FULL EQUALITY IMPACT ASSESSMENT/EQUALITY ANALYSIS
FORM HRFEIA
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Name of Policy, Decision, Strategy, Service, Function, Other (Please indicate)
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Emergency Cover Review – Equality Analysis of the impact on staff |
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Name Lead Officer Job Designation
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Liz Sandiford |
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Department
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Human Resources |
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E-Mail Address
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ElizabethSandiford@lancsfirerescueservice.org.uk
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Date of Assessment
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01 December, 2022 |
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Assessors:
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Mike Burnitt – Senior Partner McKenzie LLP
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We carry out Full Equality Impact Assessments (EIA) where we are unsure or know that the policy/decision will have an impact on an equality group or further to completing an Initial analysis negative impacts have been identified. The EIA should be undertaken/started at the beginning of the policy development process before any decision is made.
It will be updated through the decision making/policy development process until the conclusion of the decision making/ policy development process and then it is completed.
External Input:
To ensure this Equality Impact Assessment was completed with maximum objectivity and to the correct legal and statutory standards, LFRS appointed an external Equality, Diversity and Inclusion (EDI) consultancy – McKenzie LLP, to complete this assessment.
Formed in 1996, McKenzie are one of the leading UK EDI consultancies having previously worked extensively within the UK blue light / emergency sector including the NFCC and a large number of UK fire and rescue services.
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To undertake a strategic operational review (known as the Emergency Cover Review) with the aim of ensuring Lancashire Fire and Rescue Service (LFRS) is suitably resourced (people and equipment) to deal with the current and changing operational requirements and challenges of the communities of Lancashire.
The review has involved a comprehensive assessment of the location and types of resources in place compared to current incident levels and identified community risks across the county of Lancashire. This has also included an assessment, at an individual station level, of the current and changing volumes / types of incidents reported to the service and the availability of LFRS resources to respond accordingly.
A review of people resources has involved an examination and a change to some of the existing rostering / shift systems of operational staff within some LFRS stations. The proposed change is due to be realised using a phased implementation plan during the years 2023 – 2025 respectively.
It is important to note that the proposed changes are to ensure more effective deployment of resources to risk and are not a cost cutting exercise. If the proposed changes are actioned as planned, it will result in the appointment of 8 additional wholetime firefighters in LFRS.
The aim of this document is to communicate the findings of an Equality Impact Assessment examining the potential impacts this change may have on LFRS employees affected by the proposals.
Finally, please note any implementation of the Flexible Wholetime system would be with the agreement of the relevant representative bodies.
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Current Operational Crewing Arrangements in LFRS:
LFRS has 39 fire stations across the county which all operate using one or more of the following four duty systems:
Whole Time 2/2/4:
The most ‘traditional’ rostering system where firefighters work for two days, two nights and then have four days off. This typically involves working a standard 42-hour week on a rota system of two 10-hour day shifts followed by two 14-hour night shifts providing 24-hour cover from a fire station.
Flexible Day Crewing:
Fire stations are staffed by wholetime firefighters who provide cover by being physically present at the fire station during the day and remain ‘on call’ to respond to evening / night-time incidents by returning to the station from their home address. They are required to live within 5 minutes of the station.
Day Crewing Plus:
Fire stations are staffed by wholetime firefighters who provide cover by being physically present at the fire station during the day and remain ‘on call’ to respond to evening / night-time incidents by staying in purpose-built accommodation on fire station grounds to provide a rapid response at night. Employees who work this shift system receive an additional 32% pensionable paid allowance to reflect the extra commitments of being on call in the evening and being away from home.
On Call:
On Call firefighters carry an alerter, they provide a pre-determined level of cover each week and respond to emergencies in their communities from home or from work.
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Current Operational Crewing Arrangements in LFRS:
In addition to the four duty systems referred to above, LFRS is currently proposing to introduce a new system known as Flexible Whole Time which is described below.
Flexible Whole Time:
The system complies with national terms and conditions, it is similar to the Whole Time 2/2/4 arrangement (described overleaf) but functions using ‘Self-rostering’. Further to feedback during the consultation the proposals were amended to align shift start and finish times with Wholetime 224 which reduced the hours of the day shift as requested by staff. ‘Self-rostering’ is a system based on the principles of team-based working where staff plan out their own shifts to provide as much choice as possible while ensuring that required crewing levels and appliance availability is maintained. The rota is agreed at local level between those working the duty system and their managers - including the Station Manager responsible for the unit.
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Proposed Changes to Operational Crewing Arrangements in LFRS:
As a result of the findings of the Emergency Cover Review, the following changes are proposed to the establishment / duty arrangements at 9 DCP stations.
This has the potential to affect 78 people (accurate as of time of analysis), this includes staff who are both permanently and temporarily contracted to the DCP shift system. The numbers of staff affected as detailed in the table is based on the total number of staff per station who may either change duty system or location as a result of the changes at their current location.
For example, Darwen has 6 permanent DCP post holders that will be unaffected by the change. However, the remaining 8 temporary employees may be affected if these posts are required for displaced permanent employees who currently work the DCP shift system.
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The main aims/objectives of this policy[2] are: |
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Proposed Changes to Wholetime 224 Stations
As a result of the findings of the Emergency Cover Review, the following changes are proposed to the establishment / duty arrangements at 3 Wholetime 224 stations as detailed in the table.
This has the potential to affect 104 people in the event of Flexible Wholetime being introduced which affects all employees on those stations.
If the Flexible Wholetime Shift System does not get introduced, the duty system will remain as Wholetime 224 with a reduction of 4 Firefighters per station, this will result in a lower number of people being affected.
Currently there is an over establishment of people employed at Lancaster, Hyndburn and South Shore Stations, this is to manage workforce numbers and ensure there are suitably qualified staff to fill vacancies as people retire. Any reductions in staffing establishment will affect temporary staff who form the over establishment.
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The main aims/objectives of this policy[3] are: (continued) |
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Changes to Flexible Day Crewing Stations
As a result of the findings of the Emergency Cover Review, it is proposed to reduce the number of staff employed within Flexible Day Crewing Stations by 1 person. The reduction in staffing on Flexible Day Crewing stations will be through voluntary movements or retirements.
Notes on Proposed Implementation:
1: The Service commenced a consultation process from 22nd July 2022 to the 14th October 2022. The aim of the consultation was to consult with local communities and staff in respect of the proposals shown in the previous three tables. As a result of this consultation, several original proposals were duly amended to produce the final proposals listed in this document.
2: Where a decrease in resourcing is required at a particular station, LFRS aims to achieve this decrease by either voluntary transfer of staff from one station to another or via non replacement of leavers (natural turnover). No compulsory redundancies are planned as part of this process.
3: The initial proposal for the introduction of the proposed Flexible Whole Time (FWT) systems was revised as a result of feedback received during the consultation process.
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The main aims/objectives of this policy[4] are: (continued) |
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Overall Potential Positive/ Negative People Impact where duty arrangements are changed:
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Is the policy or decision new or under review or existing[5]
New/Proposed
Modified/Reviewed/Updated/Adapted
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The main intended people or groups that will be most affected by this policy are:
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Operational (‘Grey Book’) employees
Employees who may be adversely affected:
A total 182 permanent and temporary operational or ‘Grey Book’ employees are identified as being potentially affected by the implementation of this review, (this excludes the changes to FDC which will be implemented via natural turnover). (Source LFRS Human Resources Department.)
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2. Findings/Evidence
Equality Profiles are based on temporary and permanent staff based at 224 and DCP stations affected: (Source LFRS Human Resources Department)
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2.1 Equality Profiles Ethnicity
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Affected Staff: Ethnicity: Total LFRS Grey Book Staff:
Analysis and Conclusion: 2% of employees who could be adversely affected are from a minority ethnic background compared to a total of 3% (operational) staff from a minority ethnic background overall. We therefore conclude there is no evidence to suggest that this activity disproportionally affects employees on the grounds of their minority ethnicity or minority nationality.
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2.2 Age
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Staff Age Profile:
Analysis and Conclusion:
A slightly disproportionate impact is noted in the age bands 35 – 39 where the percentage of potentially affected employees is 27%. This is higher than the overall LFRS profile in this age banding as illustrated in the graph above.
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2. Findings/Evidence
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2.3 Gender
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Affected Staff: Sex: Total LFRS Grey Book Staff:
Analysis and Conclusion:
7% of employees who could be adversely affected are women compared to a total of 8% women (operational) staff in LFRS overall. We therefore conclude there is no evidence to suggest that this activity disproportionally affects employees on the grounds of their Sex.
Whilst it is noted that 95% of people who could be negatively affected are men, 92% of all ‘grey book’ staff in LFRS are men - indicating a broadly proportionate impact on employees.
Profiling information relating to other ‘Protected Characteristics’ (as defined by The Equality Act 2010) e.g. Sexual Orientation, Pregnancy / Maternity, Marriage Civil Partnerships etc. was not utilised as part of this assessment.
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Findings/Evidence: The following information/data has been considered in developing this policy/decision (This may include census data, the results of any consultation with community groups or representative bodies.)
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What did you do/consider, list any consultation with employees, service users, unions, members of the public
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What did it say ? |
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Pearson Insight were commissioned to undertake consultation which commenced 22 July 2022 for 12 weeks and closed on the 14th October 2022.
Internal consultation sessions were held for all LFRS staff, 27 engagement sessions were undertaken with firefighters plus additional sessions with LFRS managers.
The proposals were circulated to LFRS internal Employee Voice groups comprising men and women, members of staff who are LGBTQ+ and staff of different ethnicities.
Use of social media and “In the know” was used to target audiences as well as local libraries.
Three methods of feeding back into the Service were utilised:
Online public survey Online staff survey via consultation email in box
General Comments:
Representative bodies feedback
The permanent staffing profile of Stations affected by the transition from DCP to Flexible Wholetime or DCP
Fire Authority Member.
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234 responses from members of staff were received (21% response rate).
40% of staff agreed the proposals represented value for money 29% disagreed.
46% of staff agreed with the statement that the Emergency Cover Review (ECR) reflected the most effective and efficient use of resources for the whole of Lancashire.
43% of staff agreed with the proposal to introduce flexible wholetime whilst 34% disagreed.
Firefighters were supportive of the principle of self-rostering, but 64% disagreed with the length of the proposed shifts, the main comments from staff related to shift patterns not being family-friendly, concerns about honouring pre-booked leave and the impact proposed shift patterns could have on staff wellbeing.
Further to this specific feedback and to mitigate the impact of the proposal, the proposed shift systems have now been amended and the working arrangements are now the same as existing the shift Wholetime shift systems i.e. 8.00am to 6.00pm and 6.00pm to 8.00am.
Of the 37 respondents currently employed under Day Crewing Plus (DCP), 70% disagreed with the proposals for St Annes station and 62% disagreed with the plans for Penwortham station. Three quarters of these staff would prefer to work the day crewing plus system at another location. To mitigate this impact, members of staff who are permanently assigned to DCP will have the option to continue working it at a different location.
One female employee was enthusiastic about the idea of self-rostering to accommodate childcare under the proposed Flexible Wholetime system whilst other members of staff preferred the fixed working pattern.
No members of staff who identified as BME responded to the consultation.
Feedback from the 18 to 24 age group:
No issues were identified from an equality perspective.
Feedback from the 25 to 34 age group:
Some respondents liked the flexibility of the proposed Flexible Wholetime system. Others stated they preferred fixed shifts. Some didn’t like the proposed longer shifts, this has been mitigated via changing the proposal to a shorter day shift. A small number of individuals referred to the loss of the DCP allowance and travelling, this has been mitigated as those members of staff who are permanently assigned to DCP will have the option to continue working it, albeit potentially at a different location. The cost of housing St Annes and Penwortham was raised as an issue, a couple of options have been proposed and further consultation with employees and Trade Unions will take place.
Feedback from the 35 to 44 age group:
Similar to the above, though additional comments were made that it was difficult to assess the Flexible Wholetime shift system without having first worked it. A trial will take place of the new Flexible Wholetime shift system to ensure it is fit for purpose for both employees and LFRS.
Feedback from the 45 to 54 age group:
Also similar to the above, though additional comments were made that for members of staff wishing to remain on DCP they may have to travel further. It is anticipated that members of staff who are permanently assigned to DCP will have the option to continue working that shift potentially at a different location, alternatively for those where reduced travel is a priority they may opt to remain at their current station.
Feedback from the 55 to 64 age group:
As above, no specific equality issues were raised.
Feedback from the Trade Unions
FBU The FBU welcomes the total increased numbers of frontline firefighters and the reduction of the DCP system. They made several comments in relation to the proposals but did not identify any specific equality issues arising from the proposals. The FBU would not agree to working back-to-back shifts and this option has been dropped from the proposals. Consultation in relation to the creation of the new Flexible Wholetime shift system is still ongoing.
FOA Overall FOA support the proposals, suggested further DCP stations should be kept open and suggested Penwortham should remain DCP, several comments made in relation to the proposals but did not identify any equality issues. Further to the review of DCP and the ECR, deployment to DCP stations has been on a temporary basis. All relevant members of staff have been made fully aware that they have been temporarily located to a DCP station pending review. The consultation did cover permanent, temporary staff and those affected by the change from 224 to flexible wholetime.
An issue for consideration is the requirement to live within 5 mins of a station where FDC is to be introduced and the population of that area lacks diversity. However, the Service recruits from a diverse pool of people from across the Country which addresses this issue. This matter would need to be considered in the event of a change to recruitment strategy. |
3. Equality Impact
Using the table below, please indicate whether the policy/strategy/decision has a positive, negative or no impact from an equality perspective on any of the protected equality groups listed below.
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Equality
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Positive Impact It could benefit |
Negative Impact It could disadvantage |
Reason why there is a positive and negative impact and any mitigating actions already in place to reduce any negative impact |
No Impact |
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Age People of all ages
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x |
x |
The analysis has identified that the band of people aged 35 – 39 years is slightly disproportionately impacted as compared to the broader Service workforce profile. On this basis the risk of age discrimination cannot wholly be discounted. However, this group will be treated in the same way as all other age groups in terms of the implementation of the ECR.
As part of the implementation a detailed age analysis of employees will be developed as part of the delivery of the ECR.
In respect of potential positive Age-related impact, there is some evidence of reduced tolerance to shift work among older individuals (Folkard, 2009) and there may therefore be some positive health benefits of removing Day Crewing Plus rostering from older employees. |
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Disability Physical Disability Learning Disability Learning Difficulty Mental Health
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x |
x |
It is concluded that the imposition of significant changes to a firefighter’s working pattern, location or pay could result in increased anxiety in a financially challenging external environment, several measures will be implemented to mitigate this risk as detailed in the action plan.
It is noted that further to analysis LFRS can allow existing permanent wholetime firefighters who are permanently contracted to the DCP system to remain on that system if they so wish.
The previous LFRS managerial review of DCP identified a potential increased risk of mental strain among some employees. Removal of the DCP system may therefore have improved outcomes in respect of mental health. The DCP system also involves extended periods of time away from the home environment. This has been cited as a factor for higher mental strain - particularly for families (Ref LFRS DCP Review 26 October 2021) |
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Gender Identity/ Gender Reassignment
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It is concluded there is no evidence to suggest that the implementation of this activity may impact directly / indirectly on people who are proposing to undergo, are undergoing or who have undergone Gender Reassignment and therefore no further recommendations are made in this area. |
x |
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Pregnancy and Maternity
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All LFRS operational employees who are pregnant undergo workplace risk assessments and are allocated modified duties during periods of pregnancy to protect their unborn child.
It is concluded there is no evidence to suggest that this activity may impact directly / indirectly on employees who are pregnant / on maternity leave and therefore there are no further recommendations in this area. |
x |
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Equality
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Positive Impact It could benefit |
Negative Impact It could disadvantage |
Reason why there is a positive and negative impact and any mitigating actions already in place to reduce any negative impact |
No Impact |
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Race Ethnicity Nationality
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As previously stated, a small number of minority ethnicity employees across two stations are at risk from a negative impact, from the implementation of this activity. Of these an even smaller number are employed within a station that is retaining Day Crewing Plus (therefore there is minimal impact) and the other small number of people work in a station that is currently operating under Whole Time and may be required to change to Flexible Whole Time (Also minimal impact).
It is therefore concluded that the potential risk of discrimination / disadvantage to minority ethnicity employees affected by the implementation of the ECR as being low / very low. |
x |
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Belief or Religion
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x |
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There is no evidence to indicate that the implementation of this activity may adversely impact directly / indirectly on people of different faiths or none.
The proposed system of self-rostering could potentially allow employees more flexibility in respect of organising their work commitments to accommodate any personal religious commitments. |
x |
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Sex Men/Women
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X
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A total of 12 (10 of which are based at the 224 stations and will be unaffected if the 224 stations remain) women are potentially affected by the implementation of this activity.
Statistically, there is no evidence at either an organisational or individual station level to indicate any risks of disproportionality in respect of a person’s Sex.
During recent consultation events, the proposed length of new days shifts was identified as not being ‘Family Friendly’. This has subsequently been removed from the ECR proposals and the start/finish times are now aligned to the existing 2-2-4 duty system.
Also, during consultation, some employees stated a preference for flexible working to fit with family life whereas others stated their preferences to fixed working shifts indicating an overall ‘mix’ of needs. This ‘mix’ could be potentially accommodated by the new self-rostering systems.
Day Crewing Plus rostering (Particularly spending nights away from home) has previously been cited by employee forums as a principal reason why women with caring or parenting responsibilities are underrepresented within stations operating this type of rostering. |
x |
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Sexual Orientation Lesbian, Gay and bisexual people
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There is no evidence to indicate that the implementation of this activity may adversely impact directly / indirectly on people on the grounds of their Sexual Orientation.
No further recommendations are therefore made.
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x |
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Marriage and Civil Partnership (employment only) |
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There is no evidence to indicate that the implementation of this activity may adversely impact directly / indirectly on people on the grounds of their Marriage and Civil Partnership status.
No further recommendations are therefore made.
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x |
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Other groups who are not protected under the Equality Act Examples include social economic factors (i.e. poverty, isolation), unemployment, homelessness, rurality, health inequalities any other disadvantage. |
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x |
Socio economic:
§ Loss of 32% of salary allowance: Average of £10,888 p/a, (applicable to those who move to FWT/224. Those who change to FDC will be impacted via a lower percentage due to them qualifying for the FDC allowances and remuneration). § Change to pension contributions which would no longer be based on DCP allowance affecting those who move off DCP only. § Requirement to live within 5 minutes of the fire station affecting those who move to FDC only. § Risk of decreased emotional and potential financial wellbeing further to the implementation of change.
Actions to mitigate these challenges are detailed later in the Action Plan.
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Contributes to equality of opportunity |
x |
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If implemented as planned, the implementation of Flexible Whole-Time rostering should give people the same opportunity / chance to work around their own personal needs and circumstances.
Flexible Whole-Time rostering could also theoretically, allow for more part time working in the service and open up positions to people or groups currently underrepresented in the service. |
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Contributes to fostering good relationships between different groups. |
x |
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Flexible Wholetime would result the disestablishment of smaller Watch Groups and the establishment of one collective group allowing for a greater number of people working with each other facilitating a greater diversity of ideas.
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The decision will be taken in compliance with Human Rights [6] |
Yes |
x
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No |
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4. Outcome of the Equality Impact Assessment: Actions to be taken
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What course of action does the Equality Impact assessment Suggest you take
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Outcome 1 - No major change required
The EIA has not identified any potential discrimination or adverse impact and all opportunities to promote equality have been taken.
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Outcome 2 - Adjust the policy
To remove the negative impact identified in the EIA or to promote better equality.
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x
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Outcome 3 - Continue with the policy despite negative impact – Stop and Think
You need to ensure the Equality Impact Assessment clearly sets out the justification for continuing with it. You should consider whether there are sufficient plans to reduce the negative impact and to monitor impact. Complete the EIA Action Plan.
If you are continuing with the policy despite the negative impact you need to seek guidance from the Head of Human Resources as this shows the EIA demonstrates a significant impact on people with a protected characteristic
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Adjustments - Action Plan
Mitigating Actions to remove any potential negative impact
· The ECR consultation commenced the 22 July 2022, the implementation will take place over 2023 – 2025, on this basis employees will have a significant period to adjust to the changes emotionally and financially.
· All employees affected by the changes will be consulted to identify their preferences.
· The implementation period will allow those employees who permanently work the DCP shift system to remain working that system as part of this ECR. Employees who are currently working the shift system on a temporary basis, have been notified throughout the review that deployment to these stations has been on a temporary basis pending the review and they will be asked for their preferences.
· Where members of staff are compulsory transferred to a different location, they will receive travelling expenses as per LFRS Policy.
· The Service has an Employee Assistance Scheme which provides a range of well being services including financial information and telephone counselling.
· Regular communication has taken place during the consultation period, and this will also take place through the implementation period, so the views of staff can be taking into consideration.
· Regular consultation with the Trade Unions will take place during implementation.
· Moving from DCP to Flexible Wholetime or 224 increases the number of supervisory posts which increases the number of development opportunities.
· Currently exploring short term accommodation solutions for those stations moving to FDC.
· Detailed age analysis of employees to be developed to monitor impact through implementation.