Introduction
2.1
The first part of this chapter outlines some the standards used by private security providers who operate security and detection dogs, some of the key reasons why government agencies are unable to contract these services from the private sector, and the standards currently used by Australian law enforcement agencies. It then considers key international arrangements in the UK and the US as comparisons to Australia and the use of private industry to clear air cargo.
2.2
The second part outlines the Australian Standard for private sector security and detection dogs that is currently under development, support for the introduction of a national standard and key concerns and suggestions raised during the inquiry. The chapter concludes with the committee's views and recommendations.
Purpose of introducing a national standard
2.3
Detection dogs are typically used to indicate the presence of a particular scent and assist their handlers to locate items such as explosives, drugs, contraband, wildlife, or people. They may be operated by law enforcement or the private sector and are often trained for a specific purpose or project. Security patrol dogs are those used by private security companies to guard premises or as part of a security patrol.
2.4
During its inquiry, the committee received evidence that there is no agreed national standard against which private security canine detection service providers are held regarding the minimum levels of training, performance, welfare, assessment, operation, and administration that are required to carry out the role effectively and with integrity. Security canine detection service providers, meanwhile, are able to provide services to consumers without being required to meet any competency-based standard or be subject to regulation.
2.5
The lack of a national standard for privately contracted security and detection dogs has been a cause of concern for some industry participants. For example, Dog Force Australia has raised concerns about the quality of work being provided to buyers of these types of services, the safety of the community and goods being 'cleared' by canine detection services, and the unnecessary burden that can be placed on police resources where officers are required to attend to false positive indications by poorly trained or operated private security canines.
2.6
Internationally, some countries have introduced standards and certification programs for privately operated security and detection dogs. These programs provide minimum welfare, administrative, training and operational requirements. Some overseas government transport agencies have also introduced additional certification programs which facilitate government use of privately contracted canine services.
2.7
As suggested by evidence received in this inquiry, the introduction of a national standard for privately operated canine detection and security services could facilitate a number of improvements within Australia. A national standard could:
provide minimum requirements for security providers that will enhance the reliability and safety of these types of services;
improve the performance of security detection canine teams and the quality of clearances provided in the community and freight;
increase the consistency of welfare, training, operational and assessment requirements across jurisdictions;
make it easier for consumers of canine services to conduct quality checks before contracting security providers;
facilitate access to domestic and international work for Australian security providers; and
potentially streamline insurance processes for both providers and consumers of these types of services.
Standards currently used by the private sector
2.8
Submissions and correspondence received to the committee’s inquiry indicate there are a range of standards currently in use across the private sector. For example, Dog Force Australia uses its knowledge of accreditation standards employed by the NSW Police Dog Unit combined with those outlined in both the British and French standards. The Australian Working Patrol Dog Association (AWPDA) model and procedures are based upon those of the North American Police Work Dog Association. Detector Dogs Australia adopts the US Transportation Security Administration and the US National Police Canine Association standards which govern all canine deployment in the US. Peak security industry association, the Security Providers Association of Australia Limited (SPAAL), advised that Australian private security providers 'currently develop their own training standards and procedures for the dogs based on a mix of overseas standards'.
Government use of private sector canines
2.9
In the absence of a national standard, a key point of inquiry for the committee was whether any Australian government agencies, particularly those in law enforcement, currently contract canine services from the private sector. However, during its inquiry, the committee did not receive evidence that Australian, state or territory law enforcement agencies contract detection dogs or handlers from the private sector, even during internal shortfalls.
2.10
The submission from the Australian Federal Police (AFP) advised that it cannot use privately contracted canines for a range of security, operational, training, and work health and safety reasons. For example, AFP methodologies and curriculums are classified to protect their effectiveness against security threats and only made available to appropriately cleared officers. Operationally, police canines must be deployed alongside armed officers who have the appropriate expertise and legislative authority to determine and respond to threats. AFP officers are also required to be trained in evidence recovery and prosecution to enable presentation at court. There are also legislative provisions which dictate the possession, use, transportation and storage of live aids for the purposes of training canine teams. Further, the AFP is bound by workplace safety requirements which are regulated by Comcare.
