vehicles coming on board over the near future. However, they are concerned at the amount of training needed for all fire fighters to gain and maintain competence on new vehicles and other new equipment.

Reliable data was not available on individual training records, operational learning and how staff learn from incidents in other services. This leaves the Service, and its personnel, at potential risk if there is a major incident on the island.

The Chief Fire Officer has brought these issues to the attention of the Department for Justice and Home Affairs. As result, there is a business case submitted for an increase in funding to support an expanded capacity in the Service. This business case includes a provision for an increase in on-call fire fighters. In the opinion of the peer team, this business case does not go far enough. The peer team recommend that there is an increase in whole-time fire fighters.

Fire fighters and officers are spreading themselves very thinly, with all staff trying to maintain competence in many areas. All staff are carrying out an increased range of duties and spans of control/responsibility. This links into the command structure which does not support high-level specialisation. Implementing PDR Pro will help to identify the gaps in training and help to ensure that competence is established and maintained. However, capacity is needed in order to be able to deliver, monitor, manage, and supervise training.

It has been hard to recruit officers from the UK to improve capacity, even on a secondment basis, because of the difference in cost of living between much of England and Jersey. The peer team recognise this as part of the unique operating context, alongside other challenges that the Service faces.

The Business Case for increased capacity currently focuses on recruiting On-Call firefighters rather than Wholetime firefighters due to the finances that are available to the service. This carries with it inherent risks, for example: the location of the fire stations is not conducive to recruitment of On-Call firefighters; and on-call firefighters are difficult to train and maintain competence because of their limited availability. The peer team feels that this would have limited, if any, success in increasing the capacity sufficiently to manage the risks that the Service faces.

There is a strategic aim to make the island safer through legislative change. SJFRS works from Fire Safety legislation that predates those currently used in the UK, which adds to difficulties to recruitment from the UK. It is also hard for a very limited Fire Protection team to contribute to legislative change at the same time as delivering its fire protection responsibilities. Legislative changes would have a significant effect on fire safety work, and more capacity is needed to ensure inspections are up to date, risk based, and timely. There would also be an impact on the income that the Fire Safety Team currently bring in as they currently charge for some of the work they do. This includes inspections on private premises which may not be included under changed criteria if the legislation changed to be similar (or the same as) UK legislation.

Fire Safety work in general is under-resourced and the team are struggling with the capacity to maintain CPD, training, develop expertise, carry out inspections and ensure that prosecutions can be taken where necessary. Protection delivery is not adequately resourced to risk and the NFCC competency framework.

Prevention needs to be more risk-based and focused on the needs and risks of particular vulnerable people, for example, older or disabled people. There are some good partnerships in place which could be further supported by increasing the governance and monitoring arrangements. There was evidence of innovative practices, such as the proposal to use portable, hand-held ECG monitors and feeding the readings back into health. This type of trial and all of the prevention activity would benefit from being evaluated to support data led commitment of resources.

SJFRS is not comparable to any UK Fire and Rescue Service, because of the size of the island, and because there is no additional support from neighbouring Services; there is no neighbour within a reasonable timescale. Yet there are the same risks as any UK Fire and Rescue Service: high proportion of high-rise and medium-rise residential buildings, high proportion of HMOs, high proportion of hospitality businesses, large hospital facilities, industrial gas, oil and chemical storage, risks from flooding, coastal risks, schools, colleges, businesses, road traffic collisions, alongside considerable heritage, agricultural and residential properties. As a result, the SJFRS needs to be more multi-disciplined than many UK FRS to be self- sufficient in case of any incident.

The Minister sets out in the CRMP, the aim to "make Islanders and firefighters safer by improving the capacity and capability of the service." This a sensible and appropriate aim. However, the Minister, and the Director General, need to establish an agreed corporate risk appetite in relation to firefighter safety and that of the island's residents. A Fire and Rescue Service exists to protect residents and hopefully prevent a major incident. At the moment, the lack of capacity means that we heard the Service cannot assure itself, and others, that it can prevent, or deal with, a major incident, or simultaneous incidents, nor protect its firefighters or residents if such an incident were to occur.

