Review of Uniform and Dress Manual Policy Changes

Background

The RCMP provides members with the necessary articles of approved uniform items for their assigned function, which they wear in accordance with the relevant operational needs, health and safety requirements.

Directives on uniforms are contained in the Uniform and Dress Manual. Chapters 2 to 8 fall under the responsibility of the Uniform and Equipment Program within Corporate Management and Comptrollership. Chapter 1 is the responsibility of the Corps Sergeant Major, who, supported by Warrant Officers, provides guidance on grooming to ensure that matters pertaining to the orders of dress, ceremonial protocol, and state occasions are adhered to by members.

In November 2020, the Commissioner made a joint decision with the National Police Federation to allow members the flexibility to select and purchase their choice of cargo pants for reimbursement. Also, the reimbursement amount for boots was increased. The modernization of uniforms is continuing with the current initiative to update the uniform duty shirts.

Why this is important

As the environment in which police operate is continually changing, the RCMP must adapt to new demands and challenges to fulfill its mandate and promote workplace diversity. Risks associated with officer and public safety must be considered.

Review objective and scope

The Review examined the controls related to changes to the Uniform and Dress Manual and assessed the impact of risks to the RCMP such as officer impersonation, and officer and public safety.

The scope focused on the impact of the policy changes and the related implementation for the period of April 1, 2019 to December 31, 2021.

Findings highlights

• Processes are in place for the issuance, reimbursement and disposal of uniform items but procedures are not being consistently followed. Enhancing the controls over the reimbursement process and clarifying disposal requirements would facilitate compliance with uniform policies.
• Unit Commanders and Commanding Officers do not consistently enforce the standard uniform requirements and purchase non-approved uniform items. There is an opportunity to strengthen adherence to the Uniform and Dress Manual.
• Members are dissatisfied with the pace of modernization for the uniform duty shirt and the September 2022 update did not provide expected completion dates
• [REDACTED]
• Consideration should be given to strengthening compliance with the Uniform and Dress Manual while providing RCMP members with uniforms that are functional and which meets their diverse needs for comfort, health and safety

Next steps

The management response and action plan developed in response to this report demonstrate the commitment from senior management to address the review findings and recommendations. RCMP Internal Audit Function and Departmental Audit Committee will monitor the implementation of the management action plan and undertake a follow-up audit if warranted.

Recommendations

The RCMP should:

1. With respect to the RCMP Regulations:
   1. [REDACTED] identify options for how to address reimbursement, taking into consideration that members have the uniform items required to perform their work
   2. determine the short-term and longer-term options to align policies with the RCMP Regulations, taking into consideration a risk-based phased approach
2. Conduct a detailed assessment of the purchases by acquisition card and invoices to identify the extent of non-approved uniform items and equipment purchases and develop a mitigation strategy to address the risks posed
3. Review current organizational practices with a view to strengthen uniform policies while responding to equity, diversity and inclusion needs of Regular Members to:
   1. ensure compliance with entitlements and delegated financial authorities for reimbursement and purchase of uniform items
   2. ensure adherence by members to uniform requirements to maintain a consistent general duty uniform across the RCMP
   3. [REDACTED]

Context of the review

• An Audit of Uniform and Equipment was approved by the Commissioner as part of the 2021/22 to 2025/26 Risk Based Audit and Evaluation Plan
• Based on the work conducted by the internal audit team in the planning and conduct phases, it was determined that a review would be better suited to provide senior management with relevant evidence-based information related to uniform policy changes
• In consideration of the risks and organizational sensitivities related to the uniform identified in the early stages of the conduct phase, in July 2022, the Chief Audit and Evaluation Executive elected to proceed with the work as a review rather than an audit. As a result, the engagement title was modified to the Review of Uniform and Dress Manual Policy Changes.
• The Review is intended to provide senior management with an assessment of the controls and impact of risks related to changes in the Uniform and Dress Manual

Approach

Sample testing

The review examined a sample of 150 uniform transactions from E, J, G and O Divisions. This included:

• 50 transactions from the Total Expenditures and Asset Management System (TEAM) Portal – Uniform and Equipment Program Online Ordering System
• 70 transactions from the TEAM Portal – Travel and Expenses – Expense Claim
• 30 transactions from acquisition cards and invoice purchases (direct invoices and invoices linked to a contract)

Statement of conformance

The Review engagement conforms to applicable standards in the Institute of Internal Auditor’s International Professional Practices Framework and the Treasury Board of Canada Directive on Internal Audit, as supported by the results of the quality assurance and improvement program.

