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Summary |
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As part of the development of the National Framework document 2006/08, the ODPM have consulted Fire and Rescue Services and requested submissions by 10 February 2006. The following comments on the Draft National Framework were prepared and agreed by CMT for submission to the OPDM. |
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RecommendationError! Bookmark not defined.(s) |
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2.1 |
That Hampshire Fire and Rescue Authority note the contents of the Draft National Framework Document 2006/08 and Strategy for Children and Young People consultation submission. |
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3 |
Introduction Error! Bookmark not defined.and Background |
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3.1 |
Hampshire Fire and Rescue Service (HFRS) welcomes the opportunity to contribute to the National Framework 2006/08 and Strategy for Children and Young People. The following submission is therefore presented in accordance with the Fire and Rescue Circular 52 - 2005. National Framework Document 2006/08Introduction We welcome the new PSA target introduced in April 2005 :- By 2010, reduce the number of accidental fire-related deaths in the home by 20% and the number of deliberate fires by 10% HFRS has many initiatives already in place to achieve this target and more are planned. Indication of our success to date is shown in the reduction of arson related incidents which have fallen by 27% in 2005. We also welcome the proposal to lengthen the planning cycle of the National Framework to a two year period. It provides more certainty about future Government expectations so that we can develop and integrate our medium-term business plans. In particular, it will also enable Fire and Rescue Authorities to better align their own Integrated Risk Management Plans (IRMP) with the Framework. |
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4 |
Chapter 1 - Fire Prevention and Risk Management |
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4.1 |
1.6 (Paragraph numbering from the National Framework Document) The concept of an IRMP steering group appears to be new and although we can see the benefits in ensuring continued stakeholder engagement in the implementation and development of the planning process, the Framework does not make it clear who the representatives of the fire industry would be. |
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4.2 |
1.8 We are keen to see the "further development of FSEC" by the IRMP Steering Group and would hope that the positive work being undertaken in Community Fire Safety is developed as one of the factors of the community risk. |
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4.3 |
1.12 We support the comment regarding the use of Community Advocates, which we see as an essential step in fully understanding the risks to vulnerable groups with the community. This is why we are proposing to employ an older persons advocate from 2006/07. |
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4.4 |
1.19 HFRS has, over many years, developed an excellent schools' education programme and consider that we are delivering best practice in promoting fire safety to children. However, an area which appears to have been overlooked both in the Strategy and in the National Framework is the loss of life and injury caused to young people as a result of road traffic collisions. Numerous tragic examples show how at risk this group are and we believe the Fire and Rescue Authorities have an important role to play in helping to promote road safety as an integrated element of its schools education programme and youth activities. |
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4.5 |
1.23 We welcome the proposal to introduce new powers for local authorities to tackle nuisance vehicles, a development which will enhance our ability to work with partners to further develop car clearing schemes and reduce incidents of arson still further. |
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4.6 |
1.28 HFRS has made full use of the funding opportunity having been a recipient of funding for one of the 66 projects. We look forward to seeing the results of the evaluation exercise and are confident that it will show that this funding has enabled Authorities to develop initiatives that reduce the number of arson fires. An indication of continued funding through to 2010 would enable Authorities to maintain initiatives aimed at achieving the PSA target. |
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4.7 |
1.31 We welcome the fundamental review of Part b and support Approved Document B which, coupled with the house building plans for the Southeast, provide the opportunity to build safe housing for future generations. However, as detailed in our submission to the consultation in July, this will only be achieved by the inclusion of fire suppression systems. The statement: "...we are therefore considering the role that sprinklers can play as part of a package of measures." appears totally inadequate and misses a real opportunity to take more positive action. |
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4.8 |
1.34 / 1.35 We are very disappointed to hear of the delay in implementation of the Fire Regulatory Reform Order. HFRS has made many preparations for the change in Legislation. We would like a clear indication within the Framework Document as to the revised timescale for implementation and a confirmation that the ODPM will compensate Fire Services for the losses incurred due to the delay. The use of the term "Inspection Programme" should be replaced with "Audit Programme" which supports the change in emphasis seen within the new Fire regulatory reform order from an inspection of the premises to an audit of the fire risk assessment. |
