By Brian Robertson
In June, the Province of Ontario posted a draft Training and Testing Regulation under the Private Security and Investigative Services Act (PSISA), and invited stakeholders to comment on its contents.
By Brian Robertson
One of the startling omissions from the Private Security and
Investigative Services Branch’s (PSISB) plans to introduce a mandatory
training requirement for licence applicants is the presence of any
security instructor qualification standards. As an ostensible
cost-saving measure, the PSISB are going to let the question of who is
qualified to deliver security training be governed by market forces.
“Surely,” the argument goes, “the employers and career colleges who
will be delivering the training, and the students who will be taking
it, won’t allow anyone to teach who isn’t qualified. Schools will want
the training they deliver to be of the highest calibre possible.
Students will vote with their dollars and only accept training from
This is nonsense. Perhaps market forces do weed out the incompetent in
a truly free market. But once you make training mandatory you destroy
it as a free market commodity. Many employers are interested in giving
their employees only quality training. But not all of them. There are
lots of employers who have no interest in providing their employees
with any training, let alone quality training.
Will career colleges employ only fully qualified security instructors?
Some will. But there are two ways to compete in a highly competitive
market, and the market for selling entry level security training is a
cut-throat one. You can try to have a better product than everyone
else, or you can try to have the lowest price. At least some career
colleges will decide to compete on price.
Which leaves it up to students, who are hardly going to be in a
position to act as empowered consumers. Half of them will be getting
training from the employers who hired them, and will take what they
get. The other half will have to go out and buy training with their own
money. Ill-equipped to evaluate the quality of the training programs
they buy, these students will be drawn to three types of schools: the
ones with the slickest sales pitches, the ones who make the most
outrageous claims about the career opportunities that lie ahead for
their graduates, and the ones with the lowest prices.
To be fair to the Province of Ontario, there are six provinces who have
no pre-licence training requirements at all, and there are no
instructor qualifications prescribed under the mandatory training
programs in either Saskatchewan or Manitoba. B.C. alone has a process
for approving instructors before they are allowed to teach, and the
requirements for instructor approval in B.C. aren’t very hard to meet.
But for as long as the regulatory reform process has been going on in
Ontario, the PSISB has bragged that their program was going to be
custom built, not merely modelled on what was going on elsewhere, and
that the main reason that it was taking so long was because they were
taking the time necessary to get it right.
In the December 2007 issue of Canadian Security I argued that security
trainers should be licensed under the PSISA. That way the PSISB could
set reasonable requirements for instructor qualifications, subject
security instructors to criminal record and background checks, prohibit
employers and career colleges from using non-qualified instructors out
of expediency, and reinforce the credibility of the mandatory training
program in Ontario. And because security instructors can afford to
invest more in certification than guards can, they could set the
instructor approval fee high enough to cover the whole cost of
administering the process.
It would be disappointing but understandable if the government
belt-tightening brought on by the recession had made it impossible for
the province to set instructor qualification standards. But it hasn’t.
The impression one gets, rather, is that after working on mandatory
training for over three years now the province has grown weary and
decided to follow the path of least resistance, in just trying to “get
the damn thing out of the door without any further delays.”
The province may later repent at their leisure what they are doing now (ironically) in their haste.