Archived - Audit of Arming

June 2015

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1.0 Introduction

In Budget 2006, the Government of Canada formally announced its intention to arm Canada Border Services Agency (CBSA) officers and eliminate situations where border services officers (BSOs or officers) work alone.

Referred to as the Arming Initiative (the Initiative), the CBSA received approval for authorized spending of approximately $1 billion over 10 years (from 2006–2007 to 2015–2016) to cover the cost of creating the infrastructure, processes and training required to equip 4,800 officers with a duty firearm, as well as the conversion of approximately 800 seasonal student employees to 400 full-time equivalent officers. The October 2006 approval also included “Doubling Up”, which avoids situations where officers work alone. The CBSA managed Doubling Up as a separate funding stream.

Since 2006, the number of firearm-designated positions has grown from the original estimate of 4,800 to approximately 6,744 in March 2014. This includes 1,200 positions associated with conducting off-site verifications and 744 additional positions for frontline land, marine and inland enforcement. Once the Initiative is completed, in 2015–2016, the CBSA will support ongoing firearm certification of officers regardless of where they are posted to allow for the operational flexibility of a fully firearm-certified frontline workforce.

The Arming Division is part of the Training and Development Directorate, Human Resources Branch. The Division is accountable for directing the process of arming authorized CBSA officers and providing high-quality training, a sound policy foundation and a rigorous management framework.

The Security and Professional Standards Directorate within the Comptrollership Branch is accountable for establishing and evaluating the standards for the secure storage of Agency firearms and ammunition as well as for investigating and reporting upon relevant matters of alleged misconduct involving Agency firearms, ammunitions or other defensive equipment.

Senior management in the regions is responsible for ensuring that the Agency complies with the arming and use of force policies, directives and standard operating procedures issued by the Arming Division and business processes set by the Training and Development Directorate.

2.0 Significance of the audit

The CBSA manages, controls and secures Canada’s border at approximately 1,200 points across Canada. BSOs face a growing challenge in intercepting potential threats, including high-risk individuals, firearms, explosives and drugs. To ensure Canada’s borders are secure, the Government must ensure that those who guard our borders are themselves secure. Providing CBSA officers with side-arms and training, and ensuring that work-alone situations are eliminated, will help achieve this goal.

The audit objective was to assess the management control framework and practices in place to ensure:

  • The Arming Initiative objectives will be met by March 31, 2016; and
  • Arming policy and program requirements are adhered to.

The audit scope and criteria can be found in Appendix A.

3.0 Statement of conformance

The audit conforms to the Internal Auditing Standards for the Government of Canada, as supported by the results of the quality assurance and improvement program. The audit approach and methodology followed the International Standards for the Professional Practice of Internal Auditing as defined by the Institute of Internal Auditors and the Internal Auditing Standards for the Government of Canada, as required by the Treasury Board’s Policy on Internal Audit.

4.0 Audit Opinion

The Agency is on track to meet its 2016 arming objective to arm all frontline officers in designated armed positions. Relevant training and tools were provided to armed officers and a governance structure is in place to monitor the overall program. Arming policy and program requirements were adhered to. There is an opportunity to improve the management of non-conformingFootnote 1 firearms and ammunition. There is also an opportunity to review the segregation of duties of some administrative positions where an individual would have access to both firearms and ammunition.

5.0 Key Findings

The Agency established an appropriate governance structure for the Arming Initiative. Strategic oversight committees regularly received timely information that allowed for the effective monitoring of the initiative’s objectives, risks, strategies, and results. The risks for the Arming Initiative were identified and managed.

Employees were provided with the necessary training, tools, and information to support the discharge of their arming-related responsibilities.

The Agency’s duty firearms and ammunition in our sample were appropriately secured, inventoried and life-cycle managed. There are some opportunities to improve the management of inventory. This includes timely recording of practice ammunition consumption in the Corporate Administrative System and improving the configuration of stock locations in the national warehouse. Also, the disposition process of non-conforming duty firearms and ammunition should be formalised. Lastly, administrative staff should be limited from having access to both duty firearms and ammunition at the same time.

