National Security Inspectorate Sentinel House, 5 Reform Road, Maidenhead, SL6 8BY E: nsi@nsi.org.uk | W: nsi.org.uk Page 1 of 17 © NSI 2017 Dated: 20 February 2017 To: 1. All NSI Guarding Gold and Silver Companies who are approved for the provision of General Purpose Security Dogs. 2 . Applicant Companies who wish to gain approval for the above scope . TECHNICAL BULLETIN No: 0036 Guidance on the implementation of BS 8517-1:2016, the British Standard Code of Practice for the use of general purpose security dogs (Supersedes BS 8517-1:2009) BS 8517-1:2016 shows a publication date of the 30th September 2016 and is available through licensed outlets including NSI who can supply copies at a discounted rate. The new standard supersedes BS 8517-1:2009, which has been withdrawn. BS 8517-1:2016 identifies recommendations for the provision of General Purpose Security Dogs. Organisations that demonstrate compliance with BS 8517-1:2016 and also satisfy the relevant NSI criteria for approval, will be approved for the following scopes, depending on the service provided: “ Provision o f General Purpose Security Dogs” The 2016 edition will now be applied to all NSI approval schemes where the criteria for approval require compliance with BS 8517-1 as a condition of NSI approval. The Code of Practice will be applied with immediate effect, subject to the additional clarifications and guidance contained within this Technical Bulletin. Implementation timescale for Applicant Companies Applicant Companies will be audited against the 2016 edition with immediate effect and any Improvement Needs recorded against clauses of the Code of Practice will have to be satisfactorily addressed before approval can be granted. Implementation timescale for existing Approved Companies Companies holding NSI approval to BS 8517-1:2009 will be expected to comply with BS 8517-1:2016 by 30 September 2017. NSI Technical Bulletin No. 0036 Page 2 of 17 © NSI 2017 Note regarding the status of BS 8517-1:2016 Although issued as a code of practice by the British Standards Institution, it is important to note that compliance with the recommendations given in BS 8517-1:2016 is regarded as mandatory for all companies wishing to maintain an NSI approval; subject to any additional clarifications and guidance included within this Technical Bulletin or issued subsequently. The recommendations given in BS 8517-1:2016 must therefore be regarded as requirements in relation to NSI approval for the Provision of General Purpose Security Dogs. Details of the changes Highlighted under the clauses of the new Standard Comments under each clause of BS 8517-1:2016 detail the changes when compared with the corresponding clause within BS 8517-1:2009. Where the actual wording of the standard is quoted it is reproduced in bold text. Where it is considered relevant to further clarify the specified requirement, additional guidance is included in italics. We will consider alternative methods of achieving compliance with specified requirements where these can be demonstrated to be equivalent. Title The title of the standard remains the same. Contents The heading for Clause 5 has changed from kennelling/husbandry to accommodation/husbandry , which acknowledges that dogs can be accommodated in both a kennel and a domestic environment. The heading for Clause 10 has changed from transport and on-site kennelling, to transport and onsite vehicle kennelling . This reflects the fact that most sites will not have kennel facilities, so the dog will be housed within a kennel/cage within the vehicle or trailer. Foreword Publishing information BS 8517-1:2016 was prepared by Panel GW/3/-/15, Security dog users under the authority of BSI Technical Committee GW/3, Private Security Management & Services. NSI Technical Bulletin No. 0036 Page 3 of 17 © NSI 2017 Supersession Confirms that BS 8517-1:2016 now supersedes BS 8517-1:2009 which is withdrawn. Information about this document The Foreword states that the 2016 edition is a full revision of BS 8517-1, which has been updated to aid the understanding of the recommendations and reflect current practice. Use of this document No change except the removal of the below statement. It has been assumed in the preparation of this British Standard that the execution of its provisions will be entrusted to appropriately qualified and experienced people, for whose use it has been produced. Presentational conventions The following guidance paragraph has been added to presentational conventions: The word “should” is used to express recommendations of this standard. The word “may” is used in the text to express permissibility, e.g. as an alternative to the primary recommendation of the Clause. The word “can” is used to express possibility, e.g. a consequence of an action or an event. Notes and commentaries are provided throughout the text of this standard. Notes give references and additional information that are important but do not form part of the recommendations. Commentaries give background information. Contractual and legal considerations No change . 1 Scope Additional content has been added to the body of the Scope to include: records, kennelling/husbandry, dog health and welfare, equipment and clothing, training and operational requirements. The additional notes below clarify the following references or recommendations: NOTE 1 Recommendations for static site guarding and mobile patrol services are given in BS 7499. Recommendations for screening of security individuals are given in BS 7858. This part of BS 8517 also assists procurers of security dog services to ensure the service fits the end user requirements and risk profile. This part of BS 8517 excludes the provision of NSI Technical Bulletin No. 0036 Page 4 of 17 © NSI 2017 detection dogs and handlers. NOTE 2 Detection dogs and handlers are covered in BS 8517-2. 