ASSA-I :Use of Explosive Detection Dogs

(SAGAS – 6 July 2011)

Hilde De ClerckSecretary-General

• founded in June 2002 (in the aftermath of the 9/11 terrorist attacks)

• non-profit organisation / members: private security services companies providing security services at airports and for airlines

• corresponding member of CoESS (Confederation of European Security Services) and responsible for this area within CoESS

• goal: to defend the interest of the aviation security services providers in national, European and international fora

• goal: to promote by all possible means high-quality security services

Aviation Security Services Association – International

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Aviation Security Services in Europe Basic facts and figures 2010

• Total turnover European aviation security services market (public and private): ca € 3 billion

• 56 % of market outsourced to private security providers: ca € 1.6 billion

• ASSA-I members: ca 72% of outsourced market: ca € 1.25 billion

• Total market (public and private): ca 80.000 jobs• ASSA-I members: ca 41.000 guards (26.000 M/15.000 F)• Average total personnel turnover (ASSA-I members): 22 %

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EDD: legal framework

Regulation (EU) no 573/2010 of 30 June 2010 amending Regulation (EU) no 185/2010 laying down detailed measures for the implementation of the common basic standards on aviation security – Standards for the use of explosive detection dogs

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Two EDD methods

REST Free running (Remote Explosive Scent Tracing)

EDD: facts and figures

• Several ASSA-I members: experts in the field of handling explosive detection dogs for cargo screening

• Often: in combination with X-ray verification• EDD use by private security providers (in ca. half of

European airports allowed• In general: EDD deployed for screening/search of

cargo, hold bagage, mail, vehicles, unattended bags, aircrafts.

• EDD use by private security providers: in ca. half of European airports allowed

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EDD: facts and figures

• Clients willing to use more EDD because of advantages (see next slide)

• Clients still too often hampered by too strict legislative framework

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Advantages of EDD

• Effective, efficient and fast screening method when compared to e.g. X-ray screening

• Effective visual deterrent• Broad scope of applications such as : preventing the infiltration of explosives

into cargo; hold & carry-on baggage; aircrafts; vehicles; etc.• Well suited to the new “unpredictablity/predictability” thinking in security• Screening of large, inaccessible and/or hazardous spaces• Dogs work in controlled environment• Good alternative for air cargo screening:

• Logistical problems• High unit costs/low mobility of screening systems• Cargo is often problematic for X-Ray

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ASSA-I Concern

Article 12.9.3.15 of EU regulation 573/2010“Operational training shall be done on a continuous random basis during the deployment period, and shall measure EDD’s performance by means of approved training aids.”

ASSA-I asks for a clear interpretation of this article and its consequences:

• Is the approval of the training aids only necessary and applicable for training aids used during the operational training?

• Is this applicable or not for training aids used during the initial training?• Approval of training aids:

• Who will approve the training aids?• According to which procedure?• According to which specific criteria / requirements?

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ASSA-I Concern

Article 12.9.3.1(b) of Decision 2010/3572/EU“Training aids for free-running dogs used for the purpose of explosive materials odour recognition shall range from 5 to 1500 grams, and for remote explosive scent tracing dogs from 75 to 1500 grams in weight or higher as appropriate”

ASSA-I would like to see the weights interpreted as a range between X to Y grams. In this way, the necessary flexibility is given to security services providers and /or handlers to train their dogs accordingly.

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ASSA-I Concern

Attachment 12 D - Performance requirements for an EDD

ASSA-I would like to underline that it is essential that the EU Member States and/or the European Commision communicate to security services providers the detection criteria set out in attachment 12 D

Without knowledge of the content of attachment 12 D, it is impossible for security services providers to comply with :

• the detection standards in order to pass the approval procedures set out in attachment 12 E -Approval Procedures and 12 F - Approval test areas and test conditions

• the quality control standards set out in attachment 12 G - Quality Control

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ASSA-I Concern

Attachment 12 H - Free Running EDD - Standards for Deployment MethodologyRegarding “Non-containerised packaging” as mentioned in:

• Point 4: “In-flight and aiport supplies” • Point 5: “Hold baggage” • Point 6: “Cargo” • Point 7: “Mail” • Point 8: “Company Mail and Materials”

ASSA-I would like to stress the need for a clear interpretation / definition of “non-containerised packaging” so that security services providers may understand what kind of cargo can or cannot be screened by means of Free Running explosive detection dogs

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ASSA-I Concern

Attachment 12 H - Free Running EDD - Standards for Deployment MethodologyPoint 6: “The height of consolidated consignments shall not exceed 130cm in height and 100cm in depth, unless a single piece of consignment is exceeding such dimensions.”

