Address: Verwaltungs-Berufgenossenschaft, Deelbögenkamp 4, D-22297 Hamburg
Phone: 49 40 5146 2550
Fax: 49 40 5146 2013
Growing security needs as a result of generally rising criminal activity, the opening of the borders to the East and within the European Union, as well as the accession of the former German Democratic Republic, have led to a disproportionate growth in the number of commercial guard and security companies as well as the number of employees of these companies in Germany.
At the start of 1995 the number of employees in the more than 1,200 guard and security companies stood at over 155,000. The mid-sized companies have mostly 20 to 200 employees. There are also companies, however, with fewer than 10 employees and others with several thousand. Company mergers are increasingly common.
The Administration Trade Organization is responsible for legal accident insurance for these companies and their employees.
Accident Prevention Regulations
Background of the accident prevention regulations and their scope of application
With the rising occurrence of accidents, the “Guard and Security Services” (VBG 68) Accident Prevention Regulation that had been in force since May 1964 in guard and security work became outdated. It has therefore been reworked and completely redrafted, with the participation of representatives of the affected employers, employees, accident insurance companies, manufacturers’ and trade organizations as well as representatives of the Federal Minister of Labour and Social Questions, the state industrial oversight authorities, the Federal Minister of Defence, the Federal Crime Office, the state police authorities, other institutions and a specialized committee. This committee is an organ of the central office of the Safety and Health Trade Organization of the industrial trade organizations, under the responsibility of the Administration Trade Organization.
The newly drafted accident regulation went into effect 1 October 1990, after several years of consultations. The regulation is the legal standard for all employers and employees in guard and security companies. It lays out duties and lines of authority upon which newly drafted governmental ordinances specific to each specialty are based.
Guard and security work to protect persons and valuables includes:
General responsibilities of the employer
The employer or his or her agent may employ only persons who are currently qualified and adequately instructed for the desired guard and security activity. These qualifications are set out in writing.
The conduct of the personnel, including notification of deficiencies and particular dangers, must be regulated with detailed service instructions.
If particular dangers result from guard and security work, adequate supervision of the personnel must be ensured.
Guard and security tasks should be taken on only when avoidable dangers in the working area have been eliminated or secured. To this end, the scope and course of the security, including known side activities, must be set out in writing.
The employer or his or her agent, independent of the client’s duties, must ensure that the property to be secured has been inspected for dangers. Records of these inspections must be kept. These inspections must take place on a regular basis and also immediately when the occasion warrants.
The employer or his or her agent must require of the client that avoidable dangers be eliminated or dangerous locations be secured. Until these security measures are implemented, regulations should be formulated that guarantee the safety of the guard and security personnel in another manner. Inadequately secured danger zones should be excluded from surveillance.
The guard and security personnel must be instructed on the property to be secured and its specific dangers during the time period when the guard and safety activity will take place.
The guard and security personnel must be supplied with all necessary facilities, equipment and resources, especially appropriate footwear, effective flashlights in darkness, as well as personal protective gear in good condition, as needed. The personnel must be adequately instructed in the use of such resources. Equipment and other resources that are worn must not unduly restrict freedom of movement, especially of the hands.
General duties of the employee
Employees must abide by all occupational safety measures and follow the service instructions. They should not accede to any directives from the client that contravene the safety instructions.
Deficiencies and dangers that are discovered, as well as corrective measures taken, must be reported to the employer or his or her agent.
The employees must use the equipment and resources provided appropriately. They may not use or enter installations if not authorized.
Employees must not use alcoholic beverages or other intoxicants while on duty. This also applies for an appropriate time period before work: the employee must start work sober.
Employees who must wear glasses to correct their vision during guard or security work must secure these against loss or bring a replacement pair. This also applies to contact lenses.
Use of dogs
In general, only dogs tested and approved by appropriately certified and competent dog handlers are to be used for guard and security work. Untested dogs should be used only for warning tasks when they are clearly under the control of their handler, but not for additional security tasks. Dogs that have vicious tendencies or that are no longer sufficiently competent must not be used.
