• UNISON is Scotland's largest trade union representing over 145,000 members working in the public sector, including community health services. UNISON is the majority trade union for Fire Service staff who are not fire-fighters.
• UNISON Scotland does not envisage a problem with the change in name to the Scottish Fire and Rescue Service as long as this is not an indication that the renamed service will assume responsibility for the roles and duties of other emergency services, such as the ambulance service.
• The consultation proposes a National Framework to be established to allow the Scottish Executive to provide strategic direction to the Scottish Fire and Rescue Services. However there is a concern that the repeal of section 19 goes against such a strategic overview.
• UNISON Scotland is concerned about the selective use of statistics within this section of the document. There is a concern that this is being applied to justify reform within the fire service rather than reform being driven by a demand for different services.
• UNISON Scotland is also concerned about the use of Integrated Risk Management (IRM) and the possibility that this might result in a reduction in fire cover due to a lack of any pilots on IRM.
• UNISON Scotland is concerned that the Scottish Executive has made no commitment to increasing the budgets of Fire Authorities despite the increase in statutory duties.
• Any attempt to merge fire service control rooms with other emergency services or to create control rooms covering more than one brigade will involve a loss of essential skills and the loss of local knowledge.
• The Scottish Executive should make clear to employees and their unions the staffing implications of the establishment of a Common Fire Services Agency.
• UNISON Scotland is concerned that the costs of the Integrated Personal Development System (IPDS) have not been quantified and that the Executive has not given any commitment to fully fund this.

Introduction

This paper constitutes UNISON Scotland's response to the Scottish Executive's consultation paper, ‘The Scottish Fire and Rescue Service: Proposals for Legislation'.

UNISON is Scotland's largest trade union representing over 145,000 members working in the public sector in Scotland. UNISON members are employed within the Scottish Fire Service as support staff, and as Scottish citizens our members have an interest in the functions and service provision of the Scottish Fire Service.

UNISON Scotland welcomes the opportunity to respond to this consultation exercise.

The Scottish Fire Service of the Future

The legislative proposals recognise the fact that legislation has not kept pace with changes in the Fire Service and that further change will be taking place. The consultation document highlights that the role of the Fire Service has evolved and developed over many years and while its primary purpose is in tackling fires there is a range of other roles - particularly in rescue work - which it now carries out. The Scottish Executive intend to signal that change by re-naming Brigades as the Fire and Rescue Service and Fire Authorities as Fire and Rescue Authorities.

UNISON Scotland does not envisage a problem with such a name change as long as this is not an indication that the renamed service will assume responsibility for the roles and duties of other emergency services, such as the ambulance service. Also any name change invariably involves a cost, through changing everything from signs to stationery. However there is no indication within the document that the Scottish Executive will provide additional resources to implement such a change. UNISON Scotland would like to see such a commitment rather than leaving it to the fire authorities to fund such changes via their existing budgets.

 

The Framework and Supporting Structure

The consultation proposes a National Framework to be established to allow the Scottish Executive to provide strategic direction to the Scottish Fire and Rescue Services. However there is a concern that the repeal of section 19 (the Ministerial role in the decision making process affecting issues such as the closure of fire stations) goes against such a strategic overview.

By devolving such powers to local fire boards (and their respective local authorities) there is a concern that the local structures that oversee fire station closures will be unaccountable and that communities will not be able to lobby the Scottish Executive. This could lead to similar problems as has been experienced with Health Boards, whose decisions have angered many communities but who have nowhere to turn to regarding issues such as hospital closures. UNISON Scotland would not support any development which lessened public scrutiny and accountability in the provision of public services.

UNISON Scotland is concerned that those with responsibility for fire authority budgets will also have the power to close fire stations. There is a danger that stations could be closed due to budgetary pressures.

Although UNISON Scotland is generally in favour of decision making at a local level we would want the to ensure that local fire authorities are properly resourced to fulfil their duties. However UNISON Scotland believes that there should be a right of appeal to Scottish Ministers for communities faced with the closure of their local fire stations. Retaining such powers would also allow the Executive to maintain a strategic overview of all fire station closures as well as the fire service in general.

