DMFD183 Forced Entry Equipment

1.1 Report LFC-0748y to the London Fire Commissioner (LFC) explains that Babcock Critical Services Limited (BCS) is LFB’s maintenance and service provider under the vehicles and equipment contract. This contract was awarded in 2014 and runs until 2035. As part of this contract, BCS replaces, services and repairs all items listed within the vehicles and equipment contract within a lifing profile of each asset.

1.2 London Fire Brigade (LFB) currently has 102 fire stations in addition to the river station. All landbased stations have a ‘pump ladder’ appliance, which carries forced entry equipment (FEE)). Forty stations have an additional ‘pump’ appliance, which does not currently carry FEE. FEE is used to gain access into a building or premises, for firefighting or emergency purposes and for assisting the London Ambulance Service to gain access to patients. Pump ladders must carry FEE because they are most likely to be mobilised for time-critical activity.

1.3 The need for additional FEE has been identified through analysis of LFB data, staff suggestions and the LFC’s programme of station visits. The procurement of additional FEE is a key initiative from the LFC’s staff engagement sessions, which demonstrate that he is listening to staff and, where appropriate, implementing quick reforms to improve operational effectiveness.

1.4 The current arrangements for FEE are inefficient. During the LFC’s recent and ongoing station
engagement sessions, it has been identified from evidence provided by operational staff that a lack
of FEE on pumps is having a disproportionately negative impact on operational responses. This can be seen in the following circumstances:

i. If a pump attends an incident requiring FEE, staff must request and wait for a pump ladder to
get the correct equipment to the scene. This leads to delays, additional vehicle movements, and unnecessary unavailability of crews.

ii. Pump ladders are crewed by station officers (the most senior level-one commander). Therefore,
if a pump ladder has to attend the incident, this reduces the immediate availability of this finite
officer resource when a lower rank can manage these incident types. Station officers are LFB’s
most senior level-one commanders, and are expected to take command of an escalating
incident.

1.5 Incidents that require forced entry can often be time-consuming to resolve, and on some occasions are not time-critical. Each incident of this type represents the potential for a station officer to be made unavailable if FEE is only available on pump ladders. By adding FEE to the pumps, the pump can be mobilised, leaving the station officer available for more complex incidents. Incident data outlined below illustrates this inefficiency, and the potential for efficiency gains.

1.6 LFB has seen an increase in attendance at incidents involving persons collapsed behind locked doors (CBLD) from an annual average of 1,421 (2017-20) to 7,392 in 2022. This is likely to be the result of a new approach to CBLD incidents, agreed between LFB, the Metropolitan Police Service (MPS) and the London Ambulance Service (LAS), to improve this service. It is highly likely that FEE will be required at these incident types, when officers must force entry to a property to enable LAS officers
to reach patients. The new approach is based on a greater understanding between the three services of LFB’s capability in this area; and it has put a formal mechanism in place for requesting LFB resources early at these incident types when a call is made into another agency. In turn, this means LFB is being called earlier and more often.

1.7 A Memorandum of Understanding between LFB, the MPS and the LAS setting out new CBLD arrangements is currently being agreed via LFB’s governance process, in order to formalise this agreement.

2.1 In its 2018-19 inspection report, His Majesty’s Inspectorate of Constabulary and Fire and Rescue Services (HMICFRS) reported that 57 per cent of staff do not have confidence in LFB’s feedback mechanisms; and raised ‘improving efficiency of response to staff concerns’ as an area for
improvement. Implementing this initiative quickly demonstrates to staff that their suggestions are
taken on board where it makes sound business sense.

2.2 This initiative improves the safety of communities. It also improves officer availability across LFB; reduces appliance movements; and increases the availability of appliances for responding to timecritical
incidents. It improves the cost-effectiveness of delivering the FEE capability to the incident
ground.

2.3 In 2022, 49 per cent of incidents that involve gaining entry were attended by an appliance with a
station officer in charge (3,705 incidents). On average these appliances spent 26 minutes at these incidents, totalling just over 1,600 hours. This is a significant draw on a more senior officer than is generally required for these incidents. Following the deployment of FEE on pumps, LFB anticipates
that in most instances only a pump would be mobilised to this type of incident. This would free up most if not all of the 1,600 hours spent by station officers at these incidents, based on 2022 figures.

2.4 Similarly, on average a pump spends 39 minutes at these incidents; this is attributable to the pump waiting for the additional attendance of a pump ladder to obtain FEE. Following the deployment of FEE on pumps, when pump crews are not required to wait for a pump ladder to arrive, this would reduce the amount of time spent by pumps at incidents from an average of 39 minutes to 26 minutes, a saving of 13 minutes per incident; this would represent a saving of 800 hours per year, based on 2022 figures.

2.5 The potential benefits outlined above are estimates based on current practices and incident trends. Incident data will be reviewed periodically following the deployment of additional FEE to ensure these benefits have been realised.