2.11
The Australian Border Force (ABF) and the Department of Home Affairs declined to make submissions to the committee’s inquiry. However, the AFP submission explained that it works closely with the ABF to provide a breeding program, operational structures/magazines to manage explosive detection training aids, deployment of canines to designated airports and border entry points, purpose-built training facilities, and research and development.
2.12
The submission from the Queensland Police Service did not explicitly address whether it privately contracts dogs or handlers to meet demand for services; however, it did outline a range of reasons why it would be difficult to contract a provider for these services, many of which were similar to those raised by the AFP. The Queensland Police Service submission highlighted that police detection dogs must be accompanied by trained and equipped officers who can provide an immediate response where explosives or drugs are detected, as well as protect evidence as needed, which is something that a privately contracted individual would not be trained or authorised to do.
2.13
Similar to the submissions received from the Queensland Police and AFP, the NSW Police Force submission pointed out that private security licensees do not have the authority to stop, search and detain people to whom dogs have provided a positive indication or to take possession of items located during a search. The NSW Police Force submission advised that the organisation does not currently contract, or see a future need to contract, explosive detection dogs from the private security sector. Indeed, the NSW Police Force submission argued that privately operated explosive and drug detection dogs should be prohibited on account of unacceptable risks to public safety, and legal and liability risks associated with their use.
2.14
The Queensland Corrective Services submission advised that it does not privately contract canine services as it requires a specific set of skills, experience and qualifications for occupants of roles in its dog squad which are only engaged following a rigorous selection process.
Standards currently used by government agencies
2.15
Evidence to the inquiry revealed that most law enforcement agencies have existing internal standards and practices in place to maintain the integrity of their canine training and services. For example, AFP canines are trained
in-house at the AFP National Canine Operations Centre in Canberra by a specialist team. Curriculum and assessment criteria are sanctioned by AFP Learning and Development, and the program is benchmarked against the ABF, the Australian Defence Force, state and territory police, and other law enforcement partners.
2.16
According to evidence from the Police Federation of Australia (PFA), the benchmark for state and territory police dogs, police dog handlers and the care of police dogs is set out in the Australia New Zealand Policing Advisory Agency (ANZPAA) Education and Training Guidelines for Police Dog Handlers guideline which is not for public access. While some of the methodology for how dogs are trained and selected is tailored for each specific environment, at their core, these standards are the same across the country.
International comparisons
2.17
The UK and the US offer key international comparisons to the current Australian arrangements. Several contributors to the inquiry were of the view that components of the UK model, in particular, may be worthwhile emulating.
2.18
In 2016, the national standards body of the UK, the British Standards Institute (BSI), published two standards: one for the use of general purpose security dogs and another for the use of detection dogs. The first relates to guard dog operations while the second provides recommendations for passive and proactive detection dog services. Although issued as codes of practice by the BSI, compliance with the recommendations is regarded as mandatory for companies that wish to maintain National Security Inspectorate (NSI) approval for the provision of general purpose security dogs. Both standards require organisations engaged in the training or use of security and detection dogs to comply with applicable legislation and supply evidence that training is carried out exclusively by qualified personnel who pay proper regard to animal welfare.
2.19
According to information provided by the UK Home Office and the UK Department for Transport, the UK private sector explosive detection dog industry is not currently provided with any government approved standards. However, the UK Home Office is working to introduce training and accreditation standards for the private sector based on recently introduced police standards. The National Canine Training and Accreditation Scheme (NCTAS) was introduced in January 2020 and applies to police explosive detection dogs. The NCTAS provides mandatory training and accreditation standards. The private sector version of these standards, known as NCTAS-P, uses the same accreditation criteria and is expected to launch in 2020.