Excessive demands should not be put on the dogs. Adequate education and training based on the results of research on animal behaviour must be provided. Proper limits for period of service, minimum rest times and total daily service times need to be set.
The competence of the dog handler must be regularly certified. If the handler is no longer adequately qualified, authorization to handle dogs should be withdrawn.
Regulations must be formulated to guarantee smooth and safe handling of dogs, contact with the dog, the taking over and turning over of the dog, leashing and unleashing, a uniform set of commands used by different handlers, the handling of the leash and conduct when third persons are encountered.
Minimal requirements are prescribed for dog kennels concerning condition and equipping as well as setting access authorization.
When transporting dogs, a separation between transport area and passenger area must be maintained. Car trunks are not suitable under any circumstances. Separate facilities for each dog must be provided.
Use of firearms
Employees must use firearms only on express instructions of the employer or his or her agent, in accordance with all legal requirements and only when the employee is appropriately reliable, suited and trained.
Those carrying firearms must regularly participate in target practice at authorized firing ranges and prove their skill and knowledge. Corresponding records must be kept. If an employee no longer fulfils the requirements, firearms must be withdrawn.
Only officially tested and approved firearms are to be used. The firearms should be tested by experts periodically, and also whenever an inadequacy is suspected; they must be repaired by trained and officially approved persons.
Guards and security personnel must not have or use blank- or gas-firing weapons. In confrontations with armed perpetrators, these weapons provide a false sense of security that leads to extreme danger without adequate possibility of self-defence.
Strict regulations guarantee the flawless and safe use, carrying, transfer, loading and unloading, and storage of firearms and ammunition.
Transporting money and valuables
Due to the high risk of robbery, at least two couriers must be employed for transporting money in publicly accessible areas. One of these must be exclusively occupied with security. This applies also to the couriers’ movements between money transport vehicles and the locations where the money is picked up or delivered.
Exceptions are permitted only if: (1) the money transport is not recognizable by outsiders as a transport of money either from the clothing or equipment of the personnel, or from the vehicle used, the route taken or the course of the transport; (2) the incentive for robbery is significantly reduced by technical equipment that must be clearly recognizable by outsiders; or (3) only coin is being transported, and this is clearly recognizable by outsiders from the conduct and course of the transport.
Technical equipment that considerably reduces the incentive for robbery includes, for example, devices that either constantly or during the entire transport are firmly attached to the money transport container and that, in the case of a forced conveyance or snatching during delivery, automatically either immediately or after a timed delay set off an optical alarm by means of a release of coloured smoke. Additional devices such as simultaneous acoustic alarms are advisable.
The design, form, size and weight of money transport containers must be adequately manageable for carrying. They must not be attached to the courier, as this poses an increased risk.
Money transport with vehicles should in general be carried out only in vehicles specially secured for this purpose. These vehicles are adequately secured when their construction and equipment meet the requirements of Accident Prevention Regulation “Vehicles” (VBG 12) and especially the “Safety Rules for Money Transport Vehicles” (ZH1/209).
Money transport in unsecured vehicles is permissible only when exclusively coin, clearly recognizable as such, is being transported, or it is completely unrecognizable as a transport of money. In this case neither the clothing nor equipment of the personnel, nor the construction, equipping or markings of the vehicle used should indicate that money is being transported.
Transport times and routes as well as loading and unloading locations needs to be varied. Money transport vehicles must also be constantly occupied by at least one person behind barred doors during loading and unloading in public areas.
Alarm centres and vaults
Alarm centres and vaults must be adequately secured against assault. The minimal requirements are the Accident Prevention Regulation “Tellers’ windows” (VBG 120), which governs securing and equipping credit and money-changing institutions that deal with cash.
