By Boynton, Randall S.
Security Management , Vol. 45, No. 6
TO CARRY OUT the rules and regulations of the gaming industry, security needs a manual that's a sure thing
The heavily regulated casino and hospitality industry is overseen by various state and federal agencies, including state and tribal gaming commissions and liquor control authorities. A comprehensive policies and procedures manual is a key factor in ensuring compliance with the regulations these bodies establish.
A well-written manual establishes the who, what, where, when, how, and why of a casino's security operations. It sets the parameters of the policies, and it serves as a framework on which to build training programs. When litigation looms, lawyers and expert witnesses can look to the manual as a first step in assessing security at the facility.
TIMING. Management should be realistic about the time needed to complete the project, which usually exceeds preliminary estimates by as much as 50 percent. Where possible, managers should involve all decision-makers up front to minimize last-minute changes. In reality, however, some final changes cannot be avoided, and that is often the reason projects fail to meet scheduled completion dates. For example, the author was involved in developing an assets protection manual at one casino property where the vice president of human resources decided that all department manuals had to he modeled on the company manual. When the edict came down, the manual was formatted and ready to be printed. The vice president's order required the reformatting of the entire 200-page document, setting back the completion date.
TEAMWORK. Preparing the manual is a team effort. The security director or manager can act as the coordinator and assign his or her supervisory staff and senior officers as team leaders who can spearhead various segments of the development stage.
During the development stage, a checklist of all the items to he included in the manual is created. Next, a proposed table of contents is needed to rank the manual's chapters and subchapters in the order of importance or logical progression. Then each team leader assigns duties to his or her respective team members. These duties include research, writing, design, and final assembly of the product.
The team members charged with research should begin by reviewing present security and nonsecurity operations and all existing policies and procedures. Security staff should be interviewed to determine what they are doing, when they do it, why they do it, how they do it, and whether they have suggestions for doing it better. From the information gathered, a complete and comprehensive view of security operations can be attained and evaluated.
The manual should include chapters on gaming laws; state, county, and city criminal laws; hospitality or innkeeper laws; and Occupational Safety and Health Administration regulations relevant to the property. For example, trespassing is a perennial problem, and security staff must know how to handle it legally; if handled outside the bounds of law, incidents can end up in court with a verdict in favor of the trespasser.
Before the chapters dealing with these legal issues are completed, the team should review the relevant regulations, statutes, case law, and other materials to ensure that the information included is up to date. Because the details of the state criminal statute on trespassing are vital, the statute should be reproduced in full. Statutes can be purchased at the state printing office or on the Internet. Copyright laws in regard to reproducing any state statutes or other codes should be investigated before inclusion in the manual. In manuals for tribal casinos, state compact regulations and National Indian Gaming Commission Minimum Internal Control Standards relevant to security operations should be included.
Networking. Networking with peers can be an invaluable research tool. For example, at one casino, the author had to create a procedure for security escorts of celebrities, high rollers, and others with special needs. …