There are examples of silo working within the organisation where different managers have different approaches to work-life balance, some of which are not sustainable or positive. This is exacerbated by the flatter structure, with the risk that different departments can get protective about their' staff, rather than seeing all staff as contributing to a single FRS.

It is positive that the Service has undertaken a cultural change programme; but its impact needs to be reviewed on a regular basis.

2. Key recommendations

There are a number of observations and suggestions within the main section of the report. The following are the peer team's key recommendations to the council:

1. Recommendation 1

Seek innovative ways to increase capacity at Officer level to lift burden off stations to cover strategic and corporate work. The peer team suggest exploring secondments from the UK alongside the possibilities of providing accommodation (see below). There may also be an option to enter into partnership with a UK FRS to provide some of the corporate and Fire Safety roles. However, this is unlikely while there are significant differences between Jersey and the UK in legislative requirements.

2. Recommendation 2

Explore the various options to expand the capacity of the Service. As well as increasing the Wholetime capacity, further consider Dual Contracts and the flexibility of On-Call staff. Making development more appealing will enable the Service to have a wider pool of people to promote. Recognise that individuals' development and talent management is investment in the future.

2.3  Recommendation 3

Explore how the St Helier site could be imaginatively developed to include not just a new Fire and Ambulance station and Headquarters, but also accommodation. This would allow the Service to consider different operating models, such as Close Proximity Crewing or similar, to help maintain cover. It could also allow the Service to explore secondments from the UK to help with capacity. Opportunities could exist to develop commercial opportunities through this development, for example, holiday lets.

4. Recommendation 4

Ensure that PDR Pro, which has already been purchased, is used at the earliest possible opportunity to identify gaps in training. This can also be used to calculate how much time is needed to bring firefighters and officers up to date with training, and then set priorities to meet this need. SJFRS will then need to prioritise parts of National Operational Guidance to ensure realistic application.

5. Recommendation 5

Accreditation and Validation – the Service needs to decide what accreditation standard it is going to use, for example RYA or RNLI for water rescue. Appropriate training will then need to be provided, perhaps in partnership with other organisations. Validation for specialist trainers, for example Working at Height, also needs to be checked and updated. Some trainers are not confident that they are delivering training in the best possible way because they have not been revalidated for several years.

6. Recommendation 6

Dedicate resources to explore which elements of the UK National Operational Guidance (NOG) could be prioritised, adopted or adapted to enable the Service to address the risk to Jersey's fire fighters and communities.

7. Recommendation 7

Revisit the FRS sections on the JHA Risk Register, particularly those at Extreme Risk level. Identify what resources are needed in order to mitigate those risks and build them into the business case for additional resources.

8. Recommendation 8

Review the arrangement for the Government of Jersey Shared Services and revisit that relationship. Clarify what the People Hub can and should provide for the FRS and maximise the benefits of a centralised corporate support function.

9. Recommendation 9

Develop the Fire Safety department to deliver current legislative requirements, with the ambition to evolve to a more UK-style regulatory function. Establish a strategic plan to deliver this change. Consider how to mitigate the financial implications of any loss of income linked to a change in Fire Safety legislation and subsequent delivery.

10. Recommendation 10

Improve the management and use of data to enhance and support service delivery. This includes operational de-briefs as well as training records, learning from other FRSs and incidents across the UK and elsewhere.

11. Recommendation 11

Consider what could be done to make the on-call staff feel that they are an integral and valued part of the Service. This could include looking at migration policies to wholetime, terms and conditions, training options and a Close Proximity Crewing model. It could also mean exploring different types of station that UK Services have explored, for example, an on-call station housed in a business in a high-risk location, such as La Collette. It could also mean exploring different, more flexible, options for on-call and non-firefighting staff. There is an excellent example of this in the Fire Safety Team, where one of the officers is in addition a on call Fire fighter. This enhances the capacity of the Service.