2 Normative references Largely unchanged apart from referencing the up to date versions of the British Standards that in whole or in part, are normatively referenced within BS 8517-1. 3 Terms and definitions An update and new elements have been added to terms and definitions to reflect current practices. They include: The notes remain unchanged but it is worthy of note that there were numerous changes to the Dangerous Dogs Act 1991 in 2014. The key areas of change came into effect in May 2014 and are summarised as follows: Extension of section 3 of the Dangerous Dogs Act to apply to ALL places The extension of section 3 of the Dangerous Dogs Act to apply to assistance dogs Extended rights of seizure Increased sentencing Courts’ new assessment in deciding whether a dog is a danger to public safety Civil Proceedings NEW 3.8 Self-employed handler Individual engaged to provide front line services as specified in the principal contractor assignment instruction NOTE The principal contractor is ultimately responsible and accountable for service delivery to the customer. NEW 3.9 Subcontract All, or part, of a contract assigned to another service provider, where the subcontracted service provider is responsible for service delivery including the supply and management of their employees in fulfilment of the subcontract NSI Technical Bulletin No. 0036 Page 5 of 17 © NSI 2017 NEW 3.10 Subcontracted service Provision of services on behalf of a principal contractor NEW 3.11 Subcontracted services provider Company that is contracted to provide service delivery on behalf of the principal contractor NOTE The principal contractor is ultimately responsible and accountable for service delivery to the customer. 4 Administration 4.1 General No real change except to specifically reference the up to date version of BS 7499. 4.2 Subcontracted services This is a new sub-clause and covers the normal subcontractor due diligence elements that are covered in other British Standards. The organiz ation should obtain the customer’s agreement on conditions for the use of subcontracted service providers for undertaking the duties of security dog services. The subcontracted services provider should also follow the recommendations given in this British Standard. The organization should satisfy itself that these recommendations have been followed. There should be documented evidence that due diligence has been carried out. 4.3 Self-employed handlers This is another new sub-clause and similarly provides guidance on the use of self-employed handlers. The organization should satisfy itself that the self-employed handler meets the recommendations given in this British Standard. NOTE Attention is drawn to HMRC guidance on self-employment. 4.4 Insurance The insurance requirements are now much more prescriptive and this clause now reads: NSI Technical Bulletin No. 0036 Page 6 of 17 © NSI 2017 The organization should be adequately insured in accordance with BS 7499:2013, and the insurance should be specific for the operational deployment of general purpose security dogs and, where applicable, for their training and kennelling. The organization should also take into account the advisability of professional indemnity insurance where advice is given on either operational deployment or on training. 4.5 Canine records A few slight changes to the content of this clause with additional elements now being included in the content of each dog’s individual record . NEW e) Breed /cross-breed NEW h) Neuter status NEW i) Photograph(s) (adequate for identification) NEW NOTE Attention is drawn to the Microchipping of Dogs Regulations 2014 [3]. NEW l) Written veterinary confirmation of fitness for duty (see 6.1) The note added with regard to the microchipping at point J) covers the law change which came into effect from the 6th of April 2016, and states that all dogs must be microchipped and registered to an approved database by the time they are 8 weeks old. The final paragraph regarding records has more detail and emphasises the retention periods for dog records be subject to review. Records should be kept for three years after retirement or death. Minimum periods of retention of records should be reviewed, if applicable, for particular requirements, especially with regard to potential liabilities for civil action. 4.6 Assignment records A slight change with the inclusion of the word Minimum for the period that records of dogs and handlers assignments should be retained. The previous edition only required records to be kept for three years. NSI Technical Bulletin No. 0036 Page 7 of 17 © NSI 2017 An accurate record should be kept for a minimum of three years of both dogs’ and handlers’ work assignments. 4.7 Health and safety More prescriptive requirements have been added to both the organisations health and safety policy statement and risk assessments. The clause now reads: Organizations should ensure that their health and safety policy statement includes kennelling, training and operational deployment. Organizations should ensure, prior to deployment, that their risk assessment includes consideration of the health, safety and welfare of the dog. 5 Accommodation/husbandry A commentary has been added to this clause to clarify the accommodation of dogs and reads: For the purposes of this British Standard, dogs can be accommodated at either commercial or residential premises, either in kennels or in a domestic environment. 