Grenfell Tower Inquiry phase 2 report: Scottish Government response

8: Fire safety and Firefighting

Background

This chapter covers a wide range of the Grenfell report’s recommendations in relation to fire safety, firefighting operations and the role of His Majesty’s Inspectorate of Constabulary and Fire and Rescue Services (HMICFRS).

Recommendation 26 looks at the role of competence of fire risk assessors. The Inquiry found that individuals in roles which were critical for ensuring the safety of life in buildings lacked the required competence.

Recommendations 29 and 30 are in relation to the establishment of a fire college to provide training at a national level that will support education, training, research, and development of equipment.

Recommendations 31, 32 and 33 are directed at HMICFRS, relative to England and Wales to review a number of operational matters within Fire and Rescue Services including control room operations and the adequacy of training arrangements.

Recommendations 34 – 39 were specifically for LFB and concern several firefighting operational matters. The Inquiry found that during the fire there was a breakdown in communications at times, as the radios stopped working at certain distances from the ground / through a number of concrete walls.

The Inquiry also reported that on the night of the fire, firefighters were unable to distinguish between different types of hydrants and noted that LFB struggled to ensure adequate water supply on the night. The Inquiry found that many firefighters who were sent to higher floors to carry out rescues, ended up deviating from these instructions to rescue people they came across on lower floors.

For Recommendations 57 and 58, the Inquiry referred back to its Phase 1 Report outlining that the owner and manager of every high-rise residential building be required by law to prepare Personal Emergency Evacuation Plans (PEEPs) for residents who require one and be required by law to ensure the PEEP was available in a premises information box for use by fire and rescue services.

Recommendation 26 (para 113.41)

Establish a system of mandatory accreditation to certify competence of fire risk assessors by setting standards for qualification and continuing professional development.

Rationale

It was outlined in the Grenfell report that the assessor who carried out the annual fire risk assessments at Grenfell Tower, had misrepresented their experience and qualifications and was ill-qualified to carry out fire risk assessments on buildings of that size and complexity. The Inquiry and subsequent independent “Building a Safer Future report” by Dame Judith Hackitt noted the lack of accreditation, skills or real oversight of fire risk assessors and highlighted this must be addressed.

Scottish context

This matters cuts across both devolved and reserved areas of responsibility. Currently in Scotland (and across the UK), there is no legal requirement for an assessor to hold any formal certification, accreditation or experience in fire risk assessment when assessing many types of premises.

Scottish Government response

The Scottish Government accepts this recommendation. Policy development, legal considerations and a public consultation will be undertaken. The Scottish Government will also look to work closely with the UK Government to understand any UK wide implications concerning reserved powers. Regulation of professions is a UK matter under the Professional Qualifications Act 2022.

Recommendation 29 (para 113.51) and Recommendation 30 (para 113.53)

Establish an independent College of Fire and Rescue college immediately with sufficient resources to provide defined services nationally.

Permanent staff of sufficient size to manage its operations and develop the colleges functions in response to the demands of fire and rescue services nationally and the requirements of the board.

Rationale

The Inquiry highlighted the UK Government’s plans to create an independent College of Fire and Rescue expressed in their white paper “Reforming our Fire and Rescue Service” and recommended that the college be established immediately.

Scottish context

This recommendation is directed to the UK Government, but there may be some benefits to SFRS having access to such a facility where inter-operability and professional standards can be further developed.

In Scotland training arrangements for firefighters are already in place across several dedicated training facilities with an ability to access external courses as necessary for specific skills.

Scottish Government response

The Scottish Government accepts this recommendation in principle. The Scottish Government and SFRS will seek to work with the UK Government and the National Fire Chiefs Council (NFCC) to consider how SFRS might appropriately inform the development and access a fire college. This will need to be considered in the context of the existing training facilities and arrangements available to SFRS staff in Scotland.

Recommendation 31 (para 113.55)

HMI Constabulary and Fire and Rescue Services to inspect the London Fire Brigade (LFB) as soon as reasonably possible to assess and report on identified measures in relation to the control room and its staff.

Rationale

Specific to LFB this recommendation is in relation to carrying out inspections on control room operations.

Scottish context

This is a devolved matter, although issues relating to national resilience are reserved. The duties and responsibilities of SFRS and of HMFSI are defined in the Fire (Scotland) Act 2005. A new area inspection process was implemented in 2022 that measured aspects of service delivery across the three SFRS Service Delivery Areas.

