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Over the last several weeks, The Torrington Housing Authority has received complaints from some tenants of the Torrington Towers, concerning what the tenants perceive to be are lapses in security.

The situation had reached a point where tenants and! or tenant representatives contacted members of the state legislature. A meeting was held on December 7, 2009, at the Towers during which time tenants and others voiced their concerns about the topic of building security. Among those in attendance at the meeting were some members of the Torrington Housing Authority and its Executive Director, Claudia Sweeney.

Following this meeting, the Housing Authority requested that I meet with them to discuss the possibility of me doing an evaluation of the security at the Towers. On Wednesday, January 27, 2010, I met with Housing Authority Chairman, Attorney Sam Slaiby, Authority Commissioner David Murelli, and Executive Director Claudia Sweeney. I was asked to conduct a study of the security function at the Towers and to submit a proposal for conducting such a study. My proposal was submitted on Friday, January 29, 2010 and was ultimately accepted. The following is a summary of that proposal:

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PROPOSAL

The following services will be performed relative to an evaluation of security measures at the Torrington Housing Authority facility known as The Torrington Towers:

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1) An evaluation of historical crime and calls for service statistics as compiled by the Torrington Police Department and calls for service by the Torrington

Fire Department. Also, an evaluation of current security measures at the Towers. This would include, but not be limited to, current security staff effectiveness, and adequacy of structural aspects of the building, and its

current security system(s).

2) Evaluation of resident perceptions of safety issues.

3) A report of findings to include recommendations for changes, if any, to the security function currently employed at the Towers facility. Said report to be submitted to the Torrington Housing Authority.

It is understood, that the above services will be performed for the Torrington Housing Authority and as such, the Torrington Housing Authority will be the release agent for any public comment during the evaluation process and upon submission of a final report.

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STUDY

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As per the proposal, a study of the security effectiveness at the Towers was conducted and was done so over an approximate four week period.

During this time several factors involving security at the Towers as it currently exists were examined. This examination consisted of the following:

• Interviews with Housing Authority management.

• Interviews with Towers security personnel.

• Interviews with Towers tenants.

• Review of security personnel job description.

• Review of security personnel operating procedure.

• Review of tenant handbook.

• Review of Torrington Housing Authority Resident Emergency Plan. o Review of Torrington Housing Authority Employee Emergency Plan.

• Interviews with governmental figures.

• Review and study of public safety sector calls for service at the Towers, from 2006 to February 1,2010.

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• Review of pertinent Connecticut General Statutes.

• Research into the potential of Connecticut State Regulations.

• Research into potential HUD regulations.

• Research into regulations from other states pertinent to this issue.

• Discussion with the Torrington Police Department, Community Policing Office

• Discussions with Police Chief Michael Maniago and Fire Chief John Field.

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FINDINGS

As previously stated, at the onset of this study, I met with The Torrington Housing Authority Executive Director Claudia Sweeney, Chairman Saliby, and Housing Authority Member, David Murelli.

During the ensuing conversations, the Housing Authority management briefed me on the December 7, 2009 meeting during which they received complaints from residents that the security at the Torrington Towers was insufficient. Furthermore, the Housing Authority additionally conveyed that there was a level of apprehension and fear in the building during not only the daytime, but the evening and night time hours as well.

Management advised me that they were concerned about the most recent complaints, and that they were concerned because they considered the complaints, if true, to be serious, and to effect the quality of life for their tenants. Furthermore, they expressed concern over the fact that the complaints made on December 7, 2009, were not conveyed to them in such magnitude prior to the meeting. The Executive Director did convey to me that she routinely will evict problematic tenants, but must invoke the eviction process which can be lengthy.

Of noted significance is that some of the complaints voiced at the December meeting were that the Torrington Towers, once specifically for the elderly, is now of mix demographics, combining younger tenants in the same building with the elderly, This appears to be a central point fueling fear with some residents and a demand for better and expanded security. As a matter of fact, based on later referenced studies, appears to be an underlining factor across the country in high rise public housing with mixed tenant populations.

It is at this juncture that I wish to note that this study does not address the demographic makeup of the building, nor indorse or dispute the current definition of eligible tenant. That is mainly determined by federal and state laws, and local regulations. This study evaluates current security measures and only addresses

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demographics when clearly related to security. The appropriateness of mixed housing is beyond the scope of this study.

