Security professionals fret about how to protect other people and assets. It is a dynamic process of creating a safe and secure place in a world of known and unknown, predictable and unpredictable.
That is a difficult task given that designing security procedures most often does not always begin with a blank slate. Instead, the challenge for security designers is to implement procedures and measures where people and facilities are already in place. In other words, security people must design and execute a security function in an environment that they did not design.
Furthermore, to security people, their mission is to protect the people and assets of the enterprise they serve. That myopic view often results in leaving the protectors themselves, unprotected.
The Price of Negligence Is Lives and Money
A tragic and costly example of that occurred on October 10, 2017 at the Gardena, California site of Consolidated Disposal Services-Republic Services.
While working early morning hours, a G4S Secure Solutions security guard suffered fatal injuries when he was struck by a Republic Services Roll Off truck picking up roll off containers.
The California Division of Occupational Safety and Health (CalOSHA) subsequently cited Republic for four “serious” worker safety violations, and assessed fines totaling $71,435, half of the original total because Republic made corrections.
Citation 1
The Rule: “Every employer shall establish, implement, and maintain an effective Injury and Illness Prevention Program. The Program shall be in writing and, shall, at a minimum: Include procedures for identifying and evaluating work place hazards including scheduled periodic inspections to identify unsafe conditions and work practices.”
The Violation: “Republic Services failed to effectively implement their company’s written Injury and Illness Prevention Program (IIPP). Republic Services failed to effectively identify and evaluate the work conditions, per company’s written IIPP such as the lack of natural or artificial illumination for the employees required to work through the night and a system of traffic control within the yard.
The Penalty: $18,000
Citation 2
The Rule: “Working areas, stairways, aisles, passageways, work benches and machines shall be provided with either natural or artificial illumination which is adequate and suitable to provide a reasonably safe place of employment.”
The Violation: “The natural or artificial illumination provided for the GS4 Secure Solutions security guard was not adequate or suitable to provide a reasonably safe place of employment.”
The Penalty: $22,500
Citation 3
The Rule: “When adequate natural illumination or permanent artificial illumination cannot be made available to secure the safety of employees, suitable portable lights shall be provided.”
The Violation: “When adequate natural illumination or permanent artificial illumination was not made available, the management of Republic Services failed to provide suitable portable lights to employees working at the roll off yard throughout the night.”
The Penalty: $8,435
Citation 4
The Rule: “Haulage vehicles and earthmoving equipment such as scrapers, crawler tractors, bulldozers, front-end loaders, motor graders, and similar equipment shall comply with Article 10, Haulage and Earthmoving, of the Construction Safety Orders.”
The Violation: “The employer failed to ensure where a hazard existed to employees, from haulage vehicles such as the Republic Services Roll Off Vehicles, to have a system of traffic controls to abate the hazard in accordance with the requirements of Sections 1598 of these Orders.”
The Penalty: $22,500
Summary of Rule Violations and Penalties
- Failure to implement their own written prevention plan.
- Failure to provide adequate lighting.
- Failure to control traffic.
The total money fine assessed by the State of California was relatively small: $71,435. The cost of a life is incalculable. There is no information available about possible civil liability costs, or G4S liability. [1]
What Will Be Obvious Tomorrow is Not Today
Lighting and traffic control are fundamentals of exterior safety and security; so common and recognized that there are specific rules for providing them.
There is no gain in speculating why Republic ignored the rules. The company did not save any money in its failure to comply with regulations; as a condition of the penalty settlement, the state forced Republic to install the protections it was required to have in the first place!
Nevertheless, this incident is instructive because it serves as either a wake up alarm, or reminder that effective security only works if those who provide it can safely perform their duties.
The military has a term for this: Force Protection (FP). The principle of FP is that, in order to defend the master, you must first defend the defenders; otherwise, your defensive measures are useless.
However, threats and risks are not static. Conditions change, sometimes in obvious major ways, and in subtle ways, on the periphery. Changes are likely to go unnoticed in the absence of constant assessment, monitoring, and accommodation. For a security practitioner to ignore this obligation in the course of protecting principals-client personnel and assets-is malpractice. So too, it would be negligent to ignore FP Condition Changes.
Suggestions for Continuous Security Force Protection
Proper Equipment. The baseline of what is required may not be enough. An investment here will not only enhance safety, but performance and effectiveness too.
Training and Retraining. Minimum training is just that. Knowledge and skills are perishable and must be added to and refreshed.
Communication and Feedback Loop. Is communication one-way or two-way? The person who knows the most about a job and how to do it best is the person doing the job. Information sent upstream is good for collecting data but serves little purpose other than archival if not used to monitor and adapt. Security personnel should always be in the loop about condition changes.
Monitoring. A close cousin to Communication. The more formal, the better, but it should also include open-ended informality. “What else should we be watching or doing?
Testing, Simulations, and Drills. “Looks good on paper,” but will it work, and as intended? Testing, simulations, and drills are essential experiments in validation and discovery.
Intelligence. Does protective intelligence gathering address methods to defeat human security? “First, take out the guards.”
Assessments. A security plan is purely academic without assessments. Do assessments include security personnel risks, threats, and vulnerabilities?
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[1] According to Jackson Lewis PC, employers need to be alert to “…the potential liability when known dangerous working conditions are not corrected and employee complaints about hazards not investigated and addressed. Obviously, OSHA citations must be taken seriously and the offending conditions abated, and there should never be an attempt to deceive OSHA about existing safety devices or hazard corrections. OSHA has authority to issue willful citations (with possible proposed penalties up to $70,000 per violation), and in the case of a fatality, refer the matter to the U.S. Attorney for criminal proceedings. Further, such misconduct may play a key role in stripping away an employer’s immunity from suit under the Workers’ Compensation Act, exposing the employer to large damage awards, injury to business relationships, and adverse publicity.”
Michael Nossaman is PSC founder.
Refererence
https://www.osha.gov/ooc/citations/CALOSHACitation_ConsolidatedDisposalServicesLLC.pdf
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