Scottish Government response

The Scottish Government accepts this recommendation and informed by Service Delivery Area inspections, HMFSI intends to carry out a Thematic Inspection of Operations Control rooms in Scotland. This review will be scheduled in line with their inspection programme and will be undertaken with the co-operation of SFRS, in line with duties and powers described within the Fire (Scotland) Act 2005.

Recommendation 32 (para 113.56)

Inspectorate to inspect LFB to examine and report on the arrangements in place for assessing the training of incident commanders at all levels and their continuing competence.

Rationale

Specific to LFB the report identified that incident command training was less than adequate and that at the time of this tragedy, LFB could not accurately determine the competence of its incident commanders. This was due to shortcomings with accreditation and revalidation of command competence that meant those in command positions, while they may have attended refresher training, had not been tested and revalidated as competent.

Scottish context

This is a devolved matter with the duties and responsibilities of SFRS and of HMFSI defined within the Fire (Scotland) Act 2005. Duties under the Health and Safety at Work etc. Act 1974 are reserved with staff to be provided with adequate training to undertake the role they fulfil.

In Scotland there is in place a system of mandatory revalidation and accreditation in line with national guidance for all SFRS Incident Commanders. While not directly related to this recommendation, HMFSI through routine Service Delivery Area inspection reports has touched on various aspects of training across the SFRS.

Scottish Government response

The Scottish Government accepts this recommendation and will work with HMFSI to take it forward. Informed by routine SFRS Service Delivery Area inspection reports, HMFSI will carry out a Thematic Inspection of training and development for operational staff within the SFRS. This inspection is scheduled to commence in April 2025 and is likely to conclude in April 2026.

Recommendation 33 (para 113.57)

Inspectorate to inspect LFB to examine and report on its arrangements for collecting, storing and distributing information in accordance with section 7(2)(d) of the Fire and Rescue Services Act 2004, and its arrangements for identifying high-risk residential buildings and collecting, storing and distributing information relating to them.

Rationale

LFB were criticised in relation to the manner they gathered, stored, and utilised risk information relative to certain buildings across London. The system in place was deemed to be flawed and led to vital information relating to cladding and the possible risks associated with cladding being missed.

Scottish context

This is a devolved matter covered in section 9(2)(d) of the Fire (Scotland) Act 2005. HMFSI published “The Scottish Fire and Rescue Service’s arrangements for the provision of Operational Risk Information” report in 2019. This report considers arrangements in place in SFRS for gathering and providing access to risk information. The report made recommendations for improvement, and HMFSI noted that SFRS has made significant progress in actioning these recommendations.

In addition, HMFSI published a Thematic Inspection report titled “Arrangements for Firefighting in High-rise Buildings” in 2022 reviewing current SFRS operational processes in these buildings, providing recommendations and actions that SFRS accepted and are adopting.

As part of the SFRS’ operational intelligence and in addition to the quarterly assurance visits they carry out to every high-rise domestic building in Scotland, most domestic high-rise buildings are also fitted with external premises information plates near the entrance to the main door. These plates provide robust operational intelligence to attending crews, as they show relevant, easy to see information including confirmation of the address of the building, the number of storeys, position of hydrants and dry risers and relevant information on lifts and escape stairs.

Whilst use of these information plates is currently not a mandatory requirement it has been adopted by many high-rise buildings as good practice.

Scottish Government response

The Scottish Government accepts this recommendation and considers that actions already taken through the “Arrangements for Firefighting in High-rise Buildings Report 2022” look at the issues of this recommendation. HMFSI however, will review actions taken to address recommendations made within other relevant inspection reports as routine business.

Recommendation 34 (para 113.58)

LFB establish effective standing arrangements for collecting, considering, and effectively implementing lessons learned from previous incidents, inquests, and investigations.

Rationale

The Inquiry highlighted those lessons from previous incidents, such as the Lakanal House fire, had not been taken on board by local or national Government, or the London Fire Brigade. It also set out that processes should be in place to collect and learn from incidents.

Scottish context

This is a devolved matter. SFRS has an Operational Assurance Process that underpins the ability to learn lessons and promote continual improvement by the review and sharing of information. This is supported through the Organisational Learning Management Arrangement which sets out SFRS arrangements to identify, capture and manage sources of learning and embed any lessons learnt.

