10.2.12  Security Guard and Explosive Detector Dog Services and Programs

Manual Transmittal

November 22, 2011


(1) This transmits revised IRM 10.2.12 Security Guard and Explosive Detector Dog Services and Programs.

Material Changes

(1) This IRM includes new text on Security Guard and Explosive Detector Dog Services and Programs (EDDP).

Effect on Other Documents

This IRM supersedes 10.2.12, Security Guard and Explosive Detector Dog Services and Programs, dated October 21, 2008.



Effective Date


Signed by Norris L. Walker
Director, Physical Security and Emergency Preparedness  (10-21-2008)

  1. This IRM provides policy and procedure for establishing and maintaining an effective guard force service and Explosive Detector Dog Program (EDDP).

  2. One effective means to control access to facilities is through the use of a uniformed armed guard force. The primary responsibility of the guard force is to control access by screening visitors and employees for proper identification, operating security equipment (e.g. security radios, IDS/duress enunciator systems, magnetometers, x-ray scanner machines, Closed Circuit Television (CCTV) systems, etc.), and acknowledge, assess, and respond to alarm situations and other calls for service. The guard force should be supplemented by a variety of security systems creating a layered, multi-dimensional, and integrated security system, which can potentially reduce the number of guard personnel necessary. However, guard service cannot be entirely eliminated because of the necessity for a guard response and security system guard monitoring capability. Guards also increase detection capability, provide assessment and a response capability, and monitor on-going incidents.

  3. New security systems/technology will be coordinated with National Office (N.O.) Physical Security & Emergency Preparedness (PSEP) Program Security and Emergency Programs (SEP) Security Specialists and Engineers for applicability, reliability, state-of-the-art technology, security design coordination, priority programming, and funding projections.

  4. Use of a guard force is only one element of the protection program for our facilities. The Explosive Detector Dog program (EDDP) enhances the Service’s ability to ensure the security of IRS facilities and personnel through regular, random, and recurring inspections of mail, packages and vehicles entering IRS campuses and other IRS controlled critical facilities.  (10-21-2008)
Annual Self Assessment

  1. The SA is designed to measure operational programs effectiveness, strengths and weaknesses, and outline corrective actions with "Timely Get Well" dates. The Treasury Department requires all of its agencies to use the POAM (Plan of Action and Milestones (POAM). The SA report will be forwarded to the Physical Security Area Director (AD) within 30 working days of completion of the SA and to the PSEP SEP within 60 working days of completing the SA. All identified deficiencies will be corrected as soon as possible, but No-Later-Than (NLT) 180 days after identifying the deficiency, unless the PSEP SEP grants an extension based on valid justification through the PSEP AD.

  2. The SEP will compile all SA Reports and disseminate a Cross-Feed Report (report shared across various groups or facilities with a common mission and interest) identifying all Deficiencies and Best Practices. Upon receipt of this report, each AD and TM will then ensure the Cross-Feed Reports are disseminated to their respective security staff who will review the report for similar discrepancies within their territory and respond accordingly (negative responses are required). They will identify similar discrepancies at their site(s), and develop a timely POAM to resolve like Findings/Deficiencies at their site(s), and report their review and status back to their AD within 30 working days of receipt and to the SEP within 60 working days of receipt.

  3. The AD and TM will ensure a SA binder or file is established, which will contain all SA Reports generated by their site(s) for the past 3 years, Periodic Cross-Feed Reports, and Corrective Action Plans. If an electronic file is the method used a security share drive is necessary to ensure access at any time. The Annual SA Report will follow the POAM format, but must also reflect the following:

    • The location and date of the SA Report

    • The name of the person conducting the SA

    • Program areas reviewed in the SA

    • Identify and document any program deficiencies (Findings) in the SA and assign it an identifier, (For Example – Brookhaven may identify it as B-SA-2007-xxx)

    • Develop a Corrective Action Plan, identifying each "Deficiency" and list a prompt and timely Get Well Date, and what corrective action is being taken

    • Identify the person responsible for each corrective action  (10-21-2008)
Security Guard Service

  1. Each office requiring security guard service will be responsible for preparing a site-specific performance work statement (PWS), using the National Office provided Boiler Plate PWS and include their local information for the required security guard and explosive detection dog services via IRS contract (if your specific site has delegation authority). If your facility is non-delegated and you have a GSA-administered contract, you must follow the Department of Homeland Security (DHS) Federal Protective Service (FPS) contract and PWS. In the preparation of the PWS, the Service will not deviate from the IRS policy, SEP provided boilerplate PWS, or the DHS FPS SOW, as appropriate.

  2. Any local physical security requests for deviations from IRS or DHS/FPS policy specifications, or SEP issued Guard or Explosive Detector Dog PWS must be sent through the TM and AD. If approved by the AD, the request will be sent to the SEP for review and consideration, concurrence or non-concurrence, prior to going forward with a final solicitation.  (10-21-2008)
Guard Manning Standards

  1. Campus guard post/patrol standards are listed below. Non-Campus Standards are derived from the Department of Justice (DOJ) and General Services Administration (GSA) Interagency Security Committee Standards, and also based on a Risk Assessment recommendation dependent upon the threat (criminal or terrorist). A minimum of one armed security guard will be assigned to each of the following fixed posts/patrols/positions on a 24-hour/seven day per week (24/7) basis at each of the campus and computing center locations:

    • Perimeter Fence Gate: Entry Controller -- Fixed Post

    • Building Entrance: Entry Controller -- Fixed Post

    • Central Security Control Console (CSCC): Console Security Controller/Alarm Monitor -- Fixed Post

    • Internal Patrol (Rover): Designated Foot Patrol -- Area Patrol

    • External Patrol (Rover): Designated Foot or Vehicle Patrol -- Area Patrol

    • Shift Supervisor (will not work a post while simultaneously working as the supervisor) –- Must remain flexible and have the ability to roam the entire complex and respond immediately, as necessary.  (10-21-2008)
Exceptions to Guard Manning Standards

  1. With proper justification, other permanent posts or guard hours, above maximum standards, may be authorized on a case-by-case basis, based on documented and justified mission requirements, and as approved by the PSEP AD and the PSEP SEP, within budget constraints. However, temporary, short-term, and above-standard contingency posts may be authorized above or at the AD level, provided funding is available and the need is justified. For planning purposes, an annual 24-hour guard post consists of 8,760 staff hours. A guard works 1,752 productive hours annually. This level of staffing provides coverage for three (3) guard shifts on a 24/7 basis. The guard contractor has to effectively manage their staffing resources to meet the contract staffing requirements. There are; however, contract limitations on the number of consecutive hours a contract guard or explosive detector dog team may work without time-off or COTR approval.  (10-21-2008)
Central Security Control Console (CSCC)

  1. Central Security Control Console (CSCC) is a critical component of overall day-to-day security operations. Therefore, the CSCC has been designated and will be treated as a "Secured Area" in-accordance-with IRS definitions, with restricted entry/access.

