Striking the right balance

After an extensive review of all Fire and Rescue Service sector guidance was launched in 2008, Bill Gough explains how a new framework document sets a benchmark for good practice.

 

Dynamic risk assessment (DRA) is one of the principal risk assessment tools used by the emergency services. DRA was formally introduced to the Fire and Rescue Service (FRS) in 1998 when every operational member of staff was issued with a personal copy of Dynamic management of risk at operational incidents.¹

The 20-page pamphlet described the FRS approach to “the continuous process of identifying hazards, assessing risk, taking action to eliminate or reduce risk, monitoring and reviewing in the rapidly changing circumstances of an operational incident”.

 

Based on the POPMAR principles of HSG65 and the HSE’s “Five Steps”² approach, the DRA pamphlet was considered to be the bedrock of incident safety and was regularly refreshed, the eighth and most recent version being published in 2008.   

 

The DRA pamphlet came with four other volumes of national guidance designed to separately inform senior officers, managers and trainers about their health and safety duties and responsibilities and also included details on generic operational risk assessments.

 

Volume one was a guide for senior officers and provided chief fire officers with an “overview of an H&S structure for a brigade”. Volume two was directed at managers in the fire brigade and explained relevant health and safety legislation and regulation and how it should be applied.  This was effectively the FRS interpretation of HSG65 and POPMAR.  Volume three was an extensive publication of generic risk assessments (GRAs). 

 

However, given that these guides were published under Crown Copyright by the Home Office and at the time owned by Her Majesty’s Fire Service Inspectorate, litigators and enforcers were reluctant to recognise them as guidance. This was because they implicitly represented the ‘significant findings of a risk assessment’ but not one conducted by the duty holder, the employer.  

 

Published two years later, volume four was a training model that offered the sector new guidance. This volume took account of the principles of a newly developed competency framework that for the first time included national role maps and their relevant occupational standards.  However, among all of this guidance, only the DRA pamphlet and GRAs were reviewed periodically and kept up to date. 

 

Time for change

 

In 2008, under the direction of the newly appointed chief fire advisor to the Government, Sir Ken Knight, an extensive review of all FRS sector guidance was launched. 

 

While the initial focus centred on the GRAs, in summer 2009 attention turned to the four guidance volumes and the more general, existing occupational health, safety and welfare. 

 

Described by Sir Ken Knight as the “the most important of debates”, a national consultation process was launched at a two-day workshop at Craxton Wood in Cheshire in November 2009 to look at the best way forward. 

 

There was unanimous agreement that revision was necessary and overdue and that any revised publication(s) would need to consider a number of recommendations. Delegates called for the formation of a small independent review team as part of the overall guidance review programme.  

 

During the workshop it became clear that while managers from across the FRS sector were no longer ‘sighted’ on volumes one and two of the national guidance, many had no knowledge at all of the existence of volume four, training for competence.

 

The review team started its work in spring 2010 and included expert opinion from across the FRS sector as well as views, opinions, knowledge and influence from the HSE. Most important of all, it included input from the trade unions, collectively represented by the Fire Brigades Union.  

 

Veronica Adlam³  (see her ‘Unforgettable Fire’ article), who was heavily involved with the investigation into the deaths of two Stevenage firefighters in 2005⁴, was one of the team to bring important knowledge of behaviour safety to the mix. An HSE inspector, who at the time was involved with the investigation into the Atherstone-on-Stour fire⁵, which claimed the lives of four Warwickshire firefighters, was also involved. Another team member (this author) would later become involved with the investigation into the deaths of two Hampshire firefighters in April 2010.⁶

 

This was also at the same time that the HSE was conducting its long overdue ‘refresh’ of HSG65 and it was hoped that this would help shape the new guidance. The review team’s first recommendation was to replace the original volumes and DRA pamphlet with a single volume in two parts — one relating to general health and safety management in the FRS workplace and the other, more specifically, structured around the operational environment. The extensive sector research that the review team carried out took place while a debate was going on across not only emergency services but also the health and safety sector as a whole. 