12. Recommendation 12

SLT should revisit the actions from Team Jersey organisational culture programme to develop positive working relationships between operational staff and SLT

3. Summary of the peer challenge approach

1. The peer team

Peer challenges are delivered by experienced elected member and officer peers. The make-up of the peer team reflected the focus of the peer challenge and peers were selected on the basis of their relevant expertise. The peers were:

Lead Peer –Alex Johnson Chief Fire Officer South Yorkshire FRS Officer Peer – Gabby Heycock, Oxfordshire FRS

Officer Peer – Damian Watts, Surrey FRS

LGA Peer Challenge Manager – Becca Singh

NFCC Sector Led Improvement Officer – Emmanuel Williams LGA Peer Support Officer – Suraiya Khatun

2. Scope and focus

The peer team considered the following themes

1. Community Risk Management Plan – is it doing what it needs to do and is it fit for purpose. Does it adequately consider community, corporate and major hazard risks and do the priorities and initiatives in the plan constitute an appropriate strategic response.
2. Compliance with national operational guidance and progress against it
3. Fire Precautions Law – Examine the rationale and plans for reform of the Fire precautions (Jersey) Law 1977, highlight key risks and challenges arising and advise on any strategic solutions to them.
4. Capacity/Resilience and succession planning for the service. The capacity of the Service set against operational and major incident risks. The challenges and opportunities the Service faces in relation succession planning and talent management.

3. The peer challenge process

Peer challenges are improvement focused and are not designed to provide an in- depth or technical assessment of plans and proposals. The peer team used their experience and knowledge of UK fire and rescue services, structures and good practice to reflect on the information presented to them by people they met, things they saw and material that they read. It was not an inspection.

The peer team prepared by reviewing a range of documents and information in order to ensure they were familiar with the council and the challenges it is facing. The team then spent 3 days onsite in St Helier, during which they:

• Gathered information and views from more than 25 meetings, in addition to further research and reading.

• Spoke to more than 35 people including a range of FRS staff together with members and external stakeholders. In addition, the team met with every watch, including On-Call Firefighters from Western Station as well as St. Helier .

This report provides a summary of the peer team's findings. In presenting feedback, they have done so as fellow local government officers and members.

4. Feedback

1. Community Risk Management Plan (CRMP)

At the start of the CRMP, the Minister for Home Affairs states "This plan aims to make Islanders and firefighters safer by improving the capacity and capability of the service." The peer review team agree that in order to increase safety, the capacity of the Fire and Rescue Service has to be reviewed.

With an ageing population, a level of risk that is increasing as a result of population growth, higher levels of deprivation and an increase in tall buildings, standing still, or changing nothing, will in essence be moving backwards.

The approach in the CRMP of looking at the elements of prevention, protection and response is a common approach and in line with best practice. The peer review team have found that the lack of resource and strategic capacity means that the service is unable to deliver effectively across all three functions. Staff at an operational and at a

managerial level are having to make decisions on what they will prioritise which is resulting in partial delivery in some areas and the complete inability to deliver in others. As one example, if the fire safety staff focus on their critical fire safety work, including inspecting high rise buildings and meeting the legal requirements of licensing requests, they are unable to maintain the vast expectations of operational competence, despite them forming a vital part of operational resilience and response for the service.

The Service lacks the capacity to deliver on fire protection delivery at the same time as contributing to the strategic aim of making the Island safer through legislative change. Legislative change would have the highest impact on making the Island safer because it will introduce a risk assessed approach rather than a list driven mentality linked to fire service certification inspections. It will also clarify the responsibility for fire safety within a building putting the emphasis on a single, non- fire service, person and this brings in the possibility of a cultural shift accompanied by an increase in overall safety standards. New legislation would encompass more buildings than are currently certificated with the aim of creating a safer built environment for residents, visitors and fire service personnel. Whilst this would appear to increase the workload of the Protection team, in reality their work will be risk based, focussed on the highest risk and regulating compliance. The Protection team would sample the lower risk buildings and react to complaints.