  2. The CSCC must be properly secured, hardened, and utilize positive entry control procedures to prevent entry by unauthorized personnel.  (10-21-2008)
Central Security Control Console Construction

  1. All existing Central Security Control Console (CSCC) will have the following physical security features NLT two-years after publication and implementation of this IRM, unless the PSEP SEP approves an extension/exception. The PSEP SEP will provide funding for the following construction or modification requirements:

    • Slab-to-slab construction

    • No transparent glass or windows on the outer walls, unless it has been reinforced by backfilling it with a non-transparent wall that meets the slab-to-slab requirements, or if it is bullet resistant glass (expensive option and not recommended)

    • Standard commercial grade metal or solid wood entry/exit door with no glass (may have an observation peep hole)

  2. All new construction or relocations of CSCCs must meet the above standards and be located in an inner portion of the building, away from the building perimeter, to help mitigate potential blast damage, increase survivability, and maintain continuity of mission security requirements. However, new construction or major modifications will require solid reinforced concrete or filled Masonry Block walls floor to ceiling (ceiling slab to floor slab) to prevent Forced Entry Bullet Resistance (FEBR) protection for the CSCC.  (11-22-2011)
Central Security Control Console Security

  1. Only one Primary Entry Door, which will always be closed and secured (locked), unless during entry/exit. Additional doors into the Central Security Control Console (CSCC) are discouraged; however, if additional doors exist, they must be locked and used for emergencies only or by security staff and contract guard personnel only for entry or exit from a secured office or area not accessible to the general public. Primary and alternate doors may have an observation peep hole. All doors will have a lock (electric lock preferred, but not mandatory) controlled by the CSCC Operator(s) and/or a proxy card, combination, or key lock for entry.

  2. Only a limited number of personnel, authorized by the Territory Manager and/or COTR in writing, will be authorized unescorted unlimited key/card/combination and entry access into the CSCC. All other personnel and visitors must be escorted and their entry must be pre-approved and logged in and out on a Visitor Log. However, emergency responders, such as police, fire, ambulance, rescue, hazmat, etc., will be allowed unimpeded access if a known emergency is occurring. However, their actions will be monitored by guards or PSEP security staff in the immediate area. (Implement NLT 90-days after publication and implementation of this IRM).

  3. The inside of the CSCC will have a CCTV camera mounted so the CSCC guards/console can be observed via the CCFTV monitor at the 24/7 post where the CSCC duress alarm enunciates. An optional additional CCTV monitor may be positioned in the PSEP security staff office to observe the CSCC and other CCTV covered areas as well.

  4. The outside corridor of the CSCC will have a CCTV Camera mounted to monitor the immediate area outside of the CSCC door(s) and facilitate visual assessment of the area before opening the door to potential danger or unauthorized persons

  5. A direct phone line or intercom will be installed immediately outside the CSCC primary door for visiting personnel to use to communicate with the CSCC prior to entry into the CSCC, to verify their identity, and to determine their current security status prior to unlocking the CSCC door.

  6. The CSCC will be staffed by a minimum of one fully qualified armed guard (unless approved for two-guards) assigned under the guard contract – not the on-duty contract guard supervisor/program manager. (Implement when contract is renewed or modified, but not later than the start of the next option year).

  7. Weapons and ammunition will not be stored in the CSCC, as this creates a high guard pedestrian traffic into the CSCC during each shift change creating noise and disruption to the security operation.

  8. The CSCC will have an electronic duress button inside and report (annunciate) to another 24/7 fixed post (perimeter gate or building entry control point), preferably the fixed post with the interior CSCC CCTV monitoring capability.

  9. To ensure continuous seamless security operations during power outages, all Alarms/IDS, CCTVs/Monitors/Recorders/multiplexers, and the Radio Base Station/Repeater will be linked to an Uninterruptible Power Supply (UPS) capable of providing power for up to four (4) hours minimum, and/or connectivity to the building emergency back-up generator, if one is available, in existing facilities. New facilities and major reconstruction of the CSCC shall have both emergency generator and UPS connectivity. The UPS system will be located in a secured area and tested quarterly. The emergency back-up generator should be isolated and fenced or contained to prevent tampering and so the general facility population does not have access to it. If the emergency generator is located on the ground level in an external common area, it will be monitored by CCTV. Also, the emergency generator should be tested no less than once a quarter to ensure operability. (Coordinate with facility management).

  10. All security guards including those at campuses, are to immediately report any lighting outages to their local points of contact with overall responsibility for security and building management operations. A request for work repair of deficient areas identified must be initiated by phone, e-mail, or in person as outlined by local procedures. By the end of the shift, the guard's supervisor must submit any findings of deficiencies to the local Physical Security Office/COTR by using established forms approved under the contract and tracked in the officer's log book until the issue is resolved.  (10-21-2008)
Firearms Certification, Safety, Storage, Accountability, and Maintenance

  1. Due to the dangerous nature of firearms and the high potential for accidental injury, damage, theft, etc., the following firearms policy guidance is provided:  (10-21-2008)
Firearms Certification and License

  1. Armed security guards will be trained in-accordance-with contract and state requirements and certified in the use of each type of firearm issued and carried on-duty.

  2. While on-duty, security guards must have any required weapons permit and licenses in their possession.  (10-21-2008)
Firearms Safety

  1. Firearms shall be carried with the safety on and in the appropriate locally approved holster.

  2. Firearms will only be drawn as a last resort for the protection and defense of life or to prevent eminent serious bodily injury.

  3. Firearms are never to be left unattended, even momentarily, unless properly secured in the on-site firearms storage container/safe/vault/etc.

  4. Loading and unloading of firearms within IRS facilities will only take place in designated areas using a Clearing Barrel. The loading and unloading area must have issue and turn-in safety procedures clearly posted in plain view and immediately adjacent to the clearing barrel.

  5. All loading and unloading of firearms will be supervised by the on-duty guard supervisor or their responsible designee who must be qualified on the type of weapon being cleared.