Overall, training information and monitoring reports were found to be complete, timely and accurate to support ongoing oversight of arming. There is an opportunity to report the Arming training statistics to the Agency’s Executive Committee that identify the aggregate of current officers who have successfully completed the duty firearm course.

The Agency’s objective of arming all front-line officers by March 31, 2016 is on track.

6.0 Summary of recommendations

The audit makes the following recommendations:

  • Develop and implement controls for non-conforming material that includes the recall and disposal of duty firearms and ammunition.
  • Segregate duties for administrative staff that have access to both firearms and ammunition.

7.0 Management response

As the Arming Initiative transitions to a program, the findings of this audit will assist in the further development and refinement of the arming program into its steady state. The findings will allow management to enhance processes already in place and to adapt them in step with evolving Agency priorities while providing leverage for change management as we mature as a fully armed law enforcement agency.

8.0 Audit findings

8.1 Arming Initiative Governance and Accountability

Audit Criteria:

  • Appropriate governance structure for arming is established.

A formal governance framework ensures that there is effective oversight of a major project such as the Arming Initiative. An appropriate governance structure allows effective monitoring of the objectives and strengthens the overall organizational performance management and accountability.

The progress of the Arming Initiative is governed and monitored by two key oversight bodies:

  • i. The Arming Program Management Table (PMT) comprises directors general and directors from across the Agency, including the Regions. The Arming PMT is responsible for:
    • Establishing strategic direction and providing functional direction for arming activities through clearly defined outcomes and priorities;
    • Regularly reviewing the performance of arming activities; and
    • Reviewing arming expenditures to assess resource levels against performance.
  • The Arming PMT is a sub-table of the Training and Learning PMT, which reports upwards to the Corporate Management Committee and Executive Committee (EC). Overall arming progress is reported regularly to the Vice-President, Human Resources Branch who updates the EC through Agency Performance Summary reports on results and challenges.
  • ii. The Duty Firearm Course Advisory Committee (DFCAC) comprises management from both the Agency and the Customs and Immigration Union (CIU). The Agency is represented by Director General and Director level management from the Human Resources Branch (specifically from: the Labour Relations and Compensation Directorate; and the Training and Development Directorate including its Arming Division) and two Regional Directors General. The DFCAC is responsible for developing strategies to meet the following objectives:
    • Ensure officers complete Duty Firearm Course (DFC) prerequisites as soon as possible (e.g. psychological assessment and a medical assessmentFootnote 2) to allow officers to complete training prior to 2016; and,
    • Ensure officers are selected and scheduled to attend the DFC in a consistent and transparent manner.

Each committee had Terms of Reference established and included information such as: purpose and composition; planned frequency of meetings; and roles, responsibilities and authorities. Committee members confirmed that the roles, responsibilities and authorities of each committee were communicated and understood.

The DFCAC is required to meet quarterly and the Arming PMT once every four weeks. A review of 2013–2014 records of decisions confirmed that the DFCAC met in accordance with the required frequency. The Arming PMT met nine times over the 2013–2014 fiscal year although the expectation is every four weeks. Management noted that some meetings had been cancelled due to members’ unavailability.

It was observed that key documents such as training reports, status updates and statistics were provided to committees in advance of the meeting. Records of decision also indicated that discussions occurred on relevant topics including scheduling training, updates on the overall arming objectives including risks and issues, incident management training, communication strategies and health and safety.

The Agency also has an Incident Review Committee that evaluates use of force incidentsFootnote 3 involving duty firearms against Agency authorities, policies and training. This committee sits as required. More detail about the committee is presented in section 8.4.

Overall, an appropriate governance structure for the Arming Initiative was established.

8.2   Risk Management

Audit Criteria:

  • Risks that may preclude the achievement of the arming objectives are identified and managed.

In May 2012, the Arming Division completed a Programmatic Assessment which included a risk assessment. The risk assessment identified challenges that may preclude the achievement of the arming objectives as well as mitigation strategies to help reduce the probability of the risk materializing. The Arming Division identified two high level risks that were reported through the Enterprise Project Management Office (EPMO):

  • i. Inadequate training staff capacity to deliver on the continuous training and re-certification processes required to maintain an armed workforce;
  • ii. Inability to meet the commitment to train and equip sufficient number of frontline officers by 2016.

