Cargo Security Bulletin to Regulated Agents, Known Consignors, Airlines and Charter organisations

This bulletin takes the form of short highlights, PLEASE CONTACT us by e-mail if you require any FURTHER INFORMATION or EXPANSION of the information provided.

Where italics are shown this means a direct QUOTE FROM REGULATIONS, TECHNICAL STANDARDS or other CORRESPONDENCE received from the SACAA or other official bodies.

NEW PROFESSIONAL TRAINING CENTRE OPENS

We have OPENED our TRAINING CENTRE at Unit C, Wingfield Park, Geertsma Road in JET PARK (map at http://www.professionaltraining.co.za/map-to-our-training-facilities.php)

Regular scheduled TRAINING PROGRAMMES covering aviation cargo security familiarisation training take place every Tuesday and Dangerous Goods Awareness (CAT 4) every Wednesday.

The 2015 training schedule is at http://www.professionaltraining.co.za/2015-training-program.php

EUROPEAN UNION CARGO SECURITY REQUIREMENTS EFFECTIVE 1 JULY 2014.

South Africa was placed on the EU “Green List” effective 1st July 2014.

In our view, this change REDUCES the level of cargo SECURITY.

It is our STRONG ADVICE that those Regulated Agents who are REGISTERED under the EU Regulations and hold EU RA3 APPROVAL, continue to APPLY the practices applicable to the EU Regulations for two MAIN REASONS, firstly, INCREASED SECURITY and secondly, if there were an incident, and an EU accredited agent had not COMPLIED with the EU Regulations (having made a DECLARATION to do so) this could be considered a serious BREACH OF LIABILITY INSURANCE requirements.

Certain of our clients have elected to become EU REGISTERED, despite the fact that we are on the Green List, which we ENCOURAGE.

COMPREHENSIVE BACKGROUND CHECK AND CV VERIFICATION SERVICE (INCLUDING CREDIT CHECKS)

This service includes what is required under Part 110 but also provides the FULL RANGE of employee background checks including:

· DRIVERS LICENCE

· PUBLIC DRIVING PERMIT

· MATRIC CERTIFICATE AND OTHER ACADEMIC QUALIFICATIONS

· CRIMINAL RECORD CHECK

· ID VERIFICATION

· CITIZENSHIP AND PERMEANT RESIDENCE VERIFICATION

· PRIVATE SECURITY INDUSTRY REGULATORY AUTHORITY (PSIRA)

These services are available to be IMPLEMENTED at YOUR PREMISES, please contact us for full details

PART 109 AND 110

We report, once again, with DEEP REGRET, and fear of the security breach that this presents, that the SACAA have still NOT YET COMPLETED the amendments to PART 108, 109 AND 110. This has been raised at the Civil Aviation Regulations Committee (CARCom), on which committee we are represented through the Commercial Aviation Association of Southern Africa (CAASA), but despite pressure having been brought at CARCOM, by our representative, we still sit in LIMBO as far as these regulations are concerned.

There is a STRONG INDICATION that the Regulations may be READY for presentation at the 26TH JANUARY 2015 CARCom meeting.

We have mentioned on numerous occasions, in our bulletins and elsewhere, that the REQUIREMENTS UNDER PART 108 for cargo screeners are COMPLETELY INADEQUATE.

We cannot be more adamant when we say it is VITAL that although the requirements for certification of cargo screeners, and training, under Part 110, are NOT CURRENTLY APPLICABLE you NEVERTHELESS APPLY these requirements STRICTLY.

FREE CHECK OF YOUR SECURITY MANUALS

We repeat point 4 of Bulletin 33.

If your SECURITY MANUAL was not prepared by ourselves or under our supervision, we would be more than happy to provide you with a FREE CHECK and WRITTEN REPORT on your security manual. The fact that your manual may have been approved by the SACAA does not absolve you from ensuring that the manual is accurate, all inclusive and practical. Here again there may be INSURANCE LIABILITY implications if your MANUAL is INCOMPLETE.