There are practical limits in all attempts to improve occupational safety. This is especially clear in guard and security work. Whereas in other areas, structural measures and improvements lead to success, these play only a secondary role in guard and security work. Significant improvements in this area ultimately can be achieved only by changing the company organizational structure and human conduct. The newly drafted Accident Prevention Regulation “Guard and Security Services” (VBG 68), which may seem exaggerated and too detailed on superficial viewing, nevertheless takes this basic knowledge into very particular consideration.
Thus it is not surprising that since regulations have taken effect, the reportable accidents and occupational diseases in commercial guard and security companies have declined by about 20%, despite the generally increasing crime rate. Some companies which have especially conscientiously implemented the Accident Prevention Regulation, and additionally have voluntarily applied supplementary security measures based on a criteria catalogue that is available, were able to register decreases in occurrences of accidents and occupational diseases of up to 50%. This was especially true in the use of dogs.
Furthermore, the totality of the measures taken led to a reduction in the mandatory premiums for legal accident insurance for commercial guard and security companies, despite rising costs.
Overall it is clear that secure conduct can be achieved in the long run only with precise norms and organizational regulations, as well as through constant training and checking.
Working in the Bank: Now Safer for the Personnel
What long-term measures can be taken to reduce the attraction of robbing a bank? The new provisions in Germany’s Accident Prevention Regulation (APR) for “Teller’s window” (VBG 120) significantly minimizes the risk to employees of being injured or killed in bank robberies.
A precise knowledge of the conduct of bank robbers is crucial. To this end, the Administration Trade Organization has been studying bank robberies since 1966. These studies have shown that, for example, bank robbers prefer small bank branches with few employees. Approximately one-third of bank robberies occur shortly after opening or just before closing. The goal is to leave the robbed bank as quickly as possible (after 2 or 3 minutes) and with the largest possible haul. Many bank robbers work under the wide-spread misconception that DM 100,000 and more can be taken from a teller’s window. The results of these and other studies are contained in the sections “Building and equipping” and “Operations” in the “Teller’s window” APR. Measures that drastically reduce the bank robbers’ expectations are proposed here to protect the employee. The success of these measures depends upon the employees strictly adhering to them in daily practice.
What basic requirements are set in the “Teller’s window” APR? In paragraph 7 of the “Teller’s window” APR, the central requirement is laid out: “Protecting the insured requires securing the banknotes so as to considerably reduce the incentive for robbery”.
What does that mean in daily practice? Easily accessible money should be kept and worked with in publicly accessible areas only within rooms separated from the public by bullet-proof or break-proof sections.
The maximum amount of accessible money allowed is given in paragraph 32: a combined maximum of DM 50,000 is allowed if there are bullet-proof tellers’ windows, other break-proof safeguards and at least 6 employees present. DM 10,000 may not be exceeded when using break-proof safeguards (but not bullet-proof tellers’ windows) in connection with containers equipped with time-staggered releases. There must be at least 2 employees present at all times, who must be in eye-contact.
To keep the incentive for bank robbery as low as possible, amounts of accessible money should be kept well below the maximums set in the “Teller’s window” APR. In addition, paragraph 25 calls for company instructions to set the maximum allowable accessible amounts for each branch. Larger amounts necessary for business and other needs should be secured in time-lock containers to make access by bank robbers more difficult.
Tellers’ windows that are not equipped with bullet-proof or break-proof safety guards and have no central money supply facility or employee-operated automatic teller machine should not have any accessible banknotes on hand.
Securing Windows and Doors
Personnel entrance and exit doors to teller areas containing cash must be secured against viewing or entering from outside, so that bank robbers cannot easily intercept employees entering and leaving bank rooms. The employee must be able to ensure, with built-in peepholes, that no danger exists.
To prevent unnoticed entrance by bank robbers into bank rooms, door closers must ensure that doors are always kept closed.
Since a considerable incentive for theft arises from viewing banknotes, windows behind which banknotes are handled must be secured against viewing or penetrating. Statistics show that holding strictly to this requirement results in very few bank robberies through windows or personnel entrances.
