Monopoly or consistency?

The world of standards inspection is opaque. Like is often erroneously compared with not-like, and generalisations seemingly rule the roost. To tease out the nuances, then, it is necessary to dig a little deeper.

There are several differentiations which apply to the inspection process, and it’s here that we need to touch on the important ones: commodity, quality and consistency.

Two opposing views exist with respect to how an inspectorate should operate in the commercial world. Some view inspection as merely another service subject to market forces. Therefore, if inspection is too tough or expensive, the market will offer cheaper and easier alternatives.

Our view is that, rather like any public service, inspection should not be treated as a commodity. If it is left to a market to determine whether to seek high standards or low, the lowest common denominator – frequently determined by price, of course – will tend to prevail. Any attempt to drive up standards is immediately undermined by the ability to opt-out. It is desirable for a customer to be able to choose a commodity service level. It is not realistic for a ‘public’ service to be treated in the same way. If it were, we would have different benchmarks applying to the provision and measurement of standards in education, policing, healthcare and every other area where public delivery standards are vital.

At this point, it’s worth noting the medical profession promises that all patients receive a safe operation, not that higher risks (based on cost differentiators) can apply to those less able or willing to pay.

Limitations on accreditation

There is a range of quality within different inspection regimes, from the high – where we would claim the National Security Inspectorate (NSI) is well established – to the low.

All well and good if formal cataloguing were occurring in terms of risk potential. Decisions could then be made on how much risk a company or its customers was willing to take.

The problem is that no such ‘catalogue’ exists. There are merely minimum benchmarks which apply to everyone. Thus the weak immediately claim that they are the same as the strong, when the truth is they have merely passed the same basic test and no more.

One test we frequently use in the security industry is UKAS accreditation, but this comes with major limitations. While UKAS – or a similar body – is able to define the baseline, no credit is given for those that excel. A simple analogy is that of the much-discussed GCSE. Two pupils may have passed a GCSE in English Language, for example, so in one sense they are the same. However, when one pupil is awarded an A* grading and the other an E, then in the most important sense of all (ie common sense) they are clearly worlds apart.

The UKAS system is only there to mark a pass, and those who use this type of argument are the E-graders, not the A* students whose achievements are very much undermined by the ‘minimum standard’ interpretation.

The most important element of any inspection regime is consistency. As I have argued before in the pages of SMT, the standard itself is secondary to its accurate and consistent measurement. It is hard enough to maintain consistency within a single inspection regime. At the NSI, we spend a great deal of time on training, education and internal audit to ensure that, for instance, the interpretation of a tiny clause given by one inspector to a company in Newcastle is exactly the same as another company in Bristol will receive.

Companies need to have faith that they and their competitors are being treated in exactly the same way, and customers need to know that all (appropriately tiered) NSI-approved companies will perform in the same way, regardless of their size or location. Once several different inspection bodies are involved, however, consistency becomes the first casualty.

The toughest of regimes

The difficulties of internal synchronisation are multiplied exponentially when a range of bodies is operating in the same arena.

Companies need to have faith that they and their competitors are being treated in exactly the same way, and customers need to know that all (appropriately tiered) National Security Inspectorate-approved companies will perform in the same way, regardless of their size or location

Different regimes, schemes, individuals, commercial approaches and inspection time allocated to inspect what is supposedly exactly the same process apply to every inspection body. We aim for the toughest regimes, have developed the most comprehensive schemes, have selected and trained the very best people we can, work strictly on a not-for-profit basis and spend more time auditing our companies than any of our ‘competitors’.

Not surprisingly, perhaps, I strongly believe that we are head and shoulders above others in the way in which we approach our work.

So far in this article, the reader may be forgiven for thinking that I am leading up to the case for a monopoly. True, all the public service arguments support the idea of a single inspection process for our industry. The frustration of operating in an environment in which your standards are constantly undermined and then described as being equivalent – followed up by the argument that competition between inspectorates is a healthy thing – is sometimes completely dispiriting.

At the NSI, we simply cannot understand why the problems this causes to the industry are not thought through and strong action is not being taken to support our case for consistency. It is not the unfairness of our predicament that really matters at all. It is the unfairness that is then passed on to the best companies (wherein although they perform to a high standard, their customers may be persuaded that they are equivalent to the low).

The paradox is that a monopoly does not actually suit the NSI either. In the security guarding inspection ‘market’ which has been created, we have gained support from around 220 of the 300 practitioners which are subject to any form of self-regulation in a potential market of 2,000-2,500 companies. We have done so by being selective. Our niche is the top end of the market, and our proposition is that we seek only the best. Our whole not-for-profit business model is based on the willing volunteer, not the pressed man.

Deflecting us from the task

Last month, we accepted a handful of new companies (some of whom had taken a considerable time to meet our requirements) and invited around 50 to ‘carry out further work’. Those 50 took up time and effort merely to process, and they provided marginal income to fund this work.

Some rejected applicants are confrontational and occasionally threatening. In a monopoly, the ratio of good to bad applicants would be far worse, driving up the aggravation to us and deflecting us from supporting existing approved companies. Worse, we may be subject to political pressure to reduce our standards, since the rejected applicants would have nowhere else to go.

Far from being our dream, in the current regulatory regime a monopoly is quite close to being our worst nightmare.

Freedoms would be lost

The outcome of all this agonising – and we do see ourselves as being somewhere between the devil and the deep blue sea – is to press for a reasonably high, consistent standard while retaining the freedom to exceed it. Exactly what we will always seek to do, in fact. I hope this clears the air.

In the article I wrote for the August edition of SMT (‘Passport to The Promised Land’, pp43-44) we were seeking the passporting of NSI schemes into the ACS since this would involve minimal duplication, would give credit to those companies which have achieved high standards under voluntary regulation and would provide the flexibility for our version of independent certification to continue to operate well at the top end of the market.

It is heartening to see the Security Industry Authority embarking on a route towards consistency for the ACS, but the argument we were putting forward was that passporting offers the best of both worlds.