  6. Exchanging firearms at shift change must be accomplished discretely, safely, and in accordance with local procedures.

  7. As a minimum, verbal or written Firearms Safety Briefings will be provided to all guards on a weekly basis and documented in the guard shift daily log/event blotter.  (10-21-2008)
Firearms Storage and Security

  1. Firearms and ammunition will be stored in a vault, safe, lockable metal storage cabinet with a minimum one-eight inch thick steel bar and heavy duty lock. However, firearms and ammunition must be stored separately in separate storage containers or in separate lockable compartments of the same storage container.

  2. When not issued to a security guard or Internal Revenue Police Office (IRPO), firearms and ammunition will be stored as follows:

    1. one to four firearms will be secured in a lockable security container

    2. five or more firearms will be secured in an approved safe or vault.

  3. If the weapons/ammunition security container, safe, or vault is less than 750 pounds empty, it must be bolted from the inside to the floor and/or solid portion of the wall (stud/column/etc.) to prevent portability.

  4. If firearms and ammunition are maintained in an unattended room, the room will have activated intrusion detection (BMS or Motion detection) capability, CCTV coverage. The room will be locked when unattended and shall enunciate at a 24/7 manned facility, as a minimum. For facilities with new construction or major renovation that includes the weapons/ammunition room, a separate room is required. The room should be close to or adjacent to the guards locker room.

  5. A limited number of contract guard personnel and the COTR or Agency Technical Representative (ATR), on a need to know basis, will have access to the key/combination and the firearms/ammunition storage container. Authorized personnel will be designated in writing and posted in plain view on the container or immediately adjacent to it and updated annually (every 12 months), or as personnel authorized access changes.

  6. Combinations of firearms/ammunition storage containers will be changed annually as a minimum, and within three-days when a person with knowledge of it no longer has a need to know it, or if the person has departed, retired, is reassigned, terminated, etc., or if the combination is compromised. If the security container is protected by a key-lock  (10-21-2008)
Firearms Accountability

  1. Each security shift will maintain a list of all on-site weapons by serial number and conduct an inventory of all firearms and ammunition each shift to account for their status (issued, in the storage container/weapons vault, in maintenance, etc.) and document the inventory at the beginning of their respective shift. Any unaccounted for weapons/ammunition will be immediately reported to the COTR and investigated.

  2. Firearms ammunition must be a factory load (no reloads) and will be inspected monthly, documented reflecting who inspected it and when, and provided to the COTR by the 5th day of the following month. All ammunition will be replaced annually, recording the make, type, caliber, and lot number(s) of the old and new ammunition. The documentation must reflect the date and the name of the person inspecting/replacing the ammunition. A locally formatted document will be developed for this process, completed monthly and provided to the COTR.  (10-21-2008)
Firearms Maintenance

  1. All firearms will be cleaned in designated locations only, function tested (dry fire and safety function test) and inspected at least once a month (if fired on the range, the weapon must be cleaned prior to being utilized on-site or stored in the on-site weapons security container) by the contractor, who will document this procedure.

  2. Malfunctioning firearms will be placed out of service and tagged if awaiting repairs or maintenance.  (10-21-2008)

  1. Radio & Telephone Communications: Security communications and the Central Security Control Console (CSCC) are critical elements and essential assets in the security operation. The guard force is responsible for controlling and monitoring all security radio net communications and calls for service to the CSCC.

    1. FCC authorized primary and secondary (if available) security radio channels will be established, for day-to-day security operations.

    2. Within two-years of publication and implementation of this IRM, all Campuses and CCs will have as a minimum:
      • A base radio station inside the CSCC authorized through the FCC to receive radio frequencies, with a hands-free microphone
      • Base station antenna compatible with the system base station radio in the CSCC
      • Repeater, in a secured location, compatible with the base station radio frequencies in the CSCC
      • CSCC hard-line telephones lines/phone instruments
      • An optional back-up type of communications such as a Nextel or similar system for the CSCC
      • All posts, patrols, and rovers will be equipped with a portable two-way radio. An alternate means of communications such as a Nextel system is highly desirable for non-fixed guard posts. Fixed guard posts will have a back-up landline phone and a fixed (permanently installed) or portable duress alarm capability.

    3. The CSCC guard and supervisors are responsible for efficient and professional radio and telephone communications, ensuring proper language and etiquette are always displayed during normal and emergency operations. All radio and telephone transmissions must be short, concise, and professional using "Clear Speech" . Profane or obscene language must never be used or condoned.

    4. Locally devised "Call Signs" may be developed and used during radio transmissions to facilitate effective short and concise communications. The guard force may develop and utilize a locally established and approved Phonetic Alphabet; Pro-words; Duress and Authentication Words designed to facilitate transmissions, and keep communications short. If used, Duress and Authentication Words must be known by all guards and the COTR and kept confidential. They will also be changed and documented when compromised and at least every 6 months, as a minimum. If Duress words are used, a separate Duress Word will be used for security exercises. Examples of the Phonetic Alphabet, Pro-words, and Duress & Authentication Words follow:

  2. Phonetic Alphabet: Pre-established words designed to easily pronounce words or letters that sound alike, such as Alpha, Bravo, Charlie, Delta, etc., . For example, the name Phil would be phonetically pronounced as such, "I spell Phil, Papa-Hotel-India-Lima" . The first letter of each word in the preceding Phonetic Words spells the intended word or name.

  3. Pro-words: Pre-established phrases/words designed to shorten transmissions, such as: Roger (meaning I acknowledge), or ETA (meaning estimated time of arrival), etc.

  4. Duress and Authentication Words: Duress Words are a simple locally devised means of communicating duress situation and are designed to relay a covert or masked communication(s) in a manner that is not recognizable by an untrained person. When the duress word or phrase is communicated, it alerts other security guards hearing the communications that a duress situation is in progress. Authentication Words are simple locally devised words used to verify a communication or status.

  5. Alternate Forms of Communication: : An alternative optional form of communication that may be used is the security whistle, using a limited pre-established combination of long/short blasts on the whistle (recommend no more than three pre-established signals for simplicity) to communicate a predetermined message to other guards.

  6. Security Status and Communications Checks: Each security guard shift will conduct Security Status and Communications Checks with each guard and the guard supervisor no less than once each hour and every 30-minutes during severe inclement weather, periods of heightened security, and emergency situations, where a guard(s) safety could be in jeopardy.

