BROWARD OFFICE OFTII E INSPECTOR GENERAL MEMORANDUM To: tevcn Cernak, Chief Execut ive and Port Director, Port Everglades Department Kent George, Aviati on Director, Broward County Offi ce Aviation Department From: John W. coil, Inspector General 1/tj.S Date: July3 1,2012 ubj ect: OIG Final Report Re: Vendor Knowingly Permitted Unlicensed Managers to Oversee Security Services at Port Everglades and tlte Fort Lauderdale-Hollywood Intemational Airport, Ref. 0/G 12-008 Attached please find the final report of the Broward Offi ce of the Inspector General (OIG) regarding the above-captioned matter. The OIG investi gati on found that AlliedBarton ecurity ervices LLC (AIIi edBarton), ), a vendor that provides security services at both Port Everglades (the Seaport) and the Fort Lauderdal e- Holl ywood Internati onal Airport (the Airport), fail ed to ensure that its top offi cials at the eaport and the Airport obtained lega ll y required li censes from the Florida Department of Agri culture and Consumer ervices, Division of Licensing (DOL). pecificall y, we determined that Alli edBartons Di stri ct Manager, Anne Mari e Cummings, and Proj ect Manager, David Macedo, managed day-to-day security operations of li censed security personnel at both the eaport and the Airport without possessing the proper li censes as required by Fl orida law. The investi gati on also determined that AlliedBarton knew that Ms. Cummings and Mr. Macedo were not li censed when they assigned them to manage security functi ons and to direct the acti vities of li censed empl oyees at the eaport and the Airport. The OIG stresses that the investi gati on found no fault with the day-to-day security efforts provided by AlliedBarton at the Seaport and the Airport. ince Mr. Macedo is now appropriately li censed, and Ms. Cummings is no longer with AlliedBarton, we do not recommend any further acti on, and consider thi s matter closed. Attachment cc: Honorable John E. Rodstrom. Jr., Mayor, Broward County and Members. Broward Board of County Commi ssioners Bertha Henry. County Admini strator Indi viduals previously provided a Preli minary Report (under separate cover) John W. Scott. /11\pector General One North Uni,crsit) Drive. Suite Ill Plantation. I- lorida 3332..J (95--1)357-7873 I a:-. 954-357-7857 '' \\ '' bro\\ ardig.org 954-357- II P BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT =========================================================== OIG 12-008 JULY 31, 2012 Vendor Knowingly Permitted Unlicensed Managers to Oversee Security Services at Port Everglades and the Fort Lauderdale-Hollywood International Airport BROWARD OFFICE OF THE INSPECTOR GENERAL OIG 12-008 July 31, 2012 Page 1 of 17 FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT SUMMARY In May 2012, the Broward Office of the Inspector General (OIG) began an investigation into allegations that AlliedBarton Security Services LLC (AlliedBarton), a vendor that provides security services at both Port Everglades (the Seaport) and the Fort Lauderdale-Hollywood International Airport (the Airport)including checkpoint security, patrol duty, opening of gates, checking credentials and traffic controlfailed to ensure that its top officials at the Seaport and the Airport obtained legally required licenses from the Florida Department of Agriculture and Consumer Services, Division of Licensing (DOL). The OIG investigation substantiated the allegations. We determined that AlliedBartons District Manager, Anne Marie Cummings, and Project Manager, David Macedo, managed day-to-day security operations of licensed security personnel at both the Seaport and the Airport without possessing the proper licenses as required by Florida Statutes Chapter 493 (F.S. 493), which regulates the licensing of private security agencies. The failure of AlliedBarton to ensure that Ms. Cummings and Mr. Macedo were properly licensed represents not only misconduct, but a public safety concerna concern summarized by the Florida Legislature as follows: unlicensed person[s] engaged in the private security industr[y] are a threat to the welfare of the public if placed in a position of trust. The investigation determined that AlliedBarton knew that Ms. Cummings and Mr. Macedo were not licensed when they assigned them to manage security functions and to direct the activities of licensed employees at the Seaport and the Airport. Richard Mullan, Vice President/General Manager for AlliedBarton, and the companys top executive in Florida, told the OIG that he knew Ms. Cummings and Mr. Macedo were not licensed when he assigned them their responsibilities, and he did so becausein his opinionthe statute did not require either of them to be licensed. However, when interviewed by OIG Special Agents, officials at the DOL stated that any individual scheduling security guards or otherwise directing their day-to-day activities must be a licensed manager. In fact, Ms. Cummings had applied for a Class D and Class MB license on three separate occasions, and each time the DOL denied her application, in part because it concluded that she did not have the security experience required to qualify for the licenses. The OIG was also informed that AlliedBarton did not train its supervisory personnel in the requirements of F.S. 493. Further, the DOL officials revealed that the company did not seek guidance about the licensure requirements for managers until after it learned of the OIGs investigation.1 The 1 On May 16, 2012, while the OIG investigation was underway, AlliedBarton terminated Ms. Cummings employment and Mr. Macedo applied for his MB license, which he recently obtained. BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 2 of 17 DOL officials also advised that security agencies have a responsibility to be knowledgeable of the statutes, but do not have the latitude to interpret the statutes unilaterally. The OIG stresses that the investigation found no fault with the day-to-day security efforts provided by AlliedBarton at the Seaport and the Airport. Nevertheless, when AlliedBarton failed to ensure that Ms. Cummings and Mr. Macedo were properly qualified and licensed, it violated Florida law, and also violated the terms of its $19.5 million contract (Contract) with the County, while unnecessarily creating the potential for both a public safety risk and possible legal liability.2 OIG CHARTER AUTHORITY Section 12.01 of the Charter of Broward County empowers the Broward Office of the Inspector General to investigate misconduct and gross mismanagement within the Charter Government of Broward County and all of its municipalities. This authority extends to all elected and appointed officials, employees and all providers of goods and services to the County and the municipalities. On his own initiative, or based on a signed complaint, the Inspector General shall commence an investigation upon a finding of good cause. As part of any investigation, the Inspector General shall have the power to subpoena witnesses, administer oaths, require the production of documents and records, and audit any program, contract, and the operations of any division of the County, its municipalities and any providers. The Broward Office of the Inspector General is also empowered to issue reports, including recommendations, and to require officials to provide reports regarding the implementation of those recommendations. ENTITIES AND INDIVIDUALS COVERED IN THIS REPORT AlliedBarton Security Services, LLC Inc. AlliedBarton provides security services at various installations nationwide. AlliedBarton has more than 55,000 employees and 120 regional/district offices located across the United States. In December 2010, Broward County awarded the five-year, $19.5 million Contract to AlliedBarton to provide security at the Seaport and the Airport. The services AlliedBarton provides pursuant to the Contract include providing security services at checkpoints, patrol duty, opening of gates, checking credentials and traffic control, and providing security services for the buildings in which County offices are located. 2 In the preliminary version of this report, the OIG noted that the DOL had requested that we forward it the final report so that it could consider imposing sanctions against AlliedBarton. Because Ms. Cummings is no longer employed by AlliedBarton and Mr. Macedo has now obtained his MB license, it appears that any basis for sanctions no longer exists. Accordingly, the OIG will not be referring this matter for any further evaluation. BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 3 of 17 Richard Mullan Mr. Mullan is a Vice President/General Manager for AlliedBarton. Mr. Mullan is responsible for directing all of AlliedBartons operational, financial and administrative functions in the state of Florida. His office is located at AlliedBartons Deerfield Beach Branch Office. Ann Marie Cummings Ms. Cummings is a former District Manager for AlliedBarton3. She was District Manager from 2007 until AlliedBarton terminated her employment on May 16, 2012. As AlliedBartons District Manager, she was responsible for all security operational services for the Seaport and the Airport. Ms. Cummings reported directly to Mr. Mullan. David Macedo Mr. Macedo is the Project Manager for AlliedBarton. As AlliedBartons Project Manager, he is in charge of AlliedBartons security operations at the Seaport and the Airport. Mr. Macedo manages approximately 145 employees and is responsible for the day-to-day management activities that include scheduling, performance evaluations, security quality assurance checks, and security post spot checks. Until May 16, 2012, he reported to Ms. Cummings. RELEVANT GOVERNING AUTHORITIES AND BACKGROUND Port Everglades The Seaport is one of South Floridas most important economic sites. It is the gateway for international trade, cruise ships, and South Floridas main seaport for receiving refined petroleum products that include gasoline, jet fuel and other forms of alternative fuels. It is also one of Florida's leading container ports, with more than 4,200 ship calls annually. In 2011 it reported operating revenues of approximately $139 million. The Fort Lauderdale-Hollywood International Airport The Airport is an international commercial airport located in unincorporated Broward County. The airport is ranked 21st in the United States and serves more than 23 million passengers annually. It offers approximately 268 daily flights to the US, Canada, Caribbean, and Latin America. 