In order to provide the support systems and foundations for a safe and effective response to emergencies the service is having to ask the operational watches to contribute to the development and creation of policy and training frameworks. This is directly impacting on the ability of the watches to maintain their operational competencies, to provide community safety prevention activity and to contribute to the building safety agenda.

The CRMP provides a four-year plan which, if delivered, will move the service forward but there are areas where governmental support from teams such as human resources and information technology will be essential to achieving progress. This includes some of the recruitment support, administrative support and policy development. ICT could be helping the delivery of a safe FRS by ensuring that crews have fire safety information before they arrive at a premises, for example through Mobile Data Terminals or another way to access up to date information

electronically.

The UK is currently publishing new CRMP guidance. To follow the good practice in the UK, SJFRS's CRMP needs to be supported by a "robust risk analysis process" to bring it into line with best practice. This will require the use of data, from both internal and external sources, to support this analysis. The CRMP has done this at a strategic and global scale, but this needs to be used to establish a tangible assessment of risk, the recording of control measures and the ability to monitor the impact of plans on the actual level of risk.

The service should consider introducing a horizon scanning process, for example going through a PESTELO assessment, in order to support and inform the CRMP process.

The lack of managerial resource and capacity is resulting in a serious challenge to the ability to meet the legislative requirement of "Fire and Rescue Service (Jersey) Law 2011, Part 3, Article 7 Maintenance of firefighting capability" as a result of the expectations placed on operational watches and staff to compensate for the lack of managerial capacity.

2. Compliance with National Operational Guidance (NOG) and progress SJFRS is looking to the UK for models of good practice to provide a safe and effective service for Jersey. This means they are exploring compliance with the UK NOG. The peer team recognises this as a good objective aimed at protecting Jersey's residents and businesses as well as aligning training, equipment and firefighting practice, therefore, improving firefighter safety.

However, there is not currently enough resources put towards identifying, and then prioritising, what is realistic and appropriate for Jersey to comply with. Indirectly, this could leave SJFRS open to challenge under Jersey's Health and Safety legislation and an inability to provide assurance that Firefighters are adequately protected. Firefighters know that they are not validated and accredited; training records are not yet reliable in in identifying how long it would take to get all firefighters accredited and/or qualified in their various specialisms.

To provide the service they need to provide, SJFRS need to have higher levels of multi-disciplinary competence than most UK fire services in order to be prepared for the wide range of emergencies they are asked to attend. All firefighters cover all specialisms, for example Water Rescue, Working at Height. In most UK FRS, these would be provided by specialised teams or stations. In addition, Firefighters are trying to absorb the work that in an English FRS would be done by the corporate centre and support teams. This includes implementing NOG. This takes out time and people needed for ongoing training and development. For example, for high- risk, but low frequency situations, such as a potential incident at La Collette, training is a must, but gets postponed because of the need to cover for the lack of corporate staff.

The Service can therefore not assure itself that Firefighters are adequately trained. Firefighters are making do' and would have no hesitation about tackling any situation that they find themselves in, but without adequate training, they may unwittingly put themselves, and others, at risk. The Service's training, and training records, in their current state, could be in doubt in a post-incident enquiry (such as those as a result of Grenfell or the Manchester Arena) or in a court of law.

There is a lack of performance data and management. This is connected to training records, for example learning from incidents in other places means that the Service cannot assure itself that it is satisfied that Firefighters and officers are adequately managed and performing to the best of their abilities.

3. Fire Precautions Law

Fire Safety legislation in Jersey is the same as the UK's previous Fire Precautions Act. There are plans to update fire safety legislation to be in line with UK legislation which the Peer Team support. Training for Fire Safety Officers is compliant with the NFCC competency framework, takes place in the UK, and is based on UK legislation. Separate training is sourced for certification.

The Service has recently lost long-serving officers with considerable knowledge leading to a loss in corporate memory in vital areas such as prosecution. This therefore means that those Senior Officers that are qualified, have to inspect rather than set strategy and support their teams. To emphasise this issue, there is one senior fire officer who is the only person who has any previous experience of prosecutions, albeit some time ago, and might be able to lead. This would take that senior officer away from their other duties further impacting on capacity., There are concerns that the lack of personnel has impacted on the ability to maintain and improve the fire safety of the built environment other than those that are certificated. A combination of all these issues brings into doubt the ability to successfully prosecute any breaches in fire safety legislation.