These risks were monitored on a monthly basis through the EPMO project dashboards and performance summaries which are presented to the Vice-President, Human Resources Branch, and subsequently to the EC as part of the Agency Performance Summary reports. Analysis of these documents demonstrated that the number of instructors continued to increase to satisfy the Arming Initiative’s throughput. The second risk, related to the overall success of the Arming Initiative, is presented in section 8.5 of the report.

In addition to the Programmatic Assessment, the Arming Division monitors risks and mitigation strategies through the monthly EPMO Arming Project Summary Documents. The dashboards and summaries contained information on existing and other emerging risks, status of mitigation strategies and general issues associated with the Arming Initiative. A responsible unit and/or division were identified and held accountable for implementing mitigation strategies.

Overall, risks that could have precluded the achievement of the arming objectives were identified, managed and presented to senior management within the Agency.

8.3 Training and Tools

Audit Criteria:

  • Employees are provided with the necessary training, tools, and information to support the discharge of their responsibilities related to arming.

To exercise their roles and responsibilities and to reduce the risk of firearm-related accidents, it is important that armed officers have an adequate knowledge of CBSA Arming policies and firearm safe-handling practices, tools and information.

Mandatory Training

Prior to being issued and permitted to carry a duty firearm, a BSO must successfully complete a firearms safety courseFootnote 4, a medical assessment, a two part psychological assessment and an 18-day long CBSA DFC.

The audit focussed on the completion of the psychological and DFC components by reviewing a statistically representative sample of 77 officers across all regions who were armed during the audit period. All officers in our sample successfully passed these assessments.

To demonstrate that armed officers have maintained the CBSA’s established standards and skills acquired during the shooting portion of the CBSA DFC, armed officers are required to undergo annual recertification. The CBSA Standard Operating Procedure (SOP) on Agency Firearms and Defensive Equipment requires that armed officers be recertified on the duty firearm every twelve months. All armed officers in our sample were recertified. In seven cases where recertification occurred after twelve months, management had approved the delay.

During every third year, armed officers take part in an extended five-day recertification session. In addition to shooting, officers are required to demonstrate proficiency in control and defensive tactics, judgment and legal articulation.Footnote 5

The three year recertification should be completed 36 months after the officer’s successful completion of their DFC. The recertifications completed during the audit period were on time in 97% of the cases.Footnote 6 The recertification was completed more than a year later in 3% of the cases. The delays were either due to long term leave, an investigation or the inability of the officer to meet the qualification standard during the recertification and skill enhancement training.Footnote 7

Despite some delays in recertification, which can occur due to unavailability of the officer as a result of leave, injury or other operational requirements, training of officers was successfully completed prior to the issuance of a duty firearm.

Firearm practice

Prior to April 2014, all officers participated in an annual mandatory live-fire practice session under the supervision of an Agency firearm instructor. In April 2014, arming management issued a bulletin that ended the mandatory supervised practice session. The elimination of the mandatory practice session was to reduce operational pressures and free up trainers to support other priorities related to arming training. The removal of the annual mandatory live-fire practice session, which was introduced as a transition measure to encourage acceptance of arming within the CBSA, brought the CBSA in alignment with the practices of other federal departments that have armed employees. The supervised training remains available to both new graduates from the Officer Induction Training Program (OITP) and the DFC.

Arming management indicated that a significant number of armed officers were able to maintain their firearm skills without supervised practices; they also explained that Regions can offer supervised practice to officers having difficulty with recertification.

Despite the discontinuation of supervised practice, officers are authorized to practice shooting on their own time with their duty firearm and Agency supplied practice ammunition. Based on our review of consumption of practice ammunition, 63% of armed officers participated in off-duty practice in 2012–2013 and 51% in 2013–2014.

To evaluate the impact of removing the supervised practice sessions, the Arming Division may consider performing an analysis of recertification success rates from a period with and without supervision once the data has become available.