    1. While the guard is out "On Call" attending to a situation, the CSCC will conduct a security status check every ten minutes, if the guard is not heard within the last ten minutes, to ensure his/her status is secure. If the guard is not heard from or responds "Not Secure" (using a pre-established code), the CSCC must discretely dispatch a response on another frequency or using a phone line, so the subject with the guard is not alerted to the response of other guards to the scene.

    2. Hourly and 30-minute Security and Communications Status Checks will be documented in the guard shift blotter, event log, etc. These checks are essential to ensure the well-being of guards who may be under duress, injured/sick, unconscious, etc.  (11-22-2011)
Post Checks

  1. Post Checks are designed to ensure guards:

    • Are alert, fit for duty, properly performing their duties, and are knowledgeable of their post, post related equipment, written post orders/special orders, or verbal orders

    • Have the proper equipment with them on post and it is properly maintained and functioning

    • Are wearing a clean and presentable uniform in accordance with local policy and with all required accouterments, and present an overall professional well-groomed appearance

    • Are informed of any new information, policy, post requirements, threats, concerns, etc.

    • Have in their possession, all required licenses/permits/certificates, such as weapons certification, guard certifications, etc.

  2. Post Checks will be performed by the on-duty guard supervisor at least twice a shifty in the first couple of hours of the shift, than again later in the second-half of the shift.

  3. The COTR or representative, as determined and designated by the Territory Manager, will also conduct post checks on a regular and recurring basis in accordance with local procedures. Post checks will be balanced and conducted on all shifts equally.

  4. Post Checks conducted by contractor supervisors/managers and COTRs must be documented in the shift guard blotter/event log and will be maintained for 180-days, at a minimum.

  5. Security guard post orders require daily perimeter checks during all shifts as applicable by contract. Post orders where perimeter checks include night patrols, the guard must conduct an after dark assessment of the physical security posture at the facility. Guards who conduct perimeter checks must immediately report any deficient areas identified to their Supervisor. The guard Supervisor will prepare a report to be submitted to the local Physical Security Office/ COTR by the end of the shift.  (10-21-2008)

  1. Contract Project Manager : A full-time, on-site contract Project Manager (PM) will be on duty at each campus/computing center/N.O. location where there is a Guard Force. The PM duty hours will normally coincide with the weekday day-shift operation or as designated by the TM, COTR, or ATR (Mandatory for IRS contracts only).

  2. Contract Shift Supervisor : Each guard shift will have a responsible contract guard shift supervisor on-site. The same individual cannot hold the position of a security guard and a supervisor simultaneously. This does not preclude a supervisor from assisting security guards in the performance of their duties during incidents, emergencies, or during contingency operations. This is necessary, as the supervisor must be flexible and mobile to immediately respond to any location at any time.

  3. Security Contracting Officer’s Technical Representative (COTR) : A COTR or ATR will be nominated by the AWSS PSEP TM to administer each IRS security guard service contract. The COTR nomination will be sent to the IRS Contracting Officer (CO) servicing that office, and the CO will formally appoint the COTR by letter sent to each COTR and the Contractor. If a DHS/FPS contract exists at the facility, a request for an ATR program will be initiated, documented, and executed, if approved, with a letter naming and approving the ATR.

    1. For IRS contracts, assigned COTRs or Agency technical Representative will receive the available COTR/ATR training, as designated by the CO, and recertify as required.

    2. The COTR/ATR will coordinate with the CO to establish monitoring procedures and ensure the IRS takes appropriate follow-up action against the contractor when the situation warrants. The COTR/ATR will ensure all deliverables are received in a timely manner from the contractor.

    3. Each site has the responsibility for contract administration and inspection of IRS security guard service contracts through an officially appointed COTR when the CO is unable to be directly in touch with the contract work. Contract inspection may be delegated to an optional Contract Inspector (CI) or ATR, which ideally should be one of the assigned security staff personnel.

    COTR/ATR/CI responsibilities include, but are not limited to:

    1. Leading the Technical Evaluation Panel per direction of the CO to evaluate contract bid proposals.

    2. Being thoroughly familiar with the contract requirements and specifications and completing required COTR training.

    3. Scheduling and attending pre-work conferences.

    4. Interpreting drawings and specifications, with the assistance of PSEP engineers.

    5. Collecting the security clearance forms from the contractor (this can be delegated to the CI) and forwarding the forms to NBIC for processing.

    6. Notifying the contractor of the results of the suitability clearance. However, a contractor cannot report for duty until the COTR receives a copy of the suitability interim or final approval letter from National Background Investigation Check (NBIC).

    7. Advising the CO when the contractor fails to begin work in accordance with the schedule provided in the contract.

    8. Advising the CO of any factors which may cause delay in performance of work or of sub-standard performance.

    9. Personally inspecting or monitoring the work on a periodic basis, as well as ensuring that the IRS Contract Inspector (CI) or ATR, if utilized, are conducting inspections.

    10. Certifying hours as reported by the contractor.

    11. Conducting and documenting random exercises on a quarterly basis, at a minimum, using mock scenarios to measure response times, actions, tactics, techniques, procedures, and effectiveness of assigned guards.

    12. Recommending termination of contracts for default (Failing to complying with the terms of the contract).

    13. Notifying the contractor, in writing, of proposed deductions from contract payments for the contractor’s failures or omissions and of the right to appeal. Copies of proposed deduction letters shall be provided to the CO and the IRS CI, if utilized. The CO shall decide all appeals regarding proposed deductions. This responsibility may not be re-delegated by the CO.

    14. Promptly advising the CO if the contractor fails to remove, correct, or replace rejected guards, uniforms, equipment, or service.

    15. Supplying the necessary handbooks, forms, etc.

    16. Ensuring official files are maintained for each contract guard. Official files are to contain, at a minimum, the Firearm Qualification Forms and/or appropriate state Guard Card, medical examinations, CPR and first aid forms, suitability clearances, training certificates, etc. These forms will be collected by the COTR or CI and be retained by the COTR for the duration of the contract period. Upon expiration of the contract, all records will be turned over to the CO or as directed otherwise by the CO.

    Non-Delegated Campus Agency Technical Representative (ATR) : Non-delegated IRS Campuses and non-IRS Guard Service Contracts may require an ATR, which can be requested through the DHS CO and Federal Protective Service (FPS) Area or Regional Directors. ATR Program is administered through the CO and COTR. The ATRs are tenant agency employees (IRS security staff employees) designated to assist the COTR with on-site contract administration. ATR authorities are limited to basic functions as determined by the CO or COTR.