As previously stated, this study included interviews with current security personnel. The Torrington Housing Authority currently employs three individuals as security guards. The hours worked are exclusively 0800 to 1500 hours daily, Monday through Sunday.

It must be stated that during the interviews, I found all three to be very approachable and candid with their remarks. Also noted is that one of the three is a retired Torrington Police Officer whom I've work with for many years. Another I have know for almost forty years as we were members of an Explorer Scout program sponsored by the Torrington Police Department.

During these interviews, each security personnel were asked questions concerning their job as performed, their job description, operating procedure, suggestion for improvement (if any) and evaluated for their general knowledge of building security and familiarity with the Towers building and its occupants.

Each security personnel appeared frank and unafraid to offer their opinion, and each appears concerned about the level of safety in the building. All three commented on the following:

• That they believe the surveillance camera system is very good, however, there area a few weaknesses such as the solariums and of hallways on all floors.

\9 Exterior lighting is not adequate for proper surveillance.

• That the job description, as currently written, is not completely followed.

This issue will be addressed later in this report.

It That only one of the three security personnel are currently trained and certified under Connecticut General Statutes.(this was in response to my questions on certification)

• That security coverage is too limited as to times of the day and night.( two of the three guards mention this)

• That they are told by the Housing Authority that they are not security guards, rather they are "observers" who are discouraged from getting involved too much into something and should only call management and or public safety personnel.

• That ongoing training is almost non existent.

\9 That they don't believe that the situation in the building, as portrayed by some, is that bad and is not supported by their personal observations.

• That about two years ago, they were assigned to evenings and that nothing currently being complained about actually occurred.

• That they are guided in this job by an assortment of advisatory memos, and not a comprehensive set of operating procedure

As equally important in this study were my random conversations with residents of the Towers. So as not to intimidate anyone, these conversations were kept as informal, and were done during the day and evening hours. Each interview was conducted on a voluntary basis on the part of the tenant. During these interviews, the following issues came up with sufficient frequency to merit recording:

.. Tenants feel that security only during the day time is not sufficient to provide proper levels of safety, and that hours should be extended to evening and night time.

• Tenants feel that periodic meetings with Torrington Housing Authority Management would be beneficial. They feel that an opportunity to hear about housing issues and voice concerns is important to them.

e Along with increased security, they hope for better access control.

.. Tenants have concern over the ability of staff to effectively evacuate the building with public safety personnel in cases of emergency. They are also concerned for the disabled population in the building.

o That new tenants don't know the rules specified in the tenant handbook.

.. That without security, people do not sign in at night and that non residents follow authorized guests or residents into the building during evening and night time. This issue seems to be central to tenant concerns; however, it is not frequently reported through official channels.

.. Those tenants are fearful of reporting problems to the Housing Authority.

Also, that when things were reported to security, they seemed to not want to be bothered. (not supported by actual instances that could be reported'

Of significance is the fact that each tenant interviewed felt strongly about the extended hours for security.

An important part of this study was to examine the administrative aspect of the security function at the Towers. In doing so, I reviewed the security guard job description (see appendix) and found listed job duties that are being performed partially, or not at all. The following is a list of duties with this deficiency:

e Insure that all non-residents that enter the building sign in and sign out when exiting. (day time only)

.. Maintain sign iniout log. (day time only)

• Walk the ground at least every half hour. This is to be done at least twice before the end of the second shift.

• Walk all floors and stairways to be sure all is secure.

Housing Authority Management provided copies of the Tenant Handbook, Tenant Emergency Plan and Employee Emergency Plan. These documents will be discussed later in this report. Noted is that a set of standard operating procedures for security staff does not exist.

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Contact was made with the Public Housing Unit of Connecticut Department of Economic Development. As a result it was learned that Connecticut does not have particular guidelines on the establishment, or maintenance of security in public housing.

Likewise, HOD was contacted considering the same issue. HUD advised a review of the "Uniform Physical Condition Standards and Physical Inspection Requirements. The issue of security appears to be at best, an elusive subject within these standards. Although I am sure the Torrington Housing Authority is aware of these standards, a copy can be found in the appendix section of this report.

Research was conducted into the topic of mixed housing from both management and tenant perspectives. Information and studies abound on this subject matter''. From all that has been written on this subject matter, one cannot escape the fact this is a national issue and debate, not isolated to Torrington.