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4.9 |
1.36 / 1.38 Fire and Rescue Authorities should be aware of the roles played by the CPIG and the MOD Fire Service in managing risk in Crown Premises. Each Authority, as part of its IRMP, should consider the risk posed by Crown Estate and should aim to work in conjunction with the CPIG and/or Mod Fire Service to ensure that effective risk management strategies are in place for the highest risks. In some cases, this process will require identification of risks based on factors such as strategic importance and close liaison will be needed to match the IRMP to such risks. While it is recognised that MOD will retain full control of activities in MOD establishments and that some may not be appropriate for joint working given security and sensitivity considerations, a significant majority of MOD premises are high value, high risk establishments in which Fire and Rescue Authorities can play a full and active part in the protection and response arenas and contribute to the overall UK resilience capability. |
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Chapter 2 - Working together: the regional approach |
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5.1 |
2.5 We recognise the greater expectation placed upon Regional Management Boards to deliver efficiencies through collaboration. Hampshire has been particularly proactive in many areas as demonstrated in our recent Annual Efficiency Statement. We welcome the acknowledgement of the need to build sufficient resource capacity in order to make greater progress. We therefore, look forward to a favourable response to the South East capacity building bid. |
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5.2 |
2.13 / 2.14 We acknowledge the consultation process undertaken to determine the governance arrangements for regional control centres and the requirement for Regional Management Boards to establish Local Authority companies. However, no formal request has yet been received by the Chair of the South East Regional Management Board to commence the necessary work to establish a company. Therefore, the timescale of "Spring 2006" for its establishment is wholly unrealistic. |
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5.3 |
2.15 We would like to reiterate our, and the region's, previously raised concerns of the legal and financial vulnerability Authority's face because of the lack of the full business case. In paragraph 4.33 you have rightly documented the risks regarding operational continuity due the implementation of Firelink. It is surprising, therefore, that the ODPM does not appear to have accepted the same level of responsibility for implementation of the FiReControl project even though the risks of maintain existing control room systems is high. Whilst we recognise it may not be possible for you to accept responsibility for mitigating the risk of the 'soft' issues such as maintaining staff you should, we believe, accept responsibility for operational continuity of the 'hard' issues, such as failure of equipment. This is particularly relevant to Fire and Rescue Services whose current system suppliers may cease to supply and maintain the 'fire' market once a contract is awarded for the FiReControl systems. |
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6 |
Chapter 3 - Effective response |
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6.1 |
3.15 We acknowledge the need to share resources across the Local Authority boundaries. However, we feel that this statement should include some reference to regional and national capacity. If this is not included, there is a risk that each Authority will pursue these efficiencies without regard to regional and national resilience. |
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6.2 |
3.28 We support the Audit Commission's involvement in the development of the Fire CPA however, we feel that it was ill-judged to leave out the most risk critical elements of our work: "operational response". Too much energy was spent, post CPA, in describing what CPA did not cover. We therefore support the development of operational assurance and would seek for a suitable Key Line of Enquiry (KLOE) to be included in future CPA development. |
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6.3 |
3.29 We question as to whether HMFSI will, in the future, have the capacity or expertise to undertake the operational assurance role. We would rather see a peer review approach developed in conjunction with the Audit Commission. |
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6.4 |
3.31 We are concerned at the lack of up to date guidance on operational assurance. We are also concerned (if draft papers are anything to go by) that the eventual guidance will not provide Authorities with the framework necessary to develop a robust and consistent approach that properly covers all aspects of service delivery to the public. |
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7 |
Chapter 4 - Resilience |
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7.1 |
4.12 We are disappointed that Government has failed to address an acknowledged burden placed on CFA's as a result of becoming a Category 1 Responder. |
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7.2 |
4.15 We support the view that regional resilience teams have enabled a better co-ordinated response to major incidents. The recent major fire at the oil storage fire at Bunsfield in Hertfordshire showed that these teams are performing a vital role in the complex co-ordination of specialist equipment and expertise to ensure the most effective response. The future funding of these teams is unclear. It would assist Fire Authorities if the National Framework was clear as to the continued support and funding. |
