Armaguard submission to CiT inquiry

Response to the TWU’s submission to the
Road Safety Remuneration Tribunal on the
Cash In Transit Industry in Australia and
Draft RSRO
31 October 2014
1.
Response to TWU Submission
Linfox Armaguard Pty Ltd (Armaguard) has reviewed the submission (TWU’s Submission) and
Draft Road Safety Remuneration Order (TWU Draft RSRO) made by the Transport Workers Union
(TWU) on 17 October 2014.
In relation to the TWU’s submission, we note the following:
a) Risk assessments:
In its submission the TWU has suggested that the Risk Assessments must be undertaken
by ‘competent and independent persons’. We are concerned that the term ‘independent’
may be interpreted as meaning a person who is not employed by the relevant CIT
Company. This should not be the case. The risk assessors must be empowered to
undertake their risk assessments with the safety and security of the CIT Worker’s,
customer’s employees and general public being their paramount concern, but that does not
necessitate them being independent of the relevant CIT Company.
Armaguard considers that the frequency of risk assessments being undertaken should be
prior to the commencement of services at that site and again whenever changes are made
to the site which may impact on the risk profile of that site or the validity of the risk
assessment previously undertaken on that site, or after any security related incident, or
submission of a hazard report by Road Crew. It is not appropriate to have it at the renewal
of a contract as CIT contracts can be for a relatively short period of time or not exist at all.
b) Armoured vehicles
The TWU has not included in its submission the need for a mantrap in every armoured
vehicle. Armaguard’s experience with armed robberies over the years demonstrates the
necessity for a system of secure portioning which allows the crew to enter and exit the
vehicle without exposing the crew, and which restricts access to the vehicle’s cargo by
persons other than the crew.
c)
Cash Limits
Armaguard agrees with the proposed limits on non-armoured work.
In relation to CIT work undertaken in armoured vehicles, it should be up to the discretion of
the CIT Operator, taking into consideration the risk assessments relating to the sites that
are to be serviced, the number of CIT Workers crewing the vehicle and presence of a
Random Support Officer (RSO), if any, as well as their relevant insurance limits, to
determine the appropriate limit both across the pavement and in the vehicle.
d) Non-Slip Footwear
Armaguard agrees that employees should wear non-slip footwear to undertake CIT Work.
It does not, however, believe that it should supply the footwear as the needs of the workers
are many and varied when it comes to their podiatry requirements and we would not like to
interfere with their choice of footwear.
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e) Random Support Officer
Armaguard considers that, contrary to the assertions made by the TWU in its submission,
the presence of RSO’s at sites where CIT Work is to be undertaken, should be
randomised. The determination as to where and when a RSO is deployed should be made
in consideration of the risk assessments undertaken ion the relevant sites and any
intelligence regarding safety and security at the sites at the time. RSO’s should not be
allocated to every CIT job undertaken. It is well known, that having an RSO on each job
would make it predictable and lessen the value that the additional set of eyes would
otherwise have if their presence was unpredictable.
f)
Safe remuneration systems
Armaguard is surprised that the TWU are only insisting that CIT Worker’s and contractors
are paid at a rate that is no less than the Award rates. Armaguard CIT Workers are
currently paid, on average, 65% higher than the award1. It is difficult to understand why
the rates paid under the Award are appropriate given the level of skill, qualification and risk
demonstrated by competent CIT Workers.
We don’t consider that the rates under the Modern Award appropriately remunerate skilled
and competent CIT Workers. Accordingly, the TWU should be advocating an increase to
the rates of pay under the Modern Award as well as with industry participants who are
paying substantially less than Armaguard and Prosegur (whose rates of pay are also
substantially above the award).This would encourage participation in the industry by
employees who are willing to invest the time and money in becoming appropriately
qualified and skilled CIT Workers.
2.
Comments on Draft RSRO
Armaguard has reviewed the Draft Road Safety Remuneration Order submitted by the TWU on 17
October 2014 and we commend the TWU for its consultation with industry on its draft RSRO.
There are however, a number of areas that Armaguard considers need amendment:
a) Application of the RSRO to coin trucks
As the definition of Cash includes coin, the minimum requirements that apply to Armoured
and Non-Armoured vehicles in the draft RSRO apply to vehicles in which coin alone is
transported.
