Security Policy Alert: TSA Issues Updated Guidance About Rap Back Mandate Now In Effect; Feedback Requested
March 30, 2022
TSA-NA-21-03 went into effect on March 29, making it mandatory for airport operators to participate in the Rap Back program. Specifically, all new CHRC requests must also include a subscription into the Rap Back program. Existing badge holders or individuals with a completed CHRC have until March 29, 2024 to be subscribed into the Rap Back program. Air carriers and full all-cargo carriers are also now required to participate in the Rap Back program under their respective security programs.
On March 30, TSA issued a letter of clarification regarding review of Rap Back Subscription Responses, known as RBSRs. RBSRs are generated when an individual with an existing CHRC is subscribed into the Rap Back program. Under TSA-NA-21-03, airport operators are required to review the RBSRs within three business days, regardless of when the CHRC was initially conducted.
TSA understands that current RBSR queues in FPRD are substantial in some cases and has granted a period of 90 calendar days from the publication of today's letter to complete the review of RBSRs. TSA encourages airport and aircraft operators to establish processes going forward that permits the timely review of the RBSRs of individuals with existing CHRCs within three business days. The letter of clarification can be found on HSIN.
In addition, TSA has posted an updated Rap Back User Guide (RBUG) and Rap Back Overview and Privacy Informational Briefing for Airports and Aircraft Operators on HSIN. As a reminder, to participate in Rap Back, airports must complete TSA's Rap Back Overview and Privacy Informational Briefing. For the RBUG update, TSA has included an Appendix with Frequently Asked Questions. In response to a question about whether airports can collect and submit fingerprints under an air carrier's Submitting Organization Number (SON), TSA has responded in the guidance document that airports cannot due to technical issues. Here is the specific exert from the FAQ Appendix:
Q: Can one AO (such as an airport) submit a CHRC search and subscribe transaction on behalf of another AO (such as an aircraft operator) using the Submitting Organization Number (SON) of the other AO?
A: No. Such 'proxy' CHRC transactions are not permitted due to technical reasons. It is not possible for one AO to submit a Rap Back subscription on behalf of another AO.
AAAE understands that many airports provide fingerprint collection and submission services to their air carrier tenants and partners. It appears TSA is equating collection and submission of fingerprints with the submission of a Rap Back subscription, even though Rap Back subscriptions can and are added to the formatted CHRC Electronic Biometric Transmission Specification (EBTS) file by the Designated Aviation Channeler (DAC). AAAE is working with TSA to understand the technical issues referenced in the FAQ that could end the long-standing and contracted fingerprints services provided by airport operators on behalf of air carriers.
In the meantime, we would like to hear from you about any impact this will have on your badging operations and/or relationships with air carrier tenants and partners. Please fill out this short survey or send an e-mail to Colleen Chamberlain at colleen.chamberlain@aaae.org at your earliest convenience.
TSA-NA-21-03 went into effect on March 29, making it mandatory for airport operators to participate in the Rap Back program. Specifically, all new CHRC requests must also include a subscription into the Rap Back program. Existing badge holders or individuals with a completed CHRC have until March 29, 2024 to be subscribed into the Rap Back program. Air carriers and full all-cargo carriers are also now required to participate in the Rap Back program under their respective security programs.
On March 30, TSA issued a letter of clarification regarding review of Rap Back Subscription Responses, known as RBSRs. RBSRs are generated when an individual with an existing CHRC is subscribed into the Rap Back program. Under TSA-NA-21-03, airport operators are required to review the RBSRs within three business days, regardless of when the CHRC was initially conducted.
TSA understands that current RBSR queues in FPRD are substantial in some cases and has granted a period of 90 calendar days from the publication of today's letter to complete the review of RBSRs. TSA encourages airport and aircraft operators to establish processes going forward that permits the timely review of the RBSRs of individuals with existing CHRCs within three business days. The letter of clarification can be found on HSIN.
In addition, TSA has posted an updated Rap Back User Guide (RBUG) and Rap Back Overview and Privacy Informational Briefing for Airports and Aircraft Operators on HSIN. As a reminder, to participate in Rap Back, airports must complete TSA's Rap Back Overview and Privacy Informational Briefing. For the RBUG update, TSA has included an Appendix with Frequently Asked Questions. In response to a question about whether airports can collect and submit fingerprints under an air carrier's Submitting Organization Number (SON), TSA has responded in the guidance document that airports cannot due to technical issues. Here is the specific exert from the FAQ Appendix:
Q: Can one AO (such as an airport) submit a CHRC search and subscribe transaction on behalf of another AO (such as an aircraft operator) using the Submitting Organization Number (SON) of the other AO?
A: No. Such 'proxy' CHRC transactions are not permitted due to technical reasons. It is not possible for one AO to submit a Rap Back subscription on behalf of another AO.
AAAE understands that many airports provide fingerprint collection and submission services to their air carrier tenants and partners. It appears TSA is equating collection and submission of fingerprints with the submission of a Rap Back subscription, even though Rap Back subscriptions can and are added to the formatted CHRC Electronic Biometric Transmission Specification (EBTS) file by the Designated Aviation Channeler (DAC). AAAE is working with TSA to understand the technical issues referenced in the FAQ that could end the long-standing and contracted fingerprints services provided by airport operators on behalf of air carriers.
In the meantime, we would like to hear from you about any impact this will have on your badging operations and/or relationships with air carrier tenants and partners. Please fill out this short survey or send an e-mail to Colleen Chamberlain at colleen.chamberlain@aaae.org at your earliest convenience.
