Since the introduction of Part 108 into the Civil Aviation Regulations of South Africa there has been a total of 120 Known Consignors accredited by the Civil Aviation Authority, this number has gone up and down over the years and at the time of writing this post there were only 27 left. This number is dwarfed by that of approved Regulated Agents which stands at 136.
More disturbingly is that this means the country’s air cargo secure supply chain has lost 93 Known Consignors in the past 5 years or so. This slump can be attributed to numerous reasons; intangible commercial benefit, and insufficient knowledge by consignors, no targeted workshops by the authority to disseminate information and chief among all the subtle discouragement from Regulated Agents.
The role the industry can play
From the CAA, Airlines and Ground Handlers, there is no member of the secure supply chain better positioned to encourage the participation of consignors in the secure supply chain than the Freight Forwarder. The forwarders have daily dealings with consignors. Consignors believe that Part 108 is an onerous process and the Designated Officials of Regulated Agents can help in allaying this myth.
Benefits of having more Known Consignors in South Africa
Forwarders make up more than half of the Regulated Agents in the country and if every one of them encourages their 3 biggest clients to become Known Consignors we could have over 200 Known Consignors by the end of 2016.
This will benefit the cargo security regime of the country as we would all be guaranteed that the majority of the cargo boarding our planes is from companies whose personnel is trained and security conscious.
The impact of upcoming amendments in 2016
The industry is expecting amendments to Part 108 to be promulgated in 2016. These amendments will give the Known Consignor some independence from the Regulated Agent. The Known Consignor will now be required to:
- Develop their own security manual.
- Appoint a person responsible for air cargo security (equivalent of the Designated Official).
- Conduct their own vulnerability assessments
Perhaps the most significant development is the doing away with mandatory 10% screening by Regulated Agents of cargo originating from Known Consignors.
As a Part 108 practitioner over the years, I have encountered forwarders wanting to transport cargo from the consignor directly to the airlines and were put off at times by the high screening fees. With the amended regulations, it will be possible to do so without incurring screening fees provided the consignor is accredited.
South Africa has a very good air cargo security regime, this can be strengthened by addition of more Known Consignors. As the aviation industry continues to find cost efficient ways of doing business, we must always remember that we are responsible for the lives of every passenger in those aircraft.
Security is everyone’s responsibility.
Let us encourage the participation of consignors in the secure supply chain.