Chapter 70: Organisation

¶70.1 This chapter provides a broad overview of the organisational structure of the LFB in the period leading up to June 2017. It is necessary to be aware of the key elements of that structure in order to understand which departments and individuals were responsible for different aspects of its functions before and at the time of the Grenfell Tower fire.

¶70.2 On 1 October 2007, Ron Dobson was appointed LFB Commissioner, a position which he held until his retirement on 31 December 2016.¹³⁸¹³⁸ Dobson {LFB00032157/2} page 2, paragraph 5. Following a period of handover from September to December 2016, Dany Cotton was appointed interim Commissioner on 1 January 2017 and subsequently appointed to the substantive rank on 14 June 2017.¹³⁹¹³⁹ Dobson {LFB00032737/2-3} pages 2-3, paragraph 5. The permanent appointment on 14 June had been planned and was unrelated to the Grenfell Tower fire.¹⁴⁰¹⁴⁰ Phase 1 hearing: {Day50/10:3-12}.

¶70.3 The London Fire and Emergency Planning Authority (LFEPA) was abolished on 1 April 2018 and replaced by the London Fire Commissioner, who became the fire and rescue authority for Greater London. The London Fire Commissioner assumed responsibility for LFEPA's statutory obligations under the Fire and Rescue Services Act 2004 outlined above.¹⁴¹¹⁴¹ Section 1(2)(c) of the Fire and Rescue Services Act 2004, which came into force with effect from 1 April 2018 under The Policing and Crime Act 2017, section 9 and The Policing and Crime Act 2017 (Commencement No. 7) Regulations 2018, regulation 4 On 31 December 2019, Ms Cotton retired as Commissioner and was succeeded by Andrew Roe on 1 January 2020.

¶70.4 As an organisation the LFB was divided into three directorates, the heads of which reported directly to the Commissioner and were responsible for a number of different departments. The internal structure of the directorates was complex and subject to frequent changes, most notably in 2015 following a wide-ranging reorganisation of the LFB as a whole. In the following paragraphs we give a broad and simplified description of the LFB's structure before and after 2015, focusing on the departments and functions which are most relevant to the Inquiry's investigations.

Before 2015

¶70.5 Before 2015, the LFB's three directorates were the Deputy Commissioner's directorate, the Directorate of Operational Resilience and Training (together sometimes known as the two operational directorates) and the Directorate of Financial and Contractual Services.

The Deputy Commissioner's directorate

¶70.6 Rita Dexter served as Deputy Commissioner between November 2009 and March 2015.¹⁴²¹⁴² Dexter {LFB00032363/2} page 2, paragraph 4. In addition to deputising for the Commissioner, the Deputy Commissioner was responsible for the following departments within her directorate: Operational Prevention and Response, Fire Safety Regulation, Strategy and Performance, Communications, and Legal and Democratic Services.¹⁴³¹⁴³ Dexter {LFB00032363/2} page 2, paragraph 5. The first three of those departments are relevant to the Inquiry's work.

The Operational Prevention and Response department

¶70.7 The Operational Prevention and Response department¹⁴⁴¹⁴⁴ Also later known as 'Operations and Mobilising'. was responsible for the planning, direction and delivery of the LFB's operational service, mobilising crews and community safety,¹⁴⁵¹⁴⁵ Brown {LFB00032166/3} page 3, paragraph 7. including overall responsibility for the control room, fire stations and the collection, management and use of operational risk information.¹⁴⁶¹⁴⁶ Brown {Day186/7:17}-{Day186/8:1}; Brown {Day186/5:2-21}. At all relevant times, the LFB's 102 fire stations were grouped by the 33 London boroughs in which they were located,¹⁴⁷¹⁴⁷ Brown {LFB00032166/23} page 23, paragraph 74. each headed by a Borough Commander. The boroughs were in turn grouped into four Areas (North East, North West, South East and South West) each headed by an Area Deputy Assistant Commissioner (DAC). Before 2012, many of the department's responsibilities were split geographically between North London and South London, each headed by an Assistant Commissioner (AC). However, from June 2012 the role and responsibilities for the whole of London were brought together under a single Head of Operational Prevention and Response.

The Fire Safety Regulation department

¶70.8 The Fire Safety Regulation department had two broad functions: Regulatory Fire Safety and Community Safety. The Regulatory Fire Safety arm of the department was headed by two DACs, who filled the roles of Head of Fire Safety Delivery and Head of Fire Engineering and Specialist Fire Safety.¹⁴⁸¹⁴⁸ Daly {Day183/13:24}-{Day183/16:19}.

