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ADVOCACY INITIATIVES


PLACI  |  Security Programs  |  Dangerous Goods  |  E-Commerce  |  Research & Development  |  Market Access & Trade Facilitation   

 

 

Security Programs

    

  

 

 

TSA Security Programs

 

TSA mutual recognition (EU and Australia near-term)


Private canine screening (USA)

 

Paperless standards for US security programs/alignment

 

Emergency Amendments /Security Directives

 

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EU Security Programs

 

EU TAXUD Implementing and Delegating Acts

 

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Other Issues


Shipper Definition Categories

 

Known Shipper (US)

 

 

 

 

 

 

 

 

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TSA Security Programs

 

TOPIC: TSA mutual recognition

(EU and Australia near-term)

 

DESCRIPTION

Mutual recognition (MR) between US and other countries allows carriers to use origin state security programs rather than origin AND destination programs. Some have been in place for 3+ years and are expiring. MR Simplifies training and reduces cost. TSA programs are all for 3 year periods, and renewal as well as renewal timing or advance warning is essential for effective operations. Any changes should be determined well in advance. Threats should be identified and discussed with industry to develop solutions.

 

AFFECTS THESE INDUSTRY SEGMENTS

PAX and Cargo Carriers, RA’s, Forwarders, Ground Handlers

 

IMPACT

Changes to programs in place after 3 years require training and increased operational cost to PAX and Cargo Carriers, RA’s, Forwarders, Ground Handling industry segments. Lack of extension, or any significant modifications , would require extensive re-training, and likely additional (or duplicative) cargo screening for all US TSA Security Regulations allow some e-reports, but have not arrived at standards. Have not fully adopted E-CSD in programs segments.

 

TIACA ACTION

Working with TSA, as well as EU (DG MOVE) and Australia at present to extend current programs, or at very least, provide extended advance notice of any changes, as well as explanation.

 

NEXT STEPS / MOST CURRENT UPDATES

 

March 2016

Programs have been extended for interim period. Further discussions on improving the process will be taken up at TSA ASAC by mid-year.


February 11, 2016

Following discussion with the EU/TSA combined group, EU and TSA agreed to extend the joint recognition between the 2 entities. As in the past, these will have an effective term of 3 years from the effective date of extension.

 

November 2015

US/Australia is in extended modification period. Continuing dialog with TSA and EU DG MOVE to extend US/EU program intact. Participating in EU/TSA Transportation Sector Consulting Group meeting, next session in DC, December 2015.


 

TOPIC: Private canine screening (USA)

 

DESCRIPTION

Most cargo screening by canines performed by Government operated units. Resources are limited, and restricted in most cases to “on airport” screening at carriers. Enabling privately operated (and regulated) canine teams provides for more efficient screening, off airport, by other authorized parties, and enable screening of larger (skid/ULD) configurations more efficiently

 

AFFECTS THESE INDUSTRY SEGMENTS

Airlines, forwarders, Ground Handlers and postal operators

 

IMPACT

Airlines, forwarders, Ground Handlers and postal operators can screen larger configurations based on their own schedule and reduce cost by screening larger configurations

 

TIACA ACTION

Primarily a TSA issue, but can be implemented elsewhere. Leveraging TIACA’s co-chairmanship of the ASAC Air Cargo Subcommittee, we are forming a working group of industry members and regulators to explore options for moving forward, and to develop a plan for doing so. The plan will target key TSA offices, including operations, technology, and legal units, as well as political oversight committees.

 

NEXT STEPS / MOST CURRENT UPDATES

 

February 11, 2016

Industry-TSA brainstorming discussion planned for next meeting of ASAC Air Cargo Subcommittee.

 

Ongoing, long term, both 1:1 with TSA, and via ASAC committee discussions. The working group expects to hold conference calls in December and January, and to meet during the first quarter of 2016.