Like many UK FRSs, SJFRS has struggled to fund and recruit Fire Safety Officers. There is an added complication for SJFRS in that the legislative requirements are different to the UK, and therefore training and knowledge on the Jersey requirements is limited. Training would need to be provided to UK inspectors along with a period of shadowing which impacts on the time of the secondment and the ability to add value from the start. Updating the legislation in Jersey should help this situation, and it may help to encourage secondments from the UK to boost capacity. This would have a knock-on effect of freeing up firefighter time for training instead of covering fire safety work. This is not without risk, as the difference in the cost of living for much of the UK compared to Jersey also has an effect on recruitment. This is addressed elsewhere in this report.

The peer team suggest that the Fire Safety Team build on the relationships established, partly by this peer challenge, to find imaginative ways to increase capacity within the team. This includes the current two-year cycle of appointments, but also looking at recruiting non-uniformed staff, who could become part of the on- call resilience of the Service.

4. Capacity, Resilience and Succession Planning

There is a significant risk around succession. The peer team described this as being at crisis levels'. Looking at the age profile, it is possible that within the next three years all of the current Senior Management Team will have retired. Because the rank structure has been so slimmed down, it is not clear where the new senior officers will come from, including the next Chief Fire Officer. This needs to be explored as a matter of urgency, with the HR central resource, with NFCC and within the Service.

There is a centralised resource to support all government departments with Human Resources and other services provided. However, it is not clear what benefits SJFRS are getting from this resource. There are some specific support officers, who are based in the FRS HQ, but there may be other services that the FRS could tap into. The peer team recommend that SJFRS explores what else the centralised support could provide.

There is insufficient capacity at officer level to set the strategic direction of the Service and ensure that policy, inspection and prosecution work get the appropriate level of priority. Firefighters currently have to supplement the work of officers because of the lack of capacity, and this affects their capacity to train.

SJFRS has a policy of two-year internal postings to corporate roles. Individual firefighters have a posting for two years to a corporate role (such as training or fire protection). This is a good model, aimed at widening the levels of experience across the Service, but it is not communicated well and is not popular. It is not seen by firefighters as an opportunity to gain wider skills, but almost as a punitive measure where they are taken off their watch and shift pattern to perform a task they don't necessarily want to do, and form part of the flexi-duty cover. The secondments also affect the pay of some of those who take up the opportunity. Partly as a result of all of this, watch-based staff do not aspire to promotion. This adds to forthcoming problems of where future Senior Officers are going to come from. A new approach to communicating rotational two-year postings is needed, perhaps with some more flexibility, to encourage firefighters to look positively on promotion.

There is a high acceptance or tolerance of risk based on the perceived lack of options or solutions and an element of denial at different levels of the organisation. This means that firefighters in particular appear to have accepted that things cannot be changed, and are willing to take a higher degree of risk, to themselves and indirectly for the residents of Jersey, than is found in a UK FRS.

The on-call staff are a critical part of operational response and resilience, but their morale and feelings of worth are impacted by their terms and conditions. They are currently on a reduced hourly call-out rate compared to their wholetime colleagues, so there are high feelings of inequality in comparison to Wholetime staff. The current business case relies on increasing on-call staff. In the current situation, this may not be feasible because of where on-call staff need to be recruited from. If onsite accommodation could be provided, the service could explore a Close Proximity Crewing model which could help attract on-call firefighters.

5. Next steps

The LGA and NFCC recognise that senior political and managerial leadership will want to consider, discuss and reflect on these findings. Both the peer team and LGA are keen to build on the relationships formed through the peer challenge.

In the meantime, please do approach Becca Singh for any areas of further support: Becca.singh@local.gov.uk or Emily.McGuinness@local.gov.uk and they will work with the NFCC to help wherever possible.