¶70.9 Fire Safety Delivery included the department's fire safety teams, which had responsibility for managing the LFB's audit and enforcement activities under the Regulatory Reform (Fire Safety) Order 2005 (the Fire Safety Order). As with the Operational Prevention and Response department, the Fire Safety Delivery arm of the department was split into the same four geographical London areas, each headed by an Area Fire Safety Manager, and further divided by boroughs.¹⁴⁹¹⁴⁹ Jack {LFB00032244/3} page 3, paragraph 7. Fire Safety Delivery was responsible for the LFB's programme of fire safety audits carried out by fire safety inspecting officers, who could be from either operational or non-operational backgrounds.¹⁵⁰¹⁵⁰ Daly {LFB00032306/3} page 3, paragraph 9. Some fire safety inspecting officers received additional training to enable them to act as fire engineering liaison officers, who provided support to the more specialist fire engineering teams in relation to building control consultations.¹⁵¹¹⁵¹ Daly {Day183/29:12-22}; Daly {Day183/39:4-21}. Fire Safety Delivery included the Fire Safety Enforcement team, headed by Andrew Jack, which was responsible for reviewing enforcement notices produced by inspecting officers, interpreting legislation and overseeing enforcement prosecutions.¹⁵²¹⁵² Daly {Day183/18:1-20}.

¶70.10 Some senior operational officers were also senior fire safety officers. Senior fire safety officers were typically station managers or group managers who were not part of the Fire Safety department but who would be mobilised to attend incidents requiring four or more pumps to provide support to the incident commander.¹⁵³¹⁵³ Daly {MET00077774/16}. They undertook a relatively broad, short training course in the basic principles and practice of fire safety to enable them to fulfil that role.¹⁵⁴¹⁵⁴ Daly {Day183/51:8-21}. In practice, and as happened at Grenfell Tower,¹⁵⁵¹⁵⁵ Cohen-Hatton {Day185/59:18}-{Day185/61:14}. it was common for officers who were mobilised to incidents as senior fire safety officers to be assigned different roles by incident commanders.¹⁵⁶¹⁵⁶ Daly {MET00077774/16-17}; Daly {Day183/58:23-25}. AC Daly, sometime Head of Fire Safety, said that, in his view, this practice of re-assigning senior fire safety officers to operational roles reflected a failure to give priority to fire safety expertise on the incident ground.¹⁵⁷¹⁵⁷ Daly {Day183/61:24}-{Day183/62:5}.

¶70.11 The Fire Engineering and Specialist Fire Safety arm of the department included its more technical fire safety teams, such as the Fire Investigation and Fire Engineering teams. Fire Engineering, also known as the Fire Engineering Group, comprised a team of around 10 specialist fire engineers who held, or were studying for, degree-level qualifications in fire engineering.¹⁵⁸¹⁵⁸ Daly {Day183/32:7-10}. Led by two Senior Fire Engineers, the group's main function was to consider complex references from building control bodies that were beyond the experience of inspecting officers.¹⁵⁹¹⁵⁹ Daly {Day183/29:12-22}. Most of the group's work consisted of providing support to external bodies, though the group also contributed to the development of LFB policy as part of the standard process of internal consultation.¹⁶⁰¹⁶⁰ Daly {Day183/35:1-8}. Fire Engineers were not involved in the development of operational training unless they were specifically asked to contribute their expertise.¹⁶¹¹⁶¹ Daly {Day183/38:2-15}.

¶70.12 The Fire Investigation team was made up of watch-based operational personnel whose function was to attend incidents to investigate the cause of the fire. The team used the information collected from such inspections to identify trends with a view to informing activities within the LFB and to advance the work carried out by the LFB with external bodies, including those in industry, to improve fire safety across the built environment.¹⁶²¹⁶² Daly {Day183/28:2-22}.

¶70.13 The other arm of the Fire Safety department, Community Safety, concentrated on actions designed to prevent fires (such as home safety visits), on people at particular risk and on community behaviour.¹⁶³¹⁶³ Daly {Day183/14:7-18}.

The Strategy and Performance department

¶70.14 The Strategy and Performance department led the LFB's work relating to the integrated risk management plan (the London Safety Plan), its internal risk management planning, and performance reviews.¹⁶⁴¹⁶⁴ Dexter {Day178/30:1-24}. Despite its name, the department was not in fact central to the strategy or performance of the LFB's core operational responsibilities.

The Directorate of Operational Resilience and Training

¶70.15 AC Gary Reason was appointed Director of Operational Resilience and Training in January 2012.¹⁶⁵¹⁶⁵ Reason {LFB00032747/2} page 2, paragraph 7. On his retirement in January 2015, he was succeeded by AC James Dalgleish.

¶70.16 The Directorate of Operational Resilience and Training comprised the following departments: Operational Procedures, Operational Assurance, Operational Resilience, and Human Resources and Development.