3 Ms. Cummings employment with AlliedBarton was terminated on May 16, 2012. She was terminated by Mr. Mullan less than an hour after the OIG completed its interview of him. During that interview, Mr. Mullan had nothing but praise for Ms. Cummings, describing her as an excellent employee who had received numerous awards for her outstanding work. He further advised that once Ms. Cummings was able to obtain her manager license from the DOL, he would be able to shift more accountability for the Deerfield Beach Branch Office to her. BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 4 of 17 Chapter 493, Florida Statutes F.S. 493 regulates the licensure of private security, investigative, and recovery industries. Sec. 493.6100 states: The Legislature recognizes that untrained persons, unlicensed persons or businesses, or persons who are not of good moral character engaged in the private security, investigative, and recovery industries are a threat to the welfare of the public if placed in positions of trust. Regulation of licensed and unlicensed persons and businesses engaged in these fields is therefore deemed necessary. F.S. 493.6101 Definitions: (3) Licensee means any person licensed under this chapter. (13) Manager means any licensee who directs the activities of licensees at any agency or branch office F.S. 493.6301 Classes of licenses: (1) Any person, firm, company, partnership, or corporation which engages in business as a security agency shall have a Class B license. A Class B license is valid for only one location. (3) Any individual who performs the services of a manager for a: (a) Class B security agencyshall have a Class MB license. A Class M licensee, or a Class D licensee who has been licensed for a minimum of 2 years, may be designated as the manager, in which case the Class MB license is not required. F.S. 493.6303 License requirements: (1) Each agency or branch office shall designate a minimum of one appropriately licensed individual to act as a manger, directing the activities of the Class D employees [security officers]. (2) An applicant for a Class MB license shall have 2 years of lawfully gained, verifiable, full-time experience, or training in (a) Security work or related fields of work that provided equivalent experience or training; (b) Experience described in paragraph (a) for 1 year and experience described in paragraph (c) for 1 year; (c) No more than 1 year using: BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 5 of 17 1. Either college coursework related to criminal justice, criminology, or law enforcement administration; or 2. Successfully completed law enforcement-related training received from any federal, state, county, or municipal agency (d) Experience described in paragraph (a) for 1 year and work in a managerial or supervisory capacity for 1 year The Contract: Security Guard Services for Fort Lauderdale/Hollywood International Airport and Port Everglades RLI #R0821419R1 On December 7, 2010, the Broward County Commission awarded AlliedBarton the Contract to provide security services at the Seaport and the Airport. The Contract calls for AlliedBarton to be paid a maximum of $3,900,000 annually until September 20, 2013, at which time the County can opt to renew it for two one-year periods, not to exceed five-years or $19,500,000. The Contract contains provisions requiring AlliedBarton to ensure that all its personnel are properly licensed: Article 3.4: Throughout the term of this Agreement, ALLIEDBARTON shall keep fully informed of and comply with all federal, state, County and local lawsALLIEDBARTON, its subcontractors, and their officers, agents and employees shall at all times observe and comply with all such laws (Exhibit 1) Article 5.1: Licenses. Prior to commencement of operations pursuant to this Agreement and throughout the initial Term and any Renewal Term, ALLIEDBARTON shall secure and maintain any and all permits and licenses; ensure that such permits and licenses list ALLIEDBARTON as the permittee and/or licensee. (Exhibit 2) Article 8.1: The performance of the services required under this Agreement shall at all times be under the supervision and direction of an active, qualified competent local Project Manager, and such other staff as may be necessary to act in the absence of the Project Manager, who shall at all times be subject to the direction and control of ALLIEDBARTON. A Project Manager shall be assigned to the Airport and Port and shall be available during normal business hours or other hours as designated by the Aviation Department and Port Department. (Exhibit 3) Florida Department of Agriculture and Consumer Affairs, Division of Licensing The DOL is responsible for the issuance and denial of licenses. The DOL receives and examines licensing applications for statutory compliance and verifies the applicant's eligibility for licensing through former employers, educational facilities and the examination of criminal history records. INVESTIGATION This investigation is predicated on information alleging that AlliedBarton assigned two top security management officials to direct activities of security officers and to provide project oversight at the Seaport and the Airport, knowing that those managers did not have the security licenses required by F.S. 493. The OIG investigation substantiated the allegation. BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 6 of 17 The investigation involved the review of substantial documentation by OIG Special Agents including, but not limited to, F.S. 493; the Contract; Request for Letters of Intent No. R0821419R1; contract bid records, licensure application instructions, and a licensing database maintained by the DOL; DOL Case Information reports that applied F.S. 493; and business and personnel records of AlliedBarton. OIG Special Agents also conducted interviews of witnesses including Mr. Mullan, Ms. Cummings, Mr. Macedo, DOL officials, and County officials responsible for overseeing security at the Seaport and the Airport. OIG Review of the Licensing Process and AlliedBartons Failure to Comply with F.S. 493 and the Contract The OIG determined that AlliedBarton possessed a Class B license and was therefore permitted to provide security services at the Seaport and the Airport. However, neither Ms. Cummings nor Mr. Macedo, the two managers AlliedBarton assigned to handle security matters at the Seaport and the Airport, possessed an MB license. In fact, they did not even possess a Class D license, which is required for security guards.4 1. AlliedBarton was Required by Florida Law and the Contract to Ensure that its Security Managers were Properly Licensed The OIG substantiated that Ms. Cummings and Mr. Macedo were perform[ing] the services of a manager for a Class B agency at the Seaport and the Airport and were therefore required to have specific licenses pursuant to F.S. 493. In addition, Mr. Mullan, Ms. Cummings and Mr. Macedo were required to annually execute employee ethics forms wherein they acknowledged AlliedBartons commitment to compliance with all laws, regulations, and guidelines, and that they were subject to discipline for failing to detect non-compliance with legal requirements. (See samples attached as Exhibit 7). a. Anne Marie Cummings A review of information provided by AlliedBarton indicates that Ms. Cummings job duties included overseeing and managing all administrative and operational functions. Operational functions include scheduling, recruiting and training for the district.5 During her interview with OIG Special Agents, Ms. Cummings stated that in 2007 she became a 4 As part of the investigation, OIG Special Agents consulted at length with Fred Speaker, Investigator Supervisor (IS), and George Mamak, Field Investigator (FI), of the DOLs West Palm Beach Regional Office (which includes oversight of Broward County), both of whom stated that all individuals involved in security operations are required to be properly licensed. See emails attached as Exhibit 4 and Exhibit 5, the latter of which was directed to AlliedBarton, but forwarded to the OIG. (We have included these exhibits, and identified the DOL officials by name, in response to AlliedBartons suggestion in its discretionary response that the OIG merely conducted informal discussions with unnamed DOL officials. The OIG interviews of the IS and the FI are summarized below, as they were in the preliminary version of this report). The OIG also reviewed several DOL Case Information reports, one of which is attached as Exhibit 6. In that report, the DOL found that a manager and his supervisor at a nuclear power plant, two-levels removed from the security guards, were both required to maintain manager licenses. 5 Ms. Cummingss brief biographical information that was posted on AlliedBartons website described her as District Manager Broward and Ft. Lauderdale with responsibilities including operational oversight and delivery of services to her clients in the Broward/Ft. Lauderdale area. The website further stated that as part of her area of responsibility, she oversees the Port Everglades/Ft. Lauderdale Airport. (Exhibit 8) BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 7 of 17 District Manager at AlliedBartons Deerfield Beach Branch Office and took over security responsibilities that included overseeing security operations. She added that her primary role was to supervise field managers who managed the day-to-day security operations of their designated locations and to meet with clients to ensure that AlliedBarton was meeting all their security service needs. The Broward County Deputy Port Director (DPD) advised OIG Special Agents that if Mr. Macedo was unavailable, he would contact Ms. Cummings. He added that he recently contacted Ms. Cummings to get additional security guards to address a fire alarm issue that had arisen in a secured area. Ms. Cummings attempted without success to get a security license from the DOL on at least three occasions between 2007 and 2011. (See DOL summary letter, attached as Exhibit 9). First, Ms. Cummings applied for a Class D license on or about January 11, 2007 and was denied licensure because she failed to provide a legible set of fingerprints in a timely manner after being notified by the DOL. Second, Ms. Cummings applied for a Class MB license on or about May 6, 2010 and was denied licensure