Scenario-based training

The Agency also carried out different scenario-based training exercises that can include the simulation of the discharge of a duty firearm. These exercises help maintain preparedness of both management and front line officers. Table Top exercises, are a discussion-based, facilitated group analysis of an emergency situation in an informal, low stress environment. They are designed for examination of operational plans, problem identification, and in-depth problem solving. Full Scale Exercises and Red Gun Scenarios are simulated emergency events within a controlled exercise environment where personnel and equipment are deployed as if the scenario was really happening. These exercises can include: other regional, national and international enforcement agencies; emergency responders; and other government and local authorities.

Information and tools

In addition to formal training, the audit confirmed that armed officers are provided with the necessary information and tools to perform duties related to the use of force with a duty firearm. The Arming Division maintains a comprehensive policy suite made available to all employees through a dedicated CBSA Arming intranet site. This suite includes policies, directives, SOPs, guidelines, standards and bulletins related to Arming. A total of 33 arming communiqués and bulletins have been published between June 5, 2012 and December 30, 2014. They reminded armed officers about specific directives or indicated a change in the policies, SOPs, tools or directives.

8.4 Stewardship

Audit Criteria:

  • Duty firearms and ammunition are inventory and life-cycle managed, secured while in storage, and handled safely according to appropriate procedures and protocols.

8.4.1 Firearms and Ammunitions Inventory Management

CBSA duty firearms are prohibited weapons and need to be protected from loss, theft, unauthorized access, modification and removal. Further, because Agency firearms are prohibited weapons, controls over them are mandated by lawFootnote 8. The theft or loss of a firearm from the Agency and its subsequent use in a crime of violence would be an unacceptable incident. Therefore, controls over firearms inventory throughout its lifecycle should be in place and effective. A fundamental component of any inventory control system is a complete schedule of all items and pertinent information for each item that is reliable, accurate and timely.

There are a total of 10,655 CBSA duty firearmsFootnote 9 that are located across the Agency, Royal Canadian Mounted Police Armouries (for initial inspection of the duty firearm and preventive maintenance) and the firearm manufacturer’s distribution centre.

The audit tested the accuracy of the inventory of firearms in locations across the Agency against the Corporate Administrative System (CAS). A sample of 337 firearms from three regions and the national warehouse in Ottawa were reviewed to verify that the officer had possession of the firearm or that it was stored and appropriately secured. All firearms in the sample were accounted for.

A physical ammunition count was conducted in three regions and the national warehouse to verify accuracy of the ammunition inventory report generated from CAS. The results of our testing found that the inventory in the Quebec region was accurate. In the two other regions included in the scope, there were discrepancies between CAS and the physical inventory for practice ammunition.

When officers plan to practice, they must complete a form that identifies how many rounds of ammunition they are taking for practice and obtain approval from a superior. When officers return from practice, they return any ammunition that was not expended and the completed form to an administrative officer for processing. There were delays in processing these forms and updating CAS accordingly. These delays mean that on-hand inventory may not be reflected in CAS. This in turn, can affect automated minimum restock orders. The system will display that there is still ammunition on-hand for the officers to use, when in fact there may not be any ammunition available at the port of entry (POE) for practice. No issues were found with respect to inventory of duty ammunition.

At the national warehouse all ammunition identified in CAS was accounted for. However, an extra 45,000 rounds of non-conforming ammunition was not reflected in CAS. This ammunition was securely stored in a stockroom at the warehouse with other ammunition but was not reflected in any recent inventory audits. Non-conforming material should be clearly identified and quarantined while it awaits disposition.

The ammunition and firearms at the national warehouse are stored on racks and shelves in multiple locations of the stockroom. When a stockroom employee queries the location of the material in CAS, the system, as configured, only shows the stock in one general location. This is inefficient from an inventory control perspective. To compensate, the warehouse staff created their own inventory spreadsheet to manage specific inventory locations more efficiently. In 2015 the stock at the national warehouse will be transferred to another Agency location. When the stock location is established in CAS at the new location, there is an opportunity to include specific stock locations within a stockroom to facilitate efficient inventory practices.

Inventory verifications

The SOP on Agency Firearms and Defensive Equipment requires that managers ensure that firearms and ammunition inventory are verified quarterly and report unexplained discrepancies to Regional Security.