Overview of uniform

• The RCMP provides members with the necessary articles of approved uniform for their assigned function, which they wear in accordance with the relevant operational needs, health and safety requirements, and any other considerations related to the promotion of an inclusive and diverse workforce
• The RCMP distributes uniform items to more than 19,000 members in Canada from coast to coast to coast, with more than 700 detachments across the country. Members have different needs and must respond to a variety of operational environments, which requires uniform to take into account varying geography, climate, and conditions such as isolated, remote, and urban locations.
• Regular Members wear the service order uniform, referred to as the “general duty uniform” when performing frontline policing. This includes a member’s hat, shirt, blue pants with the yellow stripe, boots, duty belt with intervention options, soft body armour, and jacket or coat
  • The intervention options for the duty belt include items such as the pistol, magazines, oleoresin capsicum (pepper) spray, baton, handcuffs, naloxone pouch, folding knife, portable radio, and flashlight
• The RCMP also provides members with the red serge ceremonial uniform

As the environment in which police operate is continually changing, the RCMP needs to adapt to new demands and challenges to fulfill its mandate and seek to modernize uniform items to meet member needs.

Roles and responsibilities

Commissioner

• Final authority on matters pertaining to RCMP Working Order uniform as outlined in the RCMP Regulations, 2014

Uniform and Equipment Committee and Sub-Committee

• Supports operations by facilitating the timely assessment of submissions related to operational requirements for uniforms and equipment

National Police Federation

• Provides representation to promote and enhance the rights of RCMP Members across the country

Corps Sergeant Major

• Policy centre for the Uniform and Dress Manual – chapter 1
• Leads the Warrant Officer Program
• With support from warrant officers, provides guidance on uniform and dress, matters pertaining to orders of dress, and ceremonial protocol

Warrant Officers

• Provide liaison and advisory role to commanding officers on behalf of members and National Headquarters
• Support outreach, engagement, and modernization initiatives

Uniform and Equipment Program under Corporate Management and Comptrollership

• Policy centre for the Uniform and Dress Manual – chapters 2 to 8
• Responsible for the design, quality assurance, storage, and distribution of uniform items to members
• Maintains the Online Ordering System in TEAM for members to order RCMP-issued uniform items

Action, Innovation and Modernization

• Supports the Corps Sergeant Major and the Uniform and Equipment Program in making updates to the Uniform and Dress Manual
• Provides Gender Based Analysis Plus analysis of uniform modernization projects
• Reviews employee suggestions and feedback on uniform items through the Innovation Inbox to support modernization

Commanding Officers

• Provide direction on the orders of dress for ceremonial and community engagement functions

Unit Commanders/Supervisors

• Inform members of the uniform items necessary for their duties
• Use relevant tools and processes to ensure compliance with policy and address any failure to comply
• Condemn uniform items when they are no longer serviceable
• Approve purchases of uniform items for members in accordance with the Uniform and Dress Manual and financial policies

Members

• Adhere to the policy

Modernization: Timeline of policy changes

The timeline below identifies key events in the history of the RCMP that led to policy changes in support of modernization, indicating few significant changes prior to 2010.

1974

First troop of 32 women sworn in as RCMP

1990

Policy change: Uniform policy change to allow a turban as part of the uniform. The decision was legally challenged and upheld by the Canadian Human Rights Commission and the Supreme Court of Canada

2010

Policy change: Uniform and Dress Manual – chapter 5. Reimbursement of boots and gloves

2016

Policy change: Uniform and Dress Manual – chapter 1. Members able to order and wear a hijab

2017

Members removed the yellow stripe from uniform pants while on duty to demonstrate dissatisfaction with wages. Senior management instructed supervisors not to take any disciplinary action

2018

Action, Innovation and Modernization tasked by Commissioner to support and coordinate uniform modernization to deliver on Vision150 commitments

2019

Policy change: Uniform and Dress Manual – chapter 1. Enhancing the uniform to include a wide variety of items, such as the dastaar and kippah. Uniform and Grooming standards updated to modernize and remove outdated terminology and gender-specific language

National Uniform Survey process for frontline members to seek opinions on how the uniform works for them and what changes they would like to see for increased effectiveness. One fifth of all suggestions to the RCMP Innovation Inbox were related to uniform and equipment

2020

Policy change: Uniform and Dress Manual – chapter 5. Reimbursement of cargo pants and increase to the reimbursement entitlement for boots

Memorandum of agreement signed by the RCMP Commissioner and President of the National Police Federation for reimbursement for cargo pants and for the increase to reimbursement for boots

The Uniform Duty Shirt Pilot was initiated in November to assess new requirements to address the fit, performance and colour of the general duty shirt

2021

Policy change: Uniform and Dress Manual – chapter 5. Increases to the reimbursement entitlement for gloves

Memorandum of understanding signed by the RCMP and the National Police Federation for changes to gloves reimbursement

2022

[REDACTED]

The pilot to test duty shirt prototypes in-house was launched with expected completion by the end of January 2024

Modernization: Cargo pants and duty boots

The modernization of uniforms is a Vision150 commitment and an important issue to members. In support of modern policing, the RCMP recognizes that the uniform must address the operational environment and take into account comfort, protection, officer safety, and inclusivity, while also maintaining the meaningful traditions of the RCMP.

