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.

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