because she did not hold a Class D license, and because the DOL determined that she did not have the requisite security experience. (See June 22, 2010 DOL letter, attached as Exhibit 10). Third, Ms. Cummings again applied for a Class MB license on or about September 1, 2011 and was again denied licensure because she did not hold a Class D license, and the DOL was unable to verify her security experience. Ms. Cummingss supervisor, Mr. Mullan, stated that Ms. Cummings was an excellent long- term employee who had won numerous awards and was formerly a vice-president, but had been demoted due to company downsizing after the loss of a state contract. He stated that Ms. Cummings was kept on as a manager in order to keep her with the company. b. David Macedo Mr. Macedo had no licensure pursuant to F.S. 493 and had not submitted an application with the DOL as of the issuance of the preliminary report. Mr. Macedo disclosed to AlliedBarton on his employment application that he did not have a security guard license (Exhibit 11), but was hired and assigned as the Project Manager for the Seaport and the Airport projects in Broward County. During an interview with Special Agents of the OIG, Mr. Macedo stated he was the Project Manager for the security projects at the Seaport and the Airport. Mr. Macedos job description also indicates that he manages security officers on-location. He stated that he manages approximately 145 AlliedBarton employees at the Seaport and the Airport, and the OIG determined most of those employees are licensees. Mr. Macedo also stated that as Project Manager, he is accountable for the day-to-day operations of an assigned account, including hiring, training, disciplining and terminating staff. Although Article 8.1 of the Contract plainly states the requirement that the Project Manager be competent and qualified, AlliedBarton placed Mr. Macedo onsite at the Seaport knowing he was not licensed to manage regulated activities of AlliedBarton licensees. Additionally, the Seaport and the Airport components of AlliedBartons scope of work were responsibilities of Mr. Macedo, who only visited the Airport about once every two months. BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 8 of 17 2. AlliedBarton Knowingly Permitted Unlicensed Managers to Supervise Security Operations According to AlliedBarton, Ms. Cummings and Mr. Macedo were in positions subordinate to Mr. Mullan, who holds an active M license which expires in June 2013. Mr. Mullan informed OIG Special Agents that he is the sole manager in charge of oversight for all AlliedBarton security services operations at the Seaport and the Airport. He also admitted that he knew that Ms. Cummings and Mr. Macedo did not possess security licensesand in the case of Ms. Cummings, that her requests to obtain them had been repeatedly deniedbut stated his belief that they did not need to be licensed because they worked at his direction and under the authority of his M license, and had no security duties themselves. F.S. 493 requires that at least one properly licensed individual direct the activities of the security officers. However, Mr. Mullan admitted to OIG Special Agents that he does not direct the activities of the Class D security officers at the Seaport or the Airport, and he stated that he has infrequent contact or interaction with the daily activities on that project. AlliedBartons Area Human Resource Manager stated during an interview with the OIG that she was aware that Ms. Cummings and Mr. Macedo did not have security officer or security manager licenses. She also advised that she was aware that Ms. Cummings had been denied licensure on several occasions because of illegible fingerprints and the fact that Ms. Cummings lacked the required security experience. 3. AlliedBarton did not Undertake Reasonable Due Diligence to Comply with Licensing Requirements a. Failure to provide training During their interview with OIG Special Agents, Ms. Cummings and Mr. Macedo both stated that they had not been trained or provided any information about the requirements of F.S. 493. Specifically, Ms. Cummings stated that she was not knowledgeable of the requirements of F.S. 493 and only heard about the statute during her interview with the OIG. Mr. Macedo stated that since being employed as a Project Manager, no one from AlliedBarton or the County advised him that he needed a security license to manage the regulated activities of licensees. The OIG also determined that in 2011, there were licensing issues regarding some of AlliedBartons D licensees. (See DOL case information summary finding that seven AlliedBarton security officers performed security services while their D licenses were suspended, attached as Exhibit 12). In addition, DOL personnel also confirmed to OIG Special Agents that another investigation, identified in a DOL filing (Exhibit 13), has found that AlliedBarton security officers had failed to comply with DOL training requirements, although a BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 9 of 17 final report has not yet been issued.6 All of the security officers identified in both investigations are employed by AlliedBartons Deerfield Beach Branch Office. When questioned about the DOL investigation referenced in Exhibit 13, Ms. Cummings stated that Mr. Mullan had been aware of that investigation since as early as March 2012, and had cited the existence of it as a reason for her termination.7 In addition, Ms. Cummings stated that it was her understanding that as a result of the investigation, AlliedBarton was fined $750 for failure to submit proof that several of is security officers had completed the training needed to maintain their Class D licenses. Failure to maintain awareness of statutory license requirements The Contract requires that AlliedBarton remain fully informed of statutory license requirements. Nonetheless, it appears thatprior to the OIG investigationAlliedBarton made no attempt to inquire about the managerial licensure requirements. Mr. Mullan stated that he interpreted the word manager, as used in F.S. 493, to mean an employee who performed a security function. In Mr. Mullens opinion, if a manager did not act as a security guard, as in the case of Ms. Cummings and Mr. Macedo, there was no need for them to obtain a security license, despite the fact that they were directing security officers. As a part of the investigation, OIG Special Agents interviewed DOL officials who unequivocally stated that any personnel involved in the day-to-day operations of security services, from corporate directors down to the security officers, are required to possess the appropriate licensure per F.S. 493. The DOL officials also stated that a security agency such as AlliedBarton is required to be aware of, and comply with, all the components of F.S. 493. 4. The DOL Director Has Stated that the Activities of Security Personnel Must be Overseen by Licensed Individuals Before it submitted its discretionary response to the preliminary version of this report to the OIG, the County sought an opinion from the DOL Director (Director) that an AlliedBarton project manager need not be licensed because AlliedBartons office space at the Seaport and the Airport does not constitute a branch office. (See County Administrators July 9, 2012 letter to the Director, attached to the Countys discretionary response at Appendix A) We note that the County framed its query in a manner that conditioned the application of F.S. 493 upon a determination of whether the AlliedBarton offices at the Seaport and the Airport were branch offices, despite the fact that the OIG has never maintained that they were. Instead, we have made clear that our concern is that Ms. Cummings and Mr. Macedo had to be licensed because they were overseeing the regulated daily activities of AlliedBarton onsite security personnel and Mr. Mullanby his own admissionwas not. 6 The July 2, 2012 letter from DOL that AlliedBarton attached to its discretionary response also notes that [a]dministrative action is currently pending against the B license held by the Deerfield Beach Branch Office. 7 In his interview, Mr. Mullan denied any knowledge of the DOL investigation. BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 10 of 17 In his response letter (also attached at Appendix A), the Director agreed that the Allied Barton office space did not constitute a branch office, so that it does not need to be separately licensedas is the AlliedBarton Deerfield Beach Branch Officeand did not require the designation of a licensed individual to act as a manager. However, the Director then confirmed the OIGs finding that under F.S. 493, if an individuals responsibilities include the oversight of security activities, that individual must be licensed. The Director stated that: While AlliedBarton may not have to designate a manager to oversee a branch office in this particular instance, the agency cannot relinquish its responsibility to provide adequate direction and control to the armed personnel providing security services to the Fort Lauderdale-Hollywood International Airport and Port Everglades, two high-profile critical infrastructure facilities. A site supervisor responsible for overseeing the day-to-day activities of security personnel must still be licensed in accordance with the requirements of the law. (Emphasis added) My immediate concern, therefore, is for AlliedBarton to have a properly licensed site manager providing proper command and control to personnel carrying out the security functions at the airport and seaport. To that end, I have expedited the processing of Mr. David Macedos Class MB Security Agency Manager License. INTERVIEW SUMMARIES As a part of the investigation, OIG Special Agents conducted numerous witness interviews. Significant interviews are summarized below: 1. Interviews of DOL Officials The DOL Investigative Supervisor (IS) and Field Investigator (FI) both stated that any personnel involved in the business of providing security services, from the officers and directors on down to the security officers, are required to possess the appropriate licensure per F.S. 493. The IS further stated that if employees of a security company manned a post, supervised regulated activities, scheduled regulated activities, screened applicants, were involved in hiring or firing decisions or evaluated licensees performing regulated activities, they would