The RCMP and the National Police Federation signed a memorandum of agreement on October 30, 2020, to allow members the flexibility to purchase their choice of cargo pants and duty boots, subject to criteria and reimbursement entitlements. The joint decision was intended to address member needs for a modern front-line uniform with improved functionality and fit.

The Commissioner stated that this new entitlement supported Members’ interests at the forefront and acknowledged that many Members were previously funding these items from their own pocket. The memorandum of agreement:

• Was signed with the principle that the cargo pants and duty boots were considered resolved and were withdrawn from the collective bargaining process
• Established that the Uniform and Dress Manual would be amended by November 2020, and included an Annex that contained the entitlements for reimbursement, the use of the TEAM Portal and Form 1393 (Expense Claim) for the submission of claims, and criteria for the purchase of off-the-shelf uniform cargo pants and duty boots

The Uniform and Dress Manual – chapter 5.3 (cargo pants) and chapter 5.4 (duty boots) were amended to reflect the entitlements and criteria for reimbursement agreed upon in the annex of the memorandum of agreement. Appendix B contains the agreed upon amendments.

The memorandum of agreement also stated that the RCMP and the National Police Federation agreed to review the changes 12 months from the date of the amended policy.

The analysis provided in this engagement provides valuable information to support the 12-month review requirement of the October 30, 2020, memorandum of agreement.

Authority for reimbursement

The RCMP Regulations set out the authority of the Commissioner for the issuance of clothing for the general duty uniform.

All items remain Crown property and must be properly safeguarded until disposed of in accordance with the Regulations and RCMP directives.

• Subject to the decision by the Commissioner and the National Police Federation in November 2020, the Uniform and Dress Manual – chapter 5 provides the unit commander with the authority to approve the purchase and reimbursement of cargo pants, boots, and gloves subject to criteria and specified entitlements.
  • The policy change is popular with members. Unit commanders who were interviewed stated that members are very satisfied with the ability to purchase items off-the-shelf, and identified that members are able to purchase clothing that provides them with optimal comfort and fit for their operational duties and conditions of work.
• [REDACTED]
• The RCMP is considering options on a way forward to ensure that the organization acts within its authority

Modernization: Vision150 and beyond

Chapter 1. Uniform and Grooming standards was updated in May 2019 to identify and remove barriers for diverse groups of people while ensuring a professional look and enhanced safety. Action, Innovation and Modernization led the revision of chapter 1 to ensure that gender based analysis factors were considered.

The modernization of uniforms is ongoing with the current Uniform Duty Shirt Pilot Project, led by Action, Innovation and Modernization for the Uniform and Equipment Program.

• The pilot initially explored using off-the-shelf shirts with the option of reimbursement. Discussions in October 2021 identified the importance of the RCMP having access to the shirt rather than members buying off-the-shelf. It was determined that issuing a shirt from the Uniform and Equipment Program would provide greater overall efficiencies, access to a wide variety of sizes, and consistent colour requirements as per the Uniform and Equipment Program standards. Additionally, the use of the Uniform and Equipment Program Online Ordering System would provide better controls, the ability to monitor issuance, and lower the risk of officer impersonation.
• The Pilot is currently underway with diverse members from across Canada selected to wear and assess the prototype shirts in spring 2023

Interviewees informed the Review team that members are dissatisfied with the pace of modernization for the uniform duty shirt, as well as the lack of communication on the progress. Updates have not been regularly communicated to members throughout the Pilot, and the recent update in September 2022 does not provide expected completion times or how the shirt will be selected, which unit commanders identified as being of interest to members.

The Review team noted that the Equipment and Asset Lifecycle Management project is in progress. It includes a communication strategy that is intended to increase transparency by providing updates on the Infoweb in addition to national broadcasts to mitigate communication delays.

As modernization continues, there is a need to communicate updates with members to keep them abreast of the progress the RCMP is making with modernizing the uniform. There is a risk that members may perceive their voice is not heard, which may contribute to purchasing non-approved items on their own or through their unit commanders, as with previous purchases of cargo pants prior to the Uniform and Dress Manual policy update.

Trends: Issuance and reimbursement

Uniform and Dress Manual - chapter 5. Requisition and Supply section 5.1.1 states that units and members are provided with all essential uniform and equipment items required to carry out their duties and responsibilities, conditional upon needs, duties, supplies, funds, and other restrictions.

