High rise buildings - firefighting arrangements: report
HM Fire Service Inspectorate (HMFSI) report assessing the Scottish Fire and Rescue Service's (SFRS's) arrangements and readiness to fight fires in high rise buildings in Scotland. It contains areas of good practice and recommendations where there is scope to improve performance.
Operational Procedures
97. Firefighting in high rise buildings can be resource-intensive and physically demanding. To facilitate this, the SFRS sends more fire appliances to reports of fire in mainland high rise domestic buildings, than would normally attend at other reported dwelling fires.
98. The SFRS uses a system of SOPs which contain procedures for dealing with different types of incident or scenario. The SFRS procedure for firefighting in high rise buildings is contained in a SOP. We considered two aspects of the high rise SOP:
- suitability of the document, and
- suitability of the procedures contained within the SOP
99. There are some Ministry of Defence (MOD) operated high rise buildings which would require a different approach from the SFRS and a need for the Service to have specific liaison, engagement and preplanning with the MOD FRS. While we mention this for background, we did not explore these arrangements in our inspection.
100. There is also at least one high rise domestic building on an island and for which, parts of the SOP will not necessarily apply to. In such situations a local solution, or an adaptation to the SOP based on the specific circumstances, is appropriate.
Standard Operating Procedure (SOP)
Comment on the SOP document
101. The SFRS has acknowledged the need to amend or change its procedural documents, including SOPs. One of the challenges with written procedures is that firefighters can be swamped by the length of documents and breadth of information contained within. The Service has commenced a Document Conversion Programme and in 2021 carried out a staff survey to obtain feedback on existing documents. Consequently the high rise SOP is subject to revision by the Service to streamline the document. We examined the existing high rise SOP since it was the version in force at the time of drafting this report. We are mindful however that the Service may already have some of the content issues we mention below in hand.
102. The feedback we received at fire stations regarding the SOP referenced the suitability of the document and comment on the procedures that the document imposes. The feedback regarding the document was predominantly in line with our view that the document is over-lengthy and would benefit from a different structure.
103. The suggestions that were made to us for improvement included reducing the size of the document and structuring the document into a 'need to know'/'nice to know' split.
104. The SOP contains procedures for different scenarios in a high rise building. The procedures include:
- a standard building firefighting procedure for a fire within the lower floors of a high rise building
- a standard high rise firefighting procedure and guidance for a fire on an upper floor
- a predetermined modified firefighting procedure for a fire on an upper floor in a building where it is known that the standard procedure. cannot be applied and a unique, site-specific procedure, is then established
- an investigation procedure where no firefighting is anticipated
- a procedure for fires in chutes and lift rooms.
105. We think that there is scope for the document to be amended to improve consistency in the extent to which the procedures are offering an incident commander guidance or whether there is compulsion of actions. Terms like 'potentially applicable' and 'considerations' sit alongside actions which are described in a mandatory way: 'shall', 'should', 'as soon as possible'. While it is appropriate for any procedure to contain a combination of mandatory actions and discretionary actions, the effect here is one of uncertainty or contradiction.
106. There are a number of fragmented and unclear references in the SOP to information gathering and familiarity. Given that there are separate SFRS procedures for information gathering and familiarity visits, we think that there is scope for rationalisation in the SOP to aid clarity.
107. The guidance in the SOP advises that when a crew arrive at an incident, the external indicator plate should be consulted, and if there is no plate then OI should be consulted. This is contradictory to the aide-memoire in the SOP which advises that OI should be consulted while the crew are en-route to the incident.
108. The concept of compartment failure could be important in operational decision-making. The SOP contains evacuation criteria relevant to 'compartment', but compartment is undefined in the SOP. While 'compartment firefighting' is a generally used and understood term, it is likely to mean different things in different buildings. We think some of the references to 'compartment' in the SOP regarding domestic high rise needs a specific description or definition.
109. There is a description of the delay that would occur if the first fire appliance attending has a crew of four or if there is a delay in the attendance of the second fire appliance to attend. We think that the emphasis on four is incorrect. A first-attending fire appliance with five crew would be in a similar situation, with the crew carrying out preliminary activities and waiting for a second appliance to attend to fully put in place the system of work.