 

 

TOPIC:  Paperless standards for US security programs/alignment

 

DESCRIPTION

US TSA Security Regulations allow some e-reports, but have not arrived at standards. Have not fully adopted E-CSD in programs.

 

AFFECTS THESE INDUSTRY SEGMENTS

Regulated Agents, Forwarders, all carriers

 

IMPACT

Regulated Agents, Forwarders, and all carriers will be able to reduce cost of maintaining records for TSA and streamline operating procedures

 

TIACA ACTION

Working with TSA to define acceptable formats, and begin development of language for modification of Security Programs

 

NEXT STEPS / MOST CURRENT UPDATES

 

April 2016

Continuing discussions as part of ASAC meetings.

 

Ongoing discussions as part of ASAC, plus 1:1 with TSA. Longer term project, next meetings after beginning of 2016

 

 

TOPIC: Emergency Amendments /Security Directives

 

DESCRIPTION

After the Metrojet incident, TSA issued new EAs and SDs to carriers requiring certain changes to their procedures. As the contents are SSI and were only shared with carriers, each airline must communicate required changes to its supply chain partners – creating widespread confusion among these supply chain partners. The new requirements are burdensome and are having a negative impact on commerce.

 

AFFECTS THESE INDUSTRY SEGMENTS

Airlines, forwarders, shippers, ground handlers

 

IMPACT

Forwarders and shippers have received conflicting instructions from different airlines and are confused about what to do. Airlines are unsure how to ensure compliance with the new requirements. Air cargo business from the affected countries is dropping.

 

TIACA ACTION

TIACA has engaged with TSA and, in response, TSA published guidance for regulated IACs. This has alleviated some of the confusion. TIACA has also urged TSA to meet with industry to discuss alternative approaches that might achieve the same security goals in an operationally feasible manner. We are working closely with sister associations (IATA, A4A, AEA, CAA, AfA, FIATA, CLECAT, etc.) on a request for an industry-TSA meeting to discuss possible changes.

 

TIACA has kept members abreast of developments via Friday Flyer and other communications.

 

NEXT STEPS / MOST CURRENT UPDATES

Continue efforts to schedule an industry-TSA meeting, and continue providing updates to TIACA members.

 

 

 

 

   

EU Security Programs

 

TOPIC: EU TAXUD Implementing and Delegating Acts

 

DESCRIPTION

EU is ahead of other PLACI regimes, and is developing Member State transitional Implementing and Delegating Acts for effect in 2016. Combines customs and Civil Aviation measures in single procedure. Challenge for industry to implement. Difficult for transit cargo thru EU states with different Implementing timelines. Rule set language remains confusing.

 

AFFECTS THESE INDUSTRY SEGMENTS

Regulated Agents, PAX and all-Cargo carriers, postal operators, Ground Handlers, Forwarders for shipments moving into the EU beginning in May 2016.

 

IMPACT

RA’s, PAX and all-Cargo carriers, postal operators, Ground Handlers, Forwarders may incur Shipment delays, high costs to implement with different Member States at different times.

 

TIACA ACTION

Coordinating with other industry Assns. to pressure DG TAXUD to revise and modify language in Implementing and Delegating Acts, as well as transitional programs, and include industry in further discussions before sending regulatory language for EU Parliamentary proceedings

 

NEXT STEPS / MOST CURRENT UPDATES

 

February 11, 2016

In early February the Commission published their latest version of the UCC WP update (version 5.0). A meeting of Member States for a formal vote is planned for early March 2016.


TIACA and other associations are concerned about the short six-month advance notification of the technical specifications for information technology (IT) systems related to Advance Data, .especially as that differs significantly form what the Trade Contact Group Members (TCG, of which TIACA is a member) has consistently stated over the past 15 years. Our position is that economic operators need and require a period of minimum 18 months from the time they receive technical specifications from a National Administration, to secure proper development, testing and implementation of new electronic systems.


The Trade Contact Group members issued a joint letter to the Head of Unit at TAXUD, to raise concerns and ask for clarification on that topic, requesting the minimum of 18 months.


Separately, at the DG MOVE SAGAS committee meeting we attended in early February, TIACA put forward a number of issues which need further planning, testing and development, including: In-bound security; third country aviation security; ACC3; PLACI; One Stop Security; Cargo screening technologies; and Cyber Security.


TIACA and other SAGAS industry participants, along with EU regulators, agreed that the stakeholders positions are valid, and we should be more outspoken about what we want to achieve in these areas, and how best to achieve it. If an issue does not require regulatory change, this should not be addressed in the SAGAS, and other forums should be explored, such as DG HOME, EASA, DG CNT and others.


Industry has now been asked to consider other issues to be put forward for regulatory change, and TIACA is now determining which topics/issues we want to lead, which we want to jointly push and where we possibly should look for synergies with other involved associations.

 

Ongoing meetings and formal letters/requests to EU, further meetings and discussions in accord with others. Next meetings with EU not yet planned, awaiting further responses on proposed industry language to correct deficiencies.

 

 

Other Issues

 

TOPIC: Shipper Definition Categories

DESCRIPTION
ICAO considering removal of one category of shipper, or update with government inspected site visits. Some country regulators support change, others indecisive.

AFFECTS THESE INDUSTRY SEGMENTS
Forwarders, Airlines, Shippers

IMPACT
Shipments transported on passenger and all-cargo airlines.

Forwarders and Regulated Agents may be unable to validate their shippers directly. May eliminate ability to send certain shipments via all-cargo aircraft without potentially significant changes to screening measures, causing delays and additional handling costs.

TIACA ACTION
Working with ICAO AVSEC WGACS to discuss alternatives and industry-supported measures to validate shippers globally, and the need for feasible timelines for adapting to any changed requirements.
Next meeting in Geneva, January 2016.

NEXT STEPS / MOST CURRENT UPDATES

 

February 11, 2016

Following discussions at WGACS, it was agreed to recommend to the AVSEC Panel that the Account Consignor programs should be revised over a set time frame (not yet disclosed).TIACA further recommended to ICAO that a full analysis and review of multiple shipper category designations (such as Known Shipper, Trusted Shipper, Regulated Shipper, Certified Shipper, variations of Known Consignor). TIACA will develop an outline of the various definitions, in conjunction with regulators, as a baseline for discussion, supported by AVSEC chair.

Submitted position paper for discussions at ICAO WGACS in Geneva, January 2016. Outlined alternative programs to enable regulatory oversight to programs managed by industry.




TOPIC: Known Shipper (US)

DESCRIPTION
Per US Regulations, a shipper must be categorized as a Known Shipper (KS) in order to be transported on a passenger aircraft within or out of the US. The cost to maintain the KS system (called KSMS) is high, as is the compliance maintenance for industry. With the implementation of 100% screening on passenger aircraft in 2010, there is no compelling need for this category.

AFFECTS THESE INDUSTRY SEGMENTS
Shippers, Forwarders, Airlines, Ground Handlers

IMPACT
Eliminating or modifying the known shipper requirement could significantly expand flight options for shippers and others in the air cargo supply chain.

TIACA ACTION
Primarily a TSA issue, but can be implemented elsewhere. Leveraging TIACA’s co-chairmanship of the ASAC Air Cargo Subcommittee, we are forming a working group of industry members and regulators to explore options for moving forward, and to develop a plan for doing so. The plan will target key TSA offices, including policy, operations, and legal units, as well as political oversight committees.

NEXT STEPS / MOST CURRENT UPDATES

 

February 11, 2016
Industry-TSA brainstorming discussion planned for next meeting of ASAC Air Cargo Subcommittee. To include discussion on ICAO categorization changes.

The working group expects to hold conference calls in December and January, and to meet during the first quarter of 2016.

   


 

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Subcommittee is considering ways that TIACA might engage with global coalition supporting implementation of TFA.

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