• Chapter 5 specifies that items are to be ordered using the Online Ordering System
• Cargo pants, winter and summer duty boots and slash-resistant gloves may also be purchased off-the-shelf and submitted for reimbursement through the TEAM Portal
• Charts 1 and 2 indicate that 95% of uniform and equipment items were issued through the Online Ordering System and account for 79% of expenditures

• The Review team noted that the TEAM Portal does not contain a field that captures the quantity of items being reimbursed
• As a result, the RCMP cannot accurately identify the quantity of cargo pants, boots and gloves purchased
• The Review team estimated the quantity of items ordered from the TEAM Portal based on the value of reimbursement transactions
• Charts 1 and 2 indicate that the Uniform and Dress Manual policy changes for reimbursement of items accounts for approximately 5% of uniform and equipment items and 21% of expenditures

Trends: Boots, cargo pants and gloves

After the November 2020 policy change, there were fewer transactions for cargo pants, boots and gloves in the Online Ordering System. Charts 3 and 4 indicate that the quantity of cargo pants, boots and gloves purchased off-the-shelf and reimbursed increased significantly as of fiscal year 2021 Q4, which may be due to:

• an increase in members purchasing cargo pants off-the-shelf as a result of the new reimbursement policy; and
• an increase in members purchasing duty boots as a result of the higher reimbursement entitlement (summer boots $200 and winter boots $300) and option to combine the summer and winter boots reimbursements up to the maximum entitlement ($500) as agreed upon in the memorandum of agreement

Trends: Boots, cargo pants and gloves

Based on the trend results from Table 2 on the following page, the Review team noted:

Boots

• More members purchased off-the-shelf boots than those who ordered them through the Online Ordering System
• The average reimbursement amount for boots purchased off-the-shelf is 52% higher than the cost of issuing boots through the Online Ordering System
• Most reimbursements for boots are within the maximum reimbursement amount

Cargo Pants

• More members purchased cargo pants off-the-shelf than those who ordered them through the Online Ordering System
• The average reimbursement amount for cargo pants purchased off-the-shelf is 173% higher than the cost of issued cargo pants through the Online Ordering System
• Most reimbursements for cargo pants are within the maximum reimbursement amount

Gloves

• Fewer members purchased slash-resistant gloves off-the-shelf than through the Online Ordering System
• The average reimbursement amount for gloves purchased off-the-shelf is 27% higher than the cost of issued gloves through the Online Ordering System
• [REDACTED]

Governance

A Terms of Reference was under development for the Uniform and Equipment Committee and Uniform and Equipment Sub-Committee at the time of the Review and work remains to be completed to finalize the mandate and scope, as well as linkages to the existing RCMP governance structure. The Equipment and Asset Lifecycle Management project was also underway.

Online Ordering System: Compliance

The Review found that a process is in place for the issuance of uniform items from the RCMP Online Ordering System, which is generally being followed.

The Uniform and Dress Manual gives the unit commander authority to approve uniform items for their employees and the items issued to employees remain the property of the Crown. Unit commanders must adhere to their delegated authorities as per the Financial Administration Act. In accordance with the Uniform and Dress Manual, members are required to order the uniform items permitted for their duty code through the Uniform and Equipment Program Online Ordering System.

Interviewees stated that the process generally works well and is efficient and timely.

Table 3 indicates the results of testing a sample of 50 transactions processed through the Online Ordering System:

Based on the compliance results in Table 3, the Review team noted the following:

• Controls are in place to prevent a member from exceeding the entitlement for a single purchase. The ability to submit multiple purchases for the same item is permitted to allow for the replacement of lost or damaged items before the end of their lifecycle. There were 4 instances where members were permitted to purchase items that exceeded the entitlement (ankle boots, arctic mittens, shoulder badges and lightweight socks).
• In 2 instances, there was no evidence of Financial Administration Act Section 32 approval. The orders were submitted using a paper requisition form that included Financial Administration Act Section 32 approval; the Uniform and Equipment Program has a two-year retention policy so the forms were not available for review.

Reimbursement: Compliance

The Review found that a process is in place for the approval and reimbursement of cargo pants, boots and gloves, but procedures are not being consistently followed.

• Table 4 indicates the results of testing a sample of 70 reimbursement transactions through the TEAM Portal consisting of 30 duty boots, 35 cargo pants and 5 gloves

Based on the compliance results from Table 4, the Review team noted the following:

• Only 4% (3 out of 70) reimbursement transactions were in compliance with all requirements, including expense entitlement, financial approvals and supporting documentation
• The Review team noted where transactions were not in compliance with the reimbursement process and financial requirements. Specifically:
  • 2 transactions were reimbursed twice to the members (boots and cargo pants).
    • The Internal Audit, Evaluation and Review Data Analytics team performed an analysis of the entire reimbursement transaction population and found 7 additional instances where members were reimbursed twice for the same purchase
  • [REDACTED]
    • While all of the reimbursements for boots were within the established entitlements, transactions for all 5 gloves and 12 cargo pants exceeded the maximum Uniform and Dress Manual entitlements
  • [REDACTED]
  • None of the boots or gloves transactions had sufficient information on file to determine if the item purchased off-the-shelf met the criteria in Uniform and Dress Manual – chapter 5. The information on the receipts for the boots and gloves was limited and does not permit a unit commander to validate against the Uniform and Dress Manual criteria.
    • 3 receipts had limited information while most (32 of 35) of the sampled cargo pants transactions were for the brand 5.11 pants, which meet the specifications outlined in the Uniform and Dress Manual

Unit commanders interviewed were aware of the financial authorities and member entitlements. However, they identified that they have demanding operational environments leaving little time to read policy updates.

