Security Policy Alert: Summary of TSA's Monthly Conference Call for Airport Stakeholders
June 4, 2020
This afternoon, TSA held its monthly conference call for airport stakeholders. The conference call was led by Alan Paterno, TSA's Airport Industry Engagement Manager in the office of Plans, Policy and Engagement (PPE). Following are highlights from today's call:
Updates from Plans, Policy and Engagement
Centralized Database: Under the TSA Modernization Act of 2018, TSA is required to create a centralized database of airport and air carrier badges that have been revoked due to security violations. On May 19, TSA posted on HSIN the proposed Airport Security Program Amendment TSA-NA-20-01 regarding implementation of the centralized database. Comments on the proposed ASP amendment are due on June 30, 2020. AAAE will be submitting comments on behalf of our airport members and we welcome your input and feedback to inform those comments. We will also be soliciting comments from the AAAE Transportation Security Services Committee on our next monthly call on June 10.
Taking Back the Watchlists: As required under ASP Amendment TSA-NA-18-01 Airport Access and Vetting, all commercial service airport operator access to the No Fly and Selectee watchlists has been revoked, as of May 31, 2020. TSA thanked airports for the effort and resources needed to comply with the other options outlined in TSA-NA-18-01, acknowledging that it was harder than expected.
Airport Categorization/TSA-NA-01-01A: As discussed on last month's TSA call, TSA is working on a technical change to FAA AP 01-01, Airport Categorization, which will now have a new serial number of TSA-NA-01-01A. TSA is updating the format of the document to match their current ASP National Amendment templates and giving it the new serial number (TSA NA-01-01A). They are also updating regulatory citations throughout the document. Finally, and the key reason behind the effort, TSA plans to reserve the section on LEO response times and make an official change to the policy to clearly state that the specific LEO response times in AP 01-01/TSA NA-01-01A no longer apply. The Security Directive (SD) 1542-18-01 series supersedes the stated response times based on airport category found in AP 01-01. The TSA-NA-01-01A update is in the final review process at TSA headquarters and may be issued as early as next week.
Proposed ASP Amendment on Staff Screening/Aviation Workers: In August, TSA plans to issue for notice and comment a proposed ASP amendment regarding aviation workers. The proposed ASP amendment is under early review with TSA senior leadership and subject to change. However, as of today, TSA plans to have the ASP amendment require insider threat vulnerability assessments, insider threat risk mitigation plans based on the vulnerability assessments, and a certain amount of required screening of aviation workers. Information Circular (IC) 15-01E on Insider Threat currently recommends an insider threat vulnerability assessment, an insider threat mitigation plan, and recommended aviation worker screening in addition to the required aviation worker screening under the SD 1542-18-01 series.
Under the draft proposed ASP amendment, the aviation worker screening will require the search of an aviation worker's person and property to deter, detect and prevent unauthorized explosives, incendiaries, firearms, and other deadly dangerous items from entering the secure or sterile area of an airport. When the draft ASP amendment is posted for notice and comment, TSA will also include a draft tool that will use the number of airport identification media and public-to-secure and public-to-sterile access doors to calculate the number of hours of screening required at each airport facility. In addition, the proposed ASP amendment will require airports to use explosive detection technology for the screening of aviation workers' persons and property. TSA will include a functional requirements document for portable explosive detection technology as part of the package posted for notice and comment. TSA urged airports to play close attention to the transmittal memo when the proposed ASP Amendment is posted as TSA will be highlighting specific sections for industry to focus on for feedback and comments.
As promised, TSA has shared a draft of the proposed ASP amendment with AAAE and the Quarterly Airport Security Review airport representatives. We raised significant concerns about the aviation worker screening requirements, the tool/formula used to calculate the required number of screening hours per airport, and the requirement for explosive detection technology investment, especially in the current budget and operating environment. We will continue to work with TSA prior to the release of the proposed ASP amendment in August for notice and comment to address these issues if at all possible.
