Up until 17 November, the Security Industry Authority (SIA) will be inviting comments on the Regulatory Impact Assessment for its much-discussed Approved Contractor Scheme. Which of the four Options the SIA will eventually select has been the talk of the industry for some time now. Should we stick to industry-specific company inspection regimes, or widen the net to encompass more bodies operating on a ‘generalist ticket’? Tom Mullarkey explains why the SIA Workbook-based Option 4 could be ruinous for the private sector.

Within the next week or so, the private security industry and its stakeholders have some very important decisions to make – nearly all of them centred on whether or not there is a belief that a Security Industry Authority (SIA)-sponsored Approved Contractor Scheme (ACS) would be a valuable change. If viewed in the affirmative, what form that ACS should take is also up for discussion.

The main issues here are interwoven with interests, not least of which are the public interest and that pertaining to the commercial health of the industry itself.

There is one issue which might be lost in the cacophony of argument and counter-argument, and that is the key question focusing on how the security sector (and, indeed, its Regulator) should measure performance in terms of service delivery to the client base.

While there are numerous alternative models, it all boils down to whether or not specialisation will continue to have value in a national inspection market which is dominated – beyond the security industry – by generalists. Regular readers of Security Management Today may recall I have previously advanced the argument that while a standard should be high, it is the measurement device for that standard which really matters. Weak compliance undermines a superficially strong 'paper' standard. Strong compliance with a less rigorous standard may actually produce better results than vice versa.

Why is this important? In simple terms, the confidence the customer has in a company’s ‘badge’ of performance correlates strongly with business success. It also impacts on improvement potential, market confidence and risk appetite (to name but a few other hugely relevant factors). None of this might be readily apparent on the surface, but without clear standards and good inspection all of our industries would simply be operating within a regime akin to the Dark Ages.

Activity behind the scenes

There is an old adage that states: ‘You do not want to be in the room when the butcher is making sausages’. How inspection regimes actually work is also potentially messy, even though the results generally seem digestible.

Behind the scenes at the National Security Inspectorate (NSI), we carry out a range of activities but many of them are not made transparent to the ‘users’ of our services.

The major component is consistency. We have to be certain that all companies are measured in exactly the same way, wherever they may be and whatever their size. It is a major task to ensure that all inspectors are working from the same page, while team managers have to devote a significant proportion of their time to training.

In these sessions, we look at every inspection component of current interest, analyse where non-compliance or query patterns are emerging, evaluate the complaint registers and then provide a standardised response to each issue (ensuring that all of our inspectors are confident and authoritative should they be asked for information or advice). It is absolutely essential that all companies are offered the same objective information and advice.

Then there are the activities being assessed. Every moment of an Inspection Team’s time is focused on the scope(s) to which they inspect. Of course, many of the NSI’s inspectors have been with us for anything up to 15 years, and originate from the industry itself (which is a great boon). The intimate arguments on the pros and cons of a tiny clause in a British Standard or an NSI Code of Practice are under the spotlight. There is so much detail involved that this isn’t for those of a weak disposition.

Nonetheless, that is the NSI’s role. Indeed, there is no limit as to what we must have a defined view about and then express those opinions. If a company cannot obtain a detailed response to any question on security standards – and their implementation – from our members of staff on the ground, we would be thoroughly disappointed in ourselves. Most importantly, we carry within us the technical expertise that contributes so usefully to the development of security standards, both nationally and internationally. That said, this is but the tip of the iceberg.

Chargeable days per annum

On average, the NSI’s security guarding inspectors deliver 120 chargeable days per year. The remaining 100 or so days are set aside for training and attendance at a range of professional, external courses.

These days also encompass the preparation time needed before each inspection day during which an inspector reviews the previous audit outcomes and then agrees a programme of inspection with the company in question. In this way, the inspection time required is precisely tailored to the need. Critically, those 100 or so other days also allow for the detailed report writing without which – in our view, at least – the visit has not been completed.