[REDACTED]

[REDACTED]

Reimbursement risks

The RCMP is responsible for items purchased and reimbursed to members. [REDACTED], there is a risk that the Uniform and Dress Manual performance criteria is not being met, which can impact officer health and safety, as well as liability to the RCMP in the event of a critical incident.

Although members are able to select boots that accommodate their needs, there is a risk that members are wearing boots that provide comfort but do not adhere to the Uniform and Dress Manual performance standards as unit commanders cannot validate from receipts that boots meet the policy criteria.

• Based on the Divisional Safety Performance Report Cards prepared by RCMP Occupational Health and Safety, slips and falls have been within the top six injuries since 2017 in every division. However, occupational health and safety data does not identify the type of boots that were worn when a member was injured to assess whether the boots were purchased off-the-shelf and/or contributed to injuries.

There is also a risk that members do not have equitable access for the reimbursement of uniform items across all detachments. Some smaller detachments may not approve entitlements based on available funding. One detachment in G Division noted that orders from the Online Ordering System are not always approved when facing financial constraints, even if members are replacing uniform items that are no longer serviceable.

Non-stock items

Uniform Issue – “non-stocked items" is an expense category in the TEAM Portal for reimbursement claims for items that are approved for local purchases based on duty code but are not provided by the Online Ordering System. For example, Motorcycle Operator – Duty Code 264 can purchase specified items locally.

• The introduction of the reimbursement policy allowed members to submit reimbursement claims for cargo pants, boots and gloves under the Uniform Issue - non-stocked items category until the TEAM Portal was updated to include separate categories for the three items

The Review team examined the purchase history for each member that was in the sample for the testing of 70 reimbursement transactions to assess whether the use of the category was in compliance with the Uniform and Equipment Program Ordering Guide requirements. Testing results indicated that:

• the Uniform Issue - non-stocked items category was used for reimbursements for non-approved items, both before and after the policy change;
• 26 of the 70 (37%) transactions tested were reimbursements for non-approved items such as navy duty shirts, jackets, duty belts, running shoes, sunglasses, backpacks and ball caps; and,
• 4 members were reimbursed for off-the-shelf cargo pants with a yellow stripe purchased prior to the policy update

Table 5 indicates the use of the Uniform Issue - non-stocked items category during the scope period.

• In fiscal year 2019-20, the category was used for off-the-shelf purchases of ankle and winter boots and slash-resistant gloves
• In fiscal year 2020-21, the category included cargo pants in Q3 (November) due to the policy change, which may account for the increase in transactions and value
• In fiscal year 2020-21 Q3 (December), separate categories were created for the pants, boots and gloves, which may account for the decrease in transactions

Purchase details can only be obtained by reviewing claim receipts in the TEAM Portal, making it [REDACTED]. Although use of the Uniform Issue - non-stocked items category decreased in fiscal year 2021-22, there is a risk that it may continue to be used for non-approved items.

[REDACTED]

[REDACTED]

[REDACTED]

[REDACTED]

[REDACTED]

[REDACTED]

Summary of risk: Before and after reimbursement policy changes

System controls are in place in the Online Ordering System (fully implemented in 2014) to help ensure compliance with the Uniform and Dress Manual and financial authorities.

The risk of officer impersonation existed prior to the policy changes. Although the RCMP cannot prevent external intentional misuse of uniform items, it is important to ensure that controls are in place to reduce risks that are within the RCMP’s purview.

Purchases by unit commanders

Unit commanders do not have authority to purchase uniform items directly from suppliers or retailers without Uniform and Equipment Program guidance and National Headquarters operational policy centre approval, with the exception of duty boots, cargo pants and slash resistant gloves. Processes are in place to order special-made items that are not in stock.