There is also a concern with regard to the advisory bodies. For instance the new Advisory Group will not be established on a statutory basis. UNISON Scotland is concerned that this would make it easier for the Scottish Executive to either ignore its recommendations or change its remit. Also the wider forum on fire safety does not explicitly state that employees and their representatives will be members of such a body. UNISON Scotland would like clarification on the membership of such bodies.

 

The Core Duties of the Fire and Rescue Service

UNISON Scotland is concerned about the selective use of statistics within this section of the document. The paper highlights a drop in primary fires (while failing to provide a definition of what constitutes a ‘primary fire') and indicates a rise in special services. However the figures given are from across two different time periods and serves to exaggerate the increase in special services. Also, according to the Scottish Executive's own statistics (from the Statistical Bulletin: Criminal Justice Series: CrJ/2003/4: Fire Statistics: available at http://www.scotland.gov.uk/stats/bulletins/00255-01.asp), the latest available figures indicate that there has been an increase in all fires of 7% over the previous year.

There is a concern that the selective use of statistics is being applied to justify reform within the fire service rather than reform being driven by a demand for different services.

UNISON Scotland is also concerned about the use of Integrated Risk Management (IRM) and the possibility that this might result in a reduction in fire cover. There is a concern that IRM has not been piloted in any area and as such there is no evidence that it can provide an improvement over current standards. UNISON Scotland is concerned that a shift to IRM will take place before there are any pilots or evidence to suggest it will provide superior standards of fire cover.

Without such piloting it will be difficult for the Executive and fire authorities to anticipate any problems in the changeover to IRM, and there is a concern over the continuity and sustainability of fire cover under such circumstances. UNISON Scotland is also concerned that no additional funding commitment to IRM is given in the consultation document despite the Chief and Assistant Fire Officers Association warning that IRM would involve additional costs.

There also seems to be a different emphasis on the issues behind IRM, with the consultation document highlighting ‘providing best value' whereas the circular (Circular no. 4/2003) to Fire Authorities replaces this with ‘providing value for money'. However further on in the consultation (paragraph 4.6) the Scottish Executive admit that they agree with some respondents to their earlier consultation that Best Value and collaboration should be about improving service and not simply about economics. In fact the Scottish Executive website (http://www.scotland.gov.uk/about/FCSD/LG-PERF4/00014838/Home.aspx) defines best value as:

• Pursuing continuous improvement;
• Achieving a balance between quality and cost; and 
• Improving accountability by being more responsive to stakeholders.

This raises a concern that what has been issued for public consultation is different from the instructions given to the fire authorities who have to implement IRM. UNISON Scotland is concerned that this consultation process may therefore be flawed and could be used to cover restrictions on the budgets of local fire authorities.

Also within this section is some detail of the additional statutory duties that the Executive will demand of the fire service. However there is no clear commitment for extra resources despite the fact that Scotland has recorded a 37% rise in fatalities between 2000 and 2001, as well as having the highest rate in the UK for fatal and non fatal casualties. For instance, as revealed in a meeting of the joint Justice Committees of the Scottish Parliament, the advertising budget for community safety/ fire prevention has been cut. Thus fire prevention becomes an additional statutory duty yet the advertising budget for this issue is due to be decreased.

In paragraph 3.14, the Executive suggest that the fire service be responsible for installing smoke alarms. Considering the casualty levels this may not be the best use of fully trained fire-fighters. There is also a concern with the proposals to reform fire safety legislation including the removal of fire certificates with the duty of fire authorities to carry out periodic checks. This may result in an extra burden for already stretched resources and result in diminished fire safety.

UNISON Scotland is concerned that the Scottish Executive has made no commitment to increasing the budgets of Fire Authorities despite the increase in statutory duties.

 

Organisation and Responsibilities

On the issue of greater collaboration UNISON Scotland is concerned about the possibility of joint control rooms whereby operators may take generic calls, e.g. for police, ambulance and fire calls. The staff which work in fire service control rooms have had 4 years training, are an essential part of the fire service and help to save lives with their knowledge of their local area. Any attempt to merge these control rooms with other emergency services or to create control rooms covering more than one brigade will lessen these essential skills and involve the loss of local knowledge.