    • The Service will conduct the government portion of the security officer Initial and Annual officer proficiency examinations annually.

    • It is the responsibility of the TM to ensure that the site(s) for which they are responsible have all of the provisions of the policy specifications in the guard service and EDDP contracts, provide AWSS PSEP SEP a copy of the current guard contract, provide a copy of any subsequent modifications for each applicable security contract for which they are responsible, and ensure compliance with the requirements of and provisions contained in this section.

    • The AWSS PSEP SEP will be provided a copy of a proposed contract Performance Work Statement prior to it being forwarded to procurement, CO, etc., to ensure it contains the proper language and requirements. The SEP will either concur or non-concur with the proposed PWS. The SEP has previously directed implementation of the standard Contract Guard Performance Work Statement (PWS) with Exhibits. This standard PWS can be obtained from the PSEP PPP Office upon request.

    Contract Inspection for IRS Guard Service Contracts:

    (1) The COTR may nominate a Contract Inspector (CI) to aid in the administration of the contract. The CO and AWSS PSEP Territory Manager will approve/disapprove the CI appointment. CI appointees should be from the local physical security office. If approved, a letter from the COTR will formally appoint a CI with a copy of the letter to the CO and the Contractor. If disapproved, the COTR will assume the responsibilities for contract inspection as described below.

    (2) Training the CI is the responsibility of the COTR. It is recommended that the CI attend the COTR training to ensure that improper contract administration does not occur. The CI can be responsible for, but not limited to, the following activities:

    1. Filing each notification from NBIC on completed, satisfactory NBIC background checks

    2. Attending post-award conference

    3. Preparing schedule of inspections

    4. Providing copies of the inspection schedule to the COTR at least one week in advance of the inspection

    5. Following up on reported discrepancies with the contractor’s on-site representative to ensure that discrepancies are corrected

    6. Formally documenting the results of all inspections, filing a copy of the inspection report, and forwarding the original report to the COTR

    7. Administering the initial and annual officer proficiency examination to all officers that qualify and have successfully completed the weapons firing

    8. Obtaining all forms (e.g., firearms qualification, pistol permit, medical examination, etc.) from the contractor and forwarding to the COTR

    9. Keeping a record on each officer of all forms submitted by the contractor

    10. Making recommendations for deductions to the COTR based on CI inspection reports

    11. Scheduling and conducting all government-provided officer training and monitoring contractor-provided training

    12. Keeping training records on each officer (number of training hours, test scores, and other pertinent information)

    13. Controlling possession of the training tests

    14. Notifying the COTR of completed training requirements for each officer

    15. Verifying officer-training hours against invoice from the contractor

    16. Inventorying all weapons and ammunition authorized on-site at least once a month

    17. Inspecting, or observing the inspection of firearms in storage at least once a month for cleanliness

    18. Periodically observing to ensure that contract security personnel are using the clearing barrel to load/unload weapon

    19. Periodically remind contract security personnel they will not remove weapons from the IRS premises, unless authorized in the line of official duties to travel to another IRS site.

    (3) Individual CIs will conduct inspections as directed by the COTR, using the inspection form(s) provided by the COTR. All CIs will complete an inspection form immediately after or during the inspection of the security force shift. The CIs will deliver a copy of the inspection report to the contractor’s on-site Project Manager (PM) or supervisor and request that any deficiencies noted are corrected. Should the deficiency be serious (e.g. post abandoned, officer sleeping, etc.), the CI will immediately notify the contractor’s on-site PM or supervisor for immediate corrective action. If the contractor’s on-site supervisor does not take action immediately, the CI will notify the COTR. The original inspection report will be delivered to the COTR.

  4. CIs, ATRs, and COTRs Restrictions/Requirements:

    • Never touch an officer or his/her equipment

    • Never direct the officer to do a specific task (except in an emergency), unless you have the authority

    • Never inspect the officer’s weapons or ammunition while it is in the possession of the officer

    • Never refer to a deduction from the contract payment as a penalty. Violations of any of these could result in a legal action by the officer and/or contractor against the CI, the IRS, and/or the United States Government, or be in derogation of rights or remedies otherwise available to the government. This does not preclude a CI from asking an officer if their weapon is loaded and how much ammunition was issued or observing the loading or unloading of weapons during shift changes.

    (A) Any proposal for a reduction or increase of contract security hours/costs should be reported by the COTR to the CO so he/she can review it and plan/negotiate contract changes, as necessary.

    (B) For the first thirty (30) days of a new contract, the COTR/ATR or CI should conduct random and frequent inspections that will ensure that all officers on all shifts are performing in accordance with the contract requirements and post orders as applicable. If feasible, as resources permit, the officers should be inspected every shift, two times each week. After the first 30 days of the new contract, the inspections can be dropped to a minimum of one inspection per week per shift. The inspections must be conducted on varying days, on varying shifts, and at varying times of the shifts to be effective. This does not mean that every officer on duty must have a full inspection each shift. Should any problems with security officers occur, the inspections may be accelerated at local option.  (10-21-2008)
Explosive Detector Dog Program (EDDP)

  1. General Guidelines: This IRM provides direction, responsibilities, policies, and procedures for the effective safe implementation and utilization of contract Explosive Detector Dog Teams (EDDT). This IRM also provides valuable detailed guidance for the proper administration of the Explosive Detector Dog Program (EDDP) at all IRS facilities with assigned EDDT.  (10-21-2008)
Primary Mission of the Explosive Detector Dog Program

  1. The primary mission of the Explosive Detector Dog Program (EDDP) is to provide explosive detection services at Campuses, Computing Centers, and N.O. headquarters buildings by inspecting unsolicited high risk mail and packages arriving at facilities. The secondary mission for EDDTs is to inspect all other mail, as well as conducting other routine inspections, as time and availability permits. The secondary inspections can be accomplished between mail deliveries at vehicle entry points, in parking lots, trash bins, bushes, and/or interior/exterior common areas (excluding the kitchen and cafeteria, individual offices/cubes, etc., unless there is a bomb threat, or if these services are requested by CI or TIGTA). Local policy and procedures will dictate the scope, location(s), and specific post orders for secondary inspections.  (10-21-2008)

  1. The AWSS SEP EDDP Manager will:

    1. Develop and update policy as necessary and coordinate policy requirements consistent with Treasury Department and industry-wide principles and standards.

    2. Develop, update, and implement a Service-Wide National Performance Work Statement (PWS) or Statement of Work (SOW), and assist in coordinating contract requirements.