This verification confirmed that superintendents, with the assistance of a witness, conducted verifications on a quarterly, and in some cases, monthly basis. In one region visited, there was no documented evidence that verifications were being conducted, but management explained that the verifications occurred in an ad hoc manner without documenting the results. When gaps or issues were found during the regional verifications, actions were taken to alert involved officers and regional security if required. Discipline may also be considered for violations encountered as part of the verification.

In addition to these verifications, Regional Security conducted annual audits which provided an independent review of the control of firearms. These audits were completed in the visited regions on a quarterly or annual basis and the results were documented and shared with regional management for corrective action when required.

The verifications of Agency firearms and ammunition inventory occurred, however formal documentation of verifications across all regions would strengthen the process.

8.4.2 Firearms and Ammunition Lifecycle Management

Day-to-day maintenance

Armed employees are accountable for the day-to-day maintenance of defensive equipment which includes their duty firearm. The DFC and Arming Policy suite provide specific guidance on how to perform this maintenance.

Officers who were interviewed were aware of cleaning procedures and maintenance of the firearm following practice and training. Cleaning supplies and necessary equipment were available and accessible in the firearm room in each POE visited. Although day-to-day maintenance is not expected to be documented, observations related to maintenance were captured through the verifications done by supervisors.

Annual Inspection

In April 2014, the Arming Division implemented a change to the SOP on Agency Firearms and Defensive Equipment. It required that managers ensure all duty firearms issued to officers are inspected annually and the results documented in a checklist. In addition to a physical inspection of the firearm, this inspection includes verifying the handling skills of the officer during loading and unloading to prove the firearm safe.

Management in regions visited did not perform these inspections as they had not been aware of the requirement.

Preventive maintenance

After three years of service, or expending 5,000 rounds, CAS triggers preventive maintenance of a duty firearm. Managers and regional arming coordinators ensure that the officer arranges for their duty firearm to be collected and sent for maintenance. A spare firearm is issued to the officer while the other firearm goes through the maintenance cycle.

The Arming Division is improving the preventive maintenance process. This caused a seven-month delay to scheduled firearms maintenance but is intended to improve the process and avoid cases where a firearm has been serviced for non-scheduled maintenance followed by a preventive maintenance shortly thereafter.

Disposal of firearm and ammunition

In some cases, firearms or ammunition will need to be disposed of, and ultimately destroyed. During fiscal years 2012–2013 and 2013–2014, a total of 12 firearms were sent for disposal. Although these firearms were replaced under a warranty agreement, there was no evidence to demonstrate that the manufacturer had destroyed the problematic firearms. Upon further enquiry, the 12 firearms are still with the manufacturer, who will decide if they can be repaired; the Agency is awaiting documentation on the destruction of these firearms.

The 45,000 rounds of non-conforming ammunition that the audit located at the national warehouse were not tracked and disposed of in a timely manner. There is no formal process in place to track non-conforming material or any firearms and ammunition recall.Footnote 10

If non-conforming inventory is not quarantined and easily identified, there is a risk that it could return into the Agency’s inventory and cause harm to the CBSA or the public.

8.4.3 Security and Storage

Security and Professional Standards Directorate (SPSD) in the Comptrollership Branch is accountable for establishing and evaluating the standards for the secure storage of duty firearms and for firearms clearing and locking devices.

Secured storage

Unless an armed officer has a written authorization from his supervisor to store a duty firearm outside a CBSA facility, all duty firearms must be stored at an Agency office. When not in use, all firearms must be locked with a locking device that restricts the duty firearm from being loaded and stored in an Agency-approved metal storage container or storage locker. All locks, containers and room that are used to store defensive equipment must be approved by Regional Security.

All POEs visited were equipped with proper containers. All duty firearms, ammunition and magazines examined as part of our sample were stored in accordance with policy and procedures. All firearms in our sample were found to be secured as required.

Vulnerability Assessments

A vulnerability assessment is a process to identify and prioritize security and storage weaknesses. SPSD has undertaken an initiative to conduct vulnerability assessments of all land border POEs which was completed in January 2015.

Included in the scope of the vulnerability assessments are 12 specific security and storage elements related to the arming room that were assessed by security specialists. The audit team confirmed that these 12 elements were assessed at the POEs included in the audit. The results for all land border POEs have not yet been finalized by SPSD.