2.20
The UK Home Office and the UK Department for Transport explained that work is underway to establish the structure and governance of the NCTAS-P, including publishing non-sensitive standards, protocols and procedures for interested companies and facilitating access to government approved explosives training kits. While it is not mandatory for private companies to sign up to these standards, the UK Home Office and the UK Department for Transport pointed out that companies which incorporate the standards 'will have a competitive advantage in the sector by being government approved'.
2.21
The NCTAS-P does not cover air freight screening as this is covered by the UK Department for Transport free running explosive detection dogs (FREDD) program. The UK allows private sector companies to train and operate FREDDs and recognises their use as an appropriate screening method for air cargo. There are a number of certified FREDDs in the UK, with additional canines in training, and more applicants awaiting certification.
2.22
The UK government uses privately operated FREDDs and their handlers to check air freight for explosives in cargo sheds at British airports. The dogs undergo training to achieve government certification before deployment, and are used alongside existing screening methods. Both the certification and quality assurance process that the dogs are required to undergo is set by the Department for Transport which shares oversight with the Civil Aviation Authority (CAA). The CAA has a further responsibility to ensure that those who operate the dogs do so in line with the standards set out by the department.
2.23
Additionally, the committee heard that private security providers in the UK operate under a standard that is governed by the National Association of Security Dog Users (NASDU). The view of the Australian Working Patrol Dog Association was that this model has proven to be effective for a much larger sector than exists in Australia and that a similar association of relevant stakeholders would work well here. Under this banner, an association comprised of the police, Standards Australia, major security industry associations, dog trainers, providers, breeders and equipment manufacturers would work together to give future buyers assurance regarding the training and standards of dogs and handlers. Indeed, this association has been formed and is operating to some degree under the Standards Australia technical advisory committee that is responsible for developing the proposed standard.
2.24
The committee also received evidence regarding arrangements in the US. The US Transportation Security Administration (TSA), which was established following the September 11 terrorist attacks to prevent future attacks, permitted the air cargo industry to utilize third-party explosive detection canines as an approved screening option in 2018. The TSA created regulations and certifications in order to facilitate government use of private canine teams under a program called the Certified Cargo Screening Facility-K9. According to the TSA, the program allowed the agency to expand its network of certified explosive detection canines and thus enhance US aviation security.
Domestic air cargo screening trial
2.25
In Australia, the Federal Government has been working with the air freight industry to phase in stricter requirements for domestic air cargo screening. From June 2020, all domestic air freight not originating from a known consignor or a 'regulated air cargo agent' must be examined at piece-level at major airports prior to uplift (that is, Sydney, Melbourne, Brisbane, Adelaide and Perth domestic terminals). By June 2021, these examination requirements will apply to domestic air cargo loaded at all airports.
2.26
The expected increase in air freight screening prompted concern about the ability of existing screening methods to cope with demand. Dog Force Australia, a Registered Training Organisation and detection canine services provider, collaborated with Toll Group to examine whether explosive detection dogs could be used to relieve pressure on the x-ray technology that is currently used to screen Australian air freight. A trial was scheduled for February 2020 and Toll Group may introduce explosive detection dogs screening throughout Australia pending the results of the trial.
Australian Standard under development
2.27
As mentioned, Standards Australia, the peak non-government standards body in Australia, commenced work to develop a voluntary national standard for Private Sector Patrol and Detection Dogs following a proposal that was submitted and approved in December 2019.
2.28
‘Standards’ are documents that set out specifications, procedures and guidelines that aim to ensure products, services, and systems are safe, consistent, and reliable. There are three categories:
International standards, which are developed by international standards organisations for countries to adopt for national use;
Regional standards, which are prepared by a specific region; and
National standards, which are developed by a national standards body or other accredited body.