The Operational Procedures department

¶70.17 The Operational Procedures department was responsible for the creation and maintenance of the vast majority of the LFB's operational policies,¹⁶⁶¹⁶⁶ Reason {Day180/93:3-7}; Cowup {LFB00032784/3} page 3, paragraph 10. subject to certain exceptions, such as the Incident Command policy, for which Operational Assurance was responsible.

The Operational Assurance department

¶70.18 The Operational Assurance department was primarily concerned with ensuring effective incident command, the safety of operations and the management of risks on the incident ground.¹⁶⁷¹⁶⁷ Cotton {Day208/10:8-11}. Dany Cotton, who headed the department from its inception in 2012 before her term as Commissioner, said that it was designed to provide combined and streamlined leadership of two existing LFB functions, the Operational Review team's quality assurance of incident ground operations, and the Health and Safety team's learning from incidents to identify risks to LFB staff.¹⁶⁸¹⁶⁸ Cotton {Day208/10:12}-{Day208/11:3}; Cotton {Day208/8:3-13}. The department was responsible for producing six-monthly reports which identified risks and trends from an analysis of a wide range of sources, including the LFB's Incident Monitoring Process Database (IMPD), significant incidents, incident accident reports, fire investigation reports, training and sources from outside the LFB.¹⁶⁹¹⁶⁹ Cotton {Day208/30:16}-{Day208/32:1}; {Day208/33:24}-{Day208/34:4}; {LFB00067840} is an example of the reports produced by the department. The department was also responsible for overseeing the production of articles for Operational News, the LFB's internal circular, by which it sought to draw the attention of staff to some of the risks it had identified and any lessons to be learnt.¹⁷⁰¹⁷⁰ Cotton {Day208/12:21}-{Day208/13:10}. The functions of the Operational Assurance department were such that it was ultimately responsible for ensuring the operational effectiveness of the LFB and for ensuring that LFB staff were aware of, and adequately prepared to deal with, operational risks which might affect their safety.

¶70.19 Key teams within the Operational Assurance department included the Incident Management Policy Group (also known as the Incident Command Policy Group), which was responsible for collating the information from the sources mentioned above and producing the six-monthly reports for the Operational Directorates Co-ordination Board (the co-ordination board),¹⁷¹¹⁷¹ Cotton {Day208/31:2-12}. and the Operations Review Team, which provided oversight of the LFB's operational activities and routine training designed to maintain and develop operational skills.¹⁷²¹⁷² Cohen-Hatton {LFB00110660/2} page 2, paragraph 10.

The Operational Resilience department

¶70.20 The Operational Resilience department included contingency planning and a special operations group focused on policies, procedures and the provision of equipment related to terrorism.

The Human Resources and Development department

¶70.21 The Human Resources and Development department, previously the Training department, was responsible for the management of the LFB's contract with its external operational training provider, Babcock Training Limited (Babcock), as well as the LFB's human resources function.¹⁷³¹⁷³ Reason {Day180/93:8-15}. The LFB's operational training structure and the adequacy of particular aspects of the operational training that existed at the time of the Grenfell Tower fire, is covered in more detail below. The training of control room staff, which was not included in the Babcock contract, is covered separately in Chapter 78.

The Directorate of Finance and Contractual Services

¶70.22 The Directorate of Finance and Contractual Services, led by Sue Budden, carried out the LFB's non-operational functions, including Financial Services, Information and Computer Technology and Procurement. It is, on the whole, not relevant to the work of the Inquiry.

The Third Officer

¶70.23 Before 2015, the title of Third Officer was held by a senior operational officer in addition to their day-to-day responsibilities. Its purpose was to ensure that there were three senior uniformed officers (the Commissioner, the Director of Operational Resilience and Training, and the Third Officer) able to provide operational cover for serious incidents. From 2010, the position of Third Officer was held by David Brown, who was then an Assistant Commissioner.¹⁷⁴¹⁷⁴ Brown {Day186/10:7-21}.

The 2015 restructuring

¶70.24 In 2015, the LFB underwent an internal reorganisation and the rank of Deputy Commissioner was dropped. Commissioner Dobson said that the position was no longer required as the directors were able to deputise for him within their own areas of responsibility. In broad terms, the Deputy Commissioner's directorate was reorganised into a new Directorate of Operations. The former Directorate of Operations, Resilience and Training was renamed the Directorate of Safety and Assurance, and the Directorate of Finance and Contractual Services continued as before. In addition to some internal restructuring within each directorate, some departments and functions were moved between directorates.

¶70.25 The separate role and title of Third Officer also ended, as there were now three senior uniformed officer positions: the Commissioner, the Director of Operations and the Director of Safety and Assurance.

Directorate of Operations

¶70.26 The newly created Directorate of Operations retained responsibility for many of the departments which had previously reported to the Deputy Commissioner.