Similarly ambulance control staff have extensive skills which they deploy to assist 999 callers. These skills prevent the deterioration in a patient's condition prior to an ambulance crews arrival. They ensure that front line staff have accurate information on the location and type of incident they are attending and the condition of patients. On numerous occasions control staff have saved lives by giving telephone advice prior to the arrival of an ambulance.

UNISON Scotland recognises that there may be a role for a Common Fire Services Agency however there should be safeguards to ensure that local Fire Authorities are not restricted from obtaining any equipment they require. The consultation paper suggests there may be a role for a Common Fire Services Agency in purchasing equipment for all brigades and thus making some savings through economies of scale. However there would be costs and upheaval involved in forming such a centralised purchasing department whereas an alternative method may be for the existing fire authorities to form a Purchasing Consortium. This would still allow for larger contracts and greater bargaining powers, while maintaining local purchasing departments to deal with local stock control and localised purchasing.

The Scottish Executive should make clear to employees and their unions the staffing implications of the establishment of a Common Fire Services Agency. UNISON Scotland would like to see more details on the establishment of a Common Fire Services Agency.

There is a further concern over the comment that Scottish Ministers will take powers to impose requirements on Authorities to use and maintain specified equipment or services for all their core duties. This will remove local management options and may result in additional expenditure. Also in the document there is mention of Scottish Ministers procuring equipment for certain purposes but no mention of where the funding will come from. UNISON Scotland would like more information on where this funding will come from and whether or not it will involve PPP finance.

As regards another review of the structure and number of Fire Authorities in Scotland, UNISON Scotland is concerned that there does not appear to be a clear reason for such a review. The document implies that since England is reviewing its structures, leading to a decrease in the number of Fire Authorities, then Scotland should do the same. This does not appear to be enough justification for such an action, and its related cost.

UNISON Scotland believes that constant reorganisation is costly and inefficient when an alternative, such as establishing public service networks to allow greater collaboration between public services, could be implemented.

 

The Workforce

The section in the consultation paper dealing with the workforce fails to distinguish between fire-fighters and civilian staff despite the latter's terms and conditions being agreed through Scottish Local Government agreements while fire-fighters are subject to a UK wide agreement.

The consultation also highlights that the Scottish Executive is committed to introducing new training arrangements through an Integrated Personal Development System (IPDS). UNISON Scotland believes that this is an issue on which fire service employees and their unions should be widely consulted. There is no mention of such involvement within this document and there is a concern that publicising such changes may be a way of applying pressure to fire service employees to accept such changes.

It is anticipated that the introduction of IPDS will create a need for additional training for all personnel yet, as revealed by a joint Justice Committee meeting, the training budget for the fire service is to be decreased over the next three years. This budget will also be under strain from additional training needs related to the introduction of IRM. The Justice Minister also revealed at the joint Justice Committee meeting that the full costs of implementing IPDS had not been quantified. UNISON Scotland is concerned that such costs have not been quantified and that the Executive have not given any commitment to fully fund IPDS.

Within the National Framework the Scottish Executive also aim to provide the necessary direction for achieving greater diversity in the workforce by introducing multi-tier entry and accelerated promotion. UNISON Scotland is in favour of equal opportunities and diversity within the workplace but would like to see more detail on how the Executive propose to achieve this. UNISON Scotland would also like to see the Executive address the issue of equal pay within the fire service. In general UNISON Scotland regards such human resource issues as primarily the concern of fire authorities, their employees and the relevant trade unions.

There is further discussion within the consultation paper on pensions and disciplinary regulations although the Scottish Executive do not highlight whether this applies to all fire service employees or just fire-fighters.

In general the section on the workforce fails to take into account the role of civilian staff and explain how the proposed changes would affect their terms and conditions. UNISON Scotland would like to see some clarification on the role of such staff and any impact on the current negotiating procedures for them.