definitely be required to have the proper licensing. The IS stated that the intent of the statute is clear in that corporate officers, who may never stand a post or even visit a site, are required to go through a background check and have proper licensing. The FI stated that security companies sometimes attempt to circumvent the requirement to ensure proper licensure of managers, and that AlliedBarton would definitely have known that their managers required M or MB licenses. The IS opined that it is illogical for a company to conclude that an on-site or district manager would be excluded from the requirements of the law. The IS verified that the last audit of AlliedBartons Deerfield Beach Branch Office occurred in 2005. The IS stated that recentlyafter the onset of the OIG investigationrepresentatives of AlliedBarton asked the DOL about the requirements for managers to be licensed. BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 11 of 17 2. Interview of Richard Mullan Mr. Mullan stated that he was aware that Ms. Cummings had submitted applications for manager licenses on several occasions and was rejected. Mr. Mullan also stated that he sets goals for all of his managers and one of the goals he set for Ms. Cummings was to obtain her licenses in accordance with F.S. 493. He further stated that he wanted her to get her licenses because he wanted her to be the manager of the Deerfield Beach Branch Office. Mr. Mullan stated that Ms. Cummings was an excellent long-term employee who had received numerous awards for her outstanding work and that when she was able to obtain her manager license, he would be able to shift the accountability for the Deerfield Beach Branch Office from himself to her. Mr. Mullan stated that Mr. Macedo, whom he personally recruited, is a qualified and capable person for the duties he is assigned. Mr. Mullan described the position of Project Manager as an overhead position, and that Mr. Macedo was not required to be on site at the Port, but that AlliedBarton provided a Project Manager on-site because it was a more efficient way to deliver services. Mr. Mullan also admitted that he had always been aware that Mr. Macedo did not possess a license pursuant to F.S. 493, but stated that Mr. Macedos previous tenure as an officer with the U.S. Coast Guard provided sufficient qualifying experience. Mr. Mullan stated that he interpreted the word manager as used in F.S 493 to be limited to an employee who served a security function. He further stated that a manager would only be required to be licensed if he had security-related duties, and that in his opinion, F.S. 493 did not require every agency manager or overhead official to be licensed. Mr. Mullan also stated that DOL officials concurred with his opinion, although he later admitted that they had never rendered such an opinion to AlliedBarton or personally to himself. Instead, Mr. Mullan stated, he concluded such concurrence from the fact that prior DOL audits had not flagged the issue.8 Regarding AlliedBarton managers obtaining M, MB, D or G licenses, Mr. Mullan stated that it would be problematic for AlliedBarton to have multiple managers, as those with manager level licenses, per F.S. 493, would have signing power, thereby permitting managers to vouch for persons applying for D licenses. When asked if the issue being problematic regarding managers had to do with statutory requirements or company-related issues, Mr. Mullan stated that the State makes the determination of manager requirements. Mr. Mullan then stated that in his opinion, the AlliedBarton job title of manager was not associated with the intent of F.S. 493. Mr. Mullan stated that since AlliedBarton began providing security services at the Seaport and the Airport in February 2011, he has visited the Port 15 to 20 times to meet with the Security Manager at the Port (SMP) and Mr. Macedo. When asked if those visits included providing supervision or direction of AlliedBarton employees, Mr. Mullan replied that he would observe AlliedBarton security employees at the entry gates while entering the port and in other areas 8 As noted above, the last DOL audit of AlliedBarton was in 2005, at least five years before it entered into the Contract with the County. BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 12 of 17 during his visits. When Mr. Mullan was asked if he had ever visited the Airport security operations, he stated that I fly out of that airport all the time on business, but thereafter admitted that he had never performed official business tasks at the airport, such as checking in on security officers during their work shifts. 3. Interview of Anne Marie Cummings Ms. Cummings stated that she began employment with AlliedBartons predecessor, Barton Protective Services (BPS), in 1994 as a human resource manager. At that time, BPS provided security services and toll plaza station customer service. Before working for BPS, Ms. Cummings worked for Floridas Department of Transportation Toll Service as an assistant manager at the Lantana toll plaza station. Ms. Cummings stated that in 2004, BPS was acquired by Allied Security Inc. and subsequently became AlliedBarton. She further stated that in 2007 she became District Manager at AlliedBartons Deerfield Beach Branch Office and took over security responsibilities that included overseeing security operations. Ms. Cummings stated that she was able to turn around that office, which had previously encountered administrative problems, because she was a problem fixer, and had earned several awards for doing so. She stated that Mr. Mullan was the type of manager who wanted things done quickly, but she was not that type of manager, she needed to fully understand her assignment before making any decisions. Ms. Cummings stated that as District Manager she had no direct involvement with security guards. Her primary role was to supervise the field managers who managed the day-to-day security operations of their designated locations and to meet with clients to ensure that AlliedBarton was meeting all their service needs. Ms. Cummings stated she did not have a security license, but had attempted to obtain one on three separate occasions. Ms. Cummings stated that on two occasions she was denied a Class MB license because she did not have twelve months of security experience. She was also denied a Class D license on another occasion because her fingerprints were unreadable when she submitted them to the DOL. Ms. Cummings stated when she submitted her fingerprints to DOL last year she took it a step further and asked the Hallandale Beach Police Department (HBPD) to write a letter along with her set of fingerprints that confirmed that those were her fingerprints. She added that her fingerprints were legible when taken by the HBPD. Ms. Cummings stated that she told the DOL that she was a security district manager who was responsible for managing security personnel who directly supervised security guards and at times, when those security managers were unavailable, would direct and deploy security guard personnel if the client needed immediate help or redeployment of security officers. She added that DOL still required that she have twelve months of security experience before providing management of Class D licensees performing regulated activities. Ms. Cummings stated that Mr. Macedo was a great worker who was passionate about his job, and that she had plans for his career development, namely, for him to have a mini district within the Port. She admitted that she knew Mr. Macedo did not have a license. BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 13 of 17 Ms. Cummings was asked if she was aware of an investigation conducted by the DOL. She stated that she was aware of the investigation and that it was initiated approximately two months earlier. She added that the investigation made her very nervous, as the office had never been audited or investigated while she was District Manager. Ms. Cummings stated that the day before the OIGs interview with Mr. Mullan, she was advised Mr. Mullan wanted to meet with her following his own OIG interview. She stated that she texted his administrative assistant to inquire about the nature of the meeting and if she should be concerned, and was surprised when the administrative assistant did not respond to her text message. She described associating a directive by Mr. Mullan that she not meet with OIG Special Agents, and the refusal of the administrative assistant to respond to her text, to mean that her pending meeting with Mr. Mullan was not going to be positive. Ms. Cummings stated that during the meeting, Mr. Mullan told her she was being terminated as a result of findings in a recent DOL audit which resulted in AlliedBarton being fined $750 for its failure to submit proof that several of its employees had completed the training required to maintain their Class D licenses. She stated that she was terminated mere minutes after OIG Special Agents completed their interview of Mr. Mullan. She further stated that she felt like the fall guy. Ms. Cummings stated that she was aware of past internal audits which reviewed for verification of licenses and certification training hours in which AlliedBarton had failed miserably. 4. Interview of David Macedo Mr. Macedo stated that he started working for AlliedBarton in January 2011, and was AlliedBartons Project Manager for security projects at the Seaport and the Airport. He described his duties as including managing 145 employeesa number of whom were responsible for check point security for two gates at the Airportas well as handling payroll, scheduling, making performance evaluations, conducting security quality assurance checks, and conducting security post spot checks. He stated that he reported directly to Ms. Cummings, and indirectly to the SMP. He admitted that he did not have any type of security license and recalled that he had even documented that on his application, but that no one at AlliedBarton had said anything about it. Mr. Macedo stated that in the event of a catastrophic emergency he would direct security guards in performing any escalated emergency procedures. Mr. Macedo further stated that he would direct security personnel with the assistance of an AlliedBarton security captain who works at the Seaport, but that he was the only Project Manager for AlliedBarton at both the Seaport and the Airport. 