110. The following bullets list some other issues we noted in the document:
- Reference to Fire Survival Guidance (FSG) could be expanded to aid understanding, the term is undefined.
- There is guidance on the scenario of wet riser failure and a desired water pressure when charging a riser is specified. There is no similar guidance for normal charging of a dry riser.
- There is a description which suggests that being presented with a developed fire and persons reported on arrival is a situation that a 'short crew appliance' could be faced with. In fact any combination of attendees could encounter such a scenario.
- There is a reference to keeping smoke from the 'firefighting lift shaft' that should read 'firefighting shaft'.
- The single use of the term 'firefighting lift' is inconsistent with the other 64 references in the SOP to lifts.
- There is reference to high rise premises designed to contain a fire within the room of origin. We think this generally incorrect other than perhaps for those buildings fitted with an automatic suppression system. The reference should be to the flat of origin.
- There are references in the SOP to fire division, and wet riser threshold that are out of date, and reference to legislation that was repealed many years ago.
111. When compared to some of the guidance used outside of Scotland, the SFRS document is written in a very prescriptive way. We think that the structure and content of the SOP has scope for improvement.
Recommendation No. 6
We are mindful that a general document conversion programme is in progress and that rewrite of the high rise SOP by the Service is well advanced.
The SOP rewrite should consider the issues we mention in this report to improve its usability for the end users.
Comment on procedures in the SFRS SOP
112. The initial firefighting action for an upper floor fire includes four personnel ascending together by lift with BA 'under air' to a bridgehead position at least two floors below the reported fire. Two firefighters are then committed to fighting the fire in BA with water supplied from the riser from the floor below the fire. The other two personnel who had arrived with the firefighting team (the lift operator and the Fire Sector Commander (FSC)) then return to the ground floor (or access level) by lift and remove their BA (though of course there is scope to have a pre-determined alteration to this procedure due to building constraints).
113. The return of the FSC to the ground floor to remove BA leaves the firefighting team without close support or assistance until someone returns to or arrives at the bridgehead.
114. The fact that the four personnel are in BA 'under air' is designed to offer respiratory protection in the event that fire or smoke is unknowingly affecting the lift arrival floor. This part of the procedure is prescriptive and has its origin in a firefighting incident that occurred almost 20 years ago, following which the Health and Safety Executive issued an Improvement Notice to the then Fire Brigade to provide a safe system of work.
115. The reason for the FSC's return to the access floor is to remove BA and return the personal tally to the BA entry control. After this the FSC returns to the bridgehead and the Breathing Apparatus Entry Control Officer (BAECO) relocates to the bridgehead.
116. Personnel generally raised issues with ourselves regarding this part of the SOP. The Service has an Operational Assurance process whereby issues that arise from exercises, training and incidents can be reported on and action taken where appropriate (and we saw good examples of this relative to high rise incidents and training). However the issues raised are more generic and not issues likely to be raised through the Operational Assurance process.
117. The initial procedure in the SOP is emotive for station-based personnel and we received suggestions for change, such as:
- the procedure should not be delayed if only three firefighters are initially available to ascend, and a firefighter team leader could make the decision about suitability of bridgehead
- the FSC should be able to remain at the bridgehead rather than return to the access level.
118. Generally, SFRS crews consider that the procedure works well in areas where the weight of resources is in attendance promptly. In other areas or situations it can be challenging and put the incident commander under pressure and in a dilemma. First attending crews could be placed under psychological pressures by being unable to attempt rescue or search if the incident is serious or is 'persons reported'. (The SFRS has a rapid deployment procedure in section 6.2.4 of the SFRS's BA POG (Policy and Operational Guidance) but this cannot be used with this SOP).
119. While the initial attending incident commander always has the potential to use operational discretion where relevant, delay to supporting appliances is not unusual and is foreseeable, therefore such a situation is outside the scope of operational discretion.
120. The firefighting procedure in the SOP is prescriptive and removes a level of risk assessment and decision making from the incident commander. None of the high rise procedures that we examined from other FRSs contained this level of prescription.
