Security Policy Alert: U.S. Files Difference on ICAO Staff Screening Requirements

July 1, 2020

TSA Administrator David Pekoske informed AAAE today that the agency, on behalf of the United States, has officially filed a difference to the International Civil Aviation Organization (ICAO) regarding the recently adopted international standard for 100 percent staff screening. Late last year, the ICAO Council officially adopted an amendment to Annex 17 to require full screening of all non-passengers entering restricted areas of airports.

In the difference, TSA highlighted the multi-layered risk-based approach to insider threat mitigation in the United States. The U.S. views physical screening of employees as only a single layer in a multi-faceted approach that also includes robust and recurrent background checks; random and unpredictable physical screening throughout the airport environment; other access control measures; security awareness campaigns; training; intelligence, information and best practice sharing; and utilization of advanced technology and procedures designed to detect threats. 

There is no penalty for filing a difference but other countries or foreign air carriers may require additional measures from the U.S. and U.S. air carriers. ICAO may also audit the U.S. Australia and Canada also filed differences.

Although TSA was disappointed with ICAO's singular focus on physical screening, the agency does continue to pursue an employee screening requirement for U.S. airports. In August, TSA plans to issue for notice and comment a proposed ASP amendment regarding employee screening.  The proposed ASP amendment is under early review with TSA senior leadership and subject to change.  However, based on a draft reviewed by AAAE staff and TSA briefings to industry, the agency 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.  

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 within one year.  TSA will include a functional requirements document for portable explosive detection technology as part of the package posted for notice and comment.  

As always, AAAE will keep you updated on employee screening related issues both internationally and domestically.  In the meantime, please do not hesitate to contact us if you have any questions or need any additional information