8.4.4 Health and safety

Awareness of hazards associated with firearms as well as the health and safety requirements are important in helping to protect CBSA employees and the public.

Health and safety components are included in various CBSA training and procedural documents such as the: CBSA DFC – High Level Curriculum; CBSA Directive on Agency Firearms and Defensive Equipment; and CBSA SOP on Agency Firearms and Defensive Equipment.

Key health and safety components were identified and described throughout the above documents including roles and responsibilities, firearm safety, drawing and holstering, loading and unloading, transportation, and cleaning and maintenance.

The CBSA Directive on Agency Firearms and Defensive Equipment notes that if a supervisor/manager has knowledge of or reason to suspect that a psychological condition exists, a demand for a psychological assessment can be made.

However, the existing training material, procedural documentation and directives do not provide guidance on specific behavioural indicators that could signal an officer’s reduced capacity to possess, wear or use defensive equipment and may warrant a psychological assessment. With more guidance, a supervisor/manager may be better able to identify these behavioural indicators which could help prevent a safety issue.

It was observed that at some regional warehouses, administrative staff has access to both firearms and ammunition. Although these employees require a valid Canada Firearm Safety Course certificate, the access to both duty firearms and ammunition may pose an unnecessary risk to the Agency.

8.4.5 Incident Management and Reporting System

Management monitors all health and safety and other situations where a duty firearm is involved, recorded as a use of force incident in the Incident Management and Reporting System (IMRS). A use of force incident that involves a duty firearm occurs when a firearm is drawn under any circumstance and/or the firearm is discharged unintentionally or otherwise (this does not include training, day-to-day inspection of the duty firearm, loading and unloading).

A Use of Force Incident Report must be completed by an officer for any incident involving a firearm. All incident reports are required to be reviewed by: local management; a CBSA Use of Force instructor; and the Incident Review Committee (Committee) under the responsibility of the Arming Division.

The audit reviewed all firearm-related incidents, totalling 63, between 2012–2013 and 2013–2014. For each incident, a Use of Force Incident Report, a Use of Force Incident Review Report and a Management Review Report were duly recorded in IMRS.

In 48 out of the 63 cases, the Committee determined that appropriate actions were taken by the officers. In three cases, officers unintentionally discharged their firearms in the arming room in front of a ballistic discharge panel. In these cases, the officers had to undergo additional training. In the remaining 12 cases, the Committee determined that the officers had to review legal articulation and improve how they document their use of force report in such a manner that reviewers understand why their firearm was drawn. In three cases, discipline was administered. It should be noted that out of all 63 cases, no firearms were discharged except for the three cases of unintentional discharge.

Overall, incidents related to duty firearms were reported, investigated, and acted on when necessary.

Recommendation 1:

The Vice-President of the Human Resources Branch should develop and implement controls for non-conforming material which includes a process to effectively quarantine, recall and dispose of duty firearms and ammunition in a timely manner.

Management Response Completion date
Management agrees with the recommendation and is developing a standard operating procedure to specifically address recalled/quarantined duty firearms or ammunition and their disposal/destruction. June 2015

Recommendation 2:

The Vice-President of Human Resources Branch should ensure that there is segregation of duties for administrative staff so that these individuals do not have access to both ammunition and firearms.

Management Response Completion date
Management agrees that separation of duties for administrative staff to limit access to both firearms and ammunition is advisable whenever practicable. When it is not practicable to have such separation of duties (minimal staff, operational requirements, etc.), an exception approval by management will be required. October 2015

8.5 Monitoring and Reporting

Audit Criteria:

  • Arming training information is complete, timely and accurate to support ongoing monitoring and oversight of arming.
  • Monitoring reports are reliable, timely and presented to oversight bodies for informed decision-making.

Training statistics and progress towards the arming objectives are communicated through various presentations and dashboards to EC, DFCAC and the Arming PMT. In addition, EPMO project dashboards and performance summaries are prepared on a monthly basis to monitor and report on the status and any issues that could impact the successful delivery of the Arming Initiative. The data used to populate these reports were both complete and accurate.