121. One of the issues that the Grenfell Tower fire has highlighted is the requirement for FRSs to have in place procedures for partial or full evacuation of tall buildings in the event of significant failure of the building. Evacuation planning is an evolving area as identified elsewhere in the report and the SFRS has introduced some evacuation related content into the SOP. As the Service updates its procedures there is scope for developing the SOP to reflect the Service's evacuation arrangements and associated record keeping.
122. The SOP, having being written principally for domestic premises, would benefit from consideration of the range of issues that may apply to non-domestic high rise buildings. For example, there may be unknown potential issues with the availability, performance and use of lifts in non-domestic premises out of hours. And conversely, the information available while attending an incident in some other buildings, for example a high rise hospital, may be good and reliable to inform a course of action.
How the SOP guidance is interpreted and implemented
123. Commonly, there are local arrangements in place in relation to attendance sequencing and allocation of tasks.
124. Reportedly, the investigation procedure contained in the SOP is commonly used where a concierge is already in attendance and there is good information from CCTV.
125. During the course of our inspection we tested the awareness of personnel on the content of the SOP. The knowledge displayed was good but given that most of our visits were pre-announced, this could be expected as a consequence of pre-visit preparation. However, during one unannounced visit we experienced awareness that did not match the high standard experienced at other venues.
126. During our visits we engaged separately with Crew Commanders and Watch Commanders and it was evident that those role holders are generally knowledgeable in high rise procedures and issues and often have strong views on the subject.
127. We have identified earlier in the report that the SOP has a mixture of discretion and compulsion of action. We found that the procedures are generally interpreted as prescriptive.
128. Some Crew and Watch Commanders interviewed describe a moral dilemma where they are the incident commander and the initial attending crews cannot proceed to the fire to commence firefighting and searching until additional resources attend.
Recommendation No. 7
The SFRS should reflect on the strong views among its firefighting staff and consider whether there is scope to refine the set down procedures for tackling fires contained in the SFRS high rise SOP, taking into account the different levels of risk and by factors such as modern lift protection, smoke hood availability, automatic suppression systems, and information from cameras and attending staff.
Accessing information while en-route or on arrival at an incident
129. We have highlighted in some previous inspection reports that crews rarely use the OI tablet to access risk information and that the familiarity of operational personnel with the system varies greatly. Once again, we evidenced this during the fieldwork element of this inspection. Some staff are very comfortable and proficient using the tablet and the system, while others are less proficient.
130. The functionality of the SFRS OI system tablet contains features that are a barrier to its use by initial attending crews. Even though the SOP instructs reference to the high rise aide memoire while en-route, this is not followed by personnel. Incident commanders that we spoke to were quite clear that accessing the tablet en-route is impractical for most attendance journeys.
131. In some respects, personnel considered that the previous vehicle mounted data system had more functionality than the tablet. We received a number of suggestions for features which might encourage the use of the tablet and improve functionality, such as easier log in, link to mobilising system, automatic display of premises information, display of route information. Some of these issues are explored in-depth in our thematic inspection report on OI[15].
Alteration to procedures
132. Where a standard procedure cannot be applied, such as where there is a lift capacity restriction, or where in maisonette flats a bridgehead may be four floors below the fire floor, it is an obvious preplanning approach to set out what the alternative procedure is. The high rise SOP advises that in such a case OI should be created and a 'Fire Service Response Plan' should be produced. This offers some contradiction because the creation of OI is a requirement for all domestic high rise, not only for situations where the SOP procedures cannot be fully applied. (Though as we have seen, this is not necessarily the practice).
133. We have to conclude that the term 'Fire Service Response Plan' means different things in different documents. In the Service's OI guidance 'Fire Service Response Plan' is a coloured 3-dimensional representation of a building, and it is required in nearly all cases where OI is recorded. In the high rise SOP, the term 'Fire Service Response Plan' is clearly used to describe a pre-determined variation to a standard procedure. And within the Service's TfOC module there is reference to a 'Tactical Incident Plan' as a document that can be referenced en-route to an incident.
