Security Policy Alert: TSA Issues Policy Clarification Notice on CHRC and Rap Back Certifications
September 16, 2022
TSA issued a Policy Clarification Notice (PCN) on September 16 regarding CHRC and Rap Back certifications to emphasize that certifications are voluntary for all regulated parties, including airport operators and air carriers. The PCN has been posted on HSIN.
As discussed on TSA's monthly conference call for airport stakeholders, TSA issued the PCN to clarify that CHRC certifications are voluntary for all parties, meaning airports do not have to accept offered certifications and airlines are not required to provide one. Specifically, the PCN states that TSA does not require airport operators to accept CHRC certifications from aircraft operators, and TSA does not require aircraft operators to provide CHRC certifications to airport operators. Airport operators cannot require CHRC certifications from aircraft operators.
In situations where an aircraft operator does not provide a CHRC certification, or the airport operator does not accept a CHRC certification for an aircraft operator direct employee or authorized representative, the airport operator remains solely responsible for completing the CHRC and subscribing the individual in Rap Back before granting unescorted access.
TSA also uses the PCN to stress that the content required in the CHRC certification under the air carrier security programs is sufficient to meet an airport operator's regulatory and ASP requirements, can be accepted at face value, and is valid until cancelled. TSA has posted the required certification content as outlined in the air carrier security programs to HSIN. The PCN reads that airport operators must ensure their ASP does not contain requirements inconsistent with the policy clarification notice.
As always, please do not hesitate to contact us if you have any questions or need any additional information.
TSA issued a Policy Clarification Notice (PCN) on September 16 regarding CHRC and Rap Back certifications to emphasize that certifications are voluntary for all regulated parties, including airport operators and air carriers. The PCN has been posted on HSIN.
As discussed on TSA's monthly conference call for airport stakeholders, TSA issued the PCN to clarify that CHRC certifications are voluntary for all parties, meaning airports do not have to accept offered certifications and airlines are not required to provide one. Specifically, the PCN states that TSA does not require airport operators to accept CHRC certifications from aircraft operators, and TSA does not require aircraft operators to provide CHRC certifications to airport operators. Airport operators cannot require CHRC certifications from aircraft operators.
In situations where an aircraft operator does not provide a CHRC certification, or the airport operator does not accept a CHRC certification for an aircraft operator direct employee or authorized representative, the airport operator remains solely responsible for completing the CHRC and subscribing the individual in Rap Back before granting unescorted access.
TSA also uses the PCN to stress that the content required in the CHRC certification under the air carrier security programs is sufficient to meet an airport operator's regulatory and ASP requirements, can be accepted at face value, and is valid until cancelled. TSA has posted the required certification content as outlined in the air carrier security programs to HSIN. The PCN reads that airport operators must ensure their ASP does not contain requirements inconsistent with the policy clarification notice.
As always, please do not hesitate to contact us if you have any questions or need any additional information.