The EC is also regularly updated on the training statistics related to the number of successfully trained and armed officers. It was noted that individuals who have been successfully trained and equipped but have since left the CBSA or moved into an unarmed position are not removed from the figures presented to EC. Although the total number of successfully trained and equipped officers is important to communicate, this figure does not directly reflect the overall objective to arm the front line by March 2016.

In March 2014, the Agency estimated the number of frontline officers to be armed at 6,744. As of December 2014, the Agency has 6,433 frontline officers which include 312 new Officer Induction Training Program graduates. Of these 6,433 officers, 4,663 have already been successfully trained and armed. This leaves 1,770 officers to be trained and armed by March 31, 2016.

The Arming Division planned training of 1,558 officers during 2015–2016. The forecasted DFC success rate is 95% which means that approximately 1,480 will successfully complete their DFC.Footnote 11 There are an additional 212 officers who will be accommodated as they have restrictions on completing arming or control and defensive tactics trainingFootnote 12. In total 6,143 frontline officers are forecasted to be armed by March 31, 2016 (See Figure 1).

Figure 1: Arming of frontline officers as of December 2014:

  • Current Officers successfully trained at DFC: 4,351
  • Officer Induction Training Program graduates: 312
  • Forecasted officers to pass DFC (95% pass rate): 1,480
  • Total forecasted armed officers March 31 2015: 6,143
  • Forecasted officers to fail DFC (5% failure rate): 78
  • Estimated officers that require accommodation: 212
  • Number of officers available to be trained: 6,433

Overall, the training information and monitoring reports were found to be complete, timely and accurate in support of ongoing monitoring and oversight of the Arming Initiative. There is an opportunity for improvement to provide EC with training statistics that excludes the number of qualified individuals that have since left the Agency or moved into a non-armed position. This will provide EC with a perspective that is better linked to the arming objective. The objective of arming all frontline officers by March 31, 2016 is on track.

Appendix A – About the audit

Audit objectives and scope

The audit of Arming was approved by the Agency’s Audit Committee as part of the Risk-Based Audit Plan for 2014–2015 to 2016–2017. The audit objective was to assess the management control framework and practices in place to ensure:

  • The Arming Initiative objectives will be met by March 31, 2016; and
  • Arming policy and program requirements are adhered to.

The audit’s scope partially excluded physical security and storage:

  • The Physical Security Division within Headquarters has initiated Threat and Risk Assessments (TRAs) for each port of entry and other CBSA controlled zones such as inland enforcement. The TRAs will cover the physical security and storage capabilities of firearms and ammunition. The Follow-up Audit of the Control and Disposal of Goods Seized under the Customs Act examined physical security and storage. To allow the implementation of the action plans, an assessment of physical security and storage has been excluded from this audit. However, the audit will validate the progress of the TRAs against the action plan as it pertains to arming rooms and storage.

The audit’s scope excluded:

  • Funding: A recent independent assessment by a third party indicated a forecasted lapse of $20.1 million in 2015–2016. As of August 2014, management indicated a projected surplus of approximately $1.5 million by 2015–2016. With limited to no budget pressures, the risk of inadequate funding to support the Initiative objectives is low and has been proposed to be excluded from the audit.
  • Use of force occurrences not related to the use of firearms: CBSA officers may use force in the performance of their duties which may include situations where an officer has drawn their defensive equipment, which includes Oleoresin Capsicum (OC) spray, baton, or empty hand control, in the presence of a member of the public. Occurrences that did not involve a duty firearm were excluded from the scope.

The period covered by evidence examined was April 1, 2012 to March 31, 2014, except for analysis of practice ammunition which was from January 1, 2013 to December 31, 2014. The audit’s planning phase was from July 2014 to September 2014; the conduct phase, from October 2014 to January 2015; and the reporting phase, from February 2015 to June 2015.

Ports of entry were visited in three regions: Southern Ontario, Pacific and Quebec. The audit team also confirmed inventory practices at the national warehouse.

