Consultation on the draft National Framework for Fire and Rescue Services

I am very pleased to publish this new National Framework for Fire and Rescue Services, which sets out the priorities and objectives for the Service over the coming years.

In recent years we have seen a consistent fall in the incidence and severity of fire. Dwelling fires, which are by far the most dangerous, are at or close to an all-time low; and there has been a steep fall in the deliberately-set fires which are such a menace in many of our communities. That is to the great credit of the Fire and Rescue Service and the emphasis it places on fire safety and prevention, as the previous Framework recommended.

However, the world has changed much since then, and in ways which may tend to increase the risk of fires and other incidents. Climate change, technological advancement, ageing and global security combine to create a context in which we may need our Fire and Rescue Services more than ever. And overshadowing all of this is the terrible tragedy of Grenfell Tower, which has created some profound challenges for the Service and for others concerned with the built environment.

The Fire and Rescue Service needs to adapt to that context, to create the capacity, capability and culture to respond to an uncertain and in many ways more dangerous world. This Framework sets out how it should do so, honestly, fearlessly and objectively. It will also be essential to do so in full partnership with employees and with other stakeholders: change on this scale can never succeed if it is simply forced through or done in isolation. We are rightly proud of our firefighters; we now need to support them to confront the challenges ahead.

Jayne Bryant MS

Cabinet Secretary for Housing and Local Government

Section 21 of the Fire and Rescue Services Act 2004 (the 2004 Act) requires the Welsh Ministers to prepare a Fire and Rescue National Framework for Wales, the main purposes of which are to set out objectives and priorities for Fire and Rescue Authorities (FRAs), and to provide guidance on them.

This is the latest version of the Framework and supersedes that published in 2016. While much of the content of the 2016 Framework remains valid, there have been several very significant changes since then in the strategic context within which the Service operates. These include the Grenfell Tower fire and its aftermath, the climate emergency and advances in technology which may materially alter the risk of fire. The overarching theme of this new Framework is the need to understand those changes and their effects, and to adapt accordingly. The core business of the Service remains the maintenance of public safety by preventing and responding to fires and other incidents; but that needs to be viewed and managed through the lens of current and likely future strategic challenges.

Section 21(7) of the 2004 Act states that FRAs must have regard to the Framework; and failing, or being likely to fail, to act in accordance with it would allow the Welsh Ministers to exercise their intervention powers in section 22. In practice, we expect FRAs to pursue the objectives in this Framework as far as reasonably possible, unless there are good and evidenced reasons for not doing so (for instance, if there are better ways of achieving the same ends).

The Welsh Ministers will publish a report to Senedd Cymru on the extent to which FRAs are complying with this Framework at least every 2 years starting on the date on which the last report was made, as required by section 25 of the 2004 Act.

The gap of around 10 years between the previous Framework and this one was exceptional. Our broad intention is that this Framework should have a lifespan of no more than 4 or 5 years, although that will be a matter for the Welsh Government following the 2026 elections to Senedd Cymru.

The 2016 Framework was issued against the backdrop of a significant and sustained fall in the incidence of fires and fire casualties. There were probably multiple reasons for this, a long-term decline in the incidence of smoking and the use of open fires for heating, improvements in product and vehicle safety, and, not least, the efforts of the Service to prevent fire through advice, support and enforcement. The Framework therefore encouraged the Service to continue to prioritise preventative work alongside providing an effective emergency response. 

That balance remains valid: it must always be better to prevent fires and other emergencies from occurring than to tackle them when they do. However, while the incidence of most types of fire remains at or close to an all-time low, the decline seen in the last decade appears to have bottomed out. There are also current and likely future changes to the strategic context in which the Service operates, many of which are likely to increase the risk of fires and other emergencies.

It is beyond the scope of this Framework to provide a comprehensive and detailed account of those changes and their likely impact. However, the most obvious and significant influences are likely to include the following:

• Demographic change: the incidence of dwelling fires, and other emergencies caused by human factors, is necessarily proportional to the size and distribution of the population. Overall, the population of Wales is projected to grow only slowly in the medium to longer term, with growth of only around 3.5% in the next 15 years. However, this masks considerable regional variation: the M4 corridor is projected to experience population growth of 2 to 3 times this rate, while in other areas there is likely to be much more modest growth, or even a decline. Much of the overall growth in population arises from an increase in life expectancy rather than the birth rate or net inward migration. This ageing of the population has persisted for many years and is likely to continue. Between 2025 and 2040, the number of people in Wales aged 65 or over is projected to increase by over 23%, while the population aged 18 to 64 is projected to increase by under 4%. Again, there are likely to be regional and local variations in this, although these are harder to estimate accurately. Older people may of course be more likely to experience a fire in the home, and less likely to be able to escape from it safely and unaided.
• Climate change: is likely to increase the incidence and severity of weather-related events, even on the most modest medium-term predictions. This is particularly relevant for wildfires: milder and wetter winters may increase the length of the growing season and thus the fire loading in uncultivated areas, while hotter summers and a greater incidence of heatwave conditions are likely to increase the propensity for summer ignition. That would represent a change from current patterns: the vegetation typically found in Welsh uplands (grass and bracken) has a lower propensity to ignite in normal summer weather, and a lower fire loading, than the heather and gorse more commonly found elsewhere in the UK. The peak risk for wildfire is thus normally in the early spring, before new season growth emerges. That may well shift or extend into the summer months as global warming continues to take effect. While most wildfires have tended to be deliberately set, such a change could also increase the risks of accidental ignition as it coincides with the peak season for tourism. Climate change is also likely to increase the incidence of storms and flooding, especially but not only in the winter months. Wales is currently the only part of the UK where the FRS has a duty to respond to all flooding and inland water incidents.
• Technological change: has long acted to reduce the risk of fire, for instance by yielding fire-resistant furnishing and construction materials, and reducing reliance on chip pans and open fires. That may well continue to be the case. However, some current technological changes may have the opposite effect. For example, the rapid growth in the use of lithium-ion batteries, especially larger ones used to power e-bikes, e-scooters and road vehicles, creates a significant fire risk as well as a major firefighting challenge in the event of a thermal runaway. Battery energy storage systems, whether on a domestic or industrial scale, may do likewise, as may the widespread availability and use of generic unbranded electronic devices such as chargers. These and other changes are of course driven in part by the need to mitigate the effects of climate change and to move away from dependence on hydrocarbon fuels, so they are likely to persist in the longer term.
• The built environment: continues to evolve. As with technological change more generally, many such changes have a positive effect on the risk of fire, but by no means all. The Grenfell Tower fire was an exceptionally severe disaster, but it also demonstrated the wider potential consequences of novel uses of construction materials, and the resulting potential for fire to behave in ways that were not expected or trained for. While many specific lessons of the fire, for instance around the use of combustible cladding, have been learned, there are wider trends too. Developers and building owners are likely always to look to maximise the returns on their investment, whether through innovative use of materials and techniques which may create fire risks that are not fully understood; or by constructing complex mixed-use buildings which again present unusual and significant fire safety and firefighting challenges. Vacant premises also present significant risks of fire, in particular arising from unauthorised use, insurance fraud or arson. The COVID-19 pandemic severely affected many retail and hospitality businesses and significantly increased the number of vacant commercial premises. While the position has since stabilised, longer-term trends around, for instance, homeworking or greater reliance on online retail, may create persistently high numbers of vacancies.
• Global security: since the last Framework was published, there has been a major terrorist attack at the Manchester Arena and the Novichok poisoning in Salisbury, as well as other serious incidents. The global security position following Russia’s invasion of Ukraine and continuing conflict in the Middle East in particular, is febrile and unstable; the risks of attack by terrorists or hostile state actors are high and likely to remain so. Many such incidents will naturally require a rapid and capable FRS response, alongside those from other agencies.

Furthermore, these changes in context are dynamic, and other as yet unknown risk factors could and probably will emerge. Further technological change and security issues might be especially hard to anticipate. When the last Framework was published, for instance, the fire risks posed by lithium-ion batteries were relatively modest, and security threats might have been seen as coming more from isolated terrorists than hostile states. And the profound effects of the COVID-19 pandemic were not anticipated at all.

This is the continually shifting context within which the FRS must operate, and to which it must adapt. The FRS needs to understand how risk varies from place to place over time. It needs to develop and maintain capabilities to reflect a changing environment while also maintaining a high standard of core preventative and responsive services. Doing so will ensure that the FRS continues to play a vital role in securing public and community safety while maintaining national resilience. The rest of this Framework expands on these challenges.

The risks of fire and other incidents to which the Service responds are of course neither static nor uniform. Much is already known about, for example, demographic and behavioural risk factors for dwelling fires, the ways in which weather, vegetation and land use influence the risk of wildfire, and the topographic concentration of the risk of flooding. All these effects necessarily and significantly vary from place to place and over time.

The previous chapter set out some further ways in which the risks of fires and other incidents may change in the medium term. Many of those are global issues, but their effects will again vary. For example, only 6.7% of the population of Cardiff is aged over 75, less than half of that in Conwy and Powys, and the demographic trends described in the previous chapter may exacerbate those differences. High-rise buildings are heavily concentrated in our major cities, but the changes in the built environment described in the previous chapter could reasonably occur in any urban area.

This gives rise to 2 broad challenges for the Service:

1. Addressing changes in risk that are already occurring and/or are very likely to occur. This points to a need to understand those changes fully and to re-evaluate the capacity and capability of the Service, and the spatial distribution of its resources, accordingly.
2. Being prepared for other emerging changes in risk which are as yet unknown or less likely to occur in the short to medium term. This suggests a need for strategic vigilance and horizon-scanning, and creating a flexibility of capacity, and an innovative culture, which allows the Service to respond to such risks as and when they materialise.

This needs to be done while maintaining a high standard of existing core services. Whatever the changes in strategic risk, a substantial part of the Service’s mission is likely to remain as it is now, responding to everyday fires and other emergencies and undertaking routine fire prevention and protection work. A focus on understanding strategic change should not be at the expense of this.