• The uniform expense categories in the TEAM system include the purchase of non-stocked items of clothing and kit.
  • The purchases could be approved by the Uniform and Equipment Program for special-made items, items that are not in stock, or other operational reasons
  • Unit commanders pay for some of these purchases by acquisition card and invoices directly to suppliers and retailers using their budget funds
• Chart 5 indicates that the dollar value of purchases for the expense categories using acquisition cards and invoices ($12,783,851) exceeded the value of items issued from the Online Ordering System ($12,540,915)
• The Review team examined a sample of 30 transactions from acquisition cards and invoices to assess whether the use of the categories were approved purchases. Testing results indicated that unit commanders purchased:
  • non-approved uniform items; and
  • equipment items such as holsters, magazine pouches and chest rigs without documented approvals
• Although equipment is not within the Review scope, purchases that do not have documented approval pose a significant risk to officer health and safety if members are provided with equipment that does not meet RCMP standards

A detailed assessment is required for the RCMP to identify if non-approved equipment is being purchased by unit commanders, the reasons for the purchase, and the extent to which this is happening. This assessment would greatly contribute to fully understand the significance of the risks related to purchasing equipment directly from suppliers and retailers without documented approval.

Acquisition cards and invoices

Table 7 indicates the results of testing a sample of 30 transactions from TEAM, using acquisition card purchases, direct invoices, and invoices linked to a contract.

Based on the testing results from Table 7, most purchases were for non-approved uniform items including soft body armour, black uniform items (general duty uniform is gray shirt/navy pants), winter jackets, high visibility vests, and Gore-tex clothing. Equipment items included holsters and magazine pouches.

The Review team also noted that none of the transactions were in compliance with all requirements, namely expense entitlement, financial authorities and supporting documentation. Specifically:

• 10 transactions were for items available in the Online Ordering System and were not approved to be purchased off-the-shelf
• 2 transactions resulted in an invoice being paid twice
• 28 transactions were not in compliance with Financial Administration Act financial delegation authorities; [REDACTED]
  • 2 of the 28 transactions were acquisition card purchases for 5.11 navy cargo pants, which is not a Uniform and Dress Manual approved method of payment
• 8 transactions did not have a rationale to explain why non-approved uniform and equipment items were purchased. The rationale for 22 transactions was provided internally within a unit or division.

Unit commanders are not consistently adhering to the requirements of the uniform policy. The Review team also noted that none of the 30 transactions had evidence of unit commander consultation with the Uniform and Equipment Program to identify the reasons for the purchase outside the Online Ordering System. Unit commanders stated that they do not consult the Uniform and Equipment Program or National Headquarters policy centres about uniform and equipment items they want to purchase; instead, they consult within their own divisions.

Although the Uniform and Equipment Program has a complaint mechanism in place for members, the review found that there were only 7 Unsatisfactory Condition/Failure Reports (form 1704) submitted to the Uniform and Equipment Program during the scope period. Complaints included the white “Police” lettering peeling off the soft body armour carrier or vest and uniform defects.

Non approved purchases: Context

RCMP members require uniform items that are functional and meet their diverse needs while contributing to their health and safety, comfort and pride. The RCMP provides members with uniform items that are tested to meet standards for health and safety.

Unit commanders identified that members may buy uniform items directly from retailers, or alter RCMP-issued items, if they were not satisfied with items from the Online Ordering System, or perceived items are of poor quality, or do not meet their comfort needs.

The 2019 RCMP Uniform and Kit Modernization Survey results indicated that members purchased items outside of the Online Ordering System due to the lack of options to accommodate the diverse range of body types. Members were seeking to address their individual needs for comfort and functionality for uniform and equipment items. A lack of approved options to meet members needs can result in frustration, as well as negatively impact feelings of inclusion, belonging and pride if not provided with options that fit.

Interviewees also informed the Review Team that members experienced issues with existing RCMP uniform items. Members or Unit Commanders purchased uniform when items:

• were backordered and not available in the Online Ordering System, such as soft body armour
• did not fit appropriately
• did not meet operational demands, such as the need for a high degree of warmth or waterproofness
• contributed negatively to health, such as back problems and members could not obtain an approved ergonomic duty belt in a timely manner
• were perceived to have inferior material(s) compared to items available off-the-shelf for comfort, fit and functionality

Although interviewees identified reasons for purchasing outside of the Online Order System, the associated risks to officer health and safety with these purchases is significant particularly if purchasing equipment. Compliance with the Uniform and Dress Manual policy is required to help ensure officer safety and to minimize risk to the RCMP.

Non approved purchases: Risks

Although members and unit commanders are seeking to improve comfort and functionality when purchasing non-approved uniform and equipment, there are risks to the RCMP.