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7.3 |
4.33 We fully support the ODPM's approach to funding measures that will sustain high risk items of existing systems to ensure operational continuity and ask that the same principle be adopted for the FiReControl equipment. |
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8 |
Chapter 5 - Fire and Rescue Staff |
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8.1 |
5.12 This states a clear expectation for the Regional Management Board to have an HR Strategy by Summer 2006. This appears to be a very short timescale for such a broad regional strategy. |
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8.2 |
5.19 Hampshire Fire and Rescue Service has had significant experience dealing with children through its Schools Education Programme and supports the new requirement on Fire Authorities to carry out CRB checks on staff who will be working with children and vulnerable adults. However, we are concerned over the bureaucratic process this requires and therefore, the speed of achieving this. |
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8.3 |
5.27 We support the instigation of research by the ODPM and Health and Safety Executive into sickness absence in the Fire Service and would be keen to take an active part in the study. We welcome the introduction of targets which are based on research and a solid evidential basis. We also support targets being set across the whole workforce with an ability to cut data as required this assists in our objective to develop a more inclusive culture. |
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8.4 |
5.33 We understand the complexity of the consultation process on changes to the pension scheme and the on-going negotiations regarding the changes. However, to say, "...it is envisaged any new scheme will be operational during 2006-7" is too vague. It would help if there was early notification if there is to be slippage on the previously published start date of April 2006. Without clear information it is becoming increasingly difficult to provide new employees information about the terms and conditions they are being offered when employed. |
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Chapter 6 - Workforce Development |
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9.1 |
6.5 We welcome the opportunity to be consulted on the processes for firefighter selection and progression. We have fed our comments through to the regional HR work stream which is responding on behalf of the South East Region. Having been involved in the piloting of the firefighter selection tests and as an employer of over 750 retained personnel, we remain concerned as to the potential negative impact the selection process will have on candidates applying for RDS roles. |
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9.2 |
6.8 / 6.10 We support the statements regarding the need for flexible provision of training and development in the future and the benefits of providing some of this through regional collaboration. This is recognised and well advanced within the South East Region. |
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9.3 |
6.11 This places a requirement on RMB's to carry out a review of existing training facilities and resources by March 2007. This is planned to commence in the Spring 2006 and will be completed by the date required. |
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Chapter 7 - Finance |
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10.1 |
7.4 We support the discipline and rigour provided by the introduction of the Annual Efficiency Statements. We look forward to submitting the mid year update and are happy to report that our submission on 17 November showed us to be on target to achieve £1.19m cumulative cashable efficiency gains by the end of 2005/06. |
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10.2 |
7.19 - 7.20 We are supportive of the fact that these paragraphs indicate that new burdens will be considered for the implementation period of new dimensions equipment and the transition to the Regional Control Centres. |
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11 |
Chapter 8 - Performance Management |
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11.1 |
8.6 Paragraph 8.6 refers to the establishment of regional improvement partnerships. The South East RMB have anticipated this and as a result, Hampshire has led on a proposal to submit a capacity building bid which focuses on performance improvement in individual Authorities rather than establishing new regional bodies. |
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11.2 |
8.7 We support the development of appropriate performance assessment processes and would like to be considered as one of the stakeholders in the development of this work. It is disappointing to note that there is no mention here of the intention to develop Fire CPA to encompass operational assurance. As stated above, we feel this is a vital area that must be included as a separate KLOE in the next phase of Fire CPA. |
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11.3 |
8.11 HFRS has played a leading role in the Performance Improvement Network and the development of the Fire Service Consultation Association, both of which have enabled Fire Services across the Country to share best practice and exchange benchmark data. Recognition of these valuable inter-authority performance review forums would be helpful within this section. |
