Earlier, we saw that it was a crucial point for IACs beyond which STAs were required for cargo intended for passenger aircraft. However, the analogous requirement does not apply to on-airport SIDAs. Any employee working within a SIDA still must pass a criminal background check. The STA is generally an off-airport requirement while the background check remains required for on-airport SIDAs.
An initial concern of many was that this rule would create SIDA's in off-airport facilities. But SIDAs remain on-airport entities.
Employees and agents of United States and non-U.S. air carriers, all-cargo operators and IACs at off-airport facilities are subject to the STA. There is no identification display requirement in this regulatory change.
The Known Shipper Program remains a central foundation of the entire air cargo security program.
The TSA continues the policy that cargo from unknown shippers will not be accepted for transport aboard passenger aircraft and will maintain the centralized database for known shippers.
The definition of an unknown shipper is where the already operating program will change.
The specific security programs for passenger foreign and cargo carriers have been distributed for comment. They contain more specific requirements and enhancements to the existing program. Some of the additional requirements are designated "sensitive security Information" and may not be publicly disclosed. So it is difficult to determine exactly what are some of the more important additions to the Known Shipper program.
Generally, the greatest effect of the new cargo rule will be felt by IACs operating off-airport. The requirement for security threat assesments will have the greatest impac on those forwarders.
For aircraft operators, the biggest change is the designation of the all-cargo air carrier to be now regulated under Part 1544. For airports, the lion's share of the work will be in re-designating airport areas as SIDAs based upon the point of acceptance of cargo.
-- Tom Anthony is project manager for Los Angeles-based DMJM H&N, a consultancy that has worked on security programs at facilities including Las Vegas McCarran International Airport and Atlanta Hartsfield-Jackson International Airport. He worked for the Federal Aviation Administration for 22 years and for the Transportation Security Administration for three years.