¶70.27 The Fire Safety Regulation department, now simply called "Fire Safety", continued to incorporate the LFB's fire safety (including Fire Safety Enforcement and Fire Investigation), fire engineering and community safety functions.

¶70.28 The operational firefighting and control functions of the previous Operations, Prevention and Response department were divided between two new departments: Fire Stations and Central Operations and Control and Resource Management.¹⁷⁵¹⁷⁵ {LFB00000010}.

¶70.29 AC Brown was appointed Director of Operations in April 2015. When he retired on 31 March 2017, he was succeeded by DAC Philip Thomas George (known as Tom George).¹⁷⁶¹⁷⁶ Brown {LFB00032166/4} page 4, paragraph 9; George {LFB00032823/2} page 2, paragraph 6.

Directorate of Safety and Assurance

¶70.30 The newly renamed Directorate of Safety and Assurance continued to include Operational Procedures (re-named Operational Policy), Operational Assurance, and Operational Resilience. The Human Resources and Development department was renamed Development and Training, with its human resources functions moved to the Legal and Democratic Services department within the Directorate of Finance and Contractual Services. Health and Safety and the Operational Review Team, previously sub-departments of Operational Assurance, now reported directly to the Director.

¶70.31 Following the restructuring, on 1 December 2015 AC James Dalgleish assumed the position of Director of Safety and Assurance on an interim basis before Dany Cotton's appointment as Commissioner.¹⁷⁷¹⁷⁷ Groves {Day177/11:4-13}. Upon Ms Cotton's appointment, AC Stephen Apter became Director of Safety and Assurance in December 2016. He was in post on 14 June 2017.¹⁷⁸¹⁷⁸ Apter {LFB00067794/2} page 2, paragraph 4.

Principal LFB boards and committees

¶70.32 This section describes the principal LFB boards and committees which existed before and after the 2015 restructuring.

The Corporate Management Board

¶70.33 The Corporate Management Board was the LFB's highest-level committee, with a membership comprising the Commissioner, the three directors and some heads of department, with other officers and advisers attending when required. The Corporate Management Board held regular meetings and provided a forum for the LFB's most senior officers to discuss operational, managerial and strategic matters. It also reviewed key papers and reports before they were submitted to the LFEPA Strategy Committee for oversight.¹⁷⁹¹⁷⁹ Dobson {Day210/59:20-25}; {Day210/63:4-25}.

The Commissioner's Group

¶70.34 There was also a smaller, informal leadership group known as "the Commissioner's Group", consisting of the Commissioner, the three directors and, before the 2015 restructuring, the Third Officer. The Commissioner's Group met about once a week for informal meetings, which were not minuted, to share information with the aim of improving communications between the Commissioner and the directors.¹⁸⁰¹⁸⁰ Dobson {Day210/62:1-10}; {Day210/64:25}-{Day210/65:6}. Commissioner Dobson said that his day-to-day management and oversight of the directors was not exercised through the Commissioner's Group, but by daily individual meetings and, more formally, at the Corporate Management Board.¹⁸¹¹⁸¹ Dobson {Day210/64:21}-{Day210/65:11}.

The Operational Directorates Co-ordination Board

¶70.35 The Operational Directorates Co-ordination Board (the co-ordination board) comprised the directors and most of the senior officers and heads of department in the LFB's two operational directorates. It comprised the heads of Operational Prevention and Response, Fire Safety Regulation, Operational Procedures, Operational Resilience and Human Resources and Development (the training department). The control room was not represented. Until 2015 the co-ordination board was chaired by the Deputy Commissioner, Rita Dexter; following the restructuring in 2015 it was chaired by AC Brown in his capacity as Director of Operations. The Commissioner was not a member of the co-ordination board and did not attend its meetings.¹⁸²¹⁸² {LFB00040625/2}; Dexter {Day178/53:19}-{Day178/55:6}.

¶70.36 The primary function of the co-ordination board was to provide a forum in which the two operational directorates¹⁸³¹⁸³ Operational Resilience and Training and the Deputy Commissioner's directorate before the 2015 restructuring; Operations and Safety and Assurance following the restructuring. could discuss and co-ordinate their activities, identify risks to operational staff and identify and recommend training required in response to such risks.¹⁸⁴¹⁸⁴ Cotton {Day208/27:10-18}. Trends and lessons identified by the Operational Assurance department were brought to the co-ordination board for discussion. The co-ordination board would then select the most significant operational topics for development into paper or computer-based training.

¶70.37 In late 2016, the name of the co-ordination board was changed to the Operational Professionalism Board¹⁸⁵¹⁸⁵ Brown {LFB00084020/19} page 19, paragraph 50; {LFB00040652/1} paragraph 2. but that had no effect on its working.