FACILITATED eLEARNING TRAINING

Here again, we must state with GREAT DISAPPOINTMENT that there has been NO DISCERNIBLE PROGRESS by the SACAA to bring the eLearning system into operation. The changes to incorporate the eLearning requirements are to be contained in the Part 109 amendments (see 4 above).

SACAA SERVICE

We would like to COMPLIMENT the DIRECTOR FOR CIVIL AVIATION, MS POPPY KHOZA, for her INITIATIVE in initiating a survey of SACAA SERVICE PERFORMANCE. This survey was conducted by a team from the UNIVERSITY OF PRETORIA and consisted not only of a questionnaire, which was e-mailed to various bodies, but also meetings with industry in Gauteng and Cape Town. WE ATTENDED the GAUTENG MEETING, together with REPRESENTATIVES of a number of AVIATION ORGANISATIONS, and were assured that comments, suggestions and criticism would be CONFIDENTIAL and would be CONTAINED IN A REPORT which will be released to participants. The meeting we attended lasted some hours and there was an open detailed and SIGNIFICANT DISCUSSION, particularly focused on those WEAKNESSES that had been experienced with regard to service from the SACAA.

We will keep you advised and will distribute the report with the authority of the SACAA.

LITHIUM-ION BATTERIES

We repeat what was contained in Bulletin 33.

There have been NUMEROUS INCIDENTS of SPONTANEOUS COMBUSTION of lithium-ion batteries around the world and there are strong rumours that perhaps large quantities of lithium-ion batteries were TRANSPORTED ON MH370. Please find attached two articles that appeared in FTW written by SEAN REYNOLDS who is OUR AUTHORITY on LITHIUM-ION BATTERIES. We are running a number of half day LITHIUM-ION BATTERY COURSES over the next couple of months. Please contact us for further information.

Lithium Batteries                                                 lithium battery article

We are very pleased to say that these COURSES are now available ONLINE which means that your personnel can complete this course while continuing with their operational duties.

AVAILABILITY OF THE CARGO SCREENING TEAM INCLUDING EMERGENCY CANINE SCREENING

We are AVAILABLE 24/7 through our control room telephone number 0860 PART 108 or 011 701-3320, further alternatively, through our General Manager Compliance, David Alexander at david@prisk.co.za or cell 082 308 0169.

We are AVAILABLE 24/7 throughout the HOLIDAY PERIOD.

THANKS AND GREETINGS

WE TAKE THIS OPPORTUNITY OF THANKING OUR CLIENTS FOR THEIR SUPPORT AND TO WISH ALL OF YOU GOD’S BLESSINGS FOR THE FESTIVE SEASON AND THE NEW YEAR.

Kind Regards from the team at Professional.

SECURITY WITHOUT COMPROMISE WILL SAVE LIVES.

Kintetsu World Express first southern African logistics company to receive top EU safety accreditation – RA3 designation

Taking the lead, Kintetsu World Express South Africa became the first freight forwarder to be validated in accordance with the new, stringent EU security measures. The validation was conducted by an EU independent and accredited aviation security validator.

New EU security regulatory measures: 2014

Cargo security came under scrutiny when two packages containing viable explosive devices hidden in printer cartridges moved undetected through Europe in October 2010, before it was intercepted in Britain. This serious incident prompted the European Union to introduce, in addition to the ICAO Annexure 17 Regulations [covered under Part 108 of the SACAA regulations], additional measures to include air cargo or mail carriers operating in the EU from a third country airport (non EU).

In essence, this means that as from 1 July 2014, no cargo may be flown on an aircraft into the EU region without strict adherence to the new regulatory measures.

Stepping forward

Richard Szabo, director at KWE SA explains: “our business operations play a fundamental role in underpinning the success of our global footprint.”

“Our ranking as one of the top global freight forwarding companies bears testimony that we view our role as an integrated logistics supply chain company seriously. We value our role as involved business partners who deliver high quality services and it is thus tantamount that our corporate governance and EU conformance remain progressive, audited and in place” .