5.1 Accommodation 5.1.1 General No change 5.1.2 Kennels 5.1.2.1 Construction and siting Slight changes to the content of this clause with the construction of the kennel being so that to ensure that it is also free from the Extremes of temperature as well as damp and draughts. The previous editions note has been removed and a new paragraph inserted to cover dogs that are not housed within a kennel. Where a kennel is not used (i.e. inside residential accommodation), particular consideration should be given to the welfare of the dog(s). 5.1.2.2 Beds and bedding No change 5.1.2.3 Size No change NSI Technical Bulletin No. 0036 Page 8 of 17 © NSI 2017 5.1.2.4 Isolation No change 5.2 Hygiene A few changes with two elements being changed from the previous edition. For drain cleaning, Defra approved disinfectant has been replaced with an appropriate disinfectant and the amount of water used for cleaning during current weather conditions has been removed. The following paragraph has been added to cover dogs not housed within kennels: Where a kennel is not used (i.e. inside residential accommodation), particular consideration should be given to the welfare of the dog(s). 5.3 Premises/kennel(s) No change 5.4 Emergency and evacuation procedures for kennels 5.4.1 General A new sub-clause to provide an overview of the required emergency and evacuation procedures for both kennelled and non-kennelled dogs. Organizations should establish procedures for responding to emergencies such as fire, flooding, extreme weather or temperature conditions, intruders, etc. Where a kennel is not used (i.e. inside residential accommodation), appropriate steps should be taken for the protection of dogs in case of fire or other emergencies. 5.4.2 Monitoring No real changes apart from neighbour has been removed as one of the appropriate methods for raising the alarm. 5.4.3 Fire Minor change in that the fire risk assessment should be carried out just for kennelling facilities and not premises as well which was covered in the previous edition. 5.4.4 Evacuation No change. NSI Technical Bulletin No. 0036 Page 9 of 17 © NSI 2017 6 Health and welfare of the dog No changes . 6.1 General Minor change with an additional sentence introduced to cover vaccinations and parasite prevention treatments. Consideration should be given to vaccinations and parasite prevention treatments (e.g. fleas and worms). 6.2 Responsibility This clause was originally under kennelling/husbandry in the previous edition and emphasises the responsibility for the welfare of the dog at all times. An additional paragraph added further enforces this concept and reads: The welfare of the dog is paramount; if there is any doubt in relation to the dog’s physical ability to perform its role, the handler/owner/keeper should immediately take steps to withdraw the dog from duty and seek veterinary advice where appropriate. 6.3 Routines More specific detail has been added to this clause with practices from other areas of the 2009 edition being bracketed under the one heading. The key changes are as follows: A daily general health and well-being inspection of the dog should be carried out. Dogs should be fed, exercised and rested according to their working pattern, taking account of shifts. 6.4 Food and water Apart from the heading change with the addition of water, there are no real changes to the content of the clause. 6.5 Rest and exercise Slight changes with the removal of the public reference with regard to safety with unrestricted exercise. The paragraph now leaves the broader safety concept in situ which acknowledges all potential safety implications not just with the public. NSI Technical Bulletin No. 0036 Page 10 of 17 © NSI 2017 The note on this clause has also had an update and the additional Dangerous Dog Act legislation 1991 has been added as a reference. NOTE Attention is drawn to the Working Time Directive 2003/88/EC [6], the Animal Welfare Act 2006 [4], the Animal Health and Welfare (Scotland) Act 2006 [5] and the Dangerous Dogs Act 1991 [2]. 6.6 End of service Subtle changes to this clause, with the term disposal being removed from the equivalent clause heading in the 2009 edition. An additional statement has been added to the existing paragraph regarding the potential euthanasia of the dog and this should be a consideration: Where appropriate on grounds of health and safety and welfare A new note has been added which provides a reference within the standard for the sale or gift of dogs: NOTE Advice on the sale or gift of dogs is given in Clause 11. 7 Equipment and clothing 7.1 General equipment There are only slight modifications to this clause in terms of more explicit equipment requirements. The collar now needs to have a strong welded “D” clip , as opposed to just strong. Legislation references with in the note remain the same but have been updated in line with amendments. In terms of equipment and cross contamination the previous requirement for all listed equipment to be unique to each dog has been replaced with just Collars and muzzles. 