FAA Form 110A Credential Expiration Extension: As AAAE shared yesterday, because of logistical and administrative constraints placed on the Federal Aviation Administration (FAA) by the COVID-19 public health emergency, the FAA is extending the expiration dates for all FAA Form 110A aviation safety inspector's (ASI) credentials expiring between March 1, 2020, and August 31, 2020, to August 31, 2020. This impacts less than 10 percent of the existing credentials, or 248 out of roughly 3,600 FAA Form 110A credentials.
I-9 Documentation
TSA's Office of Chief Counsel reported that the U.S. Citizenship and Immigration Services (USCIS) has not yet made a decision or taken action to automatically extend USCIS issued documents related to citizenship and work authorization status. As a result, TSA will not accept any expired USCIS documents as part of the identity or work authorization requirements under the SD-1542-04-08 series. TSA did note that the agency will accept a number of expired documents under List B on the I-9 documentation form, such as state issued driver's licenses, TSA Hazmat and TWIC certifications. TSA will revisit acceptance of expired USCIS documents if or when USCIS makes a decision or takes action to extend expired immigration and work authorization documents.
Third Party Explosive Trace Detection Canines
The TSA Modernization Act of 2018 requires TSA to develop guidance for the use of explosives detection canine teams to provide public area security at airports. In addition to providing behavioral, medical, and technical standards for the procurement of explosives detection canines by transportation stakeholders, the statute also requires TSA to develop certification standards and guidance on deployment of explosives detection canine teams for use by transportation stakeholders to enhance public area security at transportation hubs, including airports.
TSA believes that teams should meet specific certification standards, similar to those currently required for TSA's National Program, before being allowed to screen in the public areas of airports. Canine teams intended to augment public area security in an airport environment should have a high level of environmental confidence and sociability to be deployed in an active, high paced and dynamic environment. Before entering into an agreement with a stakeholder, the canine team should be completely trained, and ready for any required validation/certification necessary for deployment in the public areas of an airport.
There are additional issues that need to be addressed before teams are deployed, or before an airport finalizes contracts with a canine team provider. These issues include local alarm response procedures agreed upon by the FSD, the airport, the law enforcement responders, and the provider. While TSA can develop some general guidelines, TSA also recognize that each airport is different and may require additional state or local law requirements.
TSA is considering forming a working group with aviation stakeholders to explore these issues and inform the guidance required under the TSA Modernization Act of 2018. TSA is also considering leveraging the standard operating procedures for the Advanced Threat Local Allocation Strategy (ATLAS) program to incorporate third party canines. TSA noted that the guidelines do not have the force and effect of law and that the third-party canine program is optional. AAAE will participate on the working group. If individual airport representatives are interested in participating as well, please let AAAE know and we will provide your contact information to TSA.
COVID-19 Related Signage at Checkpoints
In an effort to support passenger education, TSA's Office of Public Affairs is finalizing checkpoint signage related to social distancing and modified de-composure and re-composure procedures. The signage will be provided to Federal Security Directors (FSDs) as early as next week and will be provided in a number of display options, including stanchions, floor stickers, and digital files. TSA encouraged airports to work with their FSDs to coordinate the signage to meet local needs, such as digital videos, and to incorporate it into any existing airport signage related to COVID-19 procedures. TSA will provide an example of the signage once it becomes available and AAAE will share it as soon as it is available.
Airport Badging Data Quality
TSA encouraged airports to include badge expiration dates as part of their data submissions to TSA. It is important to note that badge expiration dates are NOT currently required under the SD 1542-04-08 series. TSA encouraged the inclusion of badge expiration dates to ensure that expired or revoked badges do not continue to be adjudicated or vetted by TSA. TSA stated that they are considering systematic measures in the fall that may involve TSA assigning its own expiration dates on badge records and "nuking" outdated records from TSA's systems. In response to a question from AAAE about whether TSA will be revising the SD 1542-04-08 series to require badge expiration dates, TSA stated that they are exploring all options and are open to feedback on the least onerous options for airports.