Identifying and evaluating risks

The first step in addressing the strategic context and the changes in it is to develop and maintain a thorough and evidence-driven understanding of risk levels across and within each FRS area, and developments which are likely to change that. This should be based on reliable sources of data and other forms of intelligence, and should be broken down to station area level to the extent that available information reliably supports that. Risks associated with flooding, wildfire or high-rise and/or complex buildings, for instance, are likely to be concentrated in identifiable localities, while those relating to ageing, global security or technological change may be less so.

At the most local level, the gathering of site-specific risk information under section 7(2)(d) of the Fire and Rescue Services Act 2004 can and should yield comprehensive and reliable intelligence about risks within individual premises. The same is true of fire safety audits of premises, and of home safety visits, especially to vulnerable households. This intelligence-gathering should take place in a thorough and comprehensive way, and should contribute fully to the planning and resource allocation processes that this chapter describes.

This information should be collated and analysed so as to yield a detailed and reliable picture of current demand for Fire and Rescue Services, and how that is likely to change in the foreseeable future.

It should also be subject to regular review, with new and emerging intelligence incorporated as it arises. This might include new data about already-known risks, or information about emerging risks that arises from horizon-scanning.

FRAs should:

• Identify and evaluate the effect of strategic changes on their operating environment, including but not limited to those in the previous chapter.
• Identify how the effects of those changes are likely to vary across their areas and over time.
• Engage in continual horizon-scanning to identify emerging and possible future changes in risk.
• Use intelligence and data from all appropriate sources to make these assessments and keep them under review.
• Make full and appropriate use of site-specific risk information and the findings of building safety audits, inspections and enforcement actions to develop a full understanding of risk at the station area level.

The above activity only has any value if it is reflected in operational plans which are designed to address identified patterns of risk and work effectively to mitigate the risks identified. Operational plans may need to be re-evaluated and updated to provide effective mitigation. It may well be possible to accommodate emerging risks within existing plans.

FRAs should specifically consider the following aspects of Service provision in the context of the identified patterns of risk.

Capacity

The Service will naturally need sufficient overall resources to respond to likely levels of different types of incidents, and to undertake an appropriate volume of preventative work. That may appear to be a relatively straightforward aim to meet, in light of the recent fall in incident numbers, which has not generally been matched by an equivalent reduction in Service capacity. However, this issue needs to be viewed in the context of changes in the strategic context which appear likely to increase risk, and to seasonal fluctuations in incidents such as floods and wildfires (and likely changes in such fluctuations). Against that background it may be that capacity should not be reduced further, or increased, although any such decisions should be carefully considered and fully evidenced. The Service still needs to be able to respond fully and capably to any incident at any time.

This imperative applies to prevention work as well as to emergency response. As the previous framework set out, effective fire prevention and protection programmes yield the best possible outcomes; that fire does not happen, or if it does, it causes less damage. The Service’s capacity in this area should therefore also be evaluated in the context of likely changes in risk. For example, how far does an ageing population create an increased demand for home safety visits, and how far do changes in the built environment increase the need for robust and effective fire safety inspections? The potential wider social benefits of such work should also be taken into account. Home safety visits can identify support needs that other agencies can meet; and interventions with children and young people can enable positive longer-term outcomes in terms of education and employment.

Ensuring sufficient capacity also means making the best use of resources that are available, and targeting them so that they have maximum effect. To that end, the previous Framework called for robust action to reduce attendance at false alarms. That has now occurred, although it is too soon to see the benefits of it in most of Wales. Current policies should be maintained and, where justifiable, enhanced so that resources are not wasted in responding to non-existent fires. Additionally, working practices should always ensure that firefighters’ time on duty is put to best use, subject always to maintaining their welfare and safety, as the next chapter describes.

The Service has more discretion in targeting preventative and protective measures. These should continue to focus on the highest risks, where they are likely to have the greatest value. Home safety visits, for example, should concentrate on those at greatest risk of fire in the home such as older people, people with disabilities, smokers and single parents; and regulatory fire safety should be based on an evidence-driven assessment of relative risk for premises in the Service’s area. This should still be subject to reappraisal in light of changes to strategic risk. The risks posed by climate change, for example, are likely to call for renewed efforts to reduce the risk of wildfire through education, diversion and deterrence.

FRAs should:

• Maintain sufficient responsive and preventative capacity to meet likely demand, having regard to seasonal fluctuations and emerging changes in risk.
• Continue to take action to reduce attendance at incidents arising solely from automatic fire alarms, unless there are exceptional reasons to respond.
• Ensure that staff time on duty is put to best use, subject always to health, safety and welfare considerations.
• Focus fire prevention and fire safety programmes on areas, premises and individuals at greatest risk, bearing in mind how risk is likely to evolve.

Capability

Resources are only useful if and to the extent that they are capable of meeting the purpose for which they are deployed. In the FRS, that necessarily requires a combination of appropriate skills, knowledge, leadership, equipment and procedures for applying and utilising them.

The processes for developing and sustaining such capability are well-embedded in the FRS, although the Chief Fire and Rescue Advisor and Inspector (CFRAI) has made important recommendations both about the quantity and quality of training, and about commonly-used tactics to fight dwelling fires.

Capability needs are, though, particularly driven by changes in the strategic context. Meeting them involves ensuring that the Service adapts, and is adaptable to, new risks as they emerge, and also takes advantage of improvements in firefighting technology and understanding of fire behaviour. That will very probably mean changes to doctrine, training, policies, procedures and equipment for all staff, which in turn may well mean consciously discarding outdated knowledge or practices to make way for new and more effective ones. That can be challenging, and will require commitment and support at all levels of the Service. 

Linked to that is a need for flexibility and innovation. Uncertainty about the evolution of strategic risk and about how it might manifest itself on the incident ground cannot be met simply by adhering to established practice. The Grenfell Tower fire and the response of the London Fire Brigade to it was a tragic demonstration of the consequences of doing so; of not understanding the risks of external fire spread and not responding in a way which might have reduced the loss of life. While standard operating procedures will in most cases maximise the effectiveness of an emergency response and minimise the risks to firefighter and public safety, there may be an increased need to rely on creative thinking and good judgement, within defined limits.

The FRS’s National Resilience (NR) capability is a vital component of the response to major disasters. The need for it may well increase in light of some likely changes in strategic risk, for instance involving climate change and hostile state action. While it is directly overseen and funded by the Welsh Government, it relies on the commitment of staff from all three FRSs, and on effective integration with frontline response capabilities. Good cooperation across the three FRSs will need to continue.

Previously, the NR capability included specialist crews trained to respond to marauding terrorist attacks (MTAs), equipped with ballistic protection and able to provide casualty extraction and initial trauma care. However, the experience of the Manchester Arena bombing has called that approach into serious question. MTA crews’ ballistic protection would be inadequate against many weapons used by terrorists, and having only a few such crews means it would be unlikely that they could reach the scene in time to be useful. A clearly better approach is to treat MTA attacks in the same way as any other mass casualty incident. Frontline firefighters could be deployed to assist with casualty extraction and treatment, but only once the scene has been secured and attackers neutralised by the police or special forces, meaning there would be no need for ballistic protection. Specialist USAR crews should naturally still be a part of the response to bombings and similar incidents where structures have collapsed or are at risk of doing so.

FRS capability has been the subject of numerous recommendations from the CFRAI as well as the public inquiries into the Grenfell Tower fire and Manchester Arena bombing. That is likely to continue: doing so is an integral part of the CFRAI’s role, and the capability of emergency responders is rightly a common focus for public inquiries and inquests. Such recommendations are invariably the product of careful and objective consideration of evidence from multiple sources. Acting on them is an important part of adapting to emerging risks and learning lessons from their materialisation. FRAs should therefore do so unless they are demonstrably inapplicable in a particular case, or there are demonstrably better ways of achieving the same ends (which should be pursued instead).

The law on the functions of Fire and Rescue Services has been largely unchanged since the Fire and Rescue Services Act 2004 and the Regulatory Reform (Fire Safety) Order 2005. However, that will change with the enactment of the Building Safety (Wales) Bill, which was before Senedd Cymru at the time this Framework was drafted. If passed, it will largely replace the 2005 Order with an analogous regime tailored to the risks of fire typically found in multi-occupied residential buildings. If passed, the Bill will confer inspection and enforcement powers on FRAs which largely replicate those in the 2005 Order, so it should not alter their workload significantly. However, the Bill would give local authorities significant new functions, and implementing it will require close collaboration between them and FRAs to ensure that multi-occupied buildings are as safe as possible, and to hold landlords and building owners to account.

Finally, broadening the role of firefighters, in particular to support the NHS, has been the subject of much discussion and planning since the last Framework was published. A wider preventative role encompassing water safety and road safety has also been discussed. The current Welsh Government’s position is that such broadening is not a national policy priority in light of the need to address concerns around FRS culture and governance. However, that position could change, and does not preclude individual FRS’s pursuing such opportunities if the capacity and capability to do so exists, and can be utilised without jeopardising the Service’s core role.

FRAs should:

• Ensure that firefighters and other staff have access to comprehensive and appropriate training based on identified and emerging risks, including regular refresher training, in all areas of work.
• Develop and maintain equipment, training programmes and operational doctrine, practices and procedures to meet likely emerging risks, with sufficient flexibility to adapt to new risks and threats, both strategically and on the incident ground.
• Take full advantage of relevant advances in technology and scientific understanding.
• Contribute fully to the maintenance of an effective and comprehensive all-Wales National Resilience capability.
• Mainstream response to marauding terrorist attacks, on the basis that firefighters will not be deployed until the scene has been neutralised and secured.
• Adopt and implement all relevant recommendations from public inquiries, inquests and the CFRAI, or take equivalent action of equal or greater effect.
• Work with local authorities and others to implement the Building Safety (Wales) Bill once enacted.
• Continue to explore and take advantage of opportunities to broaden the role of firefighters, having regard to the Service’s capacity and the need to discharge its core role fully and safely.

Distribution

Capacity and capability require to be distributed appropriately across each FRS area and across Wales. While response times are by no means the only useful measure of the effectiveness of Fire and Rescue Services, it is clearly important for an appropriate emergency response to arrive on scene swiftly.

At an operational level, this means reflecting what is known about the distribution of risk within an FRS area in the capacity and capability of each fire station, taking into account reasonable reliance on cross-border mutual aid. Some areas will have a higher elderly population, while others will be more prone to flooding or will experience a higher volume of road traffic collisions. While all frontline firefighters are of course trained to the same standards to deal with the same range of incidents, they can expect a different mix of incidents depending on where they are based, and are likely to develop particular expertise in responding to those they confront most often. A similar point applies to specialist appliances such as aerial ladders, rescue boats and National Resilience assets, which are and should be located close to areas where they are most likely to be deployed.

All of this has been part of the routine business of managing the Service for many years, and should continue. But it should also be undertaken in the context of likely changes to strategic risk, and how assets are distributed to meet current and emerging threats. The objective should be that all crews are suitably aware of, and trained and equipped to deal with, incident types which are (or are likely to become) particularly prevalent in their local area.

At a more strategic level, long-term shifts in risk eventually lead to a need to review frontline cover more fundamentally, and to redistribute resources within the FRS area. This process has often been heavily informed by differential changes in population, leading to greater cover in areas of population growth. But demographic change is not the only or even the main driver of changes in risk levels, as the first chapter described; and such reviews should consider all significant risk factors and how they might reasonably be expected to change.

Frontline cover reviews are complex, time-consuming and costly to implement, meaning they can only be undertaken infrequently. However, the current existence of multiple factors tending to increase strategic risk and to change how it is distributed means that all FRAs should aim to conduct such a review within the expected currency of this Framework, ie in the next 4 to 5 years. This should realign Service capacity and capability (including specialist resources) with the known distribution of risk within the Service area, and likely changes in it.

This may well be a controversial process. Proposals which involve the closing of fire stations or changing the way in which they are crewed can understandably attract local concern. FRAs should therefore engage fully with local communities over such proposals, and explain them in terms of the need to realign resources to risk. Ultimately, though, fire stations are generally not community facilities in the way that, say, hospitals or libraries are. Their location and resourcing is not driven by the need for public access; it should be based only on thorough and professional analysis of local and area-wide risk. FRAs should approach decisions about changes to frontline cover from that perspective.

This process should not neglect the need to provide a swift and effective response in rural areas. Focusing on changes to risk too narrowly could lead to an undue shift in resources to urban areas, where population growth tends to be high, and where the complexity of the built environment is usually greatest. Fires, floods, road traffic collisions and other incidents can of course occur frequently in rural areas too, and still need a response.

Indeed, meeting this need may prove particularly challenging due to long-running problems in recruiting and retaining on-call firefighters. These are not limited to Wales and may relate to changes in the rural economy that are beyond the control of FRAs or the Welsh Government. These challenges are not wholly impossible to meet and FRAs should continue to participate in discussions convened by the National Fire Chiefs Council and the Social Partnership Forum which aim to address these challenges. Nonetheless, in some cases a frontline review might conclude that it is necessary to upgrade strategically located retained duty system (RDS) stations to wholetime crewing for all or parts of the day to ensure a response; it may well be better to have an assured but more distant response from such a station than to hope for a closer response from RDS stations that are often unavailable for deployment.

FRAs should:

• Ensure FRS assets are appropriately distributed to meet the operational demand.
• Ensure that firefighters are fully aware of, and trained and equipped to respond to, incidents that are or may become particularly prevalent in their station areas.
• Aim to conduct a frontline cover review during the currency of this Framework, so as to align the distribution of Service capacity and capability to the known and likely future distribution of risk.
• Consider as part of that the need to maintain reliable and effective cover in rural as well as urban areas.
• Continue to participate in discussions aimed at overcoming challenges relating to the sustainability of the Retained Duty System.

Planning and delivering

This chapter describes processes for identifying and evaluating risk levels, and for developing, maintaining and allocating the necessary capacity and capability to address them.

These processes are fundamental to ensuring that the Service is able to address the demands that are likely to be placed on it. It is therefore important that they are fully planned and documented, and that each FRA’s intentions and progress in delivering them are clearly and openly articulated.

To do this, FRAs should compile and publish a community risk management plan, which:

• covers at least a 5-year timeframe
• describes in detail the results of the evaluation of current and likely future risks, how they vary within the Service area and how they are expected to change over time
• sets out measures to align capacity and capability to that evaluation of risk
• outlines proposals for conducting a frontline cover review, if one is not already under way, along with other proposed measures to distribute resources consistently with the distribution of risk
• contains clear objectives and measures by which progress in implementing the plan can be monitored, and which are aligned to the statutory well-being goals

The plan should be developed in the full spirit of social partnership, and should be subject to extensive public engagement and consultation. It should then be published, as should annual updates on progress with delivery. If experience of delivery suggests the plan should change, or if there are significant unanticipated changes in the risk context, then it would be appropriate to amend and update the plan accordingly.

Currently, the Local Government (Wales) Measure 2009 (the 2009 Measure) also requires FRAs to publish annual improvement plans and performance reports. The 2009 Measure no longer applies to the local authorities for which it was primarily designed, and the future of its application to FRAs will be a matter for the incoming Welsh Government. It is possible that regulations could be made under s21A of the 2004 Act which would require the production of a plan in relation to the exercise of FRAs functions, along with requirements for assessing FRAs performance. For the time being, and to avoid an undue administrative burden, it would be appropriate to subsume planning and reporting under the 2009 Measure into the arrangements described above, provided that the requirements of the Measure are still met.

FRAs should:

• Prepare and publish a community risk management plan as described above.
• Prepare and publish annual reports on delivery of that plan.
• Subsume the planning and reporting requirements of the Local Government (Wales) Measure 2009 into these arrangements, if they wish.

Firefighting is unavoidably stressful, hazardous and physically and mentally demanding. More so than many other professions. Delivering effective Fire and Rescue Services depends heavily on maintaining a workforce which is properly trained, equipped, motivated and led to meet these challenges.

Delivering this capability becomes even more challenging in the context of the changes in strategic risk described in previous chapters. Firefighters and other staff may now have to confront new or substantially more serious hazards, or situations which do not evolve as expected and where there is a need to act flexibly and decisively to keep people safe. The Grenfell Tower fire was an extreme but by no means unique example and while we may not see another fire on that scale for some time, it is still likely that changes in risk will present the Service and its employees with sudden and unanticipated challenges.

Dealing with that means more than developing and deploying overall capacity and capability, as described in the last chapter. It also means supporting employees to meet these challenges and initiating sustainable changes to practices, procedures and cultures.

Health, safety and wellbeing

The nature of the Service’s fundamental mission means that many tasks undertaken by its employees can never be completely safe. Exposure to some risk of physical harm on the incident ground is probably unavoidable and the mental challenges of dealing with people in extreme danger and distress may prove severe for firefighters and control staff alike.

Training, equipment and working practices are and must be designed to reduce these risks to as low a level as practicably possible, and to provide effective occupational health and welfare support to those who have been exposed to them. The safety and wellbeing of firefighters and other staff must always be a fundamental priority; both as part of any employer’s duty of care, and because if firefighters are not safe, then nor are those they are charged with protecting.

This involves more than simply developing and applying the same standard protective measures over time. Changes in risk and the understanding of it can and do create new hazards which need to be addressed as soon as clear evidence of them emerges. In recent years, for instance, serious and substantiated concerns have been raised in the following areas:

• Contaminants: Research has identified a higher incidence of certain cancers among firefighters which could be linked to exposure to carcinogenic combustion products, and in turn to poor practice in the maintenance and cleaning of breathing apparatus (BA). Changes to those practices have been identified and implemented, but there may be a need for further action in this area as medical understanding advances. There may also be a case for reducing usage of BA by adopting different firefighting tactics (see below).
• Compartment firefighting: The CFRAI has identified serious deficiencies in the standard approach to fighting compartment fires across the UK. These risk re-ventilating a fire and exposing firefighters and others to the very significant risks of rapid-fire development and have been implicated in almost all firefighter fatalities in the UK during the 21^st century. Changes to tactics involving ventilation control combined with a greater weight of attack, often from outside the compartment, would appear to be both safer and more effective.
• Fatigue: Maintaining a 24/7 capability to respond will inevitably raise issues around human fatigue and/or activity during a circadian low. Fatigue leads to slower reaction times, impaired motor skills and poor decision-making, all of which are obvious hazards on the incident ground. There is ample research in this area and several ways in which the risks can be mitigated, but they cannot be ignored.

While these risks are serious and must be addressed, others are likely to emerge too. Working practices and protective measures should thus be reviewed and adapted continually to maintain the safe system of work which all staff need. Where that involves changing well-established practices (as with compartment firefighting, above), it may be necessary to support retraining and adjustment to new procedures: unlearning something old can be as taxing as learning something new.

The previous Framework noted that the increase in firefighters’ normal pension age from 50 to55, to 60 (required by the Public Sector Pensions Act 2013) could make it hard for older firefighters to maintain operational fitness before they could retire on a full pension. It encouraged FRAs to provide full support to such individuals, and to explore all other options before any possibility of termination arose.

That situation has yet to materialise fully, as a legal challenge effectively extended the right to retire at age 50 to 55 for many firefighters, by reverting all those who joined before April 2012 to their former schemes. It may well, though, arise in the future, and the need to support older firefighters who may struggle to maintain operational fitness thus remains.

FRAs should:

• Ensure that for all tasks, firefighters and other staff have the safest possible systems of work, including protection from risks of flashover, fatigue and exposure to carcinogens.
• Develop and implement practices, procedures and protective measures to meet emerging risks to health, safety and wellbeing, and support staff to adopt them.
• Provide all staff with effective occupational health and welfare services.
• Support older firefighters to maintain operational fitness wherever possible.

Leadership and culture

The working culture of the Service across the UK has of course been strongly criticised in recent media reports and subsequent investigations commissioned by FRSs. Cases of harassment and bullying have been widespread, alongside allegations of favouritism and mismanagement.