 

This was also when the FRS was coming to terms with the arrest of three officers serving with Warwickshire Fire and Rescue Service following the Atherstone-on-Stour tragedy and the HSE publishing its ‘Striking the Balance^‘7 statement for the Fire Service. Tragically, two firefighters also lost their lives while fighting a fire in Southampton, and as 2010 was coming to a close Lord Young⁸  published his report. 

 

In 2011, the HSE published its Striking the Balance statement for the Police Service9 along with statements about heroic acts for both services.¹⁰  As the review team’s work was drawing to a conclusion and it was embarking on drafting a new document, the Lofstedt  report was published.¹¹

 

By autumn 2012 eight drafts had evolved and two parts had become one. The focus was biased toward operational safety, the new shape and direction of HSG65 was still not known but we were able to include the easier plan, do, check, act model and more importantly the working title had developed to a publication directed at fire and rescue authorities.

 

The duty holder

 

The change of title recognised the ‘duty’ placed upon a fire and rescue authority (FRA) to provide a fire and rescue service and, as an employer for the health, safety and welfare of all FRS employees whether or not they are operational firefighters.  A stark example of this is the £30,000 fine imposed by Mr Justice Macduff on Warwickshire County Council in December 2012 for its deficiencies in record keeping and information given to fire crews at the time of the Atherstone-on-Stour incident. 

 

In June this year the new Fire and Rescue Authorities’ health, safety and welfare framework for the operational environment¹²  was published and replaced the earlier volumes (except volume three, which remains in its existing form). The framework now offers consolidated strategic level guidance to FRAs, chief fire officers and chief executives for planning their health and safety arrangements as they apply to the unique operational and training environments of firefighters. 

 

With the exception of HSG65, which has still yet to be published, the new framework recognises the extensive review of health and safety guidance that was already under way and avoids replication of any existing or new health and safety guidance that applies to the normal and routine activities of the workplace.  One of the more important objectives satisfied by this new framework is that it sets a benchmark in the form of good practice against which existing systems and arrangements can be measured, reviewed or even audited.  

 

Top down

 

The framework calls for “clear and positive safety leadership” from FRAs, chief fire officers and their principal management teams. The call for leadership is extended to operational incidents where incident command represents an area in which leadership has a risk critical and central role.  It recognises the HSE position on heroism in the FRS.

 

The clearest example where strong leadership is required lies in establishing appropriate command and control arrangements when exercising the most critical decisions affecting firefighter safety in the often emotionally-charged circumstances where they are being called upon to “to save saveable lives”.

 

The document drew on the lessons learned from a number of operational tragedies and took onboard eight organisational responsibilities originally presented as part of a safe person concept.   

 

With additional context they have now evolved into 10 ‘principles’ that set a benchmark that in turn can be used as key performance indicators for operational safety.  In a similar way, but with added descriptive context, the original ‘personal’ responsibilities of the concept are consolidated into individual responsibilities that recognise five key elements to being a safe person that can reduce the risk of error and injury in the operational environment.  Some of these are built on behaviours that are developed with experience, while others are important non-technical skills that can be acquired through training and development. 

 

These are:

Integrated planning

 

Emphasis is placed on the importance of planning to achieve the successful delivery of an authority’s policy for safe operations.  Capturing the concept of risk-profiling the framework clearly states that to adequately address and mitigate fire and rescue-related risk in the community, operational policy must be based on an Integrated Risk Management Plan (IRMP).  

 

This requirement to achieve an ‘integrated’ approach ensures that authorities are proactive in identifying and assessing foreseeable risk. Now, in partnership with many other agencies and organisations, where possible, they need to eliminate, and control identified hazards and risks.  