Credential Authentication Technology
TSA is deploying over 500 Credential Authentication Technology machines to 90 airports, including Category X, I, and II airports. TSA will begin deploying CAT machines at 6 new airports in July and will continue these deployments at the remaining airports through the second quarter of fiscal year 2021. TSA will be sharing a more detailed CAT deployment schedule next week, which AAAE will share as soon as it is available.
National Safe Skies Alliance
Jessica Grizzle from Safe Skies provided an update on a number of recently completed and on-going projects.
This afternoon, TSA held its monthly conference call for airport stakeholders. The conference call was led by Alan Paterno, TSA's Airport Industry Engagement Manager in the office of Plans, Policy and Engagement (PPE). Following are highlights from today's call:
Centralized Database: Under the TSA Modernization Act of 2018, TSA is required to create a centralized database of airport and air carrier badges that have been revoked due to security violations. On May 19, TSA posted on HSIN the proposed Airport Security Program Amendment TSA-NA-20-01 regarding implementation of the centralized database. Comments on the proposed ASP amendment are due on June 30, 2020. AAAE will be submitting comments on behalf of our airport members and we welcome your input and feedback to inform those comments. We will also be soliciting comments from the AAAE Transportation Security Services Committee on our next monthly call on June 10.
Taking Back the Watchlists: As required under ASP Amendment TSA-NA-18-01 Airport Access and Vetting, all commercial service airport operator access to the No Fly and Selectee watchlists has been revoked, as of May 31, 2020. TSA thanked airports for the effort and resources needed to comply with the other options outlined in TSA-NA-18-01, acknowledging that it was harder than expected.
Airport Categorization/TSA-NA-01-01A: As discussed on last month's TSA call, TSA is working on a technical change to FAA AP 01-01, Airport Categorization, which will now have a new serial number of TSA-NA-01-01A. TSA is updating the format of the document to match their current ASP National Amendment templates and giving it the new serial number (TSA NA-01-01A). They are also updating regulatory citations throughout the document. Finally, and the key reason behind the effort, TSA plans to reserve the section on LEO response times and make an official change to the policy to clearly state that the specific LEO response times in AP 01-01/TSA NA-01-01A no longer apply. The Security Directive (SD) 1542-18-01 series supersedes the stated response times based on airport category found in AP 01-01. The TSA-NA-01-01A update is in the final review process at TSA headquarters and may be issued as early as next week.
Proposed ASP Amendment on Staff Screening/Aviation Workers: In August, TSA plans to issue for notice and comment a proposed ASP amendment regarding aviation workers. The proposed ASP amendment is under early review with TSA senior leadership and subject to change. However, as of today, TSA plans to have the ASP amendment require insider threat vulnerability assessments, insider threat risk mitigation plans based on the vulnerability assessments, and a certain amount of required screening of aviation workers. Information Circular (IC) 15-01E on Insider Threat currently recommends an insider threat vulnerability assessment, an insider threat mitigation plan, and recommended aviation worker screening in addition to the required aviation worker screening under the SD 1542-18-01 series.
Under the draft proposed ASP amendment, the aviation worker screening will require the search of an aviation worker's person and property to deter, detect and prevent unauthorized explosives, incendiaries, firearms, and other deadly dangerous items from entering the secure or sterile area of an airport. When the draft ASP amendment is posted for notice and comment, TSA will also include a draft tool that will use the number of airport identification media and public-to-secure and public-to-sterile access doors to calculate the number of hours of screening required at each airport facility. In addition, the proposed ASP amendment will require airports to use explosive detection technology for the screening of aviation workers' persons and property. TSA will include a functional requirements document for portable explosive detection technology as part of the package posted for notice and comment. TSA urged airports to play close attention to the transmittal memo when the proposed ASP Amendment is posted as TSA will be highlighting specific sections for industry to focus on for feedback and comments.