EU validation achievement

“Our validation underscores our impeccably high standard of service” comments Ikuhiro Hojo, director at KWE SA “particularly within the aerospace logistics industry. We were one of the first agents in South Africa to be certified against the CAA’s Part 108 security policy and this was by no means an easy feat. We continuously strive towards maintaining the highest possible standards when it comes to managing our customers’ freight.”

Independent EU aviation security validators

According to a spokesperson for Professional Cargo Security, EU aviation security validator Sander De Man; KWE SA’s first off the mark move illustrates their commitment to security and willingness to partnership with the EU, in order to achieve greater security. De Man is part of a European association of validators based in the Netherlands, Germany, France and the United Kingdom.

Continued: Kintetsu World Express receives top EU safety accreditation

He reiterated that in order to comply with the Regulations, airlines have already made written declarations of commitment to the EU. All forwarding, courier agents, airlines and consignors must become validated by an EU qualified validator accredited as such, by an EU member state.

KWE commended

David Alexander, General Manager, Compliance of Professional commended KWE SA as follows: “I am proud to be associated with Kintetsu World Express South Africa in introducing these measures and compliment them on their commitment and dedication to making our skies that much safer.”

IATA Centre of Excellence

EU independent aviation security validators have been trained through the IATA Centre of Excellence for Independent Validators; and were appointed accordingly. These accredited validators have the mandate as EU representatives to validate Airlines (validation reference ACC3), Ground Handling Agents and Forwarding Agents (validation reference RA3) and Known Consignors [validation reference KC3] as well as consignors by physical inspection of premises, records systems and procedures. Revalidation is required every 5 [five] years.

Risk assessment

There are several thousand airline cargo facilities [stations] which have to be validated before the July 2014 deadline. Non EU countries are categorized depending on risk assessment. The most secure category [in very few countries], require no further security measures except which already is in place such as the ICAO Annexure 17 measures. Intermediate risk countries must apply all the EU measures and high risk countries may not [except for exceptional circumstances], be able to export by air to EU countries at all.

Professional Cargo Security has made arrangements for another validator to spend time in South Africa within the next few weeks in order to validate forwarding and courier agents as well as Known Consignors [KC’s].

Cargo Security Bulletin to Regulated Agents, Known Consignors and Charter organisations

This bulletin takes the form of short highlights, PLEASE CONTACT us by e-mail if you require any FURTHER INFORMATION or EXPANSION of the information given.

1 FAMILIARISATION TRAINING – GOOD NEWS !!

We have just completed an ELECTRONIC TRAINING COURSE which is now available. This means YOUR STAFF will be able to complete their FAMILIARISATION TRAINING ONLINE. We are also in the process of DEVELOPING ONLINE TRAINING covering DANGEROUS GOODS and OTHER COURSES which will be available from mid JANUARY 2013. LOANER LAPTOPS, in a limited quantity, are also AVAILABLE.

VISIT OUR TRAINING PORTAL TODAY!

2 New Regulations

Part 92, 108, 109, 110 and 111 Regulations came into full EFFECT from 1ST AUGUST 2012. Please note that the SACAA PROPOSED, which proposal was accepted by an industry / SACAA sub committee, that PART 110 AND 109 TECHNICAL STANDARDS SHOULD BE KEPT RESTRICTED.

Bob Garbett, who serves on the sub committee, and on CARcom, was ADAMANTLY AGAINST this proposal for all the OBVIOUS REASONS, however, certain members of industry and the SACAA SUPPORTED THE PROPOSAL. The proposal was then submitted to CARcom (the Civil Aviation Regulations Committee) at which it was PROPOSED that Part 108 TECHNICAL STANDARDS should also be RESTRICTED. This too was carried against OBJECTIONS from the COMMERCIAL AVIATION ASSOCIATION OF SOUTHERN AFRICA (on which body Bob Garbett is an honorary Director for Life). CAASA has NOT DROPPED THIS MATTER and APPEALED the decision by CARcom. Frankly, this is a RIDICULOUS SITUATION, which option we have voiced STRONGLY at CARcom, through CAASA, as any amendments, for example to these Technical Standards would also have to be applied for creating an unnecessary burden of administration for all.