5. Interviews of County Officials The DPD stated that he reviewed the Contract with AlliedBarton and applicable security agency statutes the night before his interview and that, based on his review, the Project Manager was not required to have a license, but was required to have adequate experience. He further stated that he knew Mr. Macedo had the experience to be the Project Manager because he had interviewed Mr. Macedo for a County security position in 2007. The DPD BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 14 of 17 admitted that he knew Mr. Macedo was unlicensed, but reiterated that based on Mr. Macedos resume and his past experience, he deemed Mr. Macedo to be experienced and qualified. The SMP stated that his duties included overseeing the Contract and that he reported to the DPD. He also stated that the Contract calls for security officers to have D and G licenses in accordance with DOL requirements. The SMP stated that, per a contract requirement, AlliedBarton must provide at least ten percent of its workforce with a G license. The SMP further stated that a G license allows for security officers to carry a weapon, if directed by the Port Director. The SMP added that armed security officers are used when foreign nationals deliver shipments and cannot enter secured areas without an escort. The SMP also stated that armed security officers would be placed to monitor critical areas of ship loading and unloading areas if needed. The SMP stated that he did not know if Ms. Cummings had a license, but stated that she has a Port and an Airport badge, which reflected that a background check had been performed. The SMP stated that he was not very familiar with the content of F.S. 493 regarding the regulation of private security services. While discussing licensing requirements for AlliedBarton managers, the SMP stated that information on that issue would need to come from Port managers above his level or from the County attorney who reviewed the contract. The SMP stated that it was not his responsibility to know the statutes and whether or not AlliedBarton managers were properly licensed, as that information was to have been fleshed out by attorneys and the selection committee prior to award of the contract. He added that AlliedBarton is a large company and they should be qualified to do this work. The SMP stated that he was not aware of any provisions which would allow the on-site manager for AlliedBarton to perform his duties without the licenses required by F.S. 493. However, he opined, maybe David [Macedo] is able to work under the license of his supervisor, Ann Marie Cummings. After OIG Special Agents showed the SMP documentation indicating that Ms. Cummings had applied three times for licenses and those applications had been denied, he stated that he was unaware that she was unlicensed and pledged to follow-up on that issue. The Security Manager at the Airport (SMA) stated that his point of contact at Allied Barton for any security-related issues is Mr. Macedo. He also stated that in the early stages of the Contract he typically spoke to Mr. Macedo once a month via telephone, but that they do not communicate as regularly now. The SMA stated that he rarely communicated with Ms. Cummings, and has never seen Mr. Mullan at the Airport for business reasons. He also stated that he attended a May 21, 2012 meeting regarding the Contract, during which AlliedBarton representatives had requested additional office space, additional vehicles, salary rate changes, raising the ceiling for the Contract to $4.9 million per year, and other additional needs. The SMA admitted that he provided no oversight to ensure that AlliedBarton was adhering to the BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 15 of 17 requirements of the Contract. 9 The SMA further stated that being in that meeting this week made me realize that I need to be more involved in this contract. RESPONSES TO THE PRELIMINARY REPORT AND OIG COMMENT In accordance with Section 12.01(D)(2)(a) of the Charter of Broward County, a preliminary version of this report was provided to AlliedBarton, Richard Mullan, Anne Marie Cummings, David Macedo, and the Broward County Administrator for their discretionary written responses. The OIG received responses from the County Administrator, AlliedBarton, and Ms. Cummings, which are attached and incorporated herein as Appendix A through C, respectively. We appreciate receiving the responses. 1. Response of the County Administrator In her response, the County Administrator stated that the Seaport and the Airport are major economic engines, the protection of which is one of Broward Countys highest priorities. She stated that she disagreed that the facilities or the publics security was ever compromised or placed at risk. She further stated that County officials responsible for overseeing the Contract provided adequate oversight of AlliedBartons performance.10 The County Administrator stated that based on competing interpretations of F.S 493, the County wrote to the Director for guidance. She appended a letter from the Director to her discretionary response, in which the Director found, in partas previously addressed abovethat because AlliedBarton was not operating a branch office at the Seaport and the Airport, it did not need to designate an appropriately licensed individual to act as a manager. She also stated that absent the OIGs identification of Class D licensing issues regarding AlliedBarton employees at the Seaport and the Airport, she was unaware of any training deficiencies. Finally, the County Administrator noted that based on the response from the Director, and since the DOL has now issued an MB license to Mr. Macedo, she was satisfied with AlliedBartons performance under the contract. 2. Response of AlliedBarton In its response, AlliedBarton stated that at all times, it has been in compliance with the Contract and the requirements of F.S. 493 since (1) Ms. Cummings and Mr. Macedo did not have managerial duties as the statute defines that term, and (2) the statute only required that Mr. Mullan hold the required manager license, which he did at all times. It also stated that the OIGs allegation that millions of persons were at risk because of Mr. Macedos role in the security of 9 The preliminary version of this report incorrectly stated that the SMA admitted that the County, rather than he personally, had provided no oversight. The OIG acknowledges its error. 10 In the preliminary version of this report, the OIG articulated concerns that because the DPD, SMP, and SMA did not appear to be knowledgeable of the application of F.S. 493, the County was not equipped to fully ensure AlliedBartons performance under the Contract, although we made no findings of mismanagement. In her discretionary response, the County Administrator represented that an additional official, the Airport Security Director, is very familiar with the requirements of F.S. 493. Although he was not identified to the OIG by County officials during the interview process as having a role in the administration of the Contract, we accept the Countys representation and are thus satisfied that it did not provide inadequate oversight of AlliedBartons performance. BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 16 of 17 the Seaport was irresponsible. It further stated that both Ms. Cummings and Mr. Macedo had undergone extensive security checks which exceeded the requirements of F.S. 493. AlliedBarton complained that the OIG made incorrect interpretations of the application of F.S. 493 based on information it received wholly from unnamed DOL officials (whom the OIG has now identified by name in a previous section of this report). It stated that Ms. Cummings duties did not include any managerial responsibilities under the statute, and that although Mr. Macedo was also not a manager as defined by the statute, his position supplemented the required manager position based on his years of security-related experience. It further stated that although not required to do so, Mr. Macedo was instructed to obtain a license because AlliedBarton is committed to acting as a partner with the County in executing the Contract. The discretionary response also appended a copy of the DOLs 2005 compliance inspection report for AlliedBartons Deerfield Beach Branch Office, and cited it for the proposition that all of AlliedBartons employees were properly licensed. At the outset, we note that both the County and AlliedBarton expressed concern about the OIGs identification of the licensing issues as a public safety risk. We repeat that the OIG found no issues with the day-to-day security efforts provided by AlliedBarton. Nonetheless, the Florida Legislature has unequivocally deemed unlicensed security activity to be a threat to the welfare of the public. In this instance, the unlicensed security activity occurred at facilities which the County Administrator referred to as two critical County facilities. AlliedBarton also joined the County in contending that their offices at the Seaport and the Airport are not branch offices, thus obviating the need for Ms. Cummings and Mr. Macedo to obtain managerial licenses. Instead, both AlliedBarton and the County persist in maintaining that only an individual who directs activities in a branch officeto wit, Mr. Mullanrequires a managerial license. The OIG disagrees. We need look no further for confirmation of our assessment than the unambiguous declaration of the Director that a site supervisor responsible for overseeing the day-to-day activities of security personnel must still be licensed in accordance with the requirements of the law. Mr. Mullen, Ms. Cummings and Mr. Macedo, as well as several County officials, confirmed that Ms. Cummings and Mr. Macedo were involved in various oversight functions of day-to-day security activities. In particular, Mr. Macedo stated that in the event of a catastrophic emergency he would direct security guards in performing any escalated emergency procedures. In addition, Mr. Mullan admitted that he did not oversee the day-to-day activity of licensed security guards, and that he was rarely onsite, so that his managers license would not satisfactorily address the concerns expressed in the statute, and reiterated by the Director. In light of these facts, it is not surprising that the Director expedited the processing of Mr. Macedos Class MB license. The OIG is not familiar with all of the requirements of the background checks referenced by AlliedBarton, but we presume they were administered for all Seaport and Airport personnel. We do know, though, that Ms. Cummings applied for an F.S. 493 license on three occasions; that her application was rejected by the DOL each time; and that on one occasion, the DOL specified that the rejection was based on the fact that Ms. Cummings did not have the required security BROWARD OFFICE OF THE INSPECTOR GENERAL FINAL REPORT RE: VENDOR KNOWINGLY PERMITTED UNLICENSED MANAGERS TO OVERSEE SECURITY SERVICES AT PORT EVERGLADES AND THE FORT LAUDERDALE-HOLLYWOOD INTERNATIONAL AIRPORT OIG 12-008 July 31, 2012 Page 17 of 17 experience.11 The evidence shows that AlliedBarton was aware that the DOL had rejected her applications. In the same vein, the evidence also shows that AlliedBarton has been aware that, dating back to 2011, the DOL has raised issues with the licensing of numerous AlliedBarton Deerfield Beach Branch Office employees, and that it is currently contemplating additional administrative action against AlliedBartons Class B license. For these reasons, as well as the fact that AlliedBarton was not awarded the Contract until December 2010, the reliance placed by AlliedBarton attorneys on the DOLs 2005 compliance inspection report is inapt. 