This has been highly damaging for the Service, and not only in terms of its reputation. Dysfunctional cultures like these can hamper the ability to recruit, in particular from among groups currently under-represented in the workforce. They can also reflect a wider and deeper malaise. Tolerance of misconduct can indicate a wider sense of complacency and acceptance of bad practice.

Extensive cultural improvement programmes to address these shortcomings are already under way in all 3 FRAs, and need to continue to a successful and sustainable conclusion. That will not be quick or easy: cultural change is a slow and often challenging process, and the outcomes can be hard to measure. This Framework therefore does not set any overall deadline for this work.

Cultural change should not just be concerned with correcting identified weaknesses or dealing robustly with misconduct. The strategic challenges which the rest of this Framework describes also call for changes in this space. To meet emerging risks, the Service and its workforce will need to be agile and innovative, with staff at all levels empowered to think and act creatively as appropriate. That needs to be balanced with the ongoing need to develop and adhere to standard operational practices and procedures as part of the core role; but that cannot be relied upon to confront the challenges that lie ahead.

Continual and effective workforce engagement will also be essential for successful cultural change. Social partnership is not just a legal duty of FRSs; it is the only means of sustainably achieving the necessary cultural change. Employers and representative bodies should thus continue to work together in the full spirit of social partnership to achieve the objectives set out in this Framework, including in particular the processes of community risk planning and frontline cover review described in the previous chapter.

Although there has been some modest improvement since the last Framework was published, the firefighting workforce still lacks diversity. It remains overwhelmingly male and while data on other protected characteristics are less accurate, it appears likely also to be disproportionately white and heterosexual. This may be partly a matter of social stereotyping that firefighting is a job for men only, but it still needs to be challenged and overcome. A more diverse workforce would not only better represent the communities it serves, it may also mitigate against some of the dysfunctional behaviours and cultures which have been identified.

FRAs should:

• Develop and sustain effective leadership at all levels and a culture of professionalism, openness, inclusion and innovation.
• Engage openly and fully with staff and their representatives, in the spirit of social partnership.
• Take all practical steps to diversify the composition of the workforce, with the aim of making it more representative of the communities it serves.

The previous chapters have concentrated on the planning and delivery of Fire and Rescue Services in a changing strategic context. Much of the work involved in that is likely to be undertaken by firefighters and other staff. This, though, also calls for effective leadership, accountability and good governance at the corporate level.

Strategic leadership and funding

FRAs are legally responsible for discharging all powers and duties relating to Fire and Rescue Services in their areas, and for resourcing those services appropriately. In practice, of course, operational responsibility is delegated to the Chief Fire Officer and other staff. However, the FRA remains in overall control and needs to provide appropriate direction and support to the Service.

There are 2 basic strands to this. Firstly, FRAs need to provide clear and effective strategic leadership to the Service, including the setting of appropriate priorities and providing the resources to pursue them. Objective-setting should naturally be closely informed by the all-Wales objectives in this Framework, but these need to be tailored for each FRA’s area and operating context. In approaching this task, FRA members need to act in the interests of the area as a whole, rather than sometimes competing interests of their local authority areas or wards. Issues such as frontline cover reviews may generate significant local concern but the need to resource to risk across the whole Service area must remain the overarching objective.

Secondly, FRAs need to hold the Service and its officers to account for delivering on those objectives and priorities. The FRA needs assurance that optimal progress is being made, that the Service is adapting to changing circumstances (including but not limited to the sorts of changes described in this Framework), and that resources are being used efficiently and effectively. This should not routinely include second-guessing the professional judgements and decisions of officers on operational matters.

Subject to a consultation that was under way at the time this Framework was drafted, the financing model for FRAs allows each FRA to determine its own budget and to fund that from contributions levied on local authorities, without any form of external approval or control. That gives a degree of freedom and flexibility which is rare in the public sector. FRAs should continue to exercise that freedom responsibly, taking into account the often severe pressure on local authority budgets. They should ensure that budgets are set which fairly meet expected Service needs, but which also take into account the potential to realise savings.

Taken together, these tasks can make the role of an FRA member challenging. The professional and technical nature of much of what the Service does can be hard for a lay person to grasp, never mind to oversee or scrutinise and the changes in strategic risk that it is facing add another layer of complexity. However they also make strategic leadership more important than ever, and it is essential that members are properly supported to discharge this role effectively.

FRAs should:

• Provide clear strategic leadership to the formulation and delivery of objectives and priorities for the Service
• Act for the benefit of the whole area.
• Hold the Service and its senior officers clearly and fairly to account, respecting their professional judgement in operational matters.
• Set budgets which are realistic in light of challenges faced both by the Service and the local authorities which fund it.
• Provide FRA Members with appropriate training and support to allow them to discharge their roles effectively.

Collaboration and accountability

Good governance means more than having appropriate internal decision-making and scrutiny arrangements. It must also operate effectively in the wider context.