    3. Assist local EDDP representatives in determining whether the contractor is meeting the terms and conditions of the contract.

    4. Conduct periodic EDDP reviews, as necessary, designed to capture and document best practices, as well as potential issues/concern at each location with EDDTs.

    5. Coordinate and conduct random annual Operational Testing (OT) of assigned EDDTs to ensure proficiency and consistent capability to detect all required explosive odors at IRS facilities in compliance with the IRS Odor Recognition Proficiency Standard for Explosive Detection Canines (see Exhibit 10.2.12-1).

    6. Monitor annual certification/decertification of EDDTs based on results of N.O. or campus security staff conducted Operation Tests and contractor conducted tests in accordance with IRS policy.

    7. Provide a self-assessment checklist for the EDDP for physical security personnel to measure EDDP effectiveness and compliance with the IRM and to use in preparation of formal EDDP Compliance Reviews.

    8. Maintain a fresh on-hand supply of Non-Hazardous Explosives for Security Training and Testing (NESTT) for N.O., Campus and CC physical security staff conducted Operational Tests of EDDTs. Coordinate with the PSEP SEP for centralized bulk order purchases and direct shipping to IRS locations with EDDTs.

  2. PSEP Area Directors. Area Directors are responsible for ensuring proper implementation of the EDDP for their Area. They will coordinate with their TMs to ensure the EDDP program is in compliance with Service-wide policy and guidance.

  3. PSEP Territory Managers will ensure that:

    1. A COTR is nominated, referred to the Contracting Officer (CO), and appointed in writing by the CO, or coordinate implementation of the DHS ATR program for non-IRS contracts

    2. The assigned COTR or ATR is properly overseeing the EDDP administration and policy requirements

    3. EDDP contract funding requirements, to include funding for availability of contractor EDDTs for Operational Tests, are coordinated with the Area Directors and National Office

    4. A current copy of all IRM policy guidance, post orders/special orders, and local procedures regarding the EDDP are provided to the COTR or ATR

    5. At a minimum, local quarterly unannounced OT will be conducted of all assigned EDDTs to determine their proficiency in recognizing and detecting the designated basic explosive odors. These tests will be documented in writing and provided to the Area Director or their designated representative within five-days of the completion of the Operational Test, and to the National Office Physical Security EDDP Manager within fifteen- days after the end of the OT for that quarter

    6. EDDP Findings/Observations/Issues are monitored and corrective actions are documented and timely

    7. Incidents of explosive detector dog alerts, false alerts (except for training scenarios), and dog bites are reported to the PSEP Area Directors and the EDDP Manager within twenty-four hours with a complete report of all facts (interrogatives) and the status of the incident using a locally established report forma;

    8. Canine veterinary records are reviewed within ten-days after the annual canine physical to ensure canine fitness for duty

    9. The following documents must be provided by the EDD contractor and maintained by the COTR or the ATR:
      A copy of the most current contractor annual certification reflecting the assigned EDDT meets the IRS Odor Recognition Proficiency Standard for Explosive Detection Canines;
      A document certifying that the EDDT (specific canine and handler by name) have certified as a team (handler and canine) within the past twelve-months with the name and address of the certifier and their contact information;
      A certification stating that the EDD handler was formally trained as a EDD handler and reflects the handler’s full name, the name of the training academy/school where the training occurred as well as the training certifying official’s name and address.

    10. In the last quarter of each fiscal year (July-September) conduct and document an annual Self-Assessment (SA) review of the EDDP to ensure compliance with IRM, post orders, special orders, local policy, and contract requirements. Annual EDDP SA reports are sent to the Area Directors, or their designated representative, within thirty (30) days of completion of the SA, and to the PSEP SEP EDDP Manager within sixty (60) days of completion of the review

    11. EDDs are not permanently kenneled on IRS property. EDDs will only be temporarily kenneled on IRS property, in a portable dog crate, during the assigned handlers daily shift hours. When the handler is off-duty their assigned canine will not remain on IRS property;

    12. COTR observes annual contractor conducted certification, if conducted in the local area, of all assigned EDDTs. If possible, record this event with documentation and record it using video camera; and

    13. Maintain a compartmentalized file/folder/book with:
      Most current Contractor EDDT Certifications;
      2) Last 4 SEP and local EDDT OT Report Results;
      3) Last 12 monthly EDDT Training Reports;
      Last 12 monthly EDDT Utilization Reports;
      Last 2 SA Reports, other Program Review Reports, Findings/Observations/Corrective Actions;
      6)A Current Photo (no more than 1-year old) of each EDDT (handler and dog) with a frontal view of the team with the handler kneeling beside their assigned standing canine;
      7) Last 2-years of each canines Medical Record documents;
      Last 3-months shift schedules;
      Most recent copies of invoices of contractor purchased actual or NESTT training aids; and
      10)Other relevant EDDP program documents, as necessary.

  4. Contractor EDD Handlers and Canine Requirements :

    1. Each EDD handler must recertify every 12-months (at a minimum) with their assigned K-9, as a team, through their contractor or another independent credible EDD school or academy. The contractor certification must state that the EDDT meets the IRS Odor Recognition Proficiency Standard for Explosive Detection Canines and the named handler and canine are certified as an EDDT. A copy of the certification letter/certificate must be signed by the certifier and state the name of the EDD handler and canine, the date and location of the certification, name and address of the certifier.

    2. The Contractor must provide the above documented proof of the certification to the COTR before the EDDT can start working at any IRS facility, and within five-working days of the annual recertification due date.

    3. All handlers must be a graduate of an EDD academy/school/course (includes military courses) with an established syllabus and have a minimum of one-year successful experience handling and working an EDD, after completing their formal EDD handler training. Handling narcotic, search and rescue, or other types of dogs does not qualify as appropriate experience for purposes of working on an IRS contract.

    4. A copy of the handler’s certificate, certifying them as a formally trained EDD handler, will be reviewed by the COTR before working on an IRS site and maintained in a file by the COTR for the duration of the contract and up to two-years after the contract is terminated.

    5. Each EDD Handler will maintain and wear the locally prescribed uniform/attire when on duty, ensuring it is clean and presentable.

    6. The EDD handler may be armed if it does not result in additional contractual costs. If armed, the EDD handler will comply with the requirements set out in this IRM for guards as well as any state requirements, and carry any state required weapons permits/licenses in their possession while on-duty. Additionally, EDD handlers will follow and comply with all weapons requirements contained in paragraph of this IRM.

