Checking the actual rules on runes and staves/wands skill, my recollection was correct -- if the spell is above the character's level, this means they have to make a manoeuvre every time they activate the item, even after an initial successful check.
The manoeuvre roll is already modified by a penalty equal to the spell level; I don't see any reason to also call for an ESF check.
The rules indicate that "normal spell failure chances apply". I'd read this to imply the normal base 2% chance, or higher for attack spells. You could interpret this to mean that you should apply ESF, but this makes item use considerably less useful and doesn't feel to me like the intended interpretation.