Collaboration between public bodies was a key theme of the previous Framework, and has long featured strongly in public policy more generally. That has typically been with a view to providing more coherent services, and/or realising efficiency savings, and those imperatives are still valid. However, the changing strategic risk context which this Framework has described makes such ways of working even more important. Emerging risks and incident types may well not fit neatly within the existing remit of a single responder or service-provider. Close collaboration will be vital to understanding and planning for such eventualities, as well as for managing responses at the strategic, tactical and operational levels.

FRAs should thus continue to develop and sustain close working relationships with all relevant partners. This should involve both working via existing mechanisms such as public service boards and local resilience forums, and by creating new mechanisms to address emerging risks (as has been done with the All Wales Wildfire Board, for example).

Accountability to stakeholders and to the general public is a vital driver of improvement in any public service. It involves not only giving an account of what has been achieved, but taking into account responses, suggestions and challenges based on that. In the past, it may have been possible to rely on the Service’s generally high public standing and/or to point to the decline in the incidence of fire. After all, most people never need to call upon the Fire and Rescue Service, and may simply be grateful that it exists.

That is unlikely to suffice in the current and emerging risk context. Public concern about fire safety in high-rise buildings following Grenfell, or about wildfire in the context of climate change, have demonstrated a need to provide assurance that the Service can and will adapt to new challenges, as well as that it is providing a high standard of core services. FRAs should therefore account for progress and performance regularly, and in an open and candid way. 

Accountability may yield criticism and challenge; indeed it has very little value if it does not. Even if it is unfounded or superficial, such challenge serves as a means of verifying that current arrangements and performance levels are adequate. More substantive challenges, including those from regulators, inspectors and partner organisations, should always be welcomed rather than resisted. There has never been room for complacency and defensiveness in managing Fire and Rescue Services; and there is none at all given the changes in strategic risk that lie ahead.

FRAs should:

• Be openly, fully and candidly accountable for performance and value for money.
• Develop and sustain effective strategic and operational partnerships with local authorities, the NHS, the police and others, especially to meet emerging shared risks.
• Engage with and respond positively to recommendations for corporate and service improvement
• Sustainability and net zero.

Sustainability and net zero

The first chapter of this Framework noted that climate change was one of the main components of the shifting strategic risk picture, and was very likely to remain so. The Service needs to adapt its capacity and capability to that; but it also needs to play its part in mitigating the effects of climate change.

Fire itself can be a major component of climate change. An ordinary dwelling fire can emit several hundred kilograms of carbon dioxide, while a large wildfire can have an emissions level that is several orders of magnitude greater. Fire prevention and effective firefighting are thus important components of climate change mitigation; they can and should be accounted for as such.

However, the Service should still seek to reduce its own carbon footprint. The Welsh Government’s aim is for the whole devolved public sector to be carbon neutral by 2030, and the Service should aim to achieve that as far as possible through the greening of its estate, fleet and operations. That is likely to be subject to limitations, especially as regards fleet issues: there is currently only one wholly electric pumping appliance on the market. But that does not preclude continued efforts in other areas of the Service’s work.

FRAs should:

• Understand, undertake and account for fire prevention and firefighting as a means of mitigating climate change.
• Seek to become carbon neutral in their operations by 2030, subject to technological limitations as regards fleet issues.

Governance reform

At the time of writing this Framework, the Welsh Government was consulting on proposals to reform the governance of FRAs, within existing powers. Without pre-empting the results of that consultation, effective governance and clear accountability will be vital in attaining the objectives in this Framework. Any further reform will require primary legislation, and will be a matter for the new Welsh Government and Senedd Cymru following the May 2026 elections. 

The strategic context

Question 1

Do you agree that the account of the strategic challenges facing the Service is fair and comprehensive?

Question 2

Are there other issues that we should include in this chapter?

Resourcing to risk

Question 3

Do you think that the narrative and objectives in the resourcing to risk chapter are appropriate and important?

Question 4

Are there any other issues or objectives that we should include in this chapter?

People, leadership and culture

Question 5

Do you think that the narrative and objectives in the people, leadership and culture chapter are appropriate and important?

Question 6

Are there any other issues or objectives that we should include in this chapter?

Corporate issues

Question 7

Do you think that the narrative and objectives in the corporate issues chapter are appropriate and important?

Question 8

Are there any other issues or objectives that we should include in this chapter?

General

Question 9

We would like to know your views on the effects that the policy proposals would have on the Welsh language, specifically on opportunities for people to use Welsh and on treating the Welsh language no less favourably than English. What effects do you think there would be? How could positive effects be increased, or negative effects be mitigated?

Question 10

Please also explain how you believe the policy proposals could be formulated or changed so as to have positive effects or increased positive effects on opportunities for people to use the Welsh language and on treating the Welsh language no less favourably than the English language, and no adverse effects on opportunities for people to use the Welsh language and on treating the Welsh language no less favourably than the English language.

Question 10

We have asked a number of specific questions about the proposed new Framework. If you have any related issues or comments which we have not specifically addressed, please use this space to record them:

Submit your comments by 17 December 2025, in any of the following ways:

• complete our online form
• download, complete our response form and email fire@gov.wales
• download, complete our response form and post to:

Fire Services Branch
Welsh Government
Rhydycar
Merthyr Tydfil
CF48 1UZ 

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Number: WG53350

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