This is problematic as the payload that an armoured vehicle can carry is limited due to the
ballistic material used during the construction phase. For example, a vehicle which would
be rated to carry 5 tonnes may only be able to carry a reduced to a payload of 1-1.5 tonne
of coin after armouring, fuel and crew.
Armaguard’s armoured vehicles are often limited in the number of ATM servicing and cash
(banknote) deliveries and collections that can be done due to the volume of coin which has
been collected or delivered to customers. Coin, in these non-dedicated coin vehicles, can
be up to half of the payload and reduce our capability of servicing ATMs and undertaking
cash collections and deliveries by up to 80%.
1
Based on eastern seaboard rates of pay
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Industry standard weights for coin bags is 6.5kgs. Keeping to these weights the value of
coin held in each bag is:
$2 coin bag value $2000
$1 coin bag value $1000
50c coin bag value $200
20c coin bag value $100
10c coin bag value $100
5c coin bag value $100
Total value $3500
Total weight 39kgs
For bulk transports of coin [to major retailers, the banks, between the Mint and our depots
ad between our depots], Armaguard uses dedicated coin vehicles. These coin vehicles are
fitted with tail lifts that are capable of carrying up to 5 tonne of coin on pallets and coin
deposit bins. These vehicles are not armoured, but are all fitted with appropriate security
features.
Coin is heavy. To address this issue from a work health and safety perspective,
specialised equipment and operating procedures are required on all dedicated and nondedicated coin vehicles to assist with the transport of coin and reduce the potential for
injuries to our employees.
In armoured vehicles where coin is carried, appropriately designed coin trolleys and safe
work operating procedures have been put in place to reduce the likelihood of our
employees being injured whilst handling the coin.
Armaguard’s bulk coin transportation vehicles can carry up to 10 tonne of coin and they
have been modified to allow for pallets of coin to be placed into the vehicles and fitted with
tail lifters for non-palletised coin repositories. The coin vehicles have security features
such as GPS, radios, duress alarm and mobile phones. The vehicles are marked “coin only
no cash on board”.
Armaguard has also deployed specialised coin vehicles to service banks who have
deployed coin acceptance machines into their branches which have coin bins attached to
them which requiring collection. These bins can weigh up to 100kgs each, and cannot be
loaded onto a conventional armoured vehicle. These specialised coin vehicles are covert
and are fitted with tail lifters on the rear to assist our employees with loading the coin bins
collected.
The value of the bulk coin transported in the coin vehicles often exceeds the non-armoured
vehicle limit advocated by the TWU in its draft RSRO, but, based on our industry
experience and risk assessments, the likelihood of an armed attack on crews transporting
coin is low due to the logistics of stealing large sums of it. The risk reward simply is not
there.
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Accordingly, Armaguard believes that due to the complexities surrounding the
transportation of coin, it should not be subject to a Road Safety Remuneration Order or
any Road Safety Remuneration Order should deal with it separately to the requirements for
non-armoured and armoured vehicles.
b) Risk Assessments
We refer to our response to the TWU’s submission in paragraph 1.1(a) above regarding
the frequency with which risk assessments should be undertaken.
The TWU Draft RSRO suggests that separate risk assessments should be undertaken for
armoured and non-armoured services. In our experience, the risk assessment is one of
the factors that dictate whether armoured or non-armoured services are to be used and as
such it is more appropriate for one risk assessment to be done which considers the optimal
service to be provided.
Armaguard is concerned with the consultation and dispute resolution procedures proposed
in relation to risk assessments as they are unnecessarily burdensome.
c) Standard Operating Procedures
The requirement to describe sites by code rather than by name would be appropriate if CIT
Companies are still using publicly accessible communications channels. Where this is not
the case, it is administratively burdensome to encode information regarding sites and can
lead to confusion for employees as well as increased costs of modifying IT systems.
d) Identification of vehicles
In paragraph 32 of the TWU’s Draft RSRO, the TWU advocates both the overt display of a
company’s livery on an armoured vehicle and the covert disguise of armoured vehicles
without any livery to be displayed. In our view, all armoured vehicles should overtly display
their livery.
e) Personal Protective Equipment
Armaguard refers to its commentary in paragraph 1(d) above in relation to the inclusion of
the requirement to supply non-slip footwear.
f)
Cash Limits
Armaguard refers to its commentary in paragraph 1(c) above in relation to the inclusion of
cash limits for armoured work.
g) Escort Systems
In Armaguard’s experience, the benefit of escorts is when their presence is not readily
predictable. Crewing levels, as discussed below, should be determined in accordance with
the Risk Assessments, which should also identify when random support officers should be
deployed.