As promised, TSA has shared a draft of the proposed ASP amendment with AAAE and the Quarterly Airport Security Review airport representatives. We raised significant concerns about the aviation worker screening requirements, the tool/formula used to calculate the required number of screening hours per airport, and the requirement for explosive detection technology investment, especially in the current budget and operating environment. We will continue to work with TSA prior to the release of the proposed ASP amendment in August for notice and comment to address these issues if at all possible.
FAA Form 110A Credential Expiration Extension: As AAAE shared yesterday, because of logistical and administrative constraints placed on the Federal Aviation Administration (FAA) by the COVID-19 public health emergency, the FAA is extending the expiration dates for all FAA Form 110A aviation safety inspector's (ASI) credentials expiring between March 1, 2020, and August 31, 2020, to August 31, 2020. This impacts less than 10 percent of the existing credentials, or 248 out of roughly 3,600 FAA Form 110A credentials.
I-9 Documentation
TSA's Office of Chief Counsel reported that the U.S. Citizenship and Immigration Services (USCIS) has not yet made a decision or taken action to automatically extend USCIS issued documents related to citizenship and work authorization status. As a result, TSA will not accept any expired USCIS documents as part of the identity or work authorization requirements under the SD-1542-04-08 series. TSA did note that the agency will accept a number of expired documents under List B on the I-9 documentation form, such as state issued driver's licenses, TSA Hazmat and TWIC certifications. TSA will revisit acceptance of expired USCIS documents if or when USCIS makes a decision or takes action to extend expired immigration and work authorization documents.
Third Party Explosive Trace Detection Canines
The TSA Modernization Act of 2018 requires TSA to develop guidance for the use of explosives detection canine teams to provide public area security at airports. In addition to providing behavioral, medical, and technical standards for the procurement of explosives detection canines by transportation stakeholders, the statute also requires TSA to develop certification standards and guidance on deployment of explosives detection canine teams for use by transportation stakeholders to enhance public area security at transportation hubs, including airports.
TSA believes that teams should meet specific certification standards, similar to those currently required for TSA's National Program, before being allowed to screen in the public areas of airports. Canine teams intended to augment public area security in an airport environment should have a high level of environmental confidence and sociability to be deployed in an active, high paced and dynamic environment. Before entering into an agreement with a stakeholder, the canine team should be completely trained, and ready for any required validation/certification necessary for deployment in the public areas of an airport.
There are additional issues that need to be addressed before teams are deployed, or before an airport finalizes contracts with a canine team provider. These issues include local alarm response procedures agreed upon by the FSD, the airport, the law enforcement responders, and the provider. While TSA can develop some general guidelines, TSA also recognize that each airport is different and may require additional state or local law requirements.
TSA is considering forming a working group with aviation stakeholders to explore these issues and inform the guidance required under the TSA Modernization Act of 2018. TSA is also considering leveraging the standard operating procedures for the Advanced Threat Local Allocation Strategy (ATLAS) program to incorporate third party canines. TSA noted that the guidelines do not have the force and effect of law and that the third-party canine program is optional. AAAE will participate on the working group. If individual airport representatives are interested in participating as well, please let AAAE know and we will provide your contact information to TSA.
COVID-19 Related Signage at Checkpoints
In an effort to support passenger education, TSA's Office of Public Affairs is finalizing checkpoint signage related to social distancing and modified de-composure and re-composure procedures. The signage will be provided to Federal Security Directors (FSDs) as early as next week and will be provided in a number of display options, including stanchions, floor stickers, and digital files. TSA encouraged airports to work with their FSDs to coordinate the signage to meet local needs, such as digital videos, and to incorporate it into any existing airport signage related to COVID-19 procedures. TSA will provide an example of the signage once it becomes available and AAAE will share it as soon as it is available.