7.2 Safety equipment A canine first aid kit has been added to the detailed safety equipment that should be available. A new instruction has been added requiring that the fire extinguisher, canine first aid kit and general first aid kit are to be readily available whilst at the assignment. Items c), d) and e) should be readily available to the handler at the assignment. NSI Technical Bulletin No. 0036 Page 11 of 17 © NSI 2017 7.3 Muzzle Significant changes here with greater direction being given on the use of muzzles from both a welfare and safety perspective. Muzzles are now required to be available at all times. Before muzzling, the dog should be given an opportunity to drink, as it is easier for a dog to drink without a muzzle. The muzzle should be removed whenever the dog is thirsty. Muzzles not secured to the dog’s collar might be removed by the dog, therefore if the muzzle does not incorporate a collar the muzzle should be secured to the dog’s collar using the attachment(s) provided. Muzzles should be inspected before and after use and should not be used if damaged. A muzzled dog should be supervised at all times by a responsible person. 7.4 Maintenance The only slight change is that the previous requirement for handler equipment checks to be conducted by a member of supervisory staff has been removed. The onus is now on the handler to check all of his dog equipment and maintain the necessary records. 7.5 Uniform The composition of this clause has been reduced substantially, as it previously mirrored the constitution of BS 7499: 2013, 5.4.1. However, although the content has been streamlined, a new note has now been added as a reference for further guidance. NOTE Further guidance on uniforms is given in BS 7499:2013. 7.6 Personal protective equipment No change. 7.7 Identification Company identification card requirements remain extant but a new note has been included providing more specific guidance on the where contracted dog handling sits and the respective licensing requirements. NOTE Contracted dog handling duties as covered by this British Standard are considered to be a form of manned guarding, for which an SIA licence is required. Attention is drawn to the Private Security Act 2001 [1]. NSI Technical Bulletin No. 0036 Page 12 of 17 © NSI 2017 7.8 Records Minor word change with the requirements for equipment issue records to be logged and retained with the handler’s personnel records. The previous stipulation just required them to be logged and filed. 8 Training 8.1 General The content remains largely unchanged with the only slight additional element being that training records now also need to be made available to the handlers for their retention. 8.2 Instructors/trainers No change. 8.3 Induction training Only one change within this clause and that relates to record control in line with the previous clause 7.8. The added sentence reads: Records of induction training should be retained with the handler’s personnel records. 8.4 Basic job training A few changes have been introduced within this clause. Course content remains unchanged but the training timescale of 30 hours and the examination have been removed and replaced with; Training should meet the requirements stipulated by the industry regulator. An additional gap analysis has been introduced and similarly with the requisite record retention requirements being in line with previous clauses within this standard. The employer should carry out a gap analysis for security personnel holding a door supervision license (including those who have transitioned from a door supervision license to a security guarding license) or close protection license who wish to work in the security guarding area. Any training identified by the gap analysis should be provided. Records of basic job training should be retained with the handle r’s personnel records. This change is in line with the requirements of BS 7499: 2013, 5.5.3 and similar to SIA ACS 6.2.4, which requires organisations to ensure that the minimum competence of employees is maintained. NSI Technical Bulletin No. 0036 Page 13 of 17 © NSI 2017 8.5 Handler training Slight amendments with handler training now being required to be a minimum of 50 hours as opposed to lasting a total of 50 hours previously. Handler training may now also include recognition of prior learning, which will acknowledge existing competence against the standar ds and set competencies. Record requirements remain extant: Records of handler training should be retained with the handler’s personnel records. 8.6 Team assessment This clause was formally ‘ Assessment and refresher/on-the-job training ’. The content is similar but the requirements are more succinct and clearly defined. Annual certification has been added as an exaction for all dogs and handlers and the clause highlights that all training and assessments should be recorded and retained in accordance with 4.5, canine records. 8.7 Continuation training The only change is the inclusion of the word maintain in terms continuation training. In context that element of the clause now states: Continuation training should be used to maintain an d advance the handlers’ and dogs’ knowledge and skills. 8.8 Contingency training Minor word change within the note which recommends that contingency training be incorporated within continuation training as opposed to refresher training. The term refresher training is no longer within the new standard. 8.9 Fatigue dogs No changes. 