•ASSA-I would like the European Commission to officially confirm to the industry that in relation to the size restriction provisions, flexible operational solutions are possible, so that larger consignments may be screened by means of Free Running explosive detection dogs, while still respecting the size restrictions•The current limitations pose large operational and logistical problems for security services providers as well as their clients

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ASSA-I Concern

Attachment 12 I - Remote Explosive Scent Tracing EDD - Standards for Deployment MethodologyAttachment 12 I, point 2: “Screening Durations”: “During a 24 hour period the EDD shall not be deployed for more than five hours in total (…)” [REST EDD]Attachment 12 H, point 10: “Durations of Screening”: “An EDD may be deployed in screening duties for a maximum time of 8 hours during 24 hour period including the rest periods.” [Free Running EDD]

ASSA-I feels that the deployment procedures for REST dogs should not differ from those for Free Running dogs – especially when taking into account the reduced physical requirements (environmental, distances, etc.) for REST dogs as well as the reduced olfaction time they have

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ASSA-I Concern

Attachment 12 I - Remote Explosive Scent Tracing EDD - Standards for Deployment MethodologyPoint 3: “Technical Equipment”

ASSA-I would like a clarification regarding the following issues:• The rationale behind the parameters: “The duration of sampling of each

consignment shall be appropriate to the size and storage condition, but shall be no less than 1.5 minutes for consignments which do not exceed 180cm in height and 240 in width.”

• The relation mentioned between the duration of sampling and the size of the consignment.

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ASSA-I Concern

•ASSA-I welcomed the US TSA recognition of EU standards on the use of EDD•ASSA-I regrets US TSA Emergency Amendment of 27 May 2011 undoing this recognition: consequences: • Only those EU Member States who have established the EU

certification process are now recognised by the TSA• In other EU Member States it is impossible at this stage to

deploy EDD for US outbound operations•ASSA-I asks the EC and concerned stakeholders to urge the TSA to consider recognition to be re-entered into force for the whole of the EU

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ASSA- I Conclusions (1)

• Absence of transparent communication by the European Commission and/or the EU Member States to the security services providers of the applied detection criteria as set out in Attachment 12 D, which would be necessary for:

• Adequate training of the dogs• Certification of the dogs• Internal Quality criteria / controls

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ASSA- I Conclusions (2)

• Different deployment criteria between:– Free Running EDD and REST EDD– Between EU MS for REST EDD

• Parts of EU legislation not clear. Leads to uncertainty. Leads to different interpretations and ensuing difficulties

• Current EU legislation will only be reviewed after it has been in place for a reasonable period of time, but it is clear that the current legislation poses immediate problems for the security services providers

• Explosive detection dogs are not yet generally accepted by some national authorities as a primary (first choice) and effective screening method as compared to other methods such as X-ray screening. 18

ASSA-I would like to propose independent (i.e. verified by a recognized and independent certification body or person) testing of EDD in the EU:

•A well-organized and harmonized, uniform and consistent certification procedure will benefit both the clients and the security services providers by creating a level playing field within the EU

•Testing procedure (related to the necessity of and demand for uniform and consisting testing

–Screening tests with the dogs (Free Running en REST) under identical circumstances–Screening of cargo of clients (co-operation with EEA – DHL, TNT, etc.) according to modalities to be jointly defined–Specifically test the dogs on the specifications mentioned in the EU legislation

ASSA-I proposal: Testing of EDD (1)

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Aims of the testing (practical)•To demonstrate the use of EDD•To demonstrate the advantages of this kind of screening•To demonstrate the screening capabilities of the dogs

Aims of the testing (political)•To enhance the certification procedure in each Member State•To evaluate / update current legislation

ASSA-I proposal: Testing of EDD (2)

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ASSA-I calls upon the European Commission, the Members States and the other concerned Stakeholders to support /cooperate in independent testing of EDD in the EU

ASSA-I members with expertise in handling EDD already expressed their willingness to pilot such testing

ASSA-I proposal: Testing of EDD (3)

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ASSA-IAviation Security Services Association InternationalJan Bogemansstraat | Rue Jan Bogemans 249B-1780 WemmelBelgiumT +32 2 462 07 77F +32 2 460 14 31E-mail: assa-i@i-b-s.beWeb: www.assa-int.org

Thank you for your attention

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