FULL EQUALITY IMPACT ASSESSMENT/EQUALITY ANALYSIS                     

FORM HRFEIA           

Name of Proposal (Policy, Decision, Strategy, Service, Function, Other (Please indicate)	LFRS Safety, Health and Environment (SHE) Policy
Name Lead Officer Job Designation	Martin Fish Head of Safety, Health and Environment
Department	Safety, Health and Environment
Telephone Number E-Mail Address	01772 866904 martinfish@lancsfirerescue.org.uk
Date of Assessment/Analysis	20/08/2024

We carry out Full Equality Impact Assessments (EIA)/analysis where we are unsure or know that the proposal/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 proposal/policy development process before any decision is made.  It will be updated through the decision making/policy development process to inform the decision-making process and then it is completed.

1. Overview

The main aims/objectives of this proposal (project, function, service, policy[1] )

In Lancashire Fire and Rescue Service (LFRS) the health and safety commitments are combined with the environmental and employee wellbeing commitments into one Safety, Health and Environment Policy. This policy is reviewed at least every three years reiterating and reinforcing the principles of our Health and Safety Management System and Environmental Management System.

The SHE Policy itself, is supported by both a Health and Safety and an Environmental Management System. The wider management systems break down aspects of risk within LFRS and detail how as an organisation we are going to establish risk controls and required actions to achieve compliance with the wider safety, health and environmental legislation.

Is the policy or decision new or under review or existing[2]

New/Proposed

Modified/Reviewed/Updated/Adapted

Existing but new EIA

List the groups of people potentially affected by this proposal (e.g. job applicants, employees, customers, members of the public):

Primarily the LFRS SHE Policy impacts on LFRS employees.

The LFRS SHE Policy also requires LFRS to control SHE risks to those outside of the organisation so this policy also applies to anyone else, either individuals or groups of people, whose health and safety may be put at risk by the activities of LFRS.  Manufacturers and suppliers are also required to consider impacts on who they supply items/substances/services to.

2. Findings/Evidence

Findings/Evidence: The following information/data has been considered in developing this proposal (This may include census data, the results of any consultation with community groups or representative bodies.)
What did you do/consider List any consultation with employee voice groups, employees, unions, members of the public. List any methods used to analyse data to understand the impact on people (e.g. work force census profiles, performance, incident data)	What did it say/What are your findings
SHE Department – Professional advice to LFRS	The SHE Department provides professional advice and guidance to LFRS to ensure that the Service remains legally compliant. This review of the SHE Policy is to ensure that it remains current.
Health and Safety Executive / Environmental Regulator – good practice guidance and requirements	When developing the content of the SHE Policy, SHE Department review a wide range of sources, supported by external legislation update Services to ensure that guidance and requirements from the HSE and the Environmental Legislation Regulators are appropriately reflected within the SHE Policy and supporting management systems.
Senior management of LFRS via the HSEAG Meeting	The Service holds a quarterly SHE meeting, referred to as HSEAG which is attended by Senior Managers from all areas of LFRS which scrutinises and ensures the adequacy of LFRS SHE arrangements. Regular updates are taken to the Service HSEAG meeting which identifies new and updated requirements for the Service to comply with.
Lancashire Combined Fire Authority	The LFRS SHE Policy is approved by both the Chief Fire Officer and Chair of the CFA to reflect the governance arrangements of LFRS. The process for approval is taken through the CFA meeting structure to allow open scrutiny of LFRS SHE arrangements. The Chair of the Fire Authority (CFA) and Chief Fire Officer (CFO) has overall responsibility for compliance with the Safety, Health and Environment (SHE) Policy and the Health and Safety and Environmental Management Systems and recognise the impact that a positive health, safety and wellbeing culture can have on the organisation.
Representative Bodies – FBU, UNISON, FOA, FRSA	Working with employee representatives is vital to an effective SHE Management System. LFRS enjoys a good working relationship with the Representative Bodies on SHE issues and work jointly to raise and address areas of concern. Consultation arrangements include reviews of the SHE Policy. The DCFO chairs a formal consultation meeting with the Rep Bodies and the SHE Department ensure that Safety Representatives are updated on changes to policy and the supporting procedural Service Orders.
External Audit Process – BAB External ISO Audits	LFRS holds certification to two international ISO Standards: · ISO 14001:2015 Environmental Management Systems. · ISO 45001:2018 Occupational Health and Safety Management Systems. On an annual basis the Service undergoes an external audit to ensure that it is meeting the requirements of the management systems and the SHE Policy is fit for purpose and compliant. The outcomes of external audit process is fed into the HSEAG meeting and results communicated across the organisation.