• The RCMP is at risk of failing to meet Canada Labour Code obligations if a unit commander purchases items for members that are not assessed, tested or approved by Contract and Indigenous Policing and the Uniform and Equipment Program to assess if performance and safety criteria are met. Purchasing items directly increases the risk that members are wearing clothing and using equipment that could have a quality level below the RCMP-issued items, resulting in occupational health and officer safety risks. The RCMP may face liability if there is a critical incident and the non-approved equipment fails.
• Purchasing items that are not approved results in providing members across the organization with uniform and equipment that may have different performance standards and functionality. This leaves the RCMP at risk of inequitable uniform and equipment standards, which can impact officer and public safety as well as present potential liability.
• The RCMP is at risk of failing to meet Official Language Act obligations if a unit commander purchases non-approved, unilingual items for members that do not reflect the equal status of French and English. Unilingual signage and patches can potentially disadvantage members of the other official language community.
• The RCMP does not have visibility and oversight for the purchase of these non-approved items, but does maintain responsibility for uniform and equipment purchased by a unit commander for a member

The risks impacting officer health and safety requires the RCMP to have processes in place to prevent the direct purchase of non-approved uniform items and equipment. It is important for commanding officers to identify issues and operational needs, and that the process functions effectively to ensure that members have the uniform items required to perform their work.

The Review team noted that implementation of the Equipment and Asset Lifecycle Management Needs Assessment process is intended to provide a national intake process to request equipment and assets needed to support RCMP operations. The intent of the process is to coordinate response from the appropriate policy center to address any issues with uniform and equipment.

Adherence to uniform requirements

The review found that unit commanders and commanding officers do not consistently enforce the standard uniform requirements.

The current culture of purchasing items outside of the Uniform and Equipment Program has contributed to members being dressed inconsistently rather than the RCMP approved general duty uniform.

Unit commanders identified that:

• they would not discipline a member for wearing non-standard uniform items but would have a discussion with the member to obtain a reasonable compromise. Disciplinary action would result only for an exceptional uniform violation.
• perceived delays in addressing uniform comfort issues, as well as perceptions of superior items available off-the-shelf for functionality, contributes to member frustration and can lead to the purchase of non-approved items to meet their needs
• they want a full complement of officers on duty who feel comfortable, look professional, and have positive morale
• they are responsible for the well-being of their employees and will make decisions to allow non-approved uniform items if they believe it will contribute to the members health and safety, comfort and pride when performing policing duties

The RCMP recognizes the issue of the lack of adherence in wearing the approved uniform. The Corps Sergeant Major sent an Infoweb communique on April 5, 2022, on the importance of consistency of the RCMP approved uniform and indicated the National Police Federation is supportive of the advancement of uniform standards. As stated in the communique, the standard RCMP general duty uniform serves to ensure police identification, public confidence, member safety, and public safety.

A lack of adherence to standard uniform requirements can increase the risk to officer safety if members wear uniform items that do not meet the tested capabilities required for diverse hazards in the operational environment.

Adherence to uniform requirement challenges

Disposal throughout a member's career

The Review found that the Uniform and Dress Manual disposal guidance for identifiable uniform items is unclear.

The Uniform and Dress Manual – chapter 8.1.1. assigns responsibility for disposal to the unit commander. Uniform and Dress Manual – chapter 8.1.1. requires items of uniform no longer serviceable to be condemned at the unit level and destroyed in an environmentally safe manner, or altered so that they cannot be identified or worn as an article of uniform.

[REDACTED]

[REDACTED]

[REDACTED]

Disposal challenges

[REDACTED]

The Review found that [REDACTED]

Some unit commanders identified that their detachment has access to other federal department incinerators to burn items in an environmentally safe manner. Other unit commanders indicated that some members burn items on their personal property, some detachments recycle items, and some detachments may have periodic call-outs for members to dispose of used items.

• Following the April 2020 mass casualty in Nova Scotia, the H Division Destruction Program in 2021 identified approximately 7,000 pounds of clothing for disposal from active members

The RCMP has a National Standing Offer for hazardous goods that is intended for all divisions to use, which includes disposal for uniform items. The national standing offer was scheduled to expire on February 13, 2022, but the vendor has agreed to an extension to honour the conditions, while the new standing offer is currently pending. The review found that:

• Unit commanders and warrant officers interviewed were [REDACTED]
• The national standing offer requires detachments pay for disposal and shipping costs, as well as ensure a securing shipping process. This may be a logistics challenge for a remote detachment to send items for disposal.

[REDACTED]

The Mass Casualty Commission may have recommendations in spring 2023 related to the tracking and disposal of identifiable police uniform items.

Recommendation 1

With respect to the RCMP Regulations:

1. [REDACTED] identify options for how to address reimbursement, taking into consideration that members have the uniform items required to perform their work
2. determine the short-term and longer-term options to align policies with the RCMP Regulations, taking into consideration a risk-based phased approach

Management Action Plan

Agree.

1. In June 2023, the RCMP Senior Executive Committee held a stock take exercise with the objective of creating an achievable and effective way forward in addressing the recommendations of this review. During this meeting, Senior Executive Committee expressed a desire to continue the reimbursement model (as directed in the Uniform and Dress Manual) given flexibility it provides to Regular Members.

