CCTV Licensing A number of weeks ago I was asked to present a paper at the launch of new equipment by CCTV specialists IC Realtime Ltd. The hot topic was licensing for the sector. A week previously I was very clear in my mind what the up to date position was. The industry, and by that I mean the PSA’s Stakeholder’s Forum, had completed its review of the PSA document setting out its requirements in relation to CCTV installation. The new agreed requirements document had been signed off by the PSA Executive and was to be the basis for licensing for the sector. The previous Code of Practice had been in circulation for over 3 years and it had not proved possible to find agreement on its finalisation. When the PSA set up its own advisory consultative body in May 2009, it brought all industry parties involved in the sector together. The Electronic Security Industry Stakeholder’s Forum undertook a complete review of the previous document and after many discussions a revised draft was completed and circulated for public comment. All existing intruder alarm license holders were alerted to the proposed new requirements document as were other interested parties such as the National Standards Authority of Ireland and the Gardai. Over 350 companies known by the PSA to be involved in the CCTV sector were also notified. 9 written submissions were received and a joint committee of the PSA and the industry set about considering the comments which ranged from outright rejection of the licensing requirement to detailed editorial comment and technical reviews. For what would become the basis for licensing it was agreed that the review body would follow the tried and tested process for technical standards 6
as operated by standards bodies here in Ireland and at Cenelec in Europe. I am pleased that this process is now adopted as the way forward for future revision of such documents with the PSA and that any review committee could be shown to have carefully considered all submissions in line with well adopted procedures. I am also pleased that the review committee has set
"Under current licensing requirements for intruder alarm installations it is possible for someone to argue that they maintain alarm systems but do not install such systems..." in place a clearly defined process that will allow future comment on any requirements document to address any specific item that may be of concern to its reader. So what do I see as the current position. A week prior to the presentation of my paper, part 1 of the new European standard for CCTV installations (EN50132) was published in Europe by Cenelec and is now formally adopted here in Ireland.
Had the new standard already existed it would be unlikely that the currently agreed requirements document would need to exist in its present format. It is my view that the industry would have adopted the European standard, as we are obliged to do, but would have simply written and agreed additional measures that those trading in the sector would require – a shortened version of the current PSA document. Perhaps an example would help. Under current licensing requirements for intruder alarm installations it is possible for someone to argue that they maintain alarm systems but do not install such systems. As such they have been beyond licensing, not because they are not required to be licensed, but because the criteria for licensing are not set out in a sector specific document to a level of detail sufficient to allow for objective auditing for compliance. The current draft for CCTV installers makes it mandatory for anyone maintaining CCTV systems to be licensed. This type of requirement would not exist in a European standard and shows the need for additional requirements to a standard where a national government requires licensing for
Spring 2010 edition of Risk Manager Magazine