In contrast to personnel entrance and exit doors, doors for public traffic must have a clear view. Bank robbers can thereby be recognized early and an alarm sounded to bring assistance. Therefore it is important that the view not be obstructed by placards or the like.
Optimal Room Surveillance
In order to be able to identify the bank robber as quickly as possible, and to have effective evidence for court, optimal room surveillance equipment is prescribed in the “Teller’s window” APR. This is also important for determining whether the robber extorted money or threatened employees, since particularly brutal actions increase the penalty. Good pictures reduce the incentive to rob a bank.
The instruction “Installation directions for optimal room surveillance equipment (ORSE) SP 9.7/5” of July 1993 permitted only individual cameras as standard ORSE. Photographs are superior to video shots for identification because of greater detail recognition, resulting in better evidence. The disadvantage lies in the fact that photos are available only after the camera is triggered. Because of technical advances, the Administration technical committee now also permits the use of video cameras as possible ORSE. The corresponding instruction is now being prepared; it provides that the limited resolution of video pictures should be compensated for by using 2 views. For this, at least 2 cameras must be installed for recognizing the robber and for videotaping essential events.
Appropriate installation of the video technology can continuously record, and a “wanted” photo can thus be available without special triggering. The further advantages of the system include colour shots, quicker availability of “wanted” photos, transmission of the pictures to the police even during the robbery and the ability to constantly check the functioning of the camera.
Teller’s Window Security
The “Teller’s window” APR authorizes:
Furthermore, customer-operated teller machines support the requirements of paragraph 7, since their use can reduce the amount of money in the booth or separated room.
In order to comply with the “Teller’s window” APR, the number of employees needed at the counter and the amounts to be taken in and paid out (quantity and number) must be known before a tellers’ counter is built or remodeled. Optimal security can be achieved only when counter security corresponds to the actual flow of business.
Constant Presence with Eye contact
Certain teller security measures require a minimum of 2 to 6 employees having eye contact with each other. This requirement flows from the recognition that bank robbers prefer smaller branches with higher yields, where the tellers, when threatened with a gun, cannot withdraw behind bullet-proof shielding.
Break-proof teller shielding can be used only when 6 employees with eye contact are always present in the counter area. This does not mean a 6-person location, where not everyone is always at their workplace due to vacation, sickness, customer visits and so on. Experience shows that this condition can be fulfilled only when 8 to 10 employees work at the location. Alternatively, a floater service can possibly be used to ensure the necessary minimum number of employees.
To guarantee the constant presence of 2 employees with eye contact, the location must have 3 to 4 positions.
It is important that the facility not be opened before the required minimum number of employees are present. When consultations are taking place in adjoining rooms, the minimum number of employees at the windows must still be maintained.
Security through Separation
“Small branches” are those where the presence of at least 2 employees with eye contact in the counter area is not ensured. For these branches, bullet-proof shielding in connection with break-proof separations offers good protection, since the employee does not have to leave the secured area in the event of a robbery. Consultations are carried on in an area protected by break-proof shielding. Good communication is possible here. The bullet-proof shield, behind which the accessible cash must be kept, should be placed so that employees cannot be threatened with a weapon from the customer area. Money transactions take place by way of a prescribed hatch or sliding drawer. Since the employee must go into the bullet-proof-secured area in the event of an attack, the necessary personal security is provided. This area must not be left under any circumstances, including while handing money over to the robber.
Bullet-proof full separation presents an alternative for 1- to 3-person teller operations. It offers mechanical protection against the typical bank robbery, since all employees are separated from the robber by bullet-proof shielding. The disadvantage here is that communication with customers is reduced in the interest of security. So full bullet-proof separation is appropriate only for small branches.
The teller’s booth is a form of security in which only the teller’s work station is separated from the customer area. This possibility makes sense only for teller jobs in which the teller is fully occupied by his or her work in the booth and does not have to leave it.