9 Operational requirements 9.1 Operational duties Predominantly the same but with the introduction of two changes: NSI Technical Bulletin No. 0036 Page 14 of 17 © NSI 2017 An additional safety measure has been added to the safe lead operation when working a dog operationally, with the looped handle to now be around the wrist at all times. Specific guidance has now been introduced on the release of a dog from the lead and reads: A dog should only be released from the lead in exceptional circumstances. Any such release should be legally justifiable. The Guard Dogs Act 1975 prohibits a person from using or permitting the use of a guard dog at any premises unless there is a person capable of controlling the dog (“the handler” ) present on the premises and the dog is under the control of the handler at all times except where it is secured so that it is not at liberty to go freely about the premises. 9.2 Assignment instructions No real changes, as the clause continues to recommend the requirements detailed in BS 7499: 2013 with the additional dog elements remaining unchanged. 9.3 Risk assessment No changes . 9.4 Warning signs No changes. 9.5 Emergency contact No changes. 9.6 Welfare No changes. 10 Transport and on-site vehicle kennelling No changes to the existing reference notes. 10.1 Vehicles Minor changes to this clause with general and safety equipment listed in earlier clauses also being able to be carried by the handler as well as held within the vehicle. Vehicle ventilation requirements have been slightly enhanced and the respective sentence now reads: Vehicles should be fitted with a means to provide adequate ventilation and airflow at all times regardless of whether the vehicle is moving or stationary. NSI Technical Bulletin No. 0036 Page 15 of 17 © NSI 2017 10.2 Cages More detailed content has been introduced with an amalgamation of certain elements from 10.5 Welfare in the 2009 edition. The size of the dog should be taken into account when being placed in vehicle cages or within similar confinement. The dog should be able to stand up, turn around and lie down in comfort. Additional specifications have now been added to the cages: Cages should have non-slip flooring, which may be fitted or removable. And Consideration should be given to the design and location of the cage to reduce noise levels experienced by the driver/handler. This adds an additional factor for deliberation to the existing requirement that the dog should be in an area separated from the driver. 10.3 Means of escape No changes. 10.4 Warning signs This clause has been updated slightly with warning signs on cage exits to state that a dog might be on board. A new note has been added which provides guidance on suggested wording for cage warning signs: NOTE Suggested wording could be “Security dogs. In case of emergency, seek expert assistance/call [insert contact number]”. The external vehicle sign requirements remain extant but with the exception being only in exceptional operational circumstances as opposed to unless operationally required. 10.5 Welfare This clause has had an overhaul with the emphasis for monitoring of the dogs welfare when within the vehicles being highlighted initially. When left in the vehicle, dogs should be checked at least hourly by the handler to monitor their well-being. Dogs receiving proper rest periods has been replaced with appropriate rest periods and extreme conditions have been introduced in addition to warm weather as a potential welfare risk, as heat is not the only condition that could cause a dog to be distressed. NSI Technical Bulletin No. 0036 Page 16 of 17 © NSI 2017 The new standard requires that: All necessary precautions should be taken to ensure that dogs do not become distressed (e.g. checks carried out more frequently). 10.6 Daily routine The requirements have been condensed with pre-journey checks remaining but with checks of the dog compartment / cages to now be incorporated post use and cleaned as required with an appropriate disinfectant. 10.7 Transport of sick animals This is a new clause and reads: Vehicles and cages used during the transport of sick animals should be cleaned after use, using DEFRA-approved disinfectant and procedures. 11 Sale or gift of dogs This clause in now a commentary but the main content and requirements remain; apart from the elements detailed below: The previous requirement of not selling or gifting dogs that have been schooled in aggression to under 18s has been removed and replaced with: No dog should be sold or gifted to any persons under the age of 18 When selling or gifting a trained or part-trained dog, any known health and behavioural issues should be disclosed. The previously listed example disclaimer has now been removed. Bibliography The following publications are updated or additions to the Bibliography: Other publications [1] UNITED KINGDOM. [1] UNITED KINGDOM. Private Security Industry Act 2001. London: The Stationery Office. [3] UNITED KINGDOM. Microchipping of Dogs Regulations 2014. London: The Stationery Office. [6] EUROPEAN COMMUNITIES. 2003/88/EC. Directive 2003/88/EC of the European Parliament and of the Council of 4 November 2003 concerning certain aspects of the organisation of NSI Technical Bulletin No. 0036 Page 17 of 17 © NSI 2017 working time. Luxembourg: Office for Official Publications of the European Communities, 2003 [8] UNITED KINGDOM. Road Traffic Act 1988. London: HMSO. [10]EUROPEAN COMMUNITIES. Council Regulation (EC) No 1/2005 on the protection of animals during transport and related operations. Luxembourg: Office for Official Publications of the European Communities, 2005. The following publication has been removed: CIEH. Model licence conditions and guidance for dog boarding establishments. Chartered Institute of Environmental Health, October 1995. ISBN 0 900103 47 7. 2)