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COAC Submits Recommendations to CBP For Streamlining Checks, Credentialing For Air Cargo Employees

At the May 11, 2010 meeting of the Departmental Advisory Committee on Commercial Operations of U.S. Customs and Border Protection and Related Homeland Security Functions (COAC), COAC adopted the recommendations of its Air Cargo Security Subcommittee regarding streamlining federal background check and credentialing requirements for air cargo employees. After adopting the recommendations, COAC presented them to CBP for its consideration.

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(COAC’s Air Cargo Security Subcommittee developed a matrix of the various cargo security-related programs that affect trade participants in the air cargo supply chain in order to identify areas of possible redundancy and/or areas that could be leveraged to improve and streamline air cargo security. Duplicative federal background check and credentialing requirements for air cargo employees was the first area of the matrix the Subcommittee looked at in-depth.)

CBP Expected to Respond to Recommendations at Next COAC Meeting

According to CBP sources, CBP will be evaluating COAC’s recommendations and reporting back at the next COAC meeting as to whether CBP/Department of Homeland Security are able to implement some or all of COAC’s recommendations.

Highlights of COAC’s Recommendations to CBP

The following are highlights of COAC’s recommendations to CBP on streamlining air cargo employee background checks and credentialing:

Streamline checks, credentialing for air cargo truck drivers. According to COAC, truck drivers are subject to a number of overlapping requirements including the TSA Air Cargo Security Threat Assessment (STA) for access to unscreened air cargo, the Hazardous Materials Endorsement (HME), the TWIC (Transportation Worker Identification Credential) required for access to seaport facilities, and the CBP Free and Secure Trade (FAST) card for transborder crossings.

COAC recommends that DHS and its relevant agencies rationalize their credentialing programs to a single Security Threat Assessment (STA) and credential, especially for truck drivers whose pick up and drop off locations require STA vetting. As a short term solution, DHS should establish a policy of mutual recognition among FAST, TWIC, drivers’ licenses with HMEs, and Airport Security Identification Display Area (SIDA), notwithstanding the disparities among the programs.

Reduce overlap of checks on warehouse employees. According to COAC, employee vetting required by the TSA Indirect Air Carrier Standard Security Program (IACSSP) and the CBP requirement for employees having access to bonded facilities and cargo have significant overlap in the workers that fall under both programs. Therefore, COAC recommends there be only one process per employee - either the TSA IAC requirement or the CBP bonded cargo process.

Increase portability of airport security ID badges. COAC states that the lack of SIDA badge portability impacts many aviation employees that travel to multiple U.S. airports to perform job duties, e.g., seasonal workers, line mechanics, auditors and management.

To reduce this overlap, COAC recommends: (i) uniform TSA national standards for SIDA training applicable to all airports; (ii) employees with a valid SIDA badge for one (or more) airports should only be required to complete airport-specific familiarization at subsequent airports when SIDA access is needed at multiple airports and SIDA fees should be reduced accordingly; and (iii) the cost of the STA component could be reduced by either having TSA house the data received from the airports instead of using a third party clearinghouse, or by allowing multiple vendors to provide this function to encourage competitive pricing.

Combine CBP customs seal and TSA SIDA badge requirements. According to COAC, thousands of air carrier employees at hub and gateway airports are subject to redundant CBP Customs seal and TSA SIDA badge requirements.

COAC recommends that DHS seek to combine the TSA SIDA and CBP seal programs into a single application and credentialing process to establish one standard for access to secure air cargo and international flights. DHS should leverage common requirements between agencies to eliminate the overlap between the SIDA and Customs seal programs and the significant burden that these redundancies create for trade. COAC recommends that CBP undertake a review of the Customs Seal Program at the executive level to consider whether the additional CBP criteria are necessary.

(See ITT’s Online Archives or 05/28/10 news, 10052740, for BP summary on the posting of these recommendations.

See ITT’s Online Archives or 05/13/10 news, 10051314, for BP overview of the May 11 COAC meeting.)