3. Response of Ann Marie Cummings In her response, which was provided in the form of a series of email communications, Ms. Cummings stated that Mr. Mullan had not actually advised her that she was being terminated due to the investigation and the $750 fine, but rather that is what I thought was the reason why I was released. Instead, she stated, Mr. Mullans exact words to her were that he want[ed] to make a change. She further stated that there was no discussion whatsoever about this investigation or the fines. The subsequent change by Ms. Cummings of her recollection of her conversation with Mr. Mullan does not alter the OIGs findings in this matter. CONCLUSIONS The OIG investigation revealed that AlliedBarton engaged in misconduct because it was aware of, but ignored, statutory and contractual requirements that obligated it to employ only qualified, licensed managers in sensitive security positions at the Seaport and the Airport. Instead, immediately upon the award of the Contract, AlliedBarton installed Ms. Cummings and Mr. Macedo in those positions, both of whom they knew were not licensed. The OIG is encouraged by the fact that, despite the objections by AlliedBarton and the County, Mr. Macedos application for a managerial security license was submitted during the pendency of the investigation and approved by the DOL. Since Mr. Macedo is now appropriately licensed, and Ms. Cummings is no longer with AlliedBarton, we do not recommend any further action, and consider this matter closed. 11 The DOLs finding necessarily casts doubt upon AlliedBartons assertion that she was fully qualified, as she had five years of prior administrative experience with a security company. OIG 12-008 EXHIBIT l thereof having a direct contract with ALLI EDBARTON for all or any portion of the security officer services, but not those who merely furnish equipment or materials. 2.36 Surge Incidents shall mean a period of heightened security requiring additional staffing by security personnel exceeding nonnal levels, for indefinite periods of time. 2.37 Transportation Security Incident shall mean a security incident resulting in a significant loss of life, environmental damage, transportation system disruption, or economic disruption. 2.38 TWIG shall mean Transportation Worker Identification Credential. ARTICLE 3 SCOPE OF SERVICES 3. 1 ALLIEDBARTON shall perform all work identified in this Agreement and Exhibit "A." The parties agree that the scope of services is a description of ALLI EDBARTON's obligations and responsibilities and is deemed to include preliminary considerations and prerequisites, and all labor, materials, equipment, and tasks which are such an inseparable part of the work described that exclusion would render performance by ALLI EDBARTON impractical, illogical, or unconscionable. 3.2 ALLI EDBARTON acknowledges and agrees that the Contract Administrator has no authority to make changes that would increase, decrease, or otherwise modify the Scope of Services to be provided under this Agreement. 3.3 ALLI EDBARTON shall pay its subcontractors and suppl iers, including its CBE subcontractors and suppliers, within thirty (30) days following receipt of payment from the COUNTY for such subcontracted work or supplies. ALLIEDBARTON agrees that if it withholds an amount as retainage from such subcontractors or suppliers, that it will release such retainage and pay same within thirty (30) days following receipt of payment of retained amounts f rom COUNTY. 3.4 Throughout the term of this Agreement, ALLI EDBARTON shall keep fully informed of and comply with all federal, state, County and local laws, ordinances, codes, and regulations, and all orders and decrees of bodies or tribunals having jurisdi ction or authority which, in any manner, affect services to be provided under the terms of this Agreement. ALLIEDBARTON, its subcontractors, and their officers, agents, and employees shall at all times observe and comply with all such laws, ordinances, codes, rules, regulations, -7orders, and decrees in performing its duties, responsibilities, and obligations related to this Agreement. ARTICLE 4 TERM AND TIME OF PERFORMANCE The term of thisAgreement shall begin on the date it is fully executed by both parties and shal l end on September 30, 2013; provided, however, if the term of this Agreement extends beyond a single fiscal year of COUNTY, the continuation of this Agreement beyond the end of any fiscal year shall be subject to both the appropriation and the availability of funds in accordance with Chapter 129, Florida Statutes. The COUNTY's Director of Purchasing may renew this Agreement for up to two (2) one-year periods, upon the same terms and conditions, by giving notice of the renewal to ALLIEDBARTON at least thirty (30) calendar days prior to the end of the initial term or any renewal term. ARTICLE 5 OBLIGATIONS OF ALLIEDBARTON 5.1 ALLIEDBARTON shall provide security officer services at the Airport and Port, according to the terms and conditions of this Agreement. The hours during which ALLI EDBARTON is to conduct its operations shall be twenty-four (24) hours a day, seven (7) days a week, including holidays. ALLI EDBARTON shall provide adequate personnel at all times, and this requirement shall be reflected in its Staffing Plan. ALLIEDBARTON shall provide additional or reduced staffing at such times as may be determined by the Aviation Department and Port Department. ALLIEDBARTON shall provide all personnel, equipment, uniforms, and related office equipment and supplies for the uninterrupted and safe performance of duties, as described in Exhibit "A". ALLIEDBARTON shall guarantee and provide evidence, that all Security Officers have completed the MTSA training to comply with 33 CFR 105.210, as referenced in the materials presented during the RLI evaluation prior to being assigned to Port Everglades. Vehicles must be cleaned and maintained in accordance with the Airport's ramp access program. Further, ALLIEDBARTON shall perform in accordance with the "Annual Staffing Plan," approved by t he Aviation Department and Port Department as described below. Licenses. Prior to commencement of operati ons pursuant to this Agreement and throughout the initial Term and any Renewal Term, ALLIEDBARTON shall secure and maintain any and all permits and licenses; ensure that such permits and licenses list ALLIEDBARTON as the permittee and/or licensee. ALLIEDBARTON shall maintain and provide upon request by COUN1Y satisfactory documentary evidence of all such requi site licenses, legal permits and notifications as hereinabove required. -8OIG 12-008 EXHIBIT 2 orders, and decrees in perfonning its duties, responsibilities, and obligations related to this Agreement. ARTICLE 4 TERM AND TIME OF PERFORMANCE The tenn of this Agreement shall begin on the date it is fully executed by both parties and shall end on September 30, 2013; provided, however, if the term of this Agreement extends beyond a single fiscal year of COUNTY, the continuation of this Agreement beyond the end of any fiscal year shall be subject to both the appropriation and the availability of funds in accordance with Chapter 129, Florida Statutes. The COUNTY's Director of Pu rchasing may renew this Agreement for up to two (2) one-year periods, upon the same terms and conditions, by giving notice of the renewal to ALLIED BARTON at least thirty (30) calendar days prior to the end of the initial tenn or any renewal term. ARTICLE 5 OBLIGATIONS OF ALLIEDBARTON 5. 1 ALLI EDBARTON shall provide security officer services at the Airport and Port, according to the terms and conditions of this Agreement. The hours during which ALLIEDBARTON is to conduct its operations shall be twenty-four (24) hours a day, seven (7) days a week, including holidays. ALLIEDBARTON shall provide adequate personnel at all times, and this requirement shall be reflected in its Staffing Plan. ALLIEDBARTON shall provide additional or reduced staffing at such times as may be determined by the Aviation Department and Port Department. ALLIEDBARTON shall provide all personnel, equipment, uniforms, and related office equipment and supplies for the uninterrupted and safe performance of duties, as described in Exhibit "A". ALLIEDBARTON shall guarantee and provide evidence, that all Security Officers have completed the MTSA training to comply with 33 CFR 105.210, as referenced in the materials presented during the RLI evaluation prior to being assigned to Port Everglades. Vehicles must be cleaned and maintained in accordance with the Airport's ramp access program. Further, ALLIEDBARTON shall perform in accordance with the "Annual Staffing Plan," approved by the Aviation Department and Port Department as described below. Licenses. Prior to commencement of operations pursuant to this Agreement and throughout the initial Term and any Renewal Term, ALLJEDBARTON shall secure and maintain any and all pennits and licenses; ensure that such permits and licenses list ALLIEDBARTON as the permittee and/or licensee. ALLIEDBARTON shall maintain and provide upon request by COUNTY satisfactory documentary evidence of all such requisite licenses, legal permits and notifications as hereinabove required. -8OIG 12-008 EXHIBIT 3 Account Name: Allied Barton Securi ty Services ABA Routing Number 031000053 Account#:8615592272 Beneficiary: Allied Barton Security Services CTX Format 7.6 The ALLIEDBARTON shall keep f ull and accurate books and records in accordance with generally accepted accounti ng principles showing all of its operating expenses. The COUNTY shall have the right through its representatives, and at all reasonable times, to inspect and audit any and all books and records. The COUNTY shall have the right to audit the books and records of related parties of ALLIEDBARTON, if during the review of ALLIEDBARTON's books and records it is determined that there are related party financial transactions. Said books and records shall be made available at ALLIEDBARTON's Broward County offices for a three-year period following the , . ~ n d o ~ each annual period of this Agreement. 