Essex County Fire and Rescue Service: Cause of concern revisit letter
Letter information
From
HMI Roy Wilsher OBE QFSM
His Majesty’s Inspector of Constabulary
His Majesty’s Inspector of Fire & Rescue Services
To
Rick Hylton
Chief Fire Officer
Essex County Fire and Rescue Service
Roger Hirst
Police, Fire and Crime Commissioner
Sent on
15 February 2023
Background
In September/October 2021, we inspected Essex County Fire and Rescue Service and found that a cause of concern identified in our 2019 inspection hadn’t been fully addressed. We shared this cause of concern with you and made the following recommendation:
Cause of concern
The service has insufficient resources to meet its risk-based inspection programme. It is currently not meeting its targets. As a result, partially skilled operational staff are carrying out high-risk visits, although the service acknowledges that these are not audits. There is an absence of quality assurance of audits and visits. There is a low amount of enforcement activity. There is limited proactive engagement with businesses to promote fire safety.
Recommendations
By 30 November 2022, the service should develop and implement a clear strategy for how it will effectively meet its obligations in relation to ensuring compliance with fire safety. This should include ensuring it has appropriately trained resources, a consistent use of enforcement powers; and a mechanism to assure itself on the quality of its inspections.
You submitted documents, including a new risk-based inspection programme 2023/24 and a draft quality assurance policy, to address the cause of concern and the recommendation.
On 17 and 18 January 2023, we revisited the service to review progress. We explored the following areas:
- progress with the risk-based inspection programme;
- resources for carrying out inspections;
- progress on meeting targets;
- quality assurance of inspections;
- enforcement activity; and
- business engagement.
We interviewed staff responsible for developing and implementing your revised risk-based inspection programme and other related work. This included members of your protection, data and performance teams. We shared those findings with you at a meeting at the end of our visit.
This letter provides an update on our findings.
Governance
We found appropriate and robust governance arrangements in place to monitor progress of your plan. There is a quarterly prevention and protection governance board meeting providing oversight and scrutiny of both functions. Performance and progress are reported to service leadership team meetings and monitored by the deputy chief fire officer through the continuous improvement board. The office of the police, fire and crime commissioner provides further oversight.
Improvement plan
We were pleased to see the service’s commitment to redeveloping its risk-based inspection programme. This resulted in the introduction of the new risk-based inspection programme 2023/24 on 1 January 2023 to support the service’s overall protection strategy 2020–24.
A new draft quality assurance policy has been produced, which will be aligned to the service’s overall quality assurance framework.
The service has a succession plan in place to help manage the turnover of its protection staff.
Progress against the cause of concern
Risk-based inspection programme
The service acknowledged that its previous programme wasn’t achievable, and a new programme was introduced on 1 January 2023. The service told us it would be inspecting premises using an improved evidence-based approach, and it would be more proactively managed. This includes resourcing according to risk, sampling high-risk and very-high-risk premises, and thematic inspections.
The service is using a new dataset for understanding and identifying risk. The data has been transferred to its protection database and, at the time of the revisit, the service was reviewing and assuring the quality of the data. The data will be refreshed every six weeks.
It is currently too early to evaluate the results of the service’s new programme and show that it is working.
Resourcing of inspections
The service is increasing the number of competent inspecting officers from 21 full-time to 22.6 full-time equivalent to carry out its new risk-based inspection programme. It currently has only 17 competent staff until others have completed their training and development. This has an impact on the number and frequency of inspections of high-risk and very‑high‑risk premises that can be carried out. The service acknowledges that it is still using level 3 officers (instead of level 4) to carry out inspections at some very-high-risk premises as a result.
Workforce planning is improving and the service expects to see better recruitment and retention of protection staff, but it acknowledges that this will take time. The service also told us that it was investing £250,000 to train operational staff to carry out visits as part of its strategy to mitigate risk at lower-risk premises.
Performance
There are good performance reporting structures in place, including monthly and quarterly reports. The service has a performance dashboard with live information and is extending this to the protection team.
In 2022, the service decided to focus its resources on premises at greatest risk and set itself a target of completing 110 inspections per month. This wasn’t always achieved, but the service increased the number of inspections of premises identified as very-high-risk.
The service acknowledges that it needs to develop suitable performance metrics for the new risk-based inspection programme to help it monitor progress and understand what is working.
Quality assurance
A new quality assurance policy has been written and, at the time of inspection, was in draft format awaiting approval. As part of our revisit, we reviewed a limited number of protection records. We found some inconsistencies in the information in the records and expect the service to improve this.
Enforcement
The service still has low levels of statutory enforcement activity. It has a long-standing preference to work less formally and in a more supportive role with businesses rather than use the full extent of its enforcement powers. In the past three years, the service hasn’t pursued any prosecutions, with one potential case under consideration at the time of the revisit.
The service told us that it was committed to enforcement action that was proportionate and expected to see activity in this area increase with the new programme.
Business engagement
The service is increasing its engagement with businesses and has a dedicated business engagement manager, but acknowledges that it can do more. There has been no evaluation of business engagement, so the service doesn’t know if this part of its protection strategy contributes towards reducing risk.
Conclusion
The team was pleased to see the steps taken to address aspects of the cause of concern. We recognise the scale of the work needed and the efforts being made by staff. We found the service committed to making the changes necessary to ensure that the public is protected through fire regulation, but there is more work to do. The service must continue this journey of improvement.
The service has governance arrangements in place for continued oversight. Improvements have been made across some of the recommendations, specifically in developing a clear strategy and reviewing the risk-based inspection programme. However, the service needs to continue its work to:
- ensure it has enough appropriately trained inspectors;
- assure itself of the quality of its inspections;
- make appropriate and consistent use of enforcement powers;
- improve its proactive engagement with businesses; and
- understand the effectiveness of its protection strategy through effective evaluation.
We will not be discharging the cause of concern now. We will continue to monitor progress through updates from the service and data returns, and during our next scheduled inspection.
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Essex County Fire and Rescue Service: Cause of concern revisit letter