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ASSA-I : Use of Explosive Detection Dogs (SAGAS – 6 July 2011)

ASSA-I : Use of Explosive Detection Dogs (SAGAS – 6 July 2011). Hilde De Clerck Secretary-General . Aviation Security Services Association – International. founded in June 2002 (in the aftermath of the 9/11 terrorist attacks)

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ASSA-I : Use of Explosive Detection Dogs (SAGAS – 6 July 2011)

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  1. ASSA-I :Use of ExplosiveDetectionDogs(SAGAS – 6 July 2011) Hilde De Clerck Secretary-General

  2. Aviation Security Services Association – International • 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

  3. AviationSecurity Services in EuropeBasicfacts 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 %

  4. EDD: legalframework 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

  5. Two EDD methods REST Free running (RemoteExplosiveScentTracing)

  6. 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 6

  7. 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 7

  8. Advantages of EDD • Effective, efficientandfast screening methodwhencompared to e.g. X-ray screening • Effectivevisualdeterrent • Broad scope of applicationssuch as : preventing the infiltration of explosivesinto cargo; hold & carry-on baggage; aircrafts; vehicles; etc. • Well suitedto the new “unpredictablity/predictability” thinking in security • Screening of large, inaccessible and/orhazardousspaces • Dogswork in controlled environment • Goodalternativefor air cargo screening: • Logisticalproblems • High unit costs/low mobility of screeningsystems • Cargo is oftenproblematicforX-Ray

  9. ASSA-I Concern Article 12.9.3.15 of EU regulation 573/2010 “Operational training shallbedoneon a continuous random basis during the deploymentperiod, and shallmeasureEDD’s performance bymeans of approved training aids.” ASSA-I asksfor a clearinterpretation of thisarticle and itsconsequences: • Is the approval of the training aids onlynecessary and applicablefor training aids usedduring the operational training? • Is thisapplicableornotfor training aids usedduring the initial training? • Approval of training aids: • Whowillapprove the training aids? • According to which procedure? • According to whichspecific criteria / requirements?

  10. ASSA-I Concern Article 12.9.3.1(b) of Decision 2010/3572/EU “Training aids forfree-runningdogsusedfor the purpose of explosivematerialsodourrecognitionshall range from 5 to 1500 grams, and forremoteexplosivescenttracingdogsfrom 75 to 1500 grams in weightorhigher as appropriate” ASSA-I wouldlike to see the weightsinterpreted as a range between X to Y grams. In thisway, the necessaryflexibility is given to security services providers and /orhandlers to train theirdogsaccordingly.

  11. ASSA-I Concern Attachment 12 D - Performance requirements for an EDD ASSA-I wouldlike to underlinethatit is essentialthat the EU MemberStates and/or the EuropeanCommisioncommunicate to security services providers the detection criteria set out in attachment 12 D Without knowledge of the content of attachment 12 D, it is impossibleforsecurity services providers to complywith : • the detectionstandards 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 qualitycontrolstandards set out in attachment 12 G - QualityControl

  12. ASSA-I Concern Attachment 12 H - Free Running EDD - Standards for Deployment Methodology Regarding“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

  13. ASSA-I Concern Attachment 12 H - Free Running EDD - Standards for Deployment Methodology Point 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 restrictionprovisions, 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

  14. ASSA-I Concern Attachment 12 I - Remote Explosive Scent Tracing EDD - Standards for Deployment Methodology Attachment12 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

  15. ASSA-I Concern Attachment 12 I - Remote Explosive Scent Tracing EDD - Standards for Deployment Methodology Point 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.

  16. ASSA-I Concern ASSA-I welcomed the US TSA recognition of EU standardson the use of EDD ASSA-Iregrets US TSA EmergencyAmendment of 27 May 2011 undoingthisrecognition: consequences: Onlythose EU MemberStateswho have established the EU certificationprocess are nowrecognisedby the TSA In other EU MemberStatesit is impossible at this stage to deploy EDD for US outboundoperations ASSA-I asks the EC and concernedstakeholders to urge the TSA to considerrecognition to bere-enteredintoforcefor the whole of the EU 16

  17. ASSA- I Conclusions (1) • Absence of transparentcommunicationby the EuropeanCommission and/or the EU MemberStates to the security services providers of the applieddetection criteria as set out in Attachment 12 D, whichwouldbenecessaryfor: • Adequate training of the dogs • Certification of the dogs • Internal Quality criteria / controls

  18. ASSA- I Conclusions (2) • Different deployment criteria between: • Free Running EDD and REST EDD • Between EU MS for REST EDD • Parts of EU legislationnotclear. Leads to uncertainty. Leads to different interpretations and ensuingdifficulties • Current EU legislationwillonlybereviewedafterit has been in place for a reasonableperiod of time, butit is clearthat the currentlegislation poses immediateproblemsfor the security services providers • Explosivedetectiondogs are notyetgenerallyacceptedbysomenationalauthorities as a primary (firstchoice) and effectivescreeningmethod as compared to othermethodssuch as X-rayscreening.

  19. ASSA-I proposal: Testing of EDD (1) 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 demandfor uniform and consistingtesting • 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

  20. ASSA-I proposal: Testing of EDD (2) 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

  21. ASSA-I proposal: Testing of EDD (3) 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

  22. ASSA-IAviationSecurity 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 Thankyouforyourattention

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