By doing the sums, it becomes immediately apparent that an NSI inspector devotes nearly half a day to report writing (uncharged) in addition to the preparation time (uncharged) and inspection time (charged) itself.

The end result of all that training, preparation and report writing is not just that we are able to clear the decks for the inspection day to come. It is that the value of this day’s inspection – precisely focused, diligently researched and, I hope and trust, efficiently executed – is of tremendous benefit to the company in question.

We are able to unearth deep-seated concerns and advise on their resolution. We dip down into layers which only a thorough insight can illuminate. We know all of the ‘excuses’ (which are mercifully few) because we have heard security companies use them time and time again.

Members of staff at the NSI are able to sniff out a problem from long range, and can thus go straight to it. From the point of view of the security company paying for their audit, and also from the customer’s perspective, knowing that the inspection service is thorough – and at all times totally watertight – is essential.

Generalists aren’t the same!

How, though, would the generalist certification body operate in the same context, and particularly given that our industry is such a small fish in their huge sea?

Without the industry-specific focus which represents our bread and butter, on what do they spend their time and, indeed, how might they gain job satisfaction?

The answer explains the difference between the NSI and other inspection bodies operating in the guarding sector.

There are 14 alternative inspection bodies to the NSI, and they currently monitor a total of 70 companies. This works out at an average of five companies per body, compared to the NSI’s 230. Five companies amounts to around 3% of the audit portfolio of one inspector. Compare this to a dedicated team of 11 staff at the NSI – all focused on one subject – and the real context of this industry-specific versus generalist debate becomes clear.

Given that these five companies are (probably) geographically dispersed, the audit is likely to be shared out such that no inspector oversees any more than one company. Professional though they may be, the likelihood that these generalist inspectors will ever assemble to talk about security as a discipline is just about zero. Security does not appear on their radar screens.

As the saying goes, they are likely to ‘inspect a paint shop one day, a security company the next and an abattoir on the third’.

Regardless of their individual diligence, they simply cannot compare with the knowledge and experience a dedicated NSI inspector can bring to bear.

The strategic context

A typical general certification auditor is expected to deliver 180-plus chargeable audit days per year, a significantly higher utilisation than his or her NSI equivalent (and approximating to nearly three months’ worthless ‘overhead’ per annum). There is no time for consistency – nor indeed the need for any – and minimal opportunities for preparation or report writing. It must all be squeezed into a single day.

In some inspection bodies, auditors never actually carry out a repeat visit on a given company themselves, simply because those audits are scheduled on a ‘taxi rank’-style basis. There is simply no company-focused knowledge and no relationship being developed (that is not the case at the NSI, as both of these areas are our hallmarks).

A keen business eye will immediately fix on these utilisation figures. How can the NSI afford to run an inspection process at that price? Why do the other bodies charge roughly the same amount (or more) for less? While the NSI is generally a little more expensive than some other bodies of repute, we achieve a near-comparable cost by operating on a genuine not-for-profit basis, and by managing our costs down at every opportunity in order to keep the service ethos vibrant. That is vitally important to the interests of all our stakeholders.

Where this really bites is when these bodies place a certificate on a company’s wall which, according to them anyway, equates to one bestowed by us. The reality is that an NSI Approved Company has been far more thoroughly and diligently inspected through choice. Ultimately, the value of that effort is constantly undermined by the generalist approach proclaiming ‘equivalence’.

Turning to Option 4

If the Security Industry Authority proceeds with its Option 4 (Workbook) solution for the Approved Contractor Scheme, the value of industry-specific inspection will be lost.

There are eight separate assessment bodies selected to operate Option 4, seven of whom are elected on the ‘generalist ticket’. What, thereafter, will be the value of a more thorough and informed inspection regime – designed by the industry for the industry – if the SIA ‘Badge of Approval’ can be earned and worn through less endeavour?

If you believe industry-specific inspection knowledge and experience has a future in the security sector then please make your views known by sending in your response to the Regulatory Impact Assessment. If you do not place your opinion on record, the fear has to be that we will only really know what we have lost when it has disappeared.