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:[email protected]] 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:[email protected]] 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