DMFD290 Water-rescue training and compliance

1.1.    Report LFC-26-030 to the London Fire Commissioner (LFC) provides a detailed overview of the proposal. This is a summary of that report.

1.2.    LFB is seeking approval to spend up to £569,745 in 2026-27, to deliver water-rescue training; and achieve full compliance with the National Fire Chiefs’ Council’s (NFCC’s) Rescue Boat Code 2021. The code establishes national standards for fire and rescue services in the safe operation of powered rescue boats – including training standards for Module 3 (Water and Flood Rescue Technician) and Module 4 (Water and Flood Rescue Boat Operator). 

1.3.    LFB has ten stations with outboard-powered inflatable boats. Firefighters currently receive initial training, at these stations, in both modules; and annual continuing professional development (CPD) in Module 3. LFB is requesting to add Module 4 CPD, and recertification for both modules, to its water-rescue training offer.

1.4.    LFB reports that it delivered a level of compliance even before publication of the NFCC’s Rescue Boat Code (which is now the fire sector standard). Its gap analysis has identified improvements to ensure compliance with the national standard. LFC-26-030 states that the courses currently in place are sufficient, and are being delivered in line with the learning objectives set out in the Rescue Boat Code. However, the lack of recertification and CPD arrangements has meant that LFB operatives have fallen out of competence.
 

2.1.    If approved, this proposal will be the first operational capability that LFB funds from the Mayor’s modern firefighting allocation (£5 million in 2026-27). LFB expects the training to provide an immediate improvement in its specialist response to climate-related risks, particularly flooding. LFC-26-030 highlights this link between Mayoral priorities, identified risk and LFB’s frontline operations.

2.2.    LFB reports that the proposed improvements to its water-rescue training offer, to meet the national standards set out in the NFCC Rescue Boat Code 2021, will: 

•    improve firefighter safety
•    improve both public protection and public confidence in LFB’s water-rescue capability
•    strengthen London-wide response arrangements
•    meet the expectations of modern firefighting (such as standardised training, formal assurance of competence, risk-informed deployment and CPD).

2.3.    Water and flood rescue are hazardous operating environments. By training, assessing and re certifying its staff to nationally recognised standards, LFB aims to both reduce foreseeable risk to individual firefighters; and improve its collective and organisational response to water rescue. LFB reports that the new courses will be included in LFB’s annual training and development plan.
 

3.1.    The Public Sector Equality Duty requires the identification and evaluation of the likely potential impacts, both positive and negative, of the decision on those with protected characteristics. The LFC, and the Deputy Mayor for Planning, Regeneration and the Fire Service (the Deputy Mayor), are required to have due regard to the Public Sector Equality Duty (section 149 of the Equality Act 2010) when taking decisions. The Public Sector Equality Duty requires the identification and evaluation of the likely potential impacts, both positive and negative, of the decision on those with protected characteristics (see paragraph 3.3). 

3.2.    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.

3.3.    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.

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

•    eliminate discrimination, harassment and victimisation and other prohibited conduct
•    advance equality of opportunity between people who share a relevant protected characteristic and persons who do not share it
•    foster good relations between people who share a relevant protected characteristic and persons who do not share it.

3.5.    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:

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

3.6.    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.

3.7.    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:

•    tackle prejudice 
•    promote understanding.

3.8.    LFB reports that it has assessed its adoption of the NFCC Rescue Boat Code 2021 against the Public Sector Equality Duty. To identify potential barriers for people with protected characteristics, LFB has consulted staff extensively and from the outset. LFB has gathered evidence from which it has identified no adverse equality impacts that cannot be mitigated. 

3.9.    LFB has committed to providing water-rescue training in a way that treats all staff fairly, promotes inclusion, and complies with its statutory duties under the Equality Act 2010. Training providers and procurement teams will continue to monitor the training and to review PPE specifications, to address emerging issues promptly and ensure fair access to all staff.
 

Workforce considerations

4.1.    LFB notes direct workforce implications from the requirement to adopt a structured water-rescue training and recertification programme. LFB expects the new training standards to improve safety, competence and morale, with no long-term workforce impacts. Any issues that arise from temporarily taking staff away from their normal duties will be managed through scheduling and communication with stations. Using the existing contract with Babcock Limited will provide training capacity. 

Communications considerations

4.2.    LFB’s communications with its staff about the NFCC Rescue Boat Code, and changes to its water-rescue training, will focus on: the new requirements; why they are important; and when training will take place. LFB will use existing governance processes to update the Deputy Mayor and the GLA on this project; and it may make public-facing statements that demonstrate LFB’s commitment to firefighter and public safety.

Procurement considerations

4.3.    LFC-26-030 sets out three options that LFB considered to deliver its water-rescue training: 

•    the existing training contract with Babcock Limited
•    a separate procurement
•    in-house delivery. 

LFB concluded that delivery via Babcock Training is the best and quickest route to mitigate current risks, and achieve initial compliance with NFCC standards. LFB plans to revisit this after its Specialist Capability Review concludes. 

Sustainability considerations

4.4.    LFB has considered the adoption of the NFCC Rescue Boat Code, in relation to its environmental and sustainability objectives. It reports that:

•    using the existing Babcock contract reduces environmental impact, through efficient scheduling and use of established training venues
•    specifications for new equipment will take account of sustainability factors such as durability, repairability and safe disposal.
•    aligning with national standards should improve efficiency and reduce duplication – supporting long term sustainability.

Conflicts of interest

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

5.1.    LFB is seeking approval to spend revenue funding of £569,745 in 2026-27 on water-rescue training, to meet relevant NFCC standards. If LFB requires funding for future years, this will be requested via separate report(s) as needed, in line with governance requirements. The amount requested is included in LFB’s budget process for 2026-27; and will be contained within LFB’s £5 million modern firefighting budget in 2026-27. 

6.1.    The LFC’s General Counsel’s Department have confirmed the following.

6.2.    LFC-26-030 seeks approval of expenditure for additional training of operational staff in water rescue, in order that LFB can meet NFCC standards. It confirms that the training will be delivered under an existing contract for training services with Babcock Ltd, which has been procured in compliance with the procurement legislation.  

6.3.    LFC-26-030 identifies training requirements necessary for LFB to align itself with NFCC national standards in water rescue. Alignment of training with national operational guidance in general also fulfils recommendations made by His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services.  

6.4.    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 Greater London Authority Act 1999, as amended, 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. 

6.5.    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. 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 is identified in accordance with normal accounting practices”. Funding of additional water-rescue training modules, as detailed in this report, far exceeds the specified amount set out in the direction; and, as such, requires the prior approval of the Deputy Mayor.  

6.6.    Section 1 of the Fire and Rescue Services Act 2004 (FRSA 2004) states that the LFC is the fire and rescue authority for Greater London. The statutory basis for the actions proposed in this report is provided by section 7 and section 5A of the FRSA 2004. Section 7 (2)(a) of the FRSA 2004 provides the LFC has the power to secure the provision of personnel, services and equipment necessary to efficiently meet all normal requirements for firefighting. Furthermore, section 7 (2)(b) of the FRSA 2004 requires that the LFC must secure the provision of training for personnel. Section 5A allows the LFC to procure services and equipment they consider appropriate for purposes incidental, or indirectly incidental, to their functional purposes.