2.29
On their own, standards are voluntary. There is no requirement for the public to comply with standards. However, when Commonwealth or state governments refer to standards in legislation they become mandatory and are legally enforceable.
2.30
According to the Standards Australia submission, the scope of the new private sector patrol and detection dogs standard is limited to the private sector and includes:
training and performance requirements for service delivery by patrol (security) and detection dogs (explosives, biosecurity);
requirements for handler education and training; and
requirements for the selection, care, accommodation, welfare and breeding of working dogs.
2.31
At the time of the committee's inquiry, the details of the standard were being developed and exactly what will be included was unclear. However,
Mr Michael Goodwin, Chief Executive Officer, Dog Force Australia, emphasised that it was not the intention of the private sector to incorporate narcotics detection dog work in the private sector standard. Nor was it the intention of the private sector to undermine existing police or military organisation standards.
2.32
According to SPAAL, the proposed standard is based on the British standards (mentioned earlier) and covers private security patrol dogs, private security explosive detection dogs, private security biosecurity dogs, and initial and continuation training.
2.33
Standards Australia's technical advisory committee (TAC) is responsible for developing the new standards. In early 2020, the TAC was comprised of the following:
Australian Veterinary Association
Australian Hotels Association
Australian Security Industry Association
Royal Society for the Prevention of Cruelty to Animals
Security Providers Association of Australia Ltd
2.34
The committee subsequently received evidence that Queensland Corrective Services also had representation on the TAC.
2.35
The AFP advised that it agreed to contribute to the development of an Australian Standard that would ensure a stronger field of practice for private sector canines as 'it was in a position to provide subject matter expertise…having administered a mature and relevant operational canine program'. The AFP contributes one member to the committee who currently works within the AFP Canine capability and acts in an advisory capacity, particularly on matters concerning the discipline of canine explosives detection.
2.36
In response to a question on notice, the NSW Police Force explained that it had nominated a representative to the technical advisory committee following an invitation received from Standards Australian in 2018; however no response was received and it was unclear if the nomination was received. Following receipt of a revised project proposal from Standards Australia in August 2019, the NSW Police Force discussed the revised proposal with the ANZPAA but did not participate in the technical advisory committee.
2.37
At the hearing, the NSW Police Force also expressed its concern regarding the sharing of intelligence with the security industry due to the risk of organised crime and terrorism operating within the sector.
2.38
The private sector patrol and detection dogs standard is expected to be released for public comment in early 2021. Preliminary draft standards generally provide nine weeks for feedback from all stakeholders.
2.39
Standards Australia explained that any member of the public or organisation can propose changes at any time. Work on any amendment or revision would start subject to that proposal meeting quality requirements, and the proposal being broadly supported by stakeholders.
Support for the introduction of a national standard
2.40
Most submitters to the inquiry were supportive of the introduction of a national standard. For example, the Australian Security Industry Association Ltd (ASIAL), the peak national body representing security professionals in Australia, argued that introduction of a new standard would improve the consistency and performance of detection dogs, raise professional standards, build security capability, and provide a framework against which providers could be measured to ensure integrity and efficacy in services.
2.41
Mr Bryan de Caires, Chief Executive Officer, ASIAL, emphasised the importance of standardising the requirements for security providers across all jurisdictions. He pointed out that the security industry had been advocating for greater consistency across Australian jurisdictions regarding the general eligibility requirements for security licences such as who can be licenced and for what purposes. Specific to dog licencing, Mr de Caires explained that licencing requirements relating to training standards currently vary between jurisdictions, even between those individuals who are essentially carrying out the same role. In this respect, a standard would assist to provide some consistency and quality assurance during an expected period of increased demand for services.
2.42
Mr de Caires also pointed out that introduction of a national standard may help to overcome issues arising from the mutual recognition of security licences between jurisdictions. Currently, some states recognise individuals who obtain security licences in other states so as to reduce the administrative burden placed on individuals. However, as requirements differ between states, there may be variations in standards of services. Indeed, the committee heard that some individuals use the mutual recognition system to obtain their security licence in jurisdictions with less onerous requirements with the intention to work in states with more robust requirements.
2.43
Dog Force Australia argued that introduction of a national standard would bring Australia into line with international best practice, and SPAAL argued that the development of a recognized standard would increase public confidence and security across a range of services.
2.44
At its public hearing, the committee heard that the introduction of a national standard may facilitate access to international and domestic work for security providers. Due to differences in standards and liability across jurisdictions, live entertainment company, Live Nation, explained that it had previously flown canines around Australia in order to conduct explosives clearances at events rather than use local services.
2.45
Mr James Fidler, Director, Security, Australia and New Zealand, Live Nation, noted that an American company had been contracted to carry out canine detection and security services at the Australian Embassy in Kabul. Mr Fidler speculated that the existence and demonstration of the use of a US standard may have provided additional credibility and competitiveness to the provider's application during the tender process.
2.46
The AFP was of the view that development of an Australian Standard would ensure a stronger field of practice for those operating outside of Commonwealth, state, and territory law enforcement, defence and security agencies, and their respective legislative parameters. However, the AFP pointed out that an Australian Standard would only be able to form the basis of any canine program as operating requirements differ so widely between organisations.
2.47
The Police Federation of Australia was supportive of introducing a national standard for the private sector. Its main concern was ensuring that policing methodology did not make its way into the public environment and that any private sector guidelines do not impact existing police guidelines.
Key concerns raised
Value of privately operated detection dogs
2.48
The NSW Police Force submission was supportive of the development of a national standard for private security patrol dogs but it did not support the introduction of a standard for privately operated explosive or drug detection dogs. The NSW Police Force argued that there is a strong case for prohibiting the private use of these types of dogs as they pose unacceptable public safety, liability, and legal risks. At the public hearing, Commander McErlain, NSW Police Force contended that false positive indications resulting from privately operated explosive detection dogs are well-documented and can unnecessarily burden police resources.
2.49
Mr Michael Goodwin, Chief Executive Officer, Dog Force Australia, in contrast, argued that the operation of private explosive detection dogs can work to assist police priorities by freeing up policing resources that would otherwise have been engaged in conducting clearances for private consumers. Speaking from his experience as the previous commander of the NSW Police Dog Unit, Mr Goodwin explained that, although event organisers would book police explosive detection canine services for venue clearances several months in advance, where a police job would then conflict with the booking the police job would take precedence due to limited resources. Indeed, the committee heard that some state or territory police forces do not possess a canine explosives or general-purpose security canine capability as part of their operations.
2.50
When questioned by the committee, the Commander of the NSW Police Force Dog and Mounted Unit, Peter McErlain, explained that over the previous 12 months, the NSW Police Force had been able to resource 'generally 100 per cent' of all requests for assistance from both internal and external stakeholders.
Separate standard is needed for conservation detection dog work
2.51
At the time of the committee’s inquiry, the specifics of the national standard were still under development. However, it became clear during the inquiry that particular elements might need to be carved out from the national standard for privately operated security and detection dogs.
2.52
Due to differences in operating procedures, the conservation detection sector argued that it would prefer to develop a separate standard for conservation detection dog work rather than be included in the proposed standard currently under development.
2.53
Representatives of the conservation detection dog sector argued that standards should not be a one-size-fits-all approach. Mr Ryan Tate, Certified Handler and Assessor, Canine Detection Certification of Australia, pointed out that assessors must have experience and qualifications that are directly relevant to the dogs and handlers they are assessing. Those who have only trained and handled narcotics or explosives detection dogs would not be fit to assess people who train and handle threatened species dogs and vice versa. Further, there are significant differences between operating a conservation dog and a dog performing security and explosive detection functions in some respects, for example, being able to work off lead.
2.54
Dr La Toya Jamieson, Treasurer, Australasian Conservation Dog Network, argued that creating one assessment, even solely for application within the conservation sector, would be impractical as each dog has been trained for a specific role and purpose. Representatives of the conservation sector agreed that minimum standards for basic controls such as emergency stops, recalls, and reliability around distractions should be in place. However, they also maintained that focusing solely on meeting basic minimum standards rather than the assessments and guidelines for each specific working dog and its project should be avoided.
Clarification of the term 'biosecurity' is needed
2.55
Submissions from the conservation detection dog sector also argued that the use of the term 'biosecurity' in the proposed national standard may have unexpected and adverse impacts on conservation projects and that the meaning of the term and its purpose in the proposed standard should be clarified. During the hearing, Mr Goodwin, CEO, Dog Force Australia, clarified that the intent of the inclusion of the term 'biosecurity' in the proposed standard relates to the use of detection dogs to detect pests and others threats to Australian agriculture in ports.
Content and structure of the proposed national standard
2.56
The committee heard that there are currently a number of units of competency which sit within the Australian Skills Quality Authority (ASQA) vocational education and training framework that sufficiently address the educational requirements for privately operating security and detection dogs. According to Dog Force Australia, these four units (deploy detector dog, assisting conditioning animals, provide basic care of dog, and training dogs in agility) contain sufficient knowledge, evidence, and performance criteria for handlers to effectively work with dogs in a range of environments and at a range of capabilities. These units are delivered by registered training organisations in a way that is relevant to the context and are regulated by ASQA.
2.57
Contributors to the inquiry agreed that the national standard could be designed in a modular way so as to provide minimum basic standards that apply to all cohorts within the sector. This type of framework would allow additional components to be undertaken where needed to enable contextualisation for various fields of practice. Indeed, Mr Dave Wright, Director, Dog Force Australia, explained that the proposed standard under development has separate annexures as a way to cater for dogs that are working in different contexts such as biosecurity or explosives detection.
Compliance and enforcement of the proposed standard
Independent certification of dogs and handlers
2.58
Several submitters to the inquiry agreed that independent certification of handlers and dogs should accompany the proposed standard.
2.59
Mr Bryan de Caires, Chief Executive Officer, ASIAL, argued that while the proposed private sector standard would be voluntary, ensuring that independent certification can be provided to consumers of these services is fundamental. Independent certification would function to assure consumers that the provider is actually meeting the requirements within the standard.
2.60
In terms of implementation, Mr Ryan Tate, Certified Handler and Assessor, Canine Detection Certification of Australia, suggested that each sector could have approved assessors that operate across the country to accredit handlers and dogs in line with the standard.
2.61
Ms Tracy Lyten, Director, Skylos Ecology Pty Ltd, suggested that independent assessment could be handled through organisations such as the Canine Detection Certification of Australia, the Australasian Conservation Dog Network, or through colleges and universities.
2.62
Additionally, Mr Steve Austin, Director, Steve Austin Canine Training and Behaviour, argued that assessors should be required to meet minimum requirements. These minimum requirements, Mr Austin suggested, would include that an assesor understand the underlying scientific principles of modern canine training, be up-to-date with international developments, have no conflicts of interest, and be precluded from assessing their own organisation.
Establishment of an independent regulator
2.63
Some argued that the introduction of a national standard for the private sector should be accompanied by the establishment of an independent regulator. Peak security industry association, ASIAL, suggested that administration and enforcement of the standard could be linked to existing licensing regimes which would ensure national implementation and compliance in collaboration with peak security industry bodies.
2.64
Indeed, one of the key concerns raised by the NSW Police Force was how the proposed national standard would be regulated. As each jurisdiction has differing regulatory arrangements, licence classes, and training requirements the NSW Police Force pointed out that each state and territory would have to determine who the regulator is and how regulation would be carried out.
2.65
The NSW Police Force explained that, were NSW to implement a regulatory regime for the standard, NSW would have to manage the regime through the Security Licencing and Enforcement Directorate (SLED) to ensure consistency with the other regulation relating to the security industry. The SLED would be required to regulate training, industry activity, as well as complaints about services.
2.66
While the NSW Police Force was supportive of the introduction of a national standard, it argued that the implementation and compliance implications would be too burdensome and costly for the police to carry out and for security providers to pay for as they represent only a very small portion of the industry.
2.67
The NSW Police Force pointed out that only a small number (77) of class 1D licences (which authorise the licensee to patrol, protect or guard property with a dog) have been issued in NSW in the last two years. Of these 77 licences, 20 were mutual recognition licences transferred from Queensland, and only a small number of licensees are estimated to be trained, competent and actually carry out detection dog work.
2.68
Ms Lisa Stockley, Assistant Director (Industry Regulation), SLED, NSW Police Force, explained that:
…we couldn't fairly spread…licensing fees across the whole industry when it represents only about one per cent of the industry. We would then probably have to look at…some sort of application process that could be triggered by a section of our legislation that exists already, and the applicant would pay those costs, but then it would become cost prohibitive, I would imagine, for the applicant.
2.69
The NSW Police Force pointed out that the national security operations training package (CPP31318) does not currently contain any assessment standards for explosives detection dogs and would therefore require resources to regulate any additional training. In the scenario that new training modules were added to the package, this would mean that all existing class 1D licensees (that is, guard dog handlers) would need to be re-trained in order to maintain their licences. As there are only a few security class 1D licence holders and only two RTO’s that have delivered training courses in the last three years, NSW Police was of the view that the resources and risks associated with regulating the training of explosives detection dogs and handlers would be disproportionate to the benefits gained for the community.
2.70
The NSW Police Force acknowledged that there is expected to be increased demand for services in future according to evidence from the industry and that this may attract new entrants to the market. It acknowledged that, as with any market, new entrants will be attracted to enter and may decide not to adopt voluntary standards. As such, it may be prudent to introduce regulation for what is a fairly risky subsector of security work.
Using insurance to regulate the proposed standard
2.71
At the public hearing, the committee canvassed the impact that the introduction of a national standard for the private sector might have on security providers' insurance policies and processes. The committee was interested in understanding whether the insurance industry could provide quasi-regulation of the security industry by requiring security providers to meet particular standards in order to obtain insurance for the provision of canine services.
2.72
The committee heard that some insurance policies do not require a minimum standard to be met in order for a private security firm to gain insurance to operate security or detection canines in Australia. In some cases, insurance companies may ask for a risk assessment to be completed at the venue where a particular event is being held and a dynamic risk assessment to be completed for the course of the event.
2.73
According to evidence from Mr James Fidler, Director of Security, Australia and New Zealand, Live Nation, insurance companies in the UK have introduced a standard to which all the dogs are trained. Mr Fidler explained that, in Australia by comparison, it is difficult for event organisers to check that a security provider's canines are capable of carrying out the task as there is no performance standard that is required to be met by providers. Introduction of a national standard in Australia may thus reduce the administrative burden currently placed on consumers of security services when seeking to determine the reliability of a security provider.
Committee view
2.74
National standards provide an agreed set of procedures and specifications which help to ensure that services are safe, consistent, and reliable. The lack of an agreed standard against which private security canine detection service providers can be held has resulted in differing minimum levels of training, performance, welfare, assessment, operation, and administrative requirements within the sector.
2.75
At the time of the inquiry's establishment, the committee was not aware of any plans to develop a national standard for private security and detection dogs. Since the inquiry began, Standards Australia commenced work to develop a voluntary standard. The committee welcomes this development and looks forward to seeing the draft Australian Standard when it is available.
2.76
The intent of this committee's inquiry was not to advocate for the introduction a standard that would undermine or replace the existing standards of the police or other government organisations, but to understand ways in which the base standard of the private security industry might be enhanced to improve public confidence in these services.