Before installing a booth, it is necessary to determine whether the teller is fully occupied handling money. In smaller branches with only 2 to 4 employees, this is often not the case. If the teller has other tasks outside the booth, the security requirements of the APR are not met, since the teller is supposed to always be separated from the customers for protection against bodily attack. In practice what repeatedly happens is that while the teller is performing tasks outside the booth, the door is held open with a wedge or the key is left in the lock. Thus the security of the teller’s booth is compromised, which is of great interest to potential robbers.
The bullet-proof teller’s booth does hinder communication between the teller and customers. But since longer discussions take place in unsecured workplaces anyway, this does not present a big problem. More serious problems include ensuring draft-free ventilation and air-conditioning in small teller’s booths.
For power-driven separations, a movable steel wall, built into the counter, is raised in emergencies by way of several arranged triggers in second intervals. This creates a bullet-proof separation, with the employees behind it in a secure area. To prevent a robber from entering unnoticed, it must be activated whenever there are no employees in the vault area, or when work is being done that requires personnel to turn away from the counters. In order to avoid constant activation of the steel wall, this type of security should be used only in 2- to 4-person teller areas.
Furthermore, the tellers’ workstations can be isolated with bullet-proof separations. For this, full separations for all employees as well as tellers’ booths can be installed. This form of security, however, requires the constant presence of at least 6 employees with constant eye contact in the main hall.
Bullet-proof full separation and tellers’ booths can also be used when a minimum of 2 employees are present with eye contact and the accessible cash does not exceed DM 10,000. A time-release money container is required in this case so that the teller does not constantly have to leave the secured area to restock. Bank robbers avoid teller positions where they can expect only a small amount of cash or have to wait a long time for it. In this case, notice of the time-release container at the entrance and in the tellers’ area is important for the employees’ protection. This makes immediately clear to the potential robber that the employee has no control over the container and that only a small haul can be expected.
Security without Accessible Banknotes in the Main Hall
Security is possible even without building a separation between the employees and the customer area. But for this to reduce the incentive, no accessible quantities of money can be in the tellers’ area. Money taken in must be immediately secured. The money is kept in a cash box in an area not open to the public, so it cannot be threatened by the robber. The employees receive the necessary amounts of money through a tube delivery system in the main hall. Money taken in is sent to the cash box by this means. No minimum number of employees in the main hall is prescribed in this case. This type of security, however, results in longer waiting times for customers. The advantage is that bank robbers have virtually no chance of getting anything in a robbery.
Employee-operated automatic teller machines (ATMs) are a second way to make payments with cash that is not accessible in the main hall. These, referred to by the bank as AKT-designated machines, contain 4 to 6 magazines for holding banknotes in a time-released secured container. For payments, the required amount is called up using a keyboard, with which an alarm can also be sounded in emergencies. The money is delivered to the employee after a time delay. The length of the delay depends upon the amount of money and is set in paragraph 32 of the “Teller’s window” APR. These are set so that good service is possible, but the robber is scared off by the longer waiting times for larger amounts. Cash receipts should be secured by use of time- or double-closing containers.
At least 2 employees with eye contact must be constantly present when using an employee-operated ATM. For this reason, this form of security is appropriate only for locations in which 3 to 4 employees work. Discussions can take place in a conference room only when 2 or more employees are present in the customer area during the discussion.
In the case of a technical problem in an employee-operated ATM, appropriate instructions and measures should be prepared. These should include an emergency cash box and corresponding organizational procedures to ensure that work proceeds in accordance with the “Teller’s window” APR.
Company Directives and Instructions
The employer must prepare company directives for every teller’s window and regularly check on compliance. These directives should outline the possible events during a robbery and describe what to do during and after the robbery. Furthermore, daily instructions should be given, and use of the installed security equipment should be mandated. This is especially true when larger amounts of accessible banknotes are present. Instructions should also prescribe the manner of safekeeping for other valuable objects. Employees at the windows should be instructed in these company policies at least twice a year.
The purpose of these instructions is clear—to ensure that the employees follow the requirements of the “Teller’s window” APR for their own protection, and to significantly reduce the incentive for robbing a teller’s window.