Airport Badging Data Quality
TSA encouraged airports to include badge expiration dates as part of their data submissions to TSA. It is important to note that badge expiration dates are NOT currently required under the SD 1542-04-08 series. TSA encouraged the inclusion of badge expiration dates to ensure that expired or revoked badges do not continue to be adjudicated or vetted by TSA. TSA stated that they are considering systematic measures in the fall that may involve TSA assigning its own expiration dates on badge records and "nuking" outdated records from TSA's systems. In response to a question from AAAE about whether TSA will be revising the SD 1542-04-08 series to require badge expiration dates, TSA stated that they are exploring all options and are open to feedback on the least onerous options for airports.
Credential Authentication Technology
TSA is deploying over 500 Credential Authentication Technology machines to 90 airports, including Category X, I, and II airports. TSA will begin deploying CAT machines at 6 new airports in July and will continue these deployments at the remaining airports through the second quarter of fiscal year 2021. TSA will be sharing a more detailed CAT deployment schedule next week, which AAAE will share as soon as it is available.
National Safe Skies Alliance
Jessica Grizzle from Safe Skies provided an update on a number of recently completed and on-going projects.
- Outreach and data collection has begun for PARAS 0035 Synthesis of Escort Privileges and Escorting Practices. QuinnWilliams is the prime contractor - Julie Quinn, Principal Investigator. Additional project details can be found here. Please reach out to Jessica.grizzle@sskies.org if you are open to discussing your airport's escorting policies/procedures as part of the project's data collection. Information collected will be appropriately safeguarded.
- PARAS 0031 Airport Response to UAS Threats has been awarded.Contractor details will be announced soon. Please reach out to Jessica.grizzle@sskies.org if you have developed or are developing a specific drone response plan and are open to sharing information as part of the project's data collection. Information collected will be appropriately safeguarded.
- PARAS 0021 Utilization of Autonomous Vehicles for Security at Airports has been published and is available for free download here.
- PARAS 0016 Airports Security Vulnerability Assessments is under final review and will be published later this month. It contains step-by-step guidance to assist airports in conducting security vulnerability assessments and evaluating the results. The document will be available for download on the Safe Skies website and an associated tool will be available to airports upon request.
- PARAS 0018 Airport Security Training for Law Enforcement and Security Personnel is also under final review. The document is a comprehensive training resource to assist airports in developing training curriculum specific to their needs. Master curriculum content is intended to provide overall context for the airport environment and airport security, as well as make connections between regulatory requirements and job duties.
Screening Procedures Adjusted for COVID-19
TSA's Office of Requirements and Capabilities Analysis reported on additional adjusted screening procedures that will be implemented by mid-June at the latest. In addition to mandatory gloves, TSA has increased requirements for how often Transportation Security Officers (TSOs) must change their gloves, including at the request of passengers, when torn or dirty, for alarm resolution, and when rotating stations.
TSA has also adjusted divestiture requirements with TSA Divesture Officers focused on only verbal instructions. In the standard screening lane (not in PreCheck), passengers are asked to remove food in their carry-on baggage. Food often triggers alarms and removing food can reduce the likelihood of a search. TSA would like passengers to place their food items in the screening bins, preferably in clear plastic bags. In addition, passengers will be asked to remove belts, wallets, keys and cell phones and place them in their carry-on baggage versus in the screening bins. TSOs are particularly focused on removing belts and large jewelry to avoid false alarms.
Finally, if a passenger forgets to remove their laptop or liquids from their carry-on baggage, they will be directed back to the public area to self-divest and then re-enter the screening checkpoint for re-screening. This will reduce TSOs having to touch carry-on baggage and reduce cross-contamination.
Intelligence Briefing
TSA's Office of Intelligence and Analysis (I&A) briefed on two items. TSA's I&A recently released a report on UAS Threats to Transportation in the Homeland. The report covers UAS incidents reported to TSA between January 2018 and March 2020. The full report is posted on HSIN.
TSA also reported on Domestic Violence Extremists (DVEs), their evolving choice of tactics, particularly explosive-related tactics, and increased activity and social media posting during the COVID-19 pandemic.
Next TSA Conference Call
The next TSA monthly conference call for airport stakeholders is scheduled for Thursday, July 2, 2020 at 1 p.m. ET.
