HMICFRS response to consultation on ‘Fire and rescue services draft inspection programme and framework commencing January 2023’

Published on: 23 December 2022

Introduction

His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS) independently assesses and reports on the effectiveness and efficiency of fire and rescue services, in the public interest.

Earlier this year, we ran a public consultation on our draft fire and rescue service (FRS) inspection programme and framework commencing January 2023. The consultation ran for 4 weeks from 9 May 2022 to 6 June 2022.

We received 46 responses:

  • 37 from FRSs, or those who work in them;
  • 2 from police and crime commissioners/fire and rescue authorities;
  • 2 from trade unions;
  • 4 from other organisations; and
  • 1 from a member of the public.

The consultation asked for views on whether the proposed programme covered the right areas of fire and rescue. We requested responses to nine specific consultation questions.

Summary of responses

1. Is focusing on service improvement the most important area for our third round of inspections?

Overall, the vast majority of those who responded supported a continued focus on service improvement. Some felt that local context, including resourcing, should be considered more in our inspections. Some respondents also felt that consideration should be given to the capacity and capability of the service to make improvements, particularly in the time since its previous inspection. Some advocated a move to a more risk-based approach. A few respondents felt that there should be more focus on thematic inspection, but others felt it wasn’t appropriate yet.

2. Are there any other aspects of effectiveness that we should focus on?

A number of those who responded referred to Fire Standards and how they are reflected in our inspection programme. Some respondents said that, while they welcomed the approach, FRSs can take time to implement and adopt the standards.

There was also a recurring theme in some responses around an increased focus on co-responding and collaborating with other emergency services and other fire and rescue services. These and other responses also highlighted the importance of working with other organisations through the local resilience forum. Respondents also mentioned the importance of working with and communicating with local communities and inspecting of support functions.

3. Are there any other aspects of efficiency or productivity that we should focus on?

We received a range of answers on efficiency and productivity. These included:

  • the need to link considerations of efficiency to effectiveness and outcomes;
  • requests that we consider differing service funding restraints when inspecting efficiency; and
  • references to other work being done in the sector in this area.

4. Should we inspect the steps FRSs are taking to address climate change? This would mean spending less time on other questions.

The majority of respondents supported the principle of inspecting the steps FRSs are taking to address climate change. However, others viewed this inclusion as premature, while some felt it would be better considered as a thematic inspection. A number of respondents who were in favour of inclusion stated that this shouldn’t be to the detriment of inspecting the three main inspection pillars of effectiveness, efficiency and people.

5. If so, what should we spend less time on?

Few responses identified areas that could be removed or deprioritised. The most frequent response was to either not inspect, or to spend less time inspecting, areas where services have previously performed well. A small number advocated incorporating consideration of climate change into existing areas of the inspection without removing anything from the framework.

6. Is there anything we can do to improve how we inspect equality, diversity and inclusion?

A number of respondents felt it was important that inspection of equality, diversity and inclusion should include a range of FRS staff, not just those in operational roles. Some respondents felt that we focused solely on gender and ethnicity. And they thought that this view should be broadened to include general diversity of experience, such as neurodiversity and people who identify as LGBTQ+.

7. Is there anything we can do to improve the way in which we report our findings?

The majority of respondents welcomed our proposal to continue to find ways to reduce the time it takes for us to publish our reports, without compromising on quality or consistency. This would support services in making improvements, and make sure that our reports provide a more up-to-date reflection of them. Some also noted the importance of sharing and reporting notable and good practice.

8. Is there anything else we should do to make our FRS assessments as fair as they can be?

As highlighted above, some services felt that we should do more to consider local context when inspecting, such as governance, finance and demographics. Some services also asked for greater continuity of, and more contact with, their service liaison lead. Others, again, suggested greater opportunity for risk-based and thematic inspection.

9. If we remove our pillar judgments, would it be easier to understand the areas in which FRSs need to improve?

Respondents expressed some concern that the removal of pillar judgments would make it less easy to understand areas for improvement and track progress of the FRS. Arguments included that pillar judgments make it easier for the public (and in some cases, it was argued, the service) to understand performance. Some also advocated their retention to provide continuity with previous rounds of inspection.

Although we didn’t consult on the addition of a fifth graded judgment, a majority of those who expressed their views were in favour of this. (A small number suggested that an alternative to the label of “adequate” should be considered.)

Our response

We are grateful for all the responses to the consultation. Throughout this process, our objective has been to make sure that we continue to focus our inspection work on what matters most to the public. While we outlined our proposed framework of inspection activity in the consultation, we are open to considering other priorities and ways of working.

Overall, the consultation provided useful feedback and suggestions for the continued improvement of our inspection approach. There was broad support for the approach outlined, with some concern expressed about the removal of pillar judgments.

The arguments for retaining pillar judgments focused primarily on the importance of helping the public to clearly understand the performance of their local FRS. Our view is that pillar judgments can mask that clarity of message where a service needs to improve. For example, it is currently possible for an FRS to receive a “good” pillar judgment for effectiveness, when one of the statutory functions (for example, protection, prevention or response) requires improvement. The introduction of an “adequate” grade would also require a new methodology for determining pillar grades (and there would be a risk that pillar judgments would drift to “adequate”).

We have therefore decided to remove pillar judgments in Round 3 inspections. This mirrors the approach that is taken in our police effectiveness, efficiency and legitimacy (PEEL) inspections. We haven’t seen anything to suggest that the public are any less informed by PEEL inspection results.

We recognise the importance of climate change and the effect it is having on the sector. The significant wildfires in summer 2022 have brought this into sharp public focus. We agree with those respondents who felt that it was too soon to incorporate consideration of climate change into the framework, particularly as there is no current national standard. We will keep this under close review as we consider the design of future inspection programmes.

We don’t intend to carry out thematic inspections as part of the forthcoming round of inspections set out in this programme and framework, but these may be conducted if we consider it necessary.

Larger tranches were used in earlier inspection cycles. We intend to move to smaller batches of publications, so we can publish our reports more quickly.

We thank those who took time to help shape our programme.

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HMICFRS response to consultation on ‘Fire and rescue services draft inspection programme and framework commencing January 2023’