2.6 There is no additional training requirement for this equipment as firefighters are already trained to
use it, and it is included in the Development and Maintenance of Operational Professionalism
programme.

2.7 The current FEE carried on the pump ladders is within life until 2029-30. Therefore, rolling this equipment out to pumps, rather than employing an alternative forced entry solution, is the most effective approach because there is no additional training requirement, and the capability remains
the same across the fleet.

2.8 It is recommended that FEE is provided on all front-line pumping appliances. Currently, all pump
ladders carry FEE. FEE should be added on LFB’s current fleet of pumps, which consists of 40
additional pumping appliances, plus an additional reserve stock of four to manage servicing and
defects.

2.9 Adding FEE to the remaining 40 pumps will improve LFB’s operational effectiveness by:

i. providing a faster response: pumps assigned to an incident will not be required to wait for a
pump ladder to be ordered to an incident to use the FEE to effect entry to a premises

ii. increasing availability of senior level-one incident commanders (station officers)
iii. sending one appliance to FEE incidents instead of two.

2.10 Alternative options have been considered:

i. Placing pump ladders on the predetermined attendance for forced-entry incidents. Whilst this
measure will mean that the correct equipment will get to the incident quickly, it will increase the
draw on station officers (if applied in 2022, station officers would have spent 3,294 hours at this
incident type). Therefore, the proposal’s objective to increase availability of station officers for
more complex incidents would not be achieved.

ii.  Alternative crewing or transportation mechanisms. Measures such as delivering this equipment to the incident ground using logistical vehicles are impractical because they increase vehicles movements (a crew of firefighters will always be required to operate the equipment, so it is more efficient for the equipment to arrive with firefighters on the same vehicle). Providing the
equipment via alternative vehicles will also increase the time spent at incidents in the majority of
cases, because a fire appliance with crew will arrive at an incident faster than any of LFB’s
logistical vehicles.

iii. Placing FEE on pumps instead of pump ladders. Whilst this initiative would increase the
availability of station officers, it would remove a vital item of equipment from the vehicles most
likely to provide the first Breathing Apparatus teams in the early stages of a time-critical incident, where effecting entry in fire conditions is an early tactic. Therefore, whilst this measure
would go some way to resolving inefficiencies in forced-entry incidents, it will create a risk critical capability gap in our fire response.

3.1 The cost of providing FEE on pumps is £192,000 made up from £148,000 for the purchase of the FEE to be taken from capital funds; and £44,000 to be used from revenue funds to cover the 10-year slot price for these new items of equipment. This is shown in table 1, below.

3.2 The slot price is an inspection and maintenance cost. BCS will inspect, service and maintain the FEE in line with health and safety requirements. This includes collection and delivery to any LFB fire station with a maximum five-day turnaround. This also has an element of direct overhead and profit, but does not include unfair wear and tear, or loss. 

3.3 A 10 per cent contingency has been factored into the cost of the FEE to allow for the cost of inflation due to the current economic climate. This contingency will only be used for unforeseen rises in costs, and will not be required for the maintenance cost as this is a fixed price.

Table 1: Item cost breakdown

4.1 The LFC and the Deputy Mayor for Fire and Resilience are required to have due regard to the Public Sector Equality Duty (section 149 of the Equality Act 2010) when taking decisions. This in broad terms involves understanding the potential impact of policy and decisions on different people, taking this into account and then evidencing how decisions were reached.

4.2 It is important to note that consideration of the Public Sector Equality Duty is not a one-off task. The duty must be fulfilled before taking a decision, at the time of taking a decision, and after the decision has been taken.

4.3 The protected characteristics are: age, disability, gender reassignment, pregnancy and maternity, marriage and civil partnership (but only in respect of the requirements to have due regard to the need to eliminate discrimination), race (ethnic or national origins, colour or nationality), religion or belief (including lack of belief), sex, and sexual orientation.

4.4 The Public Sector Equality Duty requires decision-takers in the exercise of all their functions, to have due regard to the need to:

i. eliminate discrimination, harassment and victimisation and other prohibited conduct

ii. advance equality of opportunity between people who share a relevant protected characteristic and persons who do not share it

iii. foster good relations between people who share a relevant protected characteristic and persons who do not share it.

4.5 Having due regard to the need to advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it involves having due regard, in particular, to the need to:

i. remove or minimise disadvantages suffered by persons who share a relevant protected characteristic where those disadvantages are connected to that characteristic

ii. take steps to meet the needs of persons who share a relevant protected characteristic that are different from the needs of persons who do not share it

iii. encourage persons who share a relevant protected characteristic to participate in public life or in any other activity in which participation by such persons is disproportionately low.

4.6 The steps involved in meeting the needs of disabled persons that are different from the needs of persons who are not disabled include, in particular, steps to take account of disabled persons’ disabilities.

4.7 Having due regard to the need to foster good relations between persons who share a relevant protected characteristic and persons who do not share it involves having due regard, in particular, to the need to:

i. tackle prejudice

ii. promote understanding.