With that in mind, I checked into what other states may have for regulations governing security in mixed housing. By far the most comprehensive governance is found in the State of Rhode Island. Rhode Island goes into great detail setting standards for the hiring, certification and training of security personnel in public housing. They even go farther in setting standards for tenant training in security. I have attached a copy of the Rhode Island Standards and will comment further on them later in this report.

I furthermore researched any state regulations in Connecticut for security guards. In doing so I checked The Connecticut General Statutes, Chapter 534, Sections 29- 152u, through and including 29-161z. Found in this section are the certification requirements for security guards (officer), as defined in 29-152u. It appears from my reading of the statute and the Housing Authority job description that the Towers security personnel are subject to mandates in registration, selection, training and certification. I have not located any exception or grandfathering under the statute. In speaking with the Special Licensing Unit of the Dept. of Public Safety it was learned that the Housing Authority can employ the security personnel without being licensed under a "proprietary exception". However, the individual security personnel must be licensed. Only one of the current Towers security guard is currently state certified. A copy of that statute is attached and made part of this report.

As planned, I requested and received data from Chief Maniago of the Torrington Police Department on the frequency of calls for public safety services at the Towers,

2 Mixed Population Issue in State-Subsidized Elderly Housing (Ct); Management Problems Posed by Nonelderly and Elderly Tenants by Sheehan, Nancy, Stelle, Charles, University of Connecticut, Journal of Aging and Social Policy. Assisted Living in Public Housing: A Case Study on Mixing Frail Elderly and Younger Persons with Chronic Mental Illness and Substance Abuse Histories. Heumann, Leonard, University of Illinois at Urbana-Champaign. Public Housing for the Elderly in Mass. How Federal and State Disability Laws have created a Sense of Confinement, Cedrone, Christine.

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also know as 52 Summer St. for the years of 2006 to 2009 inclusive. These services include Police, Fire and Ambulance.

By far, the largest frequency of response is from Campion Ambulance service. To a much lesser extend, were fire and police responses. I have grouped it all under public safety in general. Below is a graph depicting this activity.

PUBLIC SAFETY CALLS FOR SERVICE TORRINGTON TOWERS

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As one can see from the above graph, there has been a constantly upward trend since 2006 in public safety sector responses. Although, there have been no reported major criminal activity, there have been a variety of police responses to larcenies, unwanted persons, warrant arrests, domestic disturbances, noise complaints, vehicle vandalism and unruly persons. Following is a graph depicting the instances when someone was taken into custody:

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CUSTODIAL ARRESTS

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As one can see, these custodial arrests measured from 2007 to 02/01110 peaked in 2008, reaching a total of eighteen (18) for the years reported. This police activity does not appear to have an upward trend similar to total public safety responses. Twelve of the eighteen criminal arrests were in the late afternoon, evening or early morning hours.

The following is a representation of the frequency of calls for service during hours when security is not working as compared to calls when they are.

YEAR OFF HOURS TOTAL CALLS 24 HRS
2006 86 164
2007 152 221
2008 164 -_
230
2009 197 276 As the numbers show, all reporting years have in excess of fifty percent (50%) of the public safety calls for service occurring when security is not scheduled.

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As a result of my review of the Towers security operation, I was pleased to see that both management, tenants, and employees desire the best, most justified and reasonable security measures possible. To that end, I make the following recommendations:

1. Increase the level of security: The Torrington Housing Authority needs to expand the times that security is present at the facility. Daytime coverage only is not sufficient for the structural aspects of the building, the tenant population makeup, the exposure to trespass by unauthorized persons and for the potential of emergency evacuation and other illegal activities. With fourteen (14) floors, approximately 200 units and many tenants needing assistance, the Housing Authority cannot count solely on the Torrington Fire Department or Police Department. Nor can it count on staff on off hours; the response times for off duty staff would be too long. I strongly suggest going to a twenty-four hour format

2. Revaluate daytime security measures: Currently, the day time security guards mostly operate as receptionists. Rarely can they patrol the floors or exterior. Nor do they provide much security except for monitoring the entry points and the sign in book and cameras. This runs contrary to their job description causing a potential for major liability. I suggest that the Housing Authority revaluate these day time positions. Later in this report I will offer a suggestion in this regard. It is also my opinion that the monitors for the security cameras need to be put just below eye level and that the television needs to be eliminated. Adding a television in the area where the cameras are monitored diminishes the attention span of the security personnel. Additionally, after a certain time in the evening, only one entry point should be used (entry only not emergency exiting)

3. Tenant training: Tenants are provided with handbooks outlining rules for living at the Towers and aspects of their evacuation plan. These need to be constantly evaluated for accuracy and the tenant population, as would an employee, needs to be periodically trained in safety, security, and the evacuation plan. The Torrington Police Department and Torrington Fire Department are willing and capable to assist the Housing Authority with programs in tenant educations.