2.77
The committee agrees with contributors to the inquiry that the introduction of a national standard for privately operated canine detection and security services could facilitate a number of improvements. For example, provision of minimum requirements for security providers can be expected to enhance the reliability and safety of these types of services. A national standard will also improve the performance and operation of security detection canine teams and the quality of clearances provided. Consistency of welfare, training, operational and assessment requirements across jurisdictions will be positively impacted and increased consistency could potentially facilitate greater access to work for providers. Those providers who choose to adopt an Australian national standard may also find themselves at a competitive advantage when competing for international work. In addition to this, a national standard may make it easier for consumers of canine services to conduct quality checks before deciding to engage services from providers. It may also streamline the insurance process for both providers and consumers of these services.
2.78
The committee is reassured that the AFP does not privately contract canine services due to range of security, operational and other constraints and that it has in place frameworks to maintain the integrity of its services.
2.79
The committee is pleased that the AFP is lending its expertise to the development of the proposed private sector standard and is represented on the technical advisory committee. The committee is of the view that law enforcement should be well represented on the technical advisory committee so as to ensure that only relevant methodology is incorporated and that controls around the use of methodology are robust.
2.80
The committee acknowledges the view of stakeholders that components of the UK model may be worthwhile emulating. The committee agrees that governments should play a role in assisting the private security canine detection industry to improve standards. This is being achieved by the AFP's representation on the Standards Australia technical advisory committee that is responsible for developing the proposed standard. The committee encourages other interested stakeholders—such as trainers, providers, breeders, and equipment manufacturers—to engage with Standards Australia to establish representation on the technical advisory committee.
2.81
The committee acknowledges the concerns of the NSW Police Force regarding the private operation of explosive and drug detection dogs. However, for these same reasons, the committee considers there is a need for government to assist industry to improve existing standards and thus the safety and reliability of services.
2.82
The committee considers that the considerable expertise and experience of state and territory police should be leveraged during the development of the proposed standard to improve practices and procedures within the private sector. The committee encourages ANZPAA to engage with Standards Australia regarding ways in which it could assist to strengthen private practice such as seeking representation on the technical advisory committee.
2.83
The committee heard the concerns of the conservation sector and agrees that the proposed standard should carve out conservation detection dog work from its content and use a modular framework upon which the conservation can then build contextualised components should it wish to in future.
2.84
The committee recommends that the Standards Australia technical advisory committee that is responsible for developing the national standard for private sector security and detection dogs carve out conservation detection work from the proposed Australian Standard for private sector security and detection dogs.
2.85
The committee agrees that a clear definition of the term 'biosecurity' in the proposed standard is required to avoid the private security standard inadvertently capturing conservation detection dog work.
2.86
The committee recommends that the Standards Australia technical advisory committee that is responsible for developing the national standard for private sector security and detection dogs provide a clear definition of the term 'biosecurity' in the proposed Australian Standard with a view to avoiding inadvertently capturing the work of conservation detection dogs and their handlers.
2.87
The committee is of the view that stakeholders from the security and detection dog industry and its associated sectors would find value in collaborating through an association model similar to that of the UK's NASDU. This format would enable stakeholders to collaboratively work through future matters such as determining the ways in which independent certification of dogs and handlers in achieving an agreed standard might best be managed.
2.88
The committee acknowledges the valid concerns of the NSW Police Force regarding the cost and resource implications of introducing a regulatory scheme for a minor portion of the security industry. While this is ultimately a matter for each state and territory, the committee is of the view that the expected increase in demand for privately operated detection dogs warrants further consideration. The committee heard meaningful evidence regarding the ways in which assessment and regulation might be carried out and considers that there is a potential role for the insurance industry to play in this regard.
2.89
The committee thanks all those who contributed to its inquiry and encourages stakeholders to provide feedback on the draft standard when it is available for public consultation in 2021.