7.7 The services to be provided by ALLI EDBARTON under the terms of this Agreement shall not be performed by anyone other than ALLIEDBARTON or ALLIEDBARTON's approved CBE subcontractor unless the prior written approval from the Aviation Department or the Port Department is given. ALLI EDBARTON shall require all approved subcontractors to keep such records and accounts as may be necessary in order to provide correct entries as to personnel hours and all other amounts charged to ALLIEDBARTON. ALLIEDBARTON shall require the subcontractors to keep all of their books and records of personnel hours and all amounts charged to ALLI EDBARTON for a period of three (3) years following the end of each period covered by thi s Agreement and to make same available at ALLIEDBARTON's Broward County offices, at all reasonable times, for examination and audit by the COUNTY. The COUNTY shall have the right, through its representatives, and at all reasonable times, to inspect and audit any and all books and records. 7.8 ALLIEDBARTON shall receive written notification from the Airport and Port when required to supply security officers to respond to Surge Related Incidents or Airport Security Related Incidents that require a level Orange or Red Security Threat plan change of the AVSEC requirements. Upon receipt of such notification ALLI EDBARTON shall immediately contact the Contract Administrator to discuss implementation procedures and staffing requirements. ARTICLE 8 OPERATIONAL STANDARDS 8. 1 The performance of the services required under this Agreement shall at all times be under the supervision and direction of an acti ve, qualified competent local -13Project Manager, and such other staff as may be necessary to act in the absence of the Project Manager, who shall at all times be subject to the direction and control of ALLIEDBARTON. A Project Manager shall be assigned to the Airport and Port and shall be available during normal business hours or other hours as designated by the Aviation Department and Port Department. 8.2 ALLIEDBARTON shall at all times retain qualified, competent, and experienced employees at the Airport and Port to meet the requirement outlined in Exhibit "A." ALLIEDBARTON's employees shall be clean, courteous, efficient, and neat in appearance. ALLIEDBARTON shall not employ any person or persons in or about the premises who shall use improper language, or act in a loud, boisterous or otherwise improper manner. The Aviation Department and Port Department shall be the sole judge on the question as to whether the conduct of ALLIEDBARTON's representatives is objectionable, and if so judged, ALLIEDBARTON shall take all steps necessary to eliminate the conditions which have occasioned such judgment. 8.3 agrees that its employees shall be of sufficient number so as to properly perform t he services requi red under this Agreement. If so directed by the Aviation Department or Port Department, ALLIEDBARTON shall provide for addition or reduction of employees, provided however, ALLIEDBARTON shall be paid only for the costs of the employees actually working at the Airport and Port. ALLI EDBARTON shall provide its employees with uniforms and credentials which shall be subject to approval by the Aviation Department and Port Department. All employees shall be required to wear the appropriate approved uniforms and site specific credentials provided by ALLI EDBARTON at all times when on duty. 8.4 ALLIEDBARTON shall immediately remove and keep removed from the Airport and Port premises any employee who participates in illegal acts, who violates Airport or Port rules and regulations, or the provisions of this Agreement, or who, in the opinion of ALLIEDBARTON, the Aviation Department or the Port Department is otherwise detrimental to the public interest at the Airport or Port. 8.5 In the event that a defalcation, theft, fraud or embezzlement or suspicion of same occurs or violation of 49 CFR 1542, it is ALLIEDBARTON's responsibility to immediately notify the Aviation Department or Port Department of the incident or suspected incident. ALLIEDBARTON also agrees to provide full disclosure including, but not limited to, copies of police reports of investigation, reports to bonding company, bonding company's findings, claims filed with crimes insurance carrier, and reports of any action taken against an employee. It must be ALLIEDBARTON's policy to prosecute any employee found to be involved in theft, fraud, embezzlement or any similar activity. All employees of ALLI EDBARTON must sign a pre-employment statement stating they are aware -14OIG 12-008 EXHIBIT 4 Morales, Ronald From: Mamak, Georg e Sent: Thursday, May 10, 2012 9:24 AM To: Morales, Ronald Subj ect: RE: More info, I am stil l digging. Ronald, Anyone involved in the day t o day operations of ,1 Security /\gency necu to be li censed. /\t lra-;t a "0" license. This includes project managers, regional or district managers, even owners. An MB license is what most career security people get t o be able to manage an agency. If they choose t o not get an MB, they can be designated as a manager by the agency if they have a " D" license and have two years of verifi able experience. As far as the Division is concerned, all of the above fall under the requirements of Chapter 493. As I t old you, my agency Investigates cases such as the one you described to me. It is a routine investigation. Apparently the people in question knew they had to be licensed, but since they were denied they are trying to justify being in violation of Chapter 493. I spoke to Fred yesterday. I advised him of what we had spoken about. He will be happy to speak to you when he returns Tomorrow. Please feel free to call him. He is a little more eloquent in explaining the requirements of Chapter 493. I have worked hundreds of cases and charged people in the past for doing exactly what you described to me. George Mamak From: Morales, Ronald [mailto:ROMORALES@broward.org] Sent : Thwsday, May 10, 201 2 8:27AM To: !Vlnnwk, Gcorac Subj ect: fU: : !"lore inro, 1 am sUII drgyi ng. George, Thank you for the information below. If I understood you correctly from our conversat ion yesterday, anyone whose duties fall under "security" most have at a minimum a class D license. Also, managers operating in the capacity of directing li censees need to be licensed with a class MB to have any direct or indirect supervision of subordinates who report to them. Does thi s include regional, district, or project managers? If I misunderstood anything that I've listed or highlighted below. Pl ease let me know. Can you provide me with any recent case law that fits t he case in question? Thank you, Sf\ Morales From: Mamak, George [ mailto:George.Mamak@freshfromflorida.com] Sent: Wednesday, May 09, 2012 1:38PM To: MoriJies, Ronuld Subject : More inro, I am still digging. 493.6100 Legislative intent. - The Legislature recognizes that the private security, i nvesti gative, and recovery industri es are rapidly expanding fi el ds that require r egul ation to ensure that the interest s of the public will be adequately served and protected. The Legislature recognizes that untrained persons, unlicensed persons or businesses, or persons who are not of good moral character engaged in the private security, investigative, and recovery industr ies are a threat to the wel fare of t he public if placed in positions of trust . Regulation of li censed and unlicensed persons and busi nesses engaged in these fields is therefore deemed necessary. 1 History.-ss. 2, 11, ch. 90-364; s. 4, ch. 91-429; s. 1, ch. 94-172. 493.6101 Definitions.(1) "Department" means the Department of Agriculture and Consumer Services. (2) "Person" means any individual, firm, company, agency, organization, partnership, or corporation. (3) " Li censee" means any person licensed under this chapter. ( 4) The personal pronoun "he" or the personal pronoun "she" implies the impersonal pronoun "it." (5) "Principal orricer" means an individual who holds the offic.c of president, vice president, secretary, or treasurer in a corporation. (6) "Advertising" means the submission of bids, contracting, or making known by any public notice or solicitation of business, directly or indirectly, that services regulated under this chapter are available for consideration. (7) "Good moral character" means a personal history of honesty, fairness, and respect for the ri ghts and property of others and for the laws of this state and nation. (8) "Conviction" means an adjudication of guilt by a federa l or state court resulting from plea or tri al, regardless of whether imposition of sentence was suspended. (9) "Unarmed" means that no firearm shall be carried by the licensee whi le providing services r egulated by this chapter. (10) " lkCJnclt orrtce" ntcans eaclt loe. Richard has over 30 years of proven experience In lhe security lndusvy, lnduding 1& years in lawenlorcement with combined municipal and federal agencies. Prior to)oinng AlledBarton, Rlcharo was lho Alea Securily Manager d lheAIIMla Committee for lho Of)'TipiC Games. Richard also consulled with Lake Oly CommHtoe for the Wlnf8< Olympic Games end directed the Protedlvt1 ser;;c:es for lhe President d lhe lntemaUonal Olympic Commifloe (IOC). He also served assistant Chief of Police with GWCCAuthority and was a Spacial Agenl US. Almy CIO. AddiUonaDy. Richard was an Adjunct Instructor for Fulton Coonty Police Academy and mponslblo for lhe Protective Sotvlce for lhe Seaotery o1 Defense. Richard currenUy serves on !he Board ol Ambassadors for Broward Coonty UnHed Wayand is a member lhe Association of Chiefs of Pollee, Geo'ee Prelim. Rpt., 6. However, the OIG only descri bes one such report by name and the attached report is so vague that it is impossible to compare the circumstances described therein with that of Ms. Cummings. !d. Therefore. it appears that there are no Case Information reports that suppoti the find ing that Mr. Cununings acted as a ' manager" under F.S. 493. Similarl y, Mr. Macedo was not a "manager" as that term is defined in F.S. 493.6 101(1 3). Due to the unique demands or the Count y, All iedBarton supplemented the statutory required licensed "managerial" position with the position held by Mr. Macedo, whose credential s, training, and years of security experience provided an extra layer of protection for the Port that exceeded all statutory and contractual requirements. III. AlliedBarton Complied with the Administration of the Contract. At all times, Alli edBarton has been in compliance wi th the contract between Broward County and All iedBarton (the "Contract"). having the necessary manager's li cense. The Preliminary Repoti asserts that All icdBarton breached the Contract by fai ling to comply wi th F.S. 493 's requi rement for the licensing of"managers." See Prelim. Rpt. , 9. As described above, the Licensing Compl iance Report found that all individuals requiring licensing under F. S. 493.6 10 l, including a licensed individual managi ng security personnel, were, in fact, licensed at the time of the OIG investi gation. Moreover, the Contract itself anticipates a difrerent leve l of qualification for supervisory, non-manageri al personnel such as Ms. Cummings and Mr. Macedo. Under article 8. 1, the Contract states that "the perfonnance of the services requi red under this Agreement shall at all times be under the supervision and direction of an active, qualified competent local Project 4 Manager. " Nowhere does this secti on, nor any other sec tion. state that any employee need be licensed as a manager if they do not exercise managerial duties as defi ned under F.S. 493. Therefore. All iedBarton has complied with the Contract' s provisions. I . In the Spirit of Cooperation AlliedBar1:on Has Exceeded It Obli gations Under the Licensing Requirements by Obtaining a Manager' s Liccn e for M r. Macedo. While it is clear that F.S. 493 does not require Mr. Macedo to hold a manager' s li cense because he is not a manager as the term is defined in the statue. Allied Barton has always been committed to acting as a partner wi th the County in its executi on of the Contract. Therefore, Mr. Macedo was instructed to, and has already received a manager's li cense.' V. AlliedBarton ndert ook Due Diligence to C omply with All Licensing a nd Hiring Req uirements. At all times AlliedBarton took reasonable due dili gence to comply with requirements in its hiring and screening of personneL including Ms. Cummings and Mr. Macedo. Management Reports, focusing on the qualifi cation of the officers selected to fill positions at the Port concluded that All iedBarton has demonstrated due diligence in the execution of its process for the screening, selection, and hiring of the security personnel to service the Contract requirements at the Port. See First Security 1\lfanagement Report, December 28, :?.0 11 : Second Security Management Report, July 2, 201 2. There is no evidence to support the Preliminary Report' s findings that AlliedBarton engaged in misconduct. In fact, by all ind ications Al lied Barton exceeded all security requirements for the Port and Airport. As such, AlliedBarton respectfull y requests that the OIG's Final Report correctl y determine that there are no facts to support any misconduct by Allied Barton related to licensing issues at the Pons. cc: Nancy Peterson 1 Ms. Cummings has not received a manager 's license because she is no longer employed by All iedBarton for reasons totall y unrelated to the O!G inquiry. 5 DIVISION OF LJCFN)ING Posr OFFICE Box 3927 tSso) 245-5500 TALLAHASSEE, rLORIDA 32315-3927 t3so) 245-5505 P,u 2520 NORTH MONROE STREeT FLORIDA Jlj0J.J052 FLORIDA D EPARTMENT OF AGRICULTURE AND CONSUMER SERVI CES ADAM H. PuTNAM July 2, 2012 Mr. Richard Root AlliedBarton Security Services 600 West Hillsboro Boulevard Suite 350 Deerfield Beach, Florida 33341 Dear Mr. Root: In response to your public records request, a search of our files indicates that AlliedBarton Security Services was initially issued Security Agency License B 2400212 pursuant to Chapter 493, Florida Statutes, on November 3, 2004. Administrative action is currently pending against this hcense. This license will expire, unless renewed, on November 3, 2013. As you requested, copies of the Compliance Inspection documents from case 2502135 are enclosed. Certain information provided to the Division of Licensing is exempt from Section 119.07(1 ), Florida Statutes, and Section 24(a). Article 1 of the State Constitution (the Public Records Law) in accordance with the following: Section 493 6121(5) F.S.; Section 493.6121(7), F.S.; Section 493.6122, F.S.; Section 394.4615(7), F.S.; Secti on 397.501(7)(a), F.S. ; Section 119.071, F.S. ; Section 119.15, F.S.; and the "Social Security Act", 42 U.S.C. 405 (c)(2)(C)(viii)(l}. Accordingly, any such information has not been provided in this correspondence. If you need further assistance. please call me at 850-245-5459. --------------------------------1800-HELPFLA FI6iida. www.FreshFromFiorida.com FLORIDA DEPARTMENT OF AGRICULTURE AND CONSUMER SERVICES DIVISION OF LICENSING Post Office Box 6687 Tallahassee, FL 323146687 (850) 487-0486 Internet Address: http://licgweb.doacs.state fl .uslindex.html Chapter 493. Florida Statutes CttAALE.S H. DROII:! OH COMPLIANCE INSPECTION AGENCY: BARTON PROTECTIVE SERVI CES , L.L.C. TELEPHONE#:(954 ) 698- 5888 ADDRESS: 600 W. HI LLSBORO BLVD., SUITE 350 , DEERFIELD BEACH, FL 33441 LIC#: T! 2400212 3 2502135DATE: . :!i/;s/os 9 .' J 0 M SEQ#: CASE#: PART 1 GENERAL PROVISIONS Non-Comp. N/ A 1 Bustness address. 493.6106(2)(a) ( J I 2 DACS license posted, 493.61 06(2)(b) [ J I I 3. Discl osure notice posted. 493.6106(2)(c) I I [ J 4. Li censed/designated manager. 493.6106(2)(d) ( l I I 5 City and county occupational license. 493.6107(5) [ I 6 General liability insurance, 493.6110 7. Usc of name. 493.6111(4) I I I I 8. Identification cards. 493.6111 (5) [ l ( l 9. License number In advertisement, 493.6111 (6) I I [ 1 10. Corporate officors/partners. 493.6 112 ( I I I 11. Employment/tenmination of employees, 493.6112(2) ( J I I 12. Employees properly licensed I I r I INVESTIGATIVE SERVI CES - N/A (>( ) 13. Intern termination/biannual progress report. 493.6116(5) I I [ 1 14. Interns properly sponsored. 493.6201 (6) [ l [ l 15. Carrying fi reanms, Yes ( I No I ] PART 3 SECURITY SERVICES - N/A [ 16. Firearm wai ver (returned}. 493.6115(6) l I [ J 17. Wearing of uniform, 493.6305(1) [ l [ J 18. Carrymg firearms, Yes ()() No { e,ART 4 - RECOVERY SERVI CES NA}XJ 19. lntem termination/biannual progress report. 493.6116(5) I I [ J [ I 20. Int erns properly spor.sored. 493.6401(5) [ I I I [ 1 21. Properly Inventory/noti fication letter, 493.6404 22. License number on vehicl e, 493.6404(3) l I I I ! l COMMENTS: ). 8'/ JlfiJ'l - o:r -:J/ /'Jetpk- 'Lt;:lu{- . - ./. . ---- INSPECTION ACKNOWLEDGMENT - The resulls. of lhts inspedion have been fully explamed tom y tho Depart mont of & Consumer Services Investigator. ' understand that areas of noncompliance musl be corrected an \ administrative adion may occur as a result of this tnspechon. Investi gator Signature Print Name DACS-16034 1103 formerly LC3E183 FLORIDA DEPARTMENT OF AGRICULTURE AND CONSUMER SERVICES DIVISION OF LICENSING Post Office Box 6687 Tallahassee, FL 32314-6687 (850) 487-0486 Internal Address: http://hcgweb.doacs.state.fl. usllndex.html Chapter 493. Florida Statutes CIWU.ES H. BRONSON COMM SSIONER COMPLIANCE INSPECTION AGENCY: BARTON PROTECTIVE SERVICES, L. L. C. TELEPHONE #: ( 9 54 ) 698- 5888 600 W. HILLSBORO BLVD ., SUI'l'E 350, DEERFI ELD BEACH , l"L 33441ADDRESS: DATE: t;)S /osTIME: 9 .' .3 0 _A.A LIC#: B 2400212 SEQ#: 3 CASE#: 2502135 PART 1 - GENERAL PROVISIONS Non-Comp. N/ A 1. Business address, 493.61 06(2)(a) I I I I 2. DACS llcP. nse posted, 493.6106(2)(b) I I I I 3. Disclosure noti ce posted, 493.6106(2)(c) l I [ I 4. Licensed/designated manager. 493.61 06(2)(d) I l I I 5. Ci ty and county occupational license, 493.6107(5) I I 6. Generalliabllltyinsurance, 493.6110 7. Use of name, 493.6111(4) I I I I 8. Identification cards. 493.6111 (5) I I f I 9 License number In adverti sement. 493.6111 (6) I l [ 1 10. Corporate officers/partners. 493.6112 I J I I 11 EmploymenVterminatlon of employees, 493.6112(2) I I I I 12. Employees properly licensed I I l I PART 2 INVESTIGATIVE SERVICES - N/A K 1 13. h\tern termination/biannual progress report, 493.6 116(5) ( 1 I I 14. Interns properl y sponsored, 493.6201(6) ( 1 ( J 15. Carryrng firearms, Yes { I No [ 1 PART 3 SECURITY SERVI CES - NIA ( 16. Firearm wai ver (returned}, 493.6115(6) I I 17. Wearing of uniform, 493.6305( 1) f I 18. Carrying firearms, Yes LXI No 1 PART 4 - RECOVERY SERVICES - NApl 19 Intern termination/biannual progress report, 493.6116(5) [ 1 20. Interns property sponsored, 493.6401 (5) l J 21. Property lnvontory/nol ification l etter, 493.6404 22 License number on vehicle, 493.6404{3) I I l I l I INSPECnON ACKNOWLEDGMENT The results of thts inspection have been fully explained to by the Department of J\griculturo & ConS\Jmer SetVices Investigator. I understand that areas of noncompliance must bo conected an a result of this inspection. t lrs/a.slnvesligator Signature Date Print Name DACS- 16034 1/03 formerly LC3E 183 t administrative action may occur as - --- - - . -Tt>o resul ts of this rnspectron have been fully 6Xptarned to m FLORIDA DEPARTMENT OF AGRICULTURE AND CONSUMER SERVICES DIVISION OF LICENSING Post Office Box 6687 Tallahassee, FL 32314 6687 {850) 487.0486 lntemetAddress: http://licgweb.doacs.stal e.ll.us/index.html Chapter 493. Florida Statutes CKAALES H. ORONWN COMMISSIONER COMPLIANCE INSPECTION AGENCY: BARTON PROTECTIVE SERV I CES , L.L . C. TELEPHONE#:( 954 ) 698- 5888 ADDRESS: 600 W. HILLSBORO BLVD. , SUITE 350, DEERFIELD BEACH , FL 33441 LIC#: B 240021 2 SEQ#: 3 CASE#: 2502135 PART