AAAE Security Policy Alert: Summary of TSA's Monthly Conference Call for Airport Stakeholders, August 1, 2024

Summary of TSA's Monthly Conference Call for Airport Stakeholders 
August 1, 2024 

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  This afternoon, TSA held its monthly conference call for airport stakeholders. The conference call was led by Alan Paterno, TSA's newly named Director of Aviation Plans and Engagement in the office of Policy, Plans and Engagement (PPE), for what will likely be the final time. Craig Mosford has been named to replace Paterno as the Engagement Manager for Airports but has not yet started in his new role. TSA also introduced Bob Scott on the call today who now serves as Director of Aviation Policy in PPE.
   
  Aviation Worker Screening
   
  TSA reminded airports that the period of informed compliance for the Aviation Worker Screening national amendment ends on September 25, 2024. Category X, I and II airports subject to TSA National Amendment 23-02, Aviation Worker Screening, must comply by that date. Airports that will not be in compliance by that date are encouraged to reach out to their Assistant Federal Security Directors for Inspections (AFSD-Is) or to TSA headquarters. Airports that proactively reach out to TSA prior to the end of informed compliance on September 25 and can demonstrate good faith efforts toward full compliance will have the opportunity to enter into a voluntary action plan with TSA Compliance. Airports that are not in compliance and do not contact TSA prior to the deadline will still have an opportunity to enter into an action plan but it will be an investigation action plan with letter of correction enforcement consequences.
   
  AAAE asked what the agency’s approach to aviation worker screening compliance and enforcement will be after informed compliance ends in September. TSA responded that they plan to approach it the same as all other regulations and requirements, which is in a collaborative fashion, driven by outcome focused compliance, and with progressive enforcement. TSA will utilize the existing procedures and processes for determining compliance; there is nothing special or specific to aviation worker screening compliance planned at this time. 
   
  TSA also reminded airports that Explosive Detection Screening Equipment (EDSE) Implementation Plans are due on October 25, 2024. Under the ASP amendment, