by Elliot Molemi, Compliance
There is a proposal by the SACAA to amend certain regulations to align them with the 17th amendment of ICAO’s Annex 17.
The first amendment applicable to Aviation Security in general is the changing of the definition of Background Checks in Part 1 of the Civil Aviation Regulations.
The change will still achieve the result of only having suitable candidates employed in the functions of applying security controls or having unescorted access to security restricted areas.
The main changes are in Part 108.02.1(1) which details the duties of a Regulated Agent.
The changes are a mixture of substitution of words in existing paragraphs and insertion of new paragraphs into the regulations. The changes are likely to:
- Replace “security controls” with “appropriate security controls” in paragraph (d).
- Insertion of “once security cleared/screened” in paragraph (k)
- Requiring that the Regulated Agent perform oversight/verification to subcontractors who are applying security measures on their behalf, and that they are in line with their Security Manual.
- Require that Regulated Agents perform random and unpredictable securing controls on cargo tendered as secure cargo from other Regulated Agents and Known Consignors.
- Require that Regulated Agents screen staff and visitors for explosives and explosive devices.
Other amendments to the Part 108 regulations will require:
- That the Known Cargo area be security controlled at all times.
- That the air carrier must safeguard known cargo in their care until departure of the aircraft.
- That all Transfer & Transit Cargo that is received as unknown cargo be screened to the same standards as any originating cargo.
Practical implications
The practical implications of most of these changes are negligible as they are already in practice at most agents. I will only discuss three of these changes as they require a little more application than others.
Verification of Security Companies and Screener Organisations
The Designated Official (DO) of a Regulated Agents must periodically verify that the contracted security company or screener organisation (ASSO) is performing their functions in line with the regulations and the approved security manual. This can be done by inspecting the procedures, documentation, and practical application by individuals. The DO will decide on the frequency of these checks.
Random and Unpredictable Security Controls
Performing random and unpredictable security controls on cargo received as Known Cargo could be done by either one or a combination of the following methods:
- Screening of Known Cargo.
- Opening of cargo to verify their contents, where practical and permissible.
- Making random calls to non-account clients to verify their knowledge of the cargo, address, contacts, and existence of the company.
Records of the random and unpredictable security controls will have to be kept and available to be inspected by the CAA.
Screening for explosives for staff and visitors
The screening of staff, visitors and their belongings for explosives and explosive devices when entering the facility of a Regulated Agent is perhaps the trickiest. The reasoning for it is sound but the application might be costly. This regulation will require the use of an Explosive Trace Detectors on individuals and their belongings or Explosive Detection Dogs of the belongings or any other approved screening method that can detect explosives. The good thing about this regulation is that It gives room for this to be applied on a random basis.
The next steps
These changes are still in process, Regulated Agents will have to amend their Security Manuals to detail how they are going to implement the changes.
As always, the SACAA will assist the industry in applying the changes by means of workshops and the provision of Technical Guidance Material where necessary.