4.8 An Equality Impact Assessment (EIA) was completed in September 2019 when the previous FEE was placed on appliances for operational use. Given that an additional 44 sets of the same equipment are being procured, the EIA has been reviewed and no additional changes are required.

Workforce comments

5.1 Discussions with the Fire Brigades Union (FBU) on this initiative have taken place. The FBU is supportive of increasing the amount of FEE available for operational incidents. The initiative has also, in part, been put forward through staff suggestions, which have been discussed during the LFC’s programme of station visits and been positively received. At the point of putting this recommendation forward, this programme included 53 of London’s 103 fire stations.

Sustainability comments

5.2 At the end of its serviceable life, the FEE will either be resold or recycled by BCS under the provisions of the 2014 Vehicle and Equipment Contract. The disposal process will fulfil LFB obligations under the Environmental Duty of Care Regulations. If the equipment is to be scrapped, or broken up for parts, the Vehicle and Equipment Contractor will provide full details relating to the disposal of the component parts, and will ensure that the Authority’s obligations are documented and adhered to.

5.3 FEP2237, the 2014 vehicles and equipment contract with BCS, provides for the capital replacement of fleet and equipment throughout the contract period of 21 years. Under the contract, BCS procures the new vehicles and equipment, and replaces the existing assets at their life expiry. BCS has policies in place relating to anti-slavery, sustainability and anti-corruption; this is done in accordance with the specifications and approvals issued by the LFB.

5.4 A technical Sustainability Development Impact Assessment was previously completed for this item of equipment.

5.5 Having FEE on all appliances would eliminate the need for a pump ladder to be called out after a pumping appliance had already been mobilised, therefore reducing fuel consumption and emissions.

Procurement comments

5.6 All of the vehicles and equipment to support the operation of the LFC are provided through a long-term contract with BCS. The procurement and commercial approaches are discussed and agreed between LFB and BCS to arrive at the solution that provides best value for money overall. The provision of this additional equipment has been highlighted as an urgent requirement, in order to expand the number of vehicles that carry FEE this, which will ensure greater operational resilience. BCS has moved at pace to support the requirement. The additional equipment is required to match that which already exists; if different equipment was obtained, the LFC would incur a substantial cost for retraining all firefighters as well as delaying the rollout of the additional equipment. It will be necessary to award a contract to the existing supplier (who was appointed following a competitive tender) without a further competition to avoid the costs of additional training, and ensure that the equipment is provided quickly.

Conflicts of interest

5.7 There are no conflicts of interest to declare from those involved in the drafting or clearance of this decision.

6.1 The LFC’s annual revenue budget, for the maintenance element of the whole-life cost for the 44 new sets of equipment, will be provided from a permanent virement as agreed between LFB’s Technical and Service Support and the Commissioner’s Office. The permanent virement of £4,400 per year is based on the average of the overall 10-year maintenance cost of £44,000. The virement is expected to be funded from an existing underspending budget, to be identified within Operations.

6.2 This report is requesting to commit capital expenditure of £148,000 including 10 per cent contingency for the purchase of FEE. As this will be funded through the Budget Flexibility reserve, which currently holds a balance of £17,781k, there will be no additional borrowing costs factored into the capital programme.

7.1 Under section 9 of the Policing and Crime Act 2017, the LFC is established as a corporation sole with the Mayor appointing the occupant of that office. Under section 327D of the GLA Act 1999, as amended by the Policing and Crime Act 2017, the Mayor may issue to the LFC specific or general directions as to the manner in which the holder of that office is to exercise his or her functions.

7.2 By direction dated 1 April 2018, the Mayor set out those matters, for which the LFC would require the prior approval of either the Mayor or the Deputy Mayor for Fire and Resilience (the Deputy Mayor).

7.3 Paragraph (b) of Part 2 of that direction requires the LFC to seek the prior approval of the Deputy Mayor before “[a] commitment to expenditure (capital or revenue) of £150,000 or above as identified in accordance with normal accounting practices”. The decision to purchase and maintain new FEE at a cost of up to £192,000 will therefore require approval from the Deputy Mayor.

7.4 The statutory basis for the actions proposed in this report is provided by sections 7 and 5A of the Fire and Rescue Services Act 2004 (FRSA 2004). Under section 7 (2)(a) of FRSA 2004, the Commissioner has the power to secure the provision of personnel, services and equipment necessary to efficiently meet all normal requirements for firefighting. Furthermore, section 5A allows the Commissioner to procure personnel, services and equipment they consider appropriate for purposes incidental or indirectly incidental to their functional purposes.

7.5 The report confirms the provision of FEE will be secured via an existing contract with Babcock, which was tendered compliantly in accordance with the Public Contract Regulations.

7.6 These comments have been adopted from those provided by the LFC’s General Counsel Department in report LFC-0748y to the LFC.

Appendix 1 - LFC-0748y Forced Entry Equipment