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h) Crewing Levels
Armoured believes that the risk assessment should identify the appropriate number of crew
to be manning a vehicle. There may be circumstances where it appropriate that a one
man crew is utilised.
i)
Remuneration
We refer to our response in paragraph 1(f).
3.
Further comments
In Armaguard’s “Submission to Road Safety Remuneration Tribunal on the Cash In Transit Industry in
Australia” dated 26 August 2014, we advocated for the introduction of National Standards for Safety
in the Cash In Transit Industry which would require that:
“CIT Road Crew, CIT Industry Participants and acquirers of CIT Services must not engage or
procure others to engage in the provision of CIT Services unless:
(a)
they have adopted and comply with the Cash in Transit Mandatory Code of Practice for
Safety Standards in the CIT Industry (Cth); and
(b)
they comply with, or procure that CIT Industry Participants comply with:
(i)
all applicable laws, regulations and rules for the licensing of firearms in the
relevant State or Territory, or States or Territories in which they provide CIT
Services;
(ii)
all applicable laws, regulations and rules to hold a valid security licence in the
relevant State or Territory, or States or Territories, in which they provide CIT
Services; and
(iii)
the Code of Practice on managing cash-in-transit security risks made under
section 274 of the Work Health and Safety Act 2011 (Cth) as replaced or
amended from time to time.”
We consider that our submission regarding the National Standards for Safety should be amended as
follows:
“CIT Road Crew, CIT Industry Participants and acquirers of CIT Services must not engage or
procure others to engage in the provision of CIT Services unless:
(c)
they have adopted and comply with the Road Safety Remuneration Order for the Cash
In Transit industry issued by the Road Safety Remuneration Tribunal on x date, as
amended or replaced from time to time; and
(d)
they comply with, or procure that CIT Industry Participants comply with:
(i)
all applicable laws, regulations and rules for the licensing of firearms in the
relevant State or Territory, or States or Territories in which they provide CIT
Services;
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(ii)
all applicable laws, regulations and rules to hold a valid security licence in the
relevant State or Territory, or States or Territories, in which they provide CIT
Services; and
(iii)
the Code of Practice on managing cash-in-transit security risks made under
section 274 of the Work Health and Safety Act 2011 (Cth) as replaced or
amended from time to time.”
We would also like to re-iterate our position that the RSRT must recommend that the Commonwealth
seek cooperation from the States and Territories in relation to:
a) Licencing of participants in the CIT industry – a uniform approach must be taken to licensing of
participants in the industry. This includes ensuring that the owners and operators as well as
the relevant employees of CIT businesses are suitable persons and are appropriately qualified.
Due diligence must be undertaken on all owners, operators or persons employed or engaged
in the provision of CIT Services (including known associate/intelligence checks);
b) Minimum Training standards for obtaining and retaining security and firearms licences – this
must include pre-employment qualifications and annual refresher training for all employees
and must reflect the requirements in the TWU’s Draft Submission as a minimum;
c) Annual Audits must be undertaken by CIT businesses confirming their compliance to the Road
Safety Remuneration Order, Licencing requirements, compliance with training obligations and
employee due diligence. The Annual Audits must be submitted to the relevant regulatory
body in each state and be subject to review; and
d) Enforcement – the relevant regulatory bodies must have the ability to enforce the Road Safety
Remuneration Order with fines for breaches and the ability to remove unsuitable persons
from the operation of CIT businesses. We understand that the Fair Work Ombudsmen will
have jurisdiction to enforce compliance to the RSRO, however, the state licencing bodies
should regulate the CIT industry’s compliance to their licence conditions.
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