final gra 3 9 places of lawful detention

8/17/2019 FINAL GRA 3 9 Places of Lawful Detention

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Operational Guidance

Fire and Rescue Authorities

GRA 3.9

Fighting fires in placesof lawful detention


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Generic Risk Assessment 3.9

Fighting fires in placesof lawful detention

November 2013

London: TSO


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Published by TSO (The Stationery Office) and available from:

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J002819605 C2 11/13 33722


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3

The generic risk assessments in this series only apply to England

Contents

SECTION 1

Generic Risk Assessment 3.9Fighting fires in places of lawful detention

Scope 5

Significant hazards and risks 5

Security gates and doors 6

Communication 6

Key control measures 7

Planning 7

Competence and training 8

Proceeding to an incident 9

Command and control 9

Safety Officer(s) 10

Evacuation signal 12

Safety of firefighters 12Personal protective equipment 12

Post incident 13

SECTION 2

Summary of Generic Risk Assessment 3.9Fighting fires in places of lawful detention 15


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4


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Generic Risk Assessment 3.9 – Fighting fires in places of lawful detention 5

SECTION 1

Generic Risk Assessment 3.9Fighting fires in places

of lawful detention

Scope

This generic risk assessment examines the hazards, risks and control measures relating

to fighting fires in places of lawful detention (eg prisons, courts, police cells, and secure

children homes etc).

Activities which involve specific significant hazards, eg responding to an emergency, are

covered in other generic risk assessments.

This, as for all generic risk assessments, provides a starting point for Fire and Rescue

Authorities to conduct their own assessments within the context of local conditions and

existing organisational arrangements.

Significant hazards and risks

The role of the Fire and Rescue Authority is to rescue all persons from an emergency

situation and to extinguish fires within the remit of the legislative requirement.

It is not the role of the Fire and Rescue Authority to assist in the quelling of disturbances,

riots or other similar type of incidents within the confines of places of lawful detention, nor

must Fire and Rescue Authority equipment be used for this purpose, either by fire and

rescue personnel or other on-site staff.

The hazards to fire and rescue personnel relate to:

a) Restricted access

All places of lawful detention have, by design, restricted access and egress. This may

pose a number of difficulties to personnel when attempting to deal with fire and rescue

situations. These include:

• limited choice of approach to the incident, eg it may only be possible to

approach a fire from downwind

• restricted appliance movements and rendezvous points

• difficulty and delay in accessing the scene of operations


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Generic Risk Assessment 3.9 – Fighting fires in places of lawful detention6

• difficulty in maintaining a safe access to and egress from the scene of operations

• secure and restricted working environment where large amounts of equipment

may have to be carried to the scene of operations.

b) Behaviour and possible hostilities from Detainees

When dealing with fire incidents within the confines of a prison, or other places of lawfuldetention, the behaviour from detainees can be unpredictable and lead to hostilities

against fire and rescue service personnel. Other types of potential threats from detainees

are:

• further deliberate outbreaks of fire

• ambush and possible hostage taking

• missiles being thrown, eg debris, sharps etc

• verbal threats of violence or intimidation

• physical violence/assault

• dirty protests involving human excrement (biological hazard)

• infection from bodily fluids, needle stick or other sharp injuries.

Security gates and doors

Access to or egress from any part of the premises will be restricted and will require the

assistance and cooperation of authorised on-site staff. Security gates/doors, whether

electronic or manually operated, partition the various parts of the premises to permit the

authorities to isolate areas in situations of unrest or unruly behaviour and to maintain

security and control.

Attention must be drawn to self-locking doors, eg prisons, police stations, court premises,

detention centres etc. DCOL 38/19781 informed Fire and Rescue Authorities of these

doors and identified the concerns posed for personnel safety. The doors are designed to

self-lock on being closed and will require familiarisation training and instruction for

personnel who have places of lawful detention within their area of responsibility –

including ‘cross border’ risks.

Consideration must be made by the Incident Commander of the terminology used by

other agencies to avoid confusion; for example, prison staff refer to floor levels withground floor being referred to as Floor 1.

Roofs, walls and other structures may be fitted with razor wire which is intended to

prevent escape or unauthorised access.

Communication

Due to the construction and layout of places of lawful detention, communication may be

difficult. Fireground communications must be tested for effectiveness as part of any

1 HM Prisons: Self-looking cell doors ‘Dear Chief Executive Letter’ 38/1978 Home Office Guidance 67/1978 issued7 November 1978


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planning processes and at a fire and rescue incident. Alternative communication methods

may be required and all personnel must be familiar with the evacuation procedure. The

use of available close circuit television must be considered at the outset of operations as it

can provide valuable information in respect of fire location and situation awareness.

Key control measuresPlanning

Planning is the key to enhancing the safety of firefighters and others likely to be affected

by Fire and Rescue Authority operations. Each Fire and Rescue Authority’s integrated risk

management plan will set standards and identify the resources required to ensure safe

systems of work are maintained.

Fire and Rescue Authorities must assess the hazards and risks in their area relating to this

generic risk assessment. The assessment must include other Authority’s areas where

‘cross border’ arrangements make this appropriate.

Site-specific plans must be considered for locations where the hazards and risks are

significant and plans must take into account and specify any variation from the normal

operational capability of personnel, appliances and equipment. In particular, recognition

must be given to the physical and psychological pressures that an operational incident

may apply to fire and rescue personnel.

Site specific plans must include:

• levels of response

• relevant standard operating procedures

• tactical considerations, including rendezvous points, appliance marshaling areas

and access points

• identification and, where necessary, the formal notification to person(s)

responsible for the site of any Fire and Rescue Authority operational limitations.

Planning is underpinned by information gathering, much of which will be gained through

inspections or visits by fire and rescue personnel, for example, those covered by section

7(2)d and 9(3)d of the Fire and Rescue Services Act 2004.

Information must also be gathered and used to review safe systems of work from sources

both within and outside the Fire and Rescue Authority, including:

• incident de-briefs

• health and safety events

• local authorities

• local resilience forums.

Involving others in planning is an effective way to build good working relations with

partner agencies and other interested parties, such as site owners.


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Fire and Rescue Authorities must ensure that systems are in place to record and

regularly review risk information and to ensure that new risks are identified and

recorded as soon as practicable.

Fire and Rescue Authorities must ensure that the information gathered is treated as

confidential, unless disclosure is made in the course of duty or is required for legal

reasons.

Fire and Rescue Authorities must consider the benefits of using consistent systems

and formats to record information from all sources. Consideration must also be

given to how timely access will be provided to information to support operational

decision-making.

Information needs will vary in proportion to the size and nature of the incident and

the category of the establishment’s detainees. The capacity of fire and rescue

personnel to assimilate information will vary in relation to the complexity of the

incident. Therefore, arrangements may need to be flexible and be based on more

than one system which may be available, control of the different systems will need

to be scrutinized by the Incident Commander.

Operational risk assessments for places of lawful detention must be as

comprehensive and detailed as possible. As layout will vary significantly from one

establishment to another, it is important and necessary for the details of each

operational plan to be determined by the Fire and Rescue Authority with regards to

local circumstances and after full consultation with the relevant authority.

The operational plan must be evaluated and refined by training and, wherever

possible, joint exercises involving the place of lawful detention and those fire crewsmost likely to attend any fire or other type of incident. It is imperative that Fire and

Rescue Authorities are familiar with the provision of firefighting facilities within the

confines of the establishment, particularly the location of water supplies.

Arrangements must be made with the relevant authority for agreed access to

secure areas in any part of the establishment, including individual cells. Fireground

communications must be tested for effectiveness within the confines the

establishment. Fire and rescue, police and prison personnel or other employees

must be familiar with agreed evacuation signals.

Competence and training

When formulating a competence and training strategy the Fire and Rescue Authority must

consider the following points:

• Ensure specific risk assessments for this incident type are suitable and sufficient

and that those tasked with carrying out the assessment and developing

procedures are competent to do so

• Fire and Rescue Authorities must ensure their personnel are adequately trained

to deal with the hazards and risks associated with operational incidents involving

secure accommodation and places of lawful detention


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• The level and nature of training undertaken must be shaped by informed training

needs analysis that takes account of Fire and Rescue Authority guidance on the

competency framework, National Occupational Standards and any individual

training needs.

Specific training requirements for incidents involving places of lawful detention will include:

• dissemination of the standard operating procedure and site-specific operational

tactical plans

• site-specific tactical exercises must be undertaken with other agencies or staff

likely to assist at an actual incident.

Training outcomes must be evaluated to ensure that the training provided is effective,

current and meets defined operational needs as determined by the Fire and Rescue

Authority’s integrated risk management plan.

Fire and Rescue Authorities must formulate a regular programme of training sessions and

operational risk assessments. This will permit firefighters to familiarise themselves with fireappliance holding points, vehicular access to and within the grounds of the place of lawful

detention, and to check that there are no obstructions to water supplies for firefighting

purposes.

Firefighters must be familiar with the types of locks found in prisons and other places of

lawful detention. They must know how to operate these locks and how to keep them in

the open or slipped position in order to prevent personnel from being accidentally locked

in cellular accommodation areas during firefighting operations.

It is equally important that firefighters must be familiar with operating the locking

mechanisms whilst wearing full firefighting personal protective equipment, including

gloves.

All fire and rescue personnel must be aware, through familiarisation training, of the

security implications and protocols concerning the issue, use and safe return of keys

within a prison or other place of lawful detention.

Proceeding to an incident

Under normal circumstances appliances responding to incidents in places of lawful

detention will proceed with blue lights and audible warning devices when necessary. On

the approach to a premises, and whilst manoeuvring within the precincts of the

establishment both visual and audible warning devices must be cancelled.

Command and control

The Incident Commander must follow the principles of the current national incident

command system.

Prior to committing personnel into any hazard area, the Incident Commander must take

account of the actual information available regarding the incident at the time. This will

assist them in making effective operational decisions in what are recognised assometimes dangerous, fast moving and emotionally charged environments.


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A thorough safety brief prior to deployment of all personnel who are required to be within

the hazard zone must be carried out. Crews must be reminded of their role and any

particular risks to their safety, eg violence, missiles etc.

All personnel must be briefed on detainee profiles, specific risks of violence, the locations

of vulnerable detainees, risk of infection from dirty protests, bodily fluids etc and

contingency plans, including areas for safe evacuation and decontamination.

Communication of new or changed risks must continue throughout the incident.

Utilising an inter-agency liaison officer and other sources of intelligence can assist the

Incident Commander by advising on multi-agency tactics, designated safe routes,

prioritisation of incidents etc.

It is essential that the Incident Commander maintain close liaison with the designated

senior officer of the on-site authority throughout the time of Fire Authority involvement.

Appliances and equipment must be kept at a safe distance and in a secure area so as notto fall under the control of detainees. A ‘safe distance’ will depend upon the

circumstances and must be decided after discussion with the relevant authority.

To ensure that all personnel are kept fully acquainted and briefed of all developments and

to avoid any delays in response, a forward control point must be established as fireground

control and will be responsible for co-ordinating all fire and rescue activities at the incident

scene.

A rendezvous point/marshalling point for appliances must be agreed between the Fire

and Rescue Authority and on-site authority.

As an integral part of operations all appliances and crews must establish and maintain

radio contact with fireground control.

In the case of a fire in a prison, a senior Fire Authority officer must assume the role of ‘fire

liaison officer’ and proceed to the prison incident command room where they will be part

of the corporate incident command team. This will ensure full liaison and discussion

between the Police Service and the on-site authority regarding the Fire Authority’s role.

Fire and rescue personnel must be aware that in a prison establishment, the person in

charge of the establishment will assume the role of Prison Service Incident Commander

and will remain in overall control throughout the duration of the incident. The fire liaison

officer will act as the link between the Prison Service Incident Commander and the Fire

and Rescue Authority Incident Commander, who will remain in charge of all aspects of fire

and rescue operations.

Local liaison must ensure that sufficient on-site staff are available to protect and guide fire

crews, therefore, if necessary, they can unlock gates/doors and provide information

regarding cell layout etc. Fire and rescue personnel must never work unaccompanied in a

secure environment unless concerns for the safety of on-site staff are put at risk (eg

smoke-logged areas or where other respiratory concerns are identified).


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Fire and Rescue Authority equipment must not be loaned to other personnel for any

purpose.

Fire crews must not be permitted to enter and operate in situations where there is an

unacceptable risk of physical abuse by detainees. Fire Authority Incident Commanders

must ensure that areas, which fire crews, are required enter, have previously been

secured by the onsite authority or by the police.

Safety Officer(s)

The early appointment of one or more Safety Off icer(s) will assist in supporting a tactical

plan to address risks so they can be eliminated or reduced to an acceptable level.

Those undertaking the Safety Off icer role must:

• be competent to perform the role

• ensure personnel are wearing appropriate personal protective equipment

• monitor the physical condition of personnel and/or general or specific safety

conditions at the incident, in accordance with their brief

• take any urgent corrective action required to ensure safety of personnel

• update the Incident Commander or senior safety officer regarding any change in

circumstances

• not be engaged in any other aspect of operations, unless this is required to deal

with a risk critical situation.

Safety Officers must be adequately briefed regarding the nature of the incident prior to

undertaking the task and have clear guidance as to their allocated task and the current

prevailing hazards and risks. The Incident Commander must confirm that the Safety

Officer understands:

• their role and area of responsibility

• allocated tasks

• lines of communication

• evacuation procedures.

The activities of a Safety Officer can be carried out by any of the Fire and Rescue Authority roles, but the complexity of the task, size of the incident and scope of

responsibility must be considered by the Incident Commander when determining the

supervisory level required.

Safety Officers must wear nationally recognised identification to indicate they are

undertaking the Safety Officer role.

Fire and Rescue Authorities must ensure that training and other measures (such as

aide-memoires) are in place and available to support those staff liable to undertake this

role.


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Evacuation signal

Fire and Rescue Authorities and the Prison Service use ACME Thunder Whistles. In the

case of Fire and Rescue Authorities, short blasts on the whistle indicate that the area

must be evacuated. However, in the case of the Prison Service, this would indicate

aprison employee required assistance.

To avoid confusion between the signals, Fire and Rescue Authorities must liaise locally

with the prison authority to discuss and identify an alternative assistance signal for prison

staff during incidents where the Fire Authority is involved. This must be agreed during joint

training exercises; familiarisation visits etc and written into local procedures for dealing

with incidents within places of lawful detention.

Safety of firefighters

The safety of firefighters must be considered a major priority at any incident in a place of

lawful detention. Fire and rescue Incident Commanders must not hesitate to withdraw

crews if their personal safety is put at risk.

Fire crews must be briefed in the method of unlocking secure doors/gates. On no

account must doors or gates be locked behind fire crews during an operational incident

unless this is to secure safety. Secure and safe egress must be maintained at all times

during the operational activity.

Under no circumstances must fire and rescue personnel be left to work alone in places of

lawful detention. Firefighters must work in teams of a minimum of two, preferably

accompanied by a designated member of on-site staff.

Consideration must be given to crews reporting back to the Incident Commander or entrycontrol officer at a greater frequency than is standard if issues dictate greater

communication levels are required.

When searching or firefighting in a cell, one member of the crew must remain at the cell

door to prevent it from closing. Failure to do so could result in a crew member being

trapped inside should the door be closed inadvertently by other crews or deliberately by a

detainee.

Personal protective equipment

Fire and Rescue Authorities must ensure that any personal protective equipment providedis fit for purpose and meets all required safety standards. When choosing suitable

protective garments, the standard of clothing worn beneath the specialist personal

protective equipment must also be taken into account. Consideration must also be given

to the selection of suitable sizes and gender specific requirements.

All personnel must use appropriate levels of service provided personal protective

equipment and respiratory protection equipment as determined by the safe system of

work.


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Post incident

The following measures must be considered to help eliminate or remove risks after an

incident, as appropriate to the nature and scale of the incident:

• Any safety events; personal injuries, exposure to hazardous substances

or near-misses must be recorded, investigated and reported in line with

legislative requirements such as Reporting of Injuries, Diseases and Dangerous

Occurrences Regulations 1995, etc

• Arrangements must be in place to either remove all contamination from personal

protective equipment or to ensure it’s safe and appropriate disposal and to

check that the equipment maintains the agreed levels of integrity and protection

for the wearer throughout its lifecycle

• As appropriate, occupational health support and surveillance follow-up

• Conduct de-briefing to identify and record any ‘lessons learned’ from the

incident. De-briefs will range in complexity and formality proportionate to thescale of the incident and inline with individual Fire and Rescue Authority’s

procedures

• Consider any changes required to safe systems of work, appliances or

equipment in the light of any lessons learned from de-briefs or from safety events

• Consider the need to review existing information held on a premises or location,

or the need to add a new premises or location into future planning eg by adding

to a visit or inspection programme

• Consider the need to refer to other agencies any concerns or issues that are

identified at an incident. When sharing information, due regard must be paid

to the need for confidentiality and the legal requirements arising from the Data

Protection Act

• Staff must be supported and monitored to identify whether they are experiencing

any adverse effects and to check whether they would benefit from accessing

counselling and support services

• Consideration must be given to arranging for staff to make a contemporaneous

written record of their actions. This information may be used to assist in any

internal or external investigations or enquiries that follow any incident, eg the

Coroner’s Court, police / public enquiry, etc.


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Technical references

1 ‘Dear Chief Officer letter’, 7/1991 – D Fire Standards in prison establishments: principles

of design and standards of construction (the design guide) : Fire Precautions Manual for

Prisons

2 HM Prisons: Self-locking cell doors ‘Dear Chief Officer Letter’ 38/1978 and Home Office

guidance 67/1978 issued on the 7 November 1978

3 ‘Dear Chief Officer Letter’ 5/1988 – E Fires in prison establishments, Home Office, 5 August1988 and ‘Dear Firemaster Letter’ 7/1992 – L

Home Office Technical Bulletin 1/1997

4 Decontamination procedures as identified in Manual of Firemanship book, 12, Part 2 and

the protection against blood-borne infections in the workplace: HIV and Hepatitis, Advisory

Committee on Dangerous Pathogens reports, HMSO, Crown copyright 1996. Third

impression 1996

5 Integrated Personal Development System (IPDS) and Emergency Fire Service Role Maps

6 Building Disaster Assessment Group – Key research Findings Circular 55/2004

The Regulatory Reform (Fire Safety) Order 2005

7 Prison Act 1952 – Lawful Detention


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S E

C T I O N

2

S u

m m a r y o f G e n e r i c

R i s k A s s e s s m e n t

3 . 9

F i g

h t i n g f i r e s i n p l a c e s o f l a w f u l d e t e n t i o n

T a s k – P r e - i n c i d e n t

R e

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H

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P e r s o n s a t r i s

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p p r o a c h

R

e s t r i c t e d a c c e s s

N o t a c h i e

v i n g

s u c c e s s f u l o u t c o m e

D e l a y i n a

p p l y i n g

fi r e fi g h t i n g a n d r e s c u e

t e c h n i q u e

s

D e t a i n e e s

E m p l o y e e s

F i r e a n d r e s c u e

p e r s o n n e l

P r e v e n t i o n

•

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o r g a n i s e r s a n d o t h e r e m e r g e n c y

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•

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r d o p e r a t i n g

p r o c e d u r e f o r f i r e s i n p l a c e s o f

l a w f u l d e t e n t i o n


17/22


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b e c o m p e t e n t a t g a t h e r i n g r e l e v a n t

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•

S i t u a t i o n a l a w a r e n e s s .


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T a s k – I n i t i a l s t a g e s o f t h e

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p e r s o n n e l

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L i a i s o n w i t h a u t h o r i t y

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u i p m e n t

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u i p m e n t

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f r o m b r e a t h i n g a p p a r a t u s

o p e r a t i o n s

A l l p e r s o n n e l u n d e r f u l l s u p e r v i s i o n






d e t e n t i o n .


19/22


T a s k – A s t h e i n c i d e n t d e

v e l o p s

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f .

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a z a r d

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C o n t i n u o u s r a d i o c o n t a c t

b e t w e e n c r e w s a n d

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C o n t i n u o u s l i a i s o n w i t h r e l e v a n t a u t h o r i t y

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f t e a m s o f t w o

S e c u r e r o u t e .


20/22


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f .

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o f l a w f u l d e t e n t i o n

T o x i c o r b i o l o g i c a l

h

a z a r d s

I n

f e c t i o u s d i s e a s e s

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y p o d e r m i c n e e d l e s

P

h y s i c a l a s s a u l t

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e m p l o y e e s

a n d o t h e r s


p e r s o n n e l

V a c c i n a t i o n p o l i c y , h e p a t i t

i s B ,

t e t a n u s e t c

P l a n n i n g


u i p m e n t

P r i s o n / o t h e r e m p l o y e e e s

c o r t a t a l l t i m e s

a p a r t f r o m d u r i n g b r e a t h i n

g a p p a r a t u s

o p e r a t i o n s

A l l p e r s o n n e l u n d e r f u l l s u p e r v i s i o n






d e t e n t i o n

S e c u r e r o u t e

B r e a t h i n g a p p a r a t u s i f r i s k

s o f a i r b o r n e

b i o l o g i c a l h a z a r d s a r e s u s

p e c t e d o r p r e s e n t

M a i n t e n a n c e o f s e c u r e a c

c e s s a n d e g r e s s .

D

e t a i n e e s w h o d o n o t

h

a v e E n g l i s h a s a fi r s t

l a

n g u a g e

I n j u r i e s t o

d e t a i n e e s

f r o m n o t u n d e r s t a n d i n g

i n s t r u c t i o n s g i v e n i n

E n g l i s h

D e t a i n e e s


p e r s o n n e l

U s e o f p r o m p t c a r d s f o r v a r i o u s l a n g u a g e s

I n t e r p r e t e r i f a v a i l a b l e

U s e o f l o c a l r e s o u r c e s i f p

o s s i b l e .


21/22


T a s k – P o s t I n c i d e n t

R e

f .

N o

.

A c t i v i t y

H

a z a r d

R i s k


k


4

E m e r g e n c y e v a c u a t i o n

C

o n f u s i o n w i t h p r i s o n

a

s s i s t a n c e s i g n a l s

R i s k o f i n j u r y t o fi r e

fi g h t i n g p e r s o n n e l a n d

o t h e r s

E m p l o y e e s


p e r s o n n e l

C o n t i n u o u s r a d i o c o n t a c t

b e t w e e n c r e w s a n d

w i t h F i r e A u t h o r i t y I n c i d e n t C o m m a n d e r

O t h e r l o c a l l y a g r e e d p r o c e

d u r e s w i t h t h e

a u t h o r i t y .


22/22

final gra 3 9 places of lawful detention

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