134. From a practical perspective, the use of a pre-planned alternative is well understood within the Service, but interchange of language can be confusing, and standardisation of terminology will assist with consistency and common understanding.
Carrying equipment to an upper floor
135. Firefighting on an upper floor requires appropriate equipment to be taken up with the firefighters. This equipment is normally contained in a box stowed on the appliance and which is handled by firefighters and then placed in the lift with the initial ascending team. Often firefighters require to stand on the equipment in the box while in the lift due to the lift dimension. In some locations, bags are used instead of a box.
136. The box contains hose and other equipment. The hose can be on the roll or flaked, personnel have individual preferences which doesn't necessarily match the local practice. A legacy high rise box which contains flaked hose is shown in figure 5.
Source: HMFSI
137. The SFRS introduced a new standard box of greater capacity. Some high rise buildings have relatively narrow staircases and landings and the new boxes are difficult to manoeuvre in some buildings and in some cases are therefore not in use. We witnessed the substantial effort required by crew members carrying a new-style box containing equipment between floors at an exercise.
138. The physiological demands on firefighters is an important factor in high rise firefighting and has been the subject of academic study. High rise boxes containing equipment are carried from the appliance to the lift. One of the principles of manual handling is to avoid lifting where possible and appropriate; we are therefore surprised that the new boxes are not fitted with wheels.
139. In one LSO area, boxes are carried empty on the appliance and filled on arrival at the incident. Elsewhere the box is stowed on the appliance already filled.
140. Other UK FRSs often use a combination of a backpack (see figure 6) with other equipment carried separately. The hose is in the form of a Cleveland lay[16] which lends itself to being carried over the shoulder. Elsewhere in the UK some firefighters advocate the Cleveland lay as easier to deploy in a high rise building and also easier to carry.
Recommendation No. 8
The SFRS should review its arrangements for transporting equipment for high rise firefighting with a view to introducing an arrangement which is physically less demanding than the existing arrangements.
Source: HMFSI
Comparison with firefighting guidance elsewhere
141. National operational guidance for firefighting in tall buildings is issued by the National Fire Chiefs Council (NFCC)[17] The national document contains considerations and general guidance rather than prescriptive actions.
142. There is a reference in national guidance to Stairway Protection Teams, whose function may be assigned to the 'Fire sector' then assigned to the 'Search sector'. While the SFRS adopts the national sectorisation model for incident command it does not operate a stairway protection equivalent.
143. We are aware of developments in some FRSs in England regarding the potential for firefighters to move above the bridgehead wearing BA but not 'under air'. This has been a disputed issue and has led to challenge from the Fire Brigades Union. At the time of writing this report there was no plan for the SFRS to adopt such an approach. Some comparison between the SFRS procedures and other UK FRSs is made earlier in the report. While this has not been a topical issue in Scotland, we may revisit this aspect of high rise firefighting procedure if relevant developments or changes occur in Scotland.
Cabling issues
Source: SFRS
144. Cable entanglement is a risk to firefighters where surface mounted cable is not held securely and can become loose due to heat. While it is not an issue that is unique to high rise buildings it has been a factor in some previous high rise fires. There have also been issues with riser shafts being used for installing telecom cables and subsequent compartment breaches.
145. Entanglement risk has been well identified by the Service. BA Sets have entanglement protection incorporated within them and BA teams carry wire cutters. The SFRS has run entanglement courses using custom-built entanglement training rigs at training establishments, and provided guidance on how to use cutters.
146. The potential for cable entanglement is checked during the OAV but this can only be checked in communal areas.
147. During our fieldwork we were made aware of two occasions where there were issues with cabling in high rise buildings which were then raised locally by the Service.
a. An entanglement risk in a flat fire due to unsupported cabling (see figure 7). The SFRS raised this with the housing provider.
b. An issue with inappropriate telecom cabling discovered during an OAV. The SFRS raised this with the telecom provider.
Good Practice
The SFRS has been proactive in its approach to addressing entanglement risk and it is reassuring to see that SFRS staff are aware of the hazards presented with regard to cabling and actively taking steps to address any areas of concern observed during OAVs and at incidents.
Contact
Email: HMFSI@gov.scot
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