    7. Ensure EDDTs are available during local and PSEP & SEP Operational Testing.

    8. The EDD Handler will:
      Ensure their leash (lead) and other equipment are maintained in optimal condition (not frayed, dry rotted, cracked, torn, etc.), and serviceable at all times, and immediately replace unserviceable/unsafe equipment;
      Maintain a safe and healthy environment for their assigned EDD and ensure their EDD is properly fed, hydrated, exercised, and groomed;
      Ensure their EDD is bathed and treated for ticks and other potential parasites and canine contagious diseases and provided routine immunizations as directed by the attending veterinarian on record;
      4) Ensure immunization is documented and signed/dated by the attending veterinarian stating these requirements have been met along with the treatment date(s);
      5) Ensure their EDD receives a 15-minute break every hour (as a minimum) and is afforded recurring re-hydration (water) breaks and shade if outdoors on a frequent and as needed basis. EDDs will work no more than an 8-hour day during peak season or a 10-hour day during non-peak per 24-hour day, and will have a minimum 12-hour off-site break before returning to work;
      Ensure motor vehicles used to contain or transport EDDTs on-duty on IRS property are equipped with operable climate control equipment (air conditioner and heat);
      7)Disinfect the IRS on-site temporary canine holding cage at least once a week or more, if necessary, with a veterinary approved disinfectant, removing any stool or bodily waste throughout the day, and cleaning the canine cage as necessary;
      8) Ensure their EDD receives an annual physical examination by a licensed veterinarian, and provide a signed letter from the veterinarian stating the canine is physically fit to perform EDD duties up to 10-hours per day, to include extended periods of searching, going up on their hind legs, and jumping up/down onto or off objects during searches;
      Immediately report any medical treatment, sickness, or injury of their assigned canine to the COTR;
      Ensure their EDD is properly socialized in order to temper the dog and eliminate any aggressive tendencies when around other people and canines;
      Immediately report all on-duty dog bites to the supervisor and COTR and prepare a statement or report, as directed, addressing all interrogatives and the proposed corrective actions;
      Always maintain proper control of their canine and work the canine on-leash in populated areas, ensuring any area or vehicle being searched does not have personnel in the immediate area within reach of their canine, which may potentially startle, upset, or agitate their canine; and
      Conduct EDD training and document daily training and utilization on the attached Training & Utilization Records, see Exhibit 10.2.12–2 (Monthly Explosive Detector Dog Training Report) and Exhibit 10.2.12-3 (Monthly Explosive Detector Dog Utilization Report).

    9. The EDD handler will comply with all IRS policies and procedures, post orders, special orders, memorandums, contract requirements, and other notices/verbal instructions from the CO, COTR, ATR and on-duty security supervisor, as appropriate.

    10. All contract EDD handlers must meet the same NBIC and suitability requirements as security guards.  (10-21-2008)
Explosive Detector Dog (Canine) Requirements

  1. Any breed of canine is acceptable. EDDs will not remain in IRS service once they are deemed unfit for duty by a veterinarian. Annually, a licensed veterinarian must provide a letter stating the named canine is physically fit to work in the IRS environment for up to 10-hours per day and has the ability to jump up on and off boxes/platforms at least three feet high, can routinely stand on its hind legs while sniffing high areas/boxes/packages/etc., to ensure hip-dysphasia or other hip issues existing in the canine are not physically limiting. These requirements are necessary to ensure a canine is fit for duty and not experiencing pain or discomfort in the work environment. Therefore, effective and advance planning for replacement of potentially unfit canines is essential.

  2. Each EDD must be certified through their contractor as a certified EDDT. An OT off all EDDTs will also be conducted by the IRS prior to the EDDT working IRS contracts. All EDDT must also recertify every 12-months thereafter through their contractor and quarterly by an OT conducted by the territory PSEP COTR, for IRS contracts only.  (10-21-2008)
EDDP Safety

  1. Some canines are overly protective or skittish and may bite out of fear or after being startled. Personnel at IRS facilities will be warned not to approach or touch the EDD unless the handler is present and authorizes it in order to adequately socialize the dog with people. EDDs will not be left unattended when outside of the immediate proximity and control of the handler unless properly secured in a kennel, cage, or vehicle, and without the potential for escape.

  2. All kennels, cages, rooms, or vehicles used to contain EDDs will have a prominently displayed sign(s) in large bright letters and visible from any approaching angle. The sign(s) will indicate the presence of the dog and will have the caption "Caution or Warning" or other appropriate wording agreed upon by the IRS, facility CO, and Contractor. The signage should also display the words "Authorized Personnel Only" . This is a precautionary measure intended to minimize the potential risk of a dog bite mishap.  (10-21-2008)
Operational Testing of Explosive Detector Dog Teams

  1. The OT criteria are established by the PSEP SEP. The test will consist of a minimum of five separate explosive odors (actual explosives or Non-Hazardous Explosives for Security Training and Testing (NESTT) and a distracter. The OT explosive test aids will be blind plants (location unknown by the handler and canine) and allowed to "set in-place" for a minimum of thirty-minutes prior to initiation of the blind test. (See Exhibit 10.2.12-1, page 2 (IRS Odor Recognition Proficiency Standard For Explosive Detection Canines) page 2, Test Methods, Procedures).

  2. All K-9 Contracts Performance Work Statement must be modified to reflect the following statements:

    • "The IRS reserves the right to test any of its contracted explosive detector dog teams at any time using either Actual Explosives or Non-Hazardous Explosives for Security Training and Testing (NESTT) test aids. Therefore, contractors are encouraged to train their explosive detector dog teams (EDDTs) on NESTT products as well to ensure they are prepared for a NESTT Test."

    • "If the EDDT fails the second test, the team is disqualified from working on any IRS K-9 contract until the contractor certifies in writing that the EDDT received remedial proficiency explosive detector dog training and was recertified. The IRS will then conduct another Operational Test as indicated above to ensure explosive recognition proficiency in an operational environment. If the EDDT passes the test it may resume working an IRS K-9 contract"

  3. All local OT failures will be immediately reported to the Territory Manager, Area Director, and the PSEP SEP EDDP manager. The OT report must reflect who conducted the test, a Pass or Fail, the names of the explosive detector dog handler and canine, date and time, location of OT test, and will be kept on file locally for the duration of the contract, plus two additional years. If video camera equipment is available, it is recommended the OT be recorded. The OT Test Report/Results will be recorded on Exhibit 10.2.12-4, Explosive Detector Dog Operational Test Report.  (10-21-2008)
Explosive Training Aids (ETA) - Actual or NESST

  1. Will be handled with separate disposable gloves so they do not cross-contaminate with each other and mix scents;

  2. Will be placed at varying heights (from ground level up to no more than five (5) feet high) and varying depths (no more then twelve (12) inches deep), and placed at least ten (10) feet or more apart. The height and depth of each plant must be recorded in the OT report; and

  3. Must set in-place for a minimum of 30-minutes after planting before the OT search begins, as this allows the scent of the explosive material to spread and saturate the immediate area.