Risk assessment

A preliminary risk assessment was conducted during the planning phase to identify potential areas of risk and audit priorities; it included a visit to the Saint-Bernard-de-Lacolle border crossing, marine port operations in Montréal and discussions with key personnel involved in arming. It identified the following key risk areas:

  • There is a risk that training completion objectives may not be met by March 2016 because there remain close to 1,600 frontline employees that require training by the end of the project.
  • There is a risk that armed officers may not maintain their firearm handling skills
  • There is a risk that duty firearms are not properly controlled and safeguarded at CBSA offices and outside, which could result in injury (health and safety) to Agency employees and/or the public.
  • There is a risk that key arming policy and/or procedural requirements are not being adhered to.
  • There is a risk that up-to-date inventory records are not maintained which could result in lost or stolen inventory (firearms and ammunition) that is not detected or not detected in a timely manner.
  • There is a risk that facilities and/or equipment used to store firearms and ammunition are not secured and do not meet physical security standards.

Approach and methodology

The examination phase of this audit was performed using the following approach:

  • Reviewed applicable policies, directives and procedures governing arming;
  • Interviewed officers and managers in regional offices implicated in the management or the implementation of arming and with officials in the following branches: Human Resources (as Office of Primary Interest of the Arming Initiative), Comptrollership and Operations;
  • Reviewed samples of firearm and ammunition inventory to assess the effectiveness of the storage and inventory processes; and
  • Reviewed incidents involving use of duty firearms by CBSA officers to assess the adherence to policy and procedures.

Audit criteria

Given the preliminary findings from the planning phase, the following criteria were chosen:

Lines of Enquiry Audit Criteria
Governance and Accountability 1.1 Appropriate governance structure for arming is established.
Risk Management 2.1 Risks that may preclude the achievement of the arming objectives are identified and managed.
People (Training and Tools) 3.1 Employees are provided with the necessary training, tools, and information to support the discharge of their responsibilities related to arming.
Stewardship 4.1 Duty firearms and ammunition are inventory and life-cycle managed, secured while in storage, and handled safely according to appropriate procedures and protocols.
Monitoring and Reporting 5.1 Arming training information is complete, timely and accurate to support ongoing monitoring and oversight of arming.
5.2 Monitoring reports are reliable, timely and presented to oversight bodies for informed decision-making

Appendix B – List of acronyms

BSO
Border Services Officers
CAS
Corporate Administrative System
CBSA
Canada Border Services Agency
DFC
Duty Firearm Course
DFCAC
Duty Firearm Course Advisory Committee
EC
Executive Committee
EPMO
Enterprise Project Management Office
IMRS
Incident Management and Reporting System
PMT
Program Management Table
POE
Port of entry
SPSD
Security and Professional Standards Directorate
SOP
Standard Operating Procedures
TRA
Threat Risk Assessment

Notes

Footnotes

Footnote 1

Non-conforming refers to material that cannot be used due to concerns of damage, functionality, expiration or other factors that requires disposition.

Return to footnote 1 referrer

Footnote 2

Health Canada Category III Medical Assessment.

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Footnote 3

A use of force incident occurs when a firearm is drawn under any circumstance and/or the firearm is discharged accidentally or otherwise (this does not include training, day-to-day inspection of the duty firearm, loading and unloading).

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Footnote 4

Completion of the Canadian Firearms Safety Course and/or the Canadian Restricted Firearms Safety Course.

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Footnote 5

Legal articulation is the ability to explain situational factors, the officer’s perception and risk assessment of a situation and continual reliance on the Incident Management Intervention Model, CBSA policy and the Criminal Code.

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Footnote 6

Recertification must be completed at maximum 48 months after the successful completion of the DFC.

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Footnote 7

During the course of an investigation or where the officer did not achieve the qualification standard during the recertification and subsequent skill enhancement course, defensive equipment, including the duty firearm, was removed.

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Footnote 8

Canadian Firearms Act and associated regulations.

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Footnote 9

Inventory as of December 2014. This inventory includes additional duty firearms for spares, training, future armed officers, duty firearms that are going through maintenance and non-conforming duty firearms.

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Footnote 10

Note that there were no recalls during the period of the audit.

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Footnote 11

This 95% success rate has been stable throughout the audit period.

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Footnote 12

Long-term medical or duty to accommodate restrictions or temporary restrictions which will impact the officer’s availability for training.

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