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11.4 |
8.14 We welcome the fact that there are no immediate plans to review the BVPI's and we acknowledge the work undertaken by the Working Group to develop the current indicators. We also realise the need for stability to provide year on year comparison and enable Fire and Rescue Authorities to evidence real improvement and also to allow time for the ODPM to undertake appropriate research based on the information provided by the current range of indicators. However, ruling out any change seems to be a very fixed position and in an industry undergoing such change, it may well be that in a short period, the indicators seem inadequate and in need of further development. We suggest it would be more appropriate to state that these will be kept under review and changed only where the need can be justified. |
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11.5 |
Strategy for Children and Young People |
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11.6 |
Goals and underpinning aims HFRS welcome the draft strategy from ODPM and the recognition of the contribution the Fire Service has to make to the safety of children and young people. The draft document states that the strategy "covers all aspects of Fire and Rescue Service involvement with children and young people" and further that the focus of the strategy is to "deliver effective reduction of fire risk and fire crime". As such, the goals and aims are focussed purely on fire related incidents. There is no recognition within the document of the work by the Fire Service to reduce the impact of road/traffic related death and injury amongst children and young people. This does not support the direction given within the National Framework document (Section 1.39 - Road Traffic Accidents) which encourages FRS to work in partnership to reduce the number and impact of RTC's. HFRS recommend that the strategy reflect the increasing role of Fire and Rescue Services in reducing the impact of fires and other emergencies, in particular RTC's on children and young people. |
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11.7 |
Funding arrangements The strategy provides a welcome focus on a particular group of people at risk and places emphasis on involvement of children in the design, delivery and evaluation of programmes; engagement with other agencies to identify those at risk and those who offend; development of youth training to improve life skills and divert young people from crime and anti-social behaviour. To achieve the goals and aims successfully will require sufficient resources and suitably skilled/qualified people to ensure quality outcomes are achieved. It is hoped that future funding for the service recognises the increased responsibilities and human/physical resource requirements required to deliver the strategy. |
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12 |
Contribution to Corporate Aims and Objectives |
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12.1 |
Once the final draft of the National Framework Document is published, the Service will check that the Corporate aims and objectives remain aligned to the requirements of the National Framework Document. |
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Risk Analysis |
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13.1 |
None of the proposed changes to the National Framework document significantly increase the corporate risks identified in the Corporate Risk Register but as these as confirmed any changes caused will be considered as part of the regular review of corporate risk. |
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14 |
Resource Implications |
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14.1 |
There are no resource implications as a result of this consultation submission. |
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15 |
Equality Impact Assessment |
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15.1 |
No EIA is required for the submission. |
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15.3 |
The proposals within this report are considered compatible with the provisions of the European Convention on Human Rights, the Human Rights Act 1998, and the Race Relations (Amendment) Act 2000. |
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16 |
Consultation |
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16.1 |
Senior Managers, the Service Management Team and the Corporate Management Team have been consulted of the submission and the comment received have been incorporated. |
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17 |
Conclusion |
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17.1 |
The main areas of change in the Draft National Framework is the move to a two yearly planning process, which aligns with our own IRMP proposals and an increased expectations on the Regional Management Board. Other more detailed changes have been commented upon and once the final version is published, the Service will check to ensure that current strategies align with these more subtle changes in direction. |
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Background Information (Section 100D of Local Government Act 1972) |
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The following documents disclose the facts or matters on which this report, or an important part of it, is based and has been relied upon to a material extent in the preparation of the report: http://www.safety.odpm.gov.uk/bregs/brpub/br-booklet/whole.htm Note: The list excludes: (1) published works; and (2) documents that disclose exempt or confidential information defined in the Act. |
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