In the meantime, if you do not have COPIES OF THESE TECHNICAL STANDARDS (and most Regulated Agents and airlines, ironically, all already have copies) you need to make APPLICATION to the CAA. We suggest (if you REQUIRE the TECHNICAL STANDARDS) that you address a LETTER to the SACAA requesting copies of the Part 110, 109 and 108 Technical Standards and SEND the letter to OURSELVES. WE will then APPROACH THE SACAA with batches of letters and ensure that authority for your holding a copy of the Technical Standards is obtained as soon as possible. The letter should STATE WHETHER or not you ALREADY HOLD a current set of these Technical Standards.

It was DIRECTED by CARcom at the 28th November meeting, as a result of the CAASA appeal, that this decision must be REVIEWED at the next sub committee meeting to be held in JANUARY.

3 Part 109 and Part 110

The SACAA have as yet still not completed the proposed AMENDMENTS to these Regulations which will incorporate all TRAINING including training required under Part 108 (currently regulated under Part 141) into Part 109. We hope this will be CONCLUDED by the SECOND QUARTER of NEXT YEAR. We are also advised that Aviation Information Circular AIC 18-49, which eliminates certain requirements for cargo screeners under Part 110, will be withdrawn. In the meantime, it is of MAJOR IMPORTANCE that cargo screeners COMPLY with the PROVISIONS of Part 110 which are LISTED BELOW (previously listed in Bulletin 24, April 2011, and Bulletin 19, May 2010).

a) SECURITY GRADING in terms of the Security Act no. 56 2001.

b) The security graded screener must be EMPLOYED BY A SECURITY SERVICE PROVIDER.

c) The screener must have at least DANGEROUS GOODS CAT 12.

d) The screener must have STANDARD AIR CARGO SECURITY TRAINING LEVEL 1.

e) Category 1: SECURITY SCREENER TRAINING

f) The screener must have completed AWARENESS TRAINING in terms of Part 109 (if he works at an airport) and or, if he works at an off airport Regulated Agent, FAMILIARISATION TRAINING in terms of Part 108.

g) The screener must have a CLASS II MEDICAL CERTIFICATE.

h) 40 HOURS CLASSROOM training, 40 HOURS PRACTICAL TRAINING.

i) COMPREHENSIVE BACKGROUND CHECK as set out in Part 110.

4 Designated officials, deputies and their employer to be registered with PSIRA.

Please find attached a LETTER from PSIRA dated 13th September 2012 addressed to the SACAA which was CIRCULATED by the SACAA recently. It is of SIGNIFICANT IMPORTANCE that you note that DESIGNATED OFFICIALS, their DEPUTIES and their EMPLOYERS (if you are employing persons in these positions) must be REGISTERED WITH PSIRA.

In our view, it MAKES SENSE from every point of view that INSTEAD OF EMPLOYING your own Designated Official and Deputy, these are PROVIDED BY A SERVICE PROVIDER.

5 Please refer to point 5 of Bulletin no. 29 of 20th June 2012 under “MEETING WITH DIRECTOR AND SENIOR STAFF OF AVSEC”. REPORT BACK

5.1 AIC 18-49, as mentioned above, will be WITHDRAWN.

5.2 Part 108, Part 109 Awareness Training has NOT IMPROVED.

5.3 GRADING OF DESIGNATED OFFICIALS, this has now been FINALISED, see above.

5.4 We stress that HAND SEARCH should be AVOIDED in all circumstances due to LIABILITY IMPLICATIONS.

5.5 The Part 110 and 109 AMENDMENTS have still NOT been COMPLETED.

5.6 KNOWN CONSIGNORS is still at an unacceptably LOW LEVEL.

5.7 MATURING has now been REMOVED as a security control.

Kind regards from the team at Professional Risk.

SECURITY WITHOUT COMPROMISE WILL SAVE LIVES.