   [REDACTED]

2. As the Policy Centre for the Uniform and Dress Manual (chapters 2 to 8), the Director General, Procurement, Materiel and Assets Management will ensure no other items are included to the Uniform and Dress Manual as a reimbursable item until the necessary authority is obtained.

   Until the longer term solution is found, RCMP will find alternative ways to meet the requirements of uniform items. These alternative methods include having the RCMP purchase on behalf of members. This practice has already been put into action. For example, there was a validated need to offer extreme cold weather boots for members. The approved strategy to meet this requirement was to have RCMP purchase this equipment on behalf of the Regular Members, rather than extending the reimbursement model. This practice was communicated to all Divisions in December 2022.

   Oversight and controls for this approach will be the responsibility of the Uniform and Equipment Sub-Committee.

Completion date

1. June 2024
2. Will continue until item 1a) is completed by June 2024

Position responsible

1. Director General, Procurement, Materiel and Assets Management
2. Director General, Procurement, Materiel and Assets Management; and Director General, Operational Readiness and Response, Contract and Indigenous Policing (Chair, Uniform and Equipment Sub-Committee)

Recommendation 2

Conduct a detailed assessment of the purchases by acquisition card and invoices to identify the extent of non-approved uniform items and equipment purchases and develop a mitigation strategy to address the risks posed.

Management Action Plan

Agree.

1. The sample scan conducted as part of this review identified areas of potential risks arising from the purchase of non-approved uniform and equipment. Contract and Indigenous Policing and Procurement, Materiel and Assets Management have collaborated with the Data Analytics and Oversight Monitoring group within the Internal Audit, Evaluation and Review team to conduct the detailed assessment well beyond the sample reviewed to determine the extent of the issue nationally.
2. Contract and Indigenous Policing and Procurement, Materiel and Assets Management will collaborate with all necessary stakeholders, including the Divisions and the National Police Federation, to develop a mitigation strategy to address the risks identified by the analytics review. This strategy will primarily focus on communication and education. Dependent upon the results of the detailed assessment, it may be necessary to expand the mitigation strategy to include remedial actions against those who intentionally contravene policies and negatively impact officer health and safety and ensure the effective functioning of internal controls.

Completion date

1. January 2024
2. April 2024

Position responsible

1. Director General, Procurement, Materiel and Assets Management; and Director General, Operational Readiness and Response, Contract and Indigenous Policing (Chair, Uniform and Equipment Sub-Committee); and the Data Analytics and Oversight Monitoring group within Internal Audit, Evaluation and Review
2. Director General, Operational Readiness and Response, Contract and Indigenous Policing (Chair, Uniform and Equipment Sub-Committee); and Director General, Procurement, Materiel and Assets Management

Recommendation 3

Review current organizational practices with a view to strengthen uniform policies while responding to equity, diversity and inclusion needs of Regular Members to:

1. ensure compliance with entitlements and delegated financial authorities for reimbursement and purchase of uniform items
2. ensure adherence by members to uniform requirements to maintain a consistent general duty uniform across the RCMP
3. [REDACTED]

Management Action Plan

Agree.

1. Procurement, Materiel and Assets Management has engaged with Corporate Management Systems to making changes to the TEAM Portal in order to achieve stronger compliance for these specific transactions. The planned enhancements include:
   1. As a control mechanism, providing the approver a historical view of reimbursement claims for uniform items.
   2. Prompts for the approver to validate that the requested reimbursement claim meets the Uniform and Dress Manual criteria (including valid Section 32, Financial Administration Act compliance).

2. The Corps Sergeant Major and Warrant Officers will continue to engage with Commanding Officers on matters related to non-compliance of uniforms and equipment that can be addressed at the Divisional level.

   As per response 2b) above, the mitigation strategy will include communication aimed to educate members and managers of the risks of non-approved equipment. Furthermore, the implementation of the Equipment and Asset Lifecycle Management Project and the utilization of the Uniform and Equipment Sub-Committee as the central portal for all identified capability deficiencies related to the general duty uniform, will introduce an accountable and transparent means to facilitate requests in a timely manner to meet the needs of general duty members.

3. [REDACTED]

Completion date

1. April 2024
2. Messaging will be completed by April 2024 and non-compliance will be addressed on an ongoing basis.
3. April 2024

Position responsible

1. Director General, Procurement, Materiel and Assets Management; and Director General, Corporate Management Systems
2. Corps Sergeant Major; Director General, Operational Readiness and Response, Contract and Indigenous Policing (Chair, Uniform and Equipment Sub-Committee); and Director General, Procurement, Materiel and Assets Management
3. Corps Sergeant Major; Director General, Strategic Implementation Team, Reform, Accountability and Culture; Director General, Operational Readiness and Response, Contract and Indigenous Policing (Chair, Uniform and Equipment Sub-Committee); and Director General, Procurement, Materiel and Assets Management