 

These planning arrangements take place at three organisational levels starting at the top or strategic level where priorities are decided, suitable resources are provided and strategies established.  The next level is at the systemic level where strategies for operational safety are delivered. The final level is the dynamic/incident level where risk is continuously evaluated and managed and where post-incident review delivers the lessons of experience back into the strategic level via the systemic.  This establishes the foundation on which four pillars of risk assessment support the structure of the safe person principles. 

 

Four pillars

 

The first three pillars of risk assessment describe fire service operations. They start with the previously mentioned generic hazard information derived from the combined knowledge and experiences of the entire FRS sector.  They are currently referred to as GRAs but under the next phase of guidance review they will be appropriately re-branded and have a new description that best reflects their status as generic hazard and risk statements.  

 

This generic information will then inform the approach taken by individual FRAs in satisfying their duty to conduct a suitable and sufficient assessment of foreseeable operational risk in their area and the production of standard operating procedures (SOPs).  The first two pillars are designed to ensure that when operational crews attend an incident scene they will have the skill, knowledge, equipment and information to deal with all foreseeable circumstances.

 

The third pillar of risk assessment, upon which operational safety stands captures, the ‘operational intelligence’ gathered at the scene of an incident. This is when an incident commander conducts the now familiar incident dynamic risk assessment or DRA.  

 

The intention of this is that, based on a balance of risk and benefit, the safest possible systems of work are adopted for the prevailing circumstances.  DRA also accepts that this may mean that in the case of preservation of life the lowest level of risk may briefly fall in what some may describe as the ‘intolerable’ zone.  This means that the risk assessment processes have, at the time they are deployed, taken into account all that is known and reasonably foreseeable about the hazards and risks faced by firefighters.  The fourth and final pillar recognises that there may still yet be unknown unknowns; unexpected or unforeseeable hazards that unsupervised firefighters may encounter.

 

In most cases, operational incidents are dealt with by firefighters working alongside and under the direct supervision of their line managers.  However, with this new fourth level of personal safety assessment, the framework recognises that there are circumstances when they are required to work remotely and make decisions for themselves, when the ’employers’ incident risk assessment will only have been able to take account of what is reasonable to expect, foresee or know about incident hazards and risks.  

 

There is another layer of risk assessment, one designed to inform personal safety in circumstances where unsupervised firefighters may encounter an unexpected or unforeseen situation.  This individual risk assessment adopts a behavioural approach and describes the process of identifying and assessing risk in order to influence the risk-taking behaviour and actions of firefighters when they encounter these circumstances.  

 

At the very core of this personal safety assessment and before taking any action, acting as a check and balance, is the requirement to communicate the circumstances that affect the situation to supervisors or commanders who are remote from, and not sighted on the new situation.  One such personal safety assessment, the STAR model, is included as an appendix in the framework and has also been shortlisted in two categories at this year’s IOSH awards.

 

One of the key issues to come out of the workshop was the lack of guidance for strategic managers relating to operational welfare and wellbeing.  While some may still consider five pages barely adequate, the framework now also offers links to several FRS sector research reports and HSE guides that clearly identify the who, what and how of responsible and effective arrangements for the management of welfare and physical wellbeing at incidents. More importantly, the framework establishes a clear relationship between these arrangements and the safe person principles described above.

   

Conclusion

 

At the time of writing this article, in fulfilling their statutory duty to make arrangements for dealing with fires, road traffic accidents and other emergencies, fire authorities are making contingency plans for maintaining an operational capability in the face of yet another national firefighters’ strike. 

 

They are also managing their way through what can only be described as the most significant and widely impacting cuts in funding in the Fire Service’s history.  While operational demands are being successfully managed down through community safety education and similar prevention initiatives, attending the funeral of Manchester firefighter Stephen Hunt, who was tragically killed in a Manchester city centre fire last July, brought into stark focus the importance of ensuring operational safety.  

 

As a member of the team responsible for the 66-page framework document, I sincerely hope its impact serves a simple mantra that “…everyone goes home…” 

 

References

 

Bill Gough is one of the longest serving operational officers in the British Fire and Rescue Service