  4. Actual explosive or NESST training aid utilized by the contractor are their responsibility to purchase, order, maintain, and discard. The IRS PSEP SEP will provide NESST Training aids to its territories for Operational Testing only, which must be strictly maintained and secured by territory PSEP staff personnel. The PSEP NESST aids will never be given or provided to the contractor for their routine use.  (10-21-2008)
Training and Utilization Requirements

  1. Each EDDTs Training and Utilization will be documented on separate monthly reports (see Exhibits 10.2.12–2 and 3). A separate monthly report is required for each EDDT, which reflects the type of training (e.g., vehicle search, building search, area search, carts/pallets, etc.) accomplished. The reports have a separate column for each day of the month.

  2. The reverse side of the Monthly Training & Utilization Reports will reflect any corrective actions, false alerts, progress or lack of progress, actual finds, remarks (vacation/sick/extenuating circumstances), etc. The reports will be completed and provided to the COTR not later than five-days after the end of the previous reporting month.

  3. A minimum of four-hours training will be conducted for each EDDT each work week and documented on the Monthly Training Report. The training must be balanced and include all of the odors required in Exhibit 2.10.12-1 (IRS Odor Recognition Proficiency Standard for Explosive Detection Canines). It is recommended that at least 50% of the training is with blind plants (training aids hidden without the handler or K-9 knowing where the training aid is or what type of aid is being used). Handlers should minimize planting their own training aids as the handlers’ odor will transfer to the aid and the canine may start to alert on the handlers odor, and the handler will know where the aid is located. An exception to this is, if an EDD is having trouble detecting a specific type of explosive odor the handler may have to know where the aid is hidden to better acquaint the EDD with odor and to read the EDDs alert. This methodology may be used until the team can successfully detect the odor in a blind test; however, this must be documented in the Monthly Training Report.

  4. All actual or Non-Hazardous Explosives for Security Training and Testing (NESTT) training aids must be replaced on a regular basis. Actual explosive training aids must be replaced with new training aids no less than once every two-years. Outdated old contractor owned explosive training aids will be removed from the contract site by the contractor and disposed of. Each NESTT explosive training aid will be replaced within six-months of opening the sealed aid. The date of the initial receipt and opening of the aids outer wrapper must be documented as well as each use of each training aid. Immediately after using a NESTT aid it must be properly and completely resealed in order to retain its properties and odor. Each aid must have an identifying mark on it (letter or number) to distinguish it from others. The mark will be recorded in a document as a reference.

  5. Each contractor will be required to provide invoices/receipts indicative of the types, quantity, and dates of the purchase of the actual or NESST training aids. An inventory will be maintained reflecting the type and quantity of actual and/or NESTT aids on hand and the date of receipt and or destruction/deactivation of old aids.  (10-21-2008)
Storage of Explosive Training Aids (ETA)

  1. If actual ETAs are used, all ETAs will be stored in separate individual containers in a manner to prevent cross-contamination with other explosive odors. Therefore, all ETAs must have their own separate and sealed container (jar/zip-lock bags/ etc.), unless they are the same type and odor.

  2. All ETAs will be signed out and in from the storage container, properly accounted for and properly sealed in a separate container after each use.Actual explosive training aids will never be left unattended when out of the storage container. The person utilizing the actual training aids, or another assistant, must remain in the general area of the actual aids to prevent tampering or theft while the aids are out of storage.

  3. If actual ETAs are used, they will be stored in accordance with state standards and in an approved explosive storage magazine/vault, provided by the contractor, and will have required signs, as necessary, affixed to them.

  4. If actual aids are stored outside the facility in an exterior vault they must be stored in an explosive magazine that is bolted down or heavy enough to prevent someone from lifting it – a minimum of 750 pounds. The external magazine containing actual explosives must have good illumination in the area around it and observed by a CCTV camera and recorded. The security container will be checked each shift by the guard force and recorded to ensure it is properly locked and secured. These security checks will be recorded in the daily security shift log or on a locally devised form.

  5. If the training aid storage container is found to be unsecured, an inventory will be conducted by the contractor and the PSEP Territory security staff. If actual explosives are missing, an investigation will be conducted and reported to Criminal Investigation (CI)/TIGTA, if the explosives are not accounted for within four-hours. Additionally, the PSEP AD and SEP will also be notified if the explosive(s) are not found within 4-hours. A report of the known facts will be immediately provided to the AD and the PSEP SEP EDDP Manager, and an incident report will be submitted through SAMC.  (10-21-2008)
Inventory of Explosive Training Aids

  1. The COTR and contractor will jointly conduct inventory of all actual explosive training aids stored on IRS controlled property once a quarter and document the results. If shortages are identified, it will be immediately reported locally, an investigation will be conducted, and an incident report will be completed immediately and forwarded to the PSEP AD and the SEP EDDP Manager, and reported to SAMC.  (10-21-2008)
Material Safety Data Sheets (MSDS)

  1. A MSDS will be maintained on all actual and NESTT explosive training aids as long as they are in our inventory.  (10-21-2008)
Transporting Explosives on IRS Property

  1. When contractors are transporting actual explosive training aids on IRS property, the transport vehicle must meet state requirements concerning the quantity, type of vehicle, transport container the explosives are contained in, as well as fire extinguisher, and signage requirements.

  2. Drivers of vehicles transporting explosives on IRS property must ensure all state safety and licensing requirements are met.

Exhibit 10.2.12-1 
IRS Odor Recognition Proficiency Standard for Explosive Detection Canines

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Exhibit 10.2.12-2 
Page 2 of 4

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Exhibit 10.2.12-3 
Page 3 of 4

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Exhibit 10.2.12-4 
Page 4 of 4

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Exhibit 10.2.12-5 
Monthly Explosive Detector Dog Training Report

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Exhibit 10.2.12-6 
Monthly Explosive Detector Dog Utilization Report

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Exhibit 10.2.12-7 
Explosive Detector Dog Operational Test Report

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