3. Equality Impact

Using the table below please indicate what impact will the implementation of this proposal have on people who share characteristics protected by the Equality Act 2010.  

Equality	Positive Impact It could benefit	Negative Impact It could disadvantage	Neutral/ No Impact	Reason why there is a positive and negative impact and any mitigating actions already in place to reduce any negative impact
Age People of all ages	Yes			The SHE policy is designed to provide suitable and sufficient protection to all employees and others who may be affected by LFRS activities.  In this respect the SHE Policy has a positive effect on diverse groups, as it requires statutory risk assessments for all LFRS work activities. Risk assessments must also take account of protection of others who may be impacted by LFRS. LFRS has identified that overall, the Service has an ageing workforce. As part of the SHE Audit and Development plan to ensure that the Service is considering the impact of aging, particularly in the context operational staff being able to meet the physical demands of firefighting tasks and associated mandatory fitness requirements.  Staff are supported to maintain good levels of fitness with access to fitness equipment, ongoing health surveillance and professional support if they experience any difficulties performing the role.  When employing a young person under the age of 18, whether for work, work experience, or as an apprentice, employers have the same responsibilities for their health, safety and welfare as they do for other employees.  LFRS has implemented arrangements under the SHE Policy to safeguard young people when they are in an LFRS workplace.
Disability Physical, Learning Disability   Learning Difficulty Mental Health, Carers of disabled people	Yes			LFRS recruitment and selection processes include medical screening by the LFRS Occupational Health Unit. This process will identify any disability which may impact on health and safety in the workplace, in context with the wider requirements of a specific job role. LFRS has an individual health risk assessment processes in place. Each group of job roles within the Service has been risk assessed to identify the health hazards which that role is exposed to.  This provides structure to the individual health risk assessment process and enables a Manager to consider the needs of an individual and identify the feasibility of implementation of reasonable adjustments. When required, Managers have access to support from Human Resources, Occupational Health Unit and SHE Department to complete the individual health risk assessment process. Wellbeing is a key focus within the health and safety management system.  LFRS has a range of support mechanisms which staff can access to promote good mental health.  All employees have access to an external Employee Assistance Programme which includes specialist counselling and support.  Following traumatic incidents, staff can be supported through the Trauma Risk Management process (TRiM). Regular workplace wellbeing toolbox talks are carried out across all areas of the Service to actively promote the support available to staff.
Gender Identity/ Gender Reassignment			No impact identified.
Pregnancy and Maternity	Yes			Female firefighters as soon as they are aware they are pregnant notify line management and are immediately taken off operational activity to protect themselves and the unborn child.  This policy decision is taken in line with national FRS guidance and the inability to control what incident types a pregnant firefighter would be exposed to. New and expectant mothers undergo a person specific risk assessment with their line manager with support from the Occupational Health Unit which ensures that health and safety is ensured through the pregnancy when they are in workplace and upon return after childbirth.
Race Ethnicity Nationality			No impact identified.
Belief or Religion		Yes		The EIA process has identified two aspects which have a negative impact in relation to Belief or Religion for the firefighter role: · Turban-wearing Sikhs – Head Protection · Restrictions on Facial Hair for Breathing Apparatus and other respiratory protective equipment (RPE) Sections 11 and 12 of the Employment Act 1989 as amended by Section 6 of the Deregulation Act 2015 exempts turban-wearing Sikhs from any legal requirement to wear head protection at a workplace. A workplace is defined broadly and means any place where work is undertaken including any private dwelling, vehicle, aircraft, installation or moveable structure (including construction sites). There is a limited exception for particularly dangerous and hazardous tasks performed by individuals working in occupations which involve providing an urgent response to an emergency where a risk assessment has identified that head protection is essential for the protection of the individual e.g. such as a fire fighter entering a burning building, dealing with hazardous materials. Some staff or potential new entrants into LFRS may have facial hair to reflect religious beliefs.  In the context of the firefighter role, facial hair is a risk to health and safety.   The respiratory protective equipment (BA set and P3 masks) relies on a good seal against the face. If there are any gaps around the edges of the mask, 'dirty' air will pass through these gaps and into the persons lungs. Facial hair – stubble and beards, make it impossible to get a good seal of the mask to the face.  Requirements from the HSE (HSG53 Document) requires that you are clean-shaven when wearing tight-fitting masks to prevent leakage of contaminated air around the edges of the mask and into your lungs. There is no non-tight fit RPE available which is suitable for the firefighting environment, therefore it is not possible to deviate from this position.
	Yes			Within LFRS a number of staff have identified that they are vegans and have requested different operational PPE due to leather based items being used.  Staff already has the option to wear rubber fire boots, and due to enhancements in PPE technology options for alternative firefighting gloves are now coming onto the market for staff who are Ethical vegans.
Gender Men/Women	Yes			The Personal Protective Equipment at Work Regulations 1992 require that any personal protective equipment supplied is suitable for the individual. This ensures that individuals from all protected groups are provided with PPE that is suitable and sufficient. As part of the arrangements for provision of PPE, all staff undergo a sizing exercise to make sure that the PPE provided fits and is suitable for the person.  This is done by LFRS staff who have been trained by manufacturers to size and fit PPE. If there are issues with PPE fitting, the Procurement Department will work with supplies to source and appropriate item of PPE, and this could include having items specially manufactured for the individual when this is possible.
Sexual Orientation Lesbian, Gay, bisexual and straight people			No impact identified.
Marriage and Civil Partnership (employment only)			No impact identified.
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.	Yes			Poverty – Under the HSW Act – Section 9 there is a duty not to charge employees for things done or provided in relation to health and safety in the workplace, therefore it is at no cost to individual employees.
Contributes to equality of opportunity	Yes			As outlined above, SHE legislation applies to all groups of LFRS staff, but also impacts on those who may be impacted by LFRS activities.  The SHE Policy provides a framework for how LFRS manages SHE risks and this applies to the whole organisation and means that all groups of LFRS staff, and those outside the organisation can benefit from safe workplaces and activities with SHE hazards controlled.
Contributes to fostering good relationships between different groups	Yes			The SHE Policy does not directly promote inclusivity but provides a clear framework for Safety, Health and Environment. The advantage of a clear written SHE policy supported by Senior Leaders is that it will help to ensure that the Health and Safety provisions are applied consistently across the Service which helps towards promoting equality and diversity.
The decision will be taken in compliance with Human Rights [3]	Yes				Yes
	No

4. Outcome of the Equality Impact Assessment: Actions to be taken

What course of action does the Equality Impact assessment Suggest you take

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.

Outcome 2 - Adjust the policy

To remove the negative impact identified in the EIA or to promote better equality.

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

5. Equality Impact Assessment/ Analysis Action Plan and Review

As a result of performing this analysis, what actions are proposed to remove or reduce any negative impact of adverse outcomes identified on people (employees, applicants, customers, members of the public) who share characteristics protected by the Equality Act 2010 or who are non-legislative characteristics.

Further action required:   Yes                          No

Impact identified on the Protected Characteristics

Action Required

Responsible Officer

Completion Date

Review Date

5.1 The completed EIA should be attached to the management/project report, so the details can be considered as part of the decision-making process at the relevant Board/Meeting.

5.2 Update the EIA monitoring spreadsheet on the R Drive.

Equality Impact Assessment Approved By:

Date Approved:

Further guidance on completing Equality Impact Assessments is available from Human Resources.

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[1] Policy refers to any policy strategy, procedure, function decision or delivery of service

[2] To tick the box: right click, properties, click check the box

[3] Human Rights are the basic rights and freedoms that belong to every person in Europe regardless of nationality and citizenship. Human Rights are based on the five FREDA principles: Fairness, Respect. Equality, Dignity, Autonomy.