4. Develop a security policy and procedure manual: It is vital from a liability stand point that the Housing Authority develops such a document. Each expectation, each duty and each method of response to situations must be spelled out and trained for.

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5. Documentation: On a shift basis, the security staff must create and maintain a log of activity. Such a log can document any unusual circumstances, tenant's complaints, and responses from public safety. I recommend that this be computerized so the Housing Authority Management can monitor this information with ease on a regular basis. It is furthermore felt that a new incident report form must be developed for the accurate and timely documentation of noteworthy events or situations. Documentation must also be done on all security staff training. This is extremely important in risk management.

6. Communication with tenants on a regular basis: Much gossip, misinformation and even disinformation can be alleviated with regularly scheduled management! tenant meetings. These informational gatherings can additionally used for tenant training and training from outside resources. Management can continue to utilize outside services, such as the block watch program and the Police Department and the Fire Marshal's Office to help in the accomplishment of this goal. Increased communications would foster more timely and accurate reporting; of instances.

7. Contracting out security: Because the security of tenants and property and for obvious liability reasons, I strongly recommend contracting out uniformed security. Companies specializing or having experience in public housing exist and currently provide very good service. Advantages abound by taking this track. First, competitive pricing would be available. Significant (but not completely) liability would be assumed by the contractor. Training and certification can be required and more effectively accomplished with a professional security company. These companies can be required to provide staff that is trained in CPR, recognition of elder abuse and the abuse of the disabled. An assortment of standards, similar to Rhode Island can be mandated and accomplished with greater efficiency than if done by the Housing Authority. For an opinion of private security in public housing, one can look to Naugatuck, Connecticut for additional input.

8. Establish police/fire liaison: Assign a member of the management to be a liaison with the Torrington Fire and Torrington Police Departments. This would provide excellent opportunity for the communication of important public safety information for the Housing Authority the tenants and the surround area.

At this juncture, I wish to make it clear that I am impressed by the obvious sincerity of the Housing Authority and its staff in providing me with information and their time when conducting this study. I firmly believe that by wanting this objective evaluation of the security at the Towers, the Housing Authority has set the stage for creating the highest quality of life that can reasonably be had by the tenants.

Needless to say, to accomplish my recommendations, the management of the Torrington Housing Authority must address the fact that the three current security guards are unionized and under contract. The current personnel possess a significant amount of knowledge of tenants, authorized guests, and contractors that

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cannot be dismissed as of not being of any consequence. However, of primary importance is the safety of the tenants and their guests, city property, and the reduction of liability. To place these concerns in proper perspective, significant changes should be made, and can be made in a planned and compassionate manner. The Housing Authority must seek the advice of labor counsel. Through negotiations with the appropriate union, the Housing Authority can reclassify positions, change job descriptions, and option out of the security business through attrition. In the mean time, the Authority can research companies that are potential contractors, and establish contract requirements for bid requests.

In conclusion, the research for this project enabled me to conclude that the Torrington Housing Authority assumes a significant risk of liability by maintaining the current status quo with respect to security. Civil liability for the Honsing Authority is a mine field of issues. By way of the December 7, 2009 meeting, the tenants have in effect put the Authority on notice. At some point it will be argued that a major problem was foreseeable and preventable if appropriate measures had been taken. This may be the case even in the current atmosphere of chronic under reporting from the tenants.

I with to thank the Torrington Housing Authority, its Executive Director and staff for their time and input. I further wish to thank the many tenants I spoke to. Their time, patience and the kind reception they gave me was greatly appreciated.

Robert F. Milano

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APENDEX

1. Chapter 534, Connecticut General Statutes

2. Job Description Torrington Housing Authority Security

3. State of Rhode Island, Pubic Housing Security Standards

4. HUD Physical Conditions Standards

5. Public Housing Security Article by William F. Blake and James Carino, Blake and Associates Inc.,Littleton, Co.

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