Following Phase 1 of the Grenfell Inquiry, SFRS has made changes regarding responding to incidents in high-rise domestic buildings. This included reviewing and updating their standard operating procedures for attending incidents at such premises. SFRS will continue to review current practices and closely consider any outcomes of HMFSIs 2024-25 Thematic Inspections which will include a review of the Service’s Operational Assurance provision.

Scottish Government response

The Scottish Government accepts this recommendation. SFRS has appropriate arrangements in place which are well documented including appropriate governance at strategic levels to ensure they are effective in meeting this recommendation.

Recommendation 35 (para 113.59) and Recommendation 36 (para 113.60)

Fire and rescue services that continue to use low power intrinsically safe radios as part of breathing apparatus should consider reserving them only for situations in which there is a real risk of igniting flammable gases and generally using radios of higher power, particularly in high-rise buildings.

All fire and rescue services give consideration to providing all firefighters with digital radios.

Rationale

During the fire in Grenfell Tower there was a breakdown in communications at times, as the radios used by firefighters stopped working at certain distances from the ground / through a certain number of concrete walls. This was largely attributed to the use of “intrinsically safe” analogue radios.

Scottish context

This is a devolved matter. SFRS reviewed and updated the standard operating procedures for attending incidents in high-rise domestic buildings after the Phase 1 Report. SFRS have a transition programme in place to phase out the use of analogue radios in the Service, including for use in breathing apparatus. Several intrinsically safe radios will remain in use for appropriate situations and strategically deployed as required. Digital Radio roll out commenced in September 2024 for the East and North Service Delivery Areas with the West following on throughout 2025. On completion, a simultaneous switch over from analogue to digital will conclude this programme.

Scottish Government response

The Scottish Government accepts these recommendations and is content that SFRS has taken steps to review and update procedures. SFRS will monitor roll out, report progress through the SFRS High-rise Continual Improvement Group (HRCIG) and assess effectiveness of implementation.

Recommendation 37 (para 113.61)

Firefighters be trained to respond appropriately to the loss of communications and to understand how to restore them.

Rationale

During the fire in Grenfell Tower there was a breakdown in communications at times, as the radios used by firefighters stopped working at certain distances from the ground / through a certain number of concrete walls. The Inquiry found that firefighters had to resort to measures such as using runners with information written on paper, to provide information to the Incident Command Unit.

Scottish context

This is a devolved matter. SFRS have protocols in place for loss of established communications at incidents and through Operations Control. SFRS will continue to review and consider whether their protocols are fit for purpose.

Scottish Government response

The Scottish Government accepts this recommendation. SFRS have completed a review of the protocols for potential loss of radio communications at incidents and no further action is currently required.

Recommendation 38 (para 113.62)

Basic training on the structure and operation of the water supply system, including the different types of hydrants in use and their functions, be given to all firefighters.

Rationale

The Inquiry found that on the night of the Grenfell Tower fire, firefighters were unable to distinguish between different types of hydrants.

Scottish context

This is a devolved matter. SFRS already ensure that principles of water supply system and water management are embedded within foundation training for firefighters. In addition, SFRS undertake Operational Assurance Visits at high-rise domestic buildings that include the check and operation of available hydrants.

Scottish Government response

The Scottish Government accepts this recommendation. A gap analysis on learning content, particularly around hydrant types will be undertaken by SFRS and action taken if required.

Recommendation 39 (para 113.63)

All fire and rescue services establish and periodically review agreed protocol with statutory water undertakers to enable effective communication in relation to the supply of water for firefighting purposes.

Rationale

The Inquiry found that firefighters struggled at times to get adequate water pressure to combat fires during the incident.

Scottish context

This is a devolved matter. SFRS have in place established protocols and communications with Scottish Water which means water can be supplemented at incidents where necessary. Despite these arrangements being in place, the ability to increase flow and pressure in certain areas and incidents can be challenging due to the age and design of infrastructure.

Scottish Government response

The Scottish Government accepts this recommendation. SFRS will review established protocols to consider if more can be achieved in line with the recommendation.

Recommendation 41 (para 113.65)

National Fire Chiefs Council (NFCC) consider whether, and if so in what circumstances, firefighters should be discouraged from departing from their instructions on their own initiative and provide appropriate training in how to respond to a situation.

Rationale

The Inquiry found that many firefighters who were sent to higher floors to carry out rescues, ended up deviating from these instructions to rescue people they came across on lower floors.

Scottish context

This is a devolved matter. SFRS adhere to National Operational Guidance that sets out parameters on which firefighters should act upon the evacuation brief given, to ensure health and safety of its personnel at incidents. In certain circumstances operational discretion may be used to deviate from the brief though this must be agreed and documented with Incident Commanders prior to deviating from policy or guidance at incidents.

Scottish Government response

The Scottish Government accepts this recommendation. SFRS will consider wider outcomes, following NFCC consideration and any change to National Operational Guidance in association with their Health and Safety Function.

Recommendation 57 (para 113.82)

Further consideration be given to the recommendations made in the Phase 1 Report in the light of our findings in this report (regarding personal emergency evacuation plans).

Rationale

The Inquiry noted that there were no plans in place for evacuating Grenfell Tower and that a significant number of those who died were children, had disabilities, or were vulnerable in other ways. In the Phase 1 Report the Inquiry recommended that the owner and manager of every high-rise residential building be required by law to prepare Personal Emergency Evacuation Plans (PEEPs) for all residents whose ability to evacuate the building without assistance may be compromised (such as persons with reduced mobility or impaired cognition); and to include current information about them and their associated PEEPs in a premises information box.

The UK Government in response to its most recent consultation on this topic (The Emergency Evacuation Information Sharing Plus (EEIS+)) will introduce Residential Personal Emergency Evacuation Plans (RPEEPs) which outlines that Responsible Persons must carry out a Person-Centred Fire Risk Assessment (PCFRA) to identify fire risks to those residents in their flats including in relation to evacuation. This assessment must also include potential mitigations that are practical, proportionate, and safe. They must provide a statement to the resident on what they have discussed and make this available to the local fire and rescue service. In addition, they must also provide building level evacuation plans to the local fire and rescue service, for both 18 metres+ buildings and 11-18 metres buildings with a simultaneous evacuation strategy in place.

Scottish context

This is a devolved matter. Scottish Government are supportive of ensuring that a person-centred risk assessment is offered where appropriate to reduce risks of fire in their own home. This includes providing information on what to do in the event of a fire. This information is covered in the Practical Fire Safety Guidance for High-Rise Domestic Buildings and Practical Fire Safety Guidance for Specialised Housing.

In 2020 the Scottish Government sent fire safety information awareness leaflets to residents of every high-rise building in Scotland, highlighting how to reduce the risk of a fire happening, and how to reduce the risk of harm should a fire happen. For those at high-risk of harm from fire, SFRS can also be contacted to carry out a Home Fire Safety Visit, to discuss risks and actions that can be taken to reduce these. Additionally, SFRS carry out quarterly Operational Assurance visits to every high-rise domestic building in Scotland, checking features such as the fire doors, lifts, escape stairs, dry / wet risers and hydrants.

In the event of a fire, SFRS would undertake a rescue of any person who is unable to self-evacuate and / or who is affected by fire or smoke, regardless of any assessment in place.

Scottish Government response

The Scottish Government accepts this recommendation in principle. In 2025, we will carry out alongside SFRS, a high-rise fire safety information awareness raising campaign. This will involve engagement with relevant stakeholders to understand how best to reach those we need to.

Additionally, the fire safety toolkits developed specifically for high-rise domestic buildings will be updated and circulated to relevant organisations, such as factors, landlords, COSLA and owners’ associations.

In addition, the Scottish Government has asked the Scottish Law Commission to undertake a project on Compulsory Owners Associations. They are exploring legal options for the establishment, formation and operation of compulsory owners’ associations and the rights and responsibilities to be imposed on them. The recommendations from the Scottish Law Commission are anticipated in Spring 2026 for consideration by Ministers. Following the Law Commission's recommendations, the Scottish Government will consider whether compulsory owners associations may be a route to ensure that those who are unable to self-evacuate have a person-centred risk assessment in place.

Recommendation 58 (para 113.83)

Advice contained in paragraph 79.11 of the LGA Guide be reconsidered.

Rationale

The paragraph referenced was contained in the Local Government Associations (LGA) “Fire safety in purpose-built blocks of flats” guidance document. LGA no longer hosts this document, and it is instead hosted on the UK Government website. The paragraph has been removed from the guidance, with a note saying that policy in this area is being developed. LGA is specific to England and Wales.

Scottish context

This is a devolved matter. Scotland has its own Practical Fire Safety Guidance for High-Rise Domestic Buildings and Practical Fire Safety Guidance for Specialised Housing.

Scottish Government response

The Scottish Government accepts this recommendation in principle. The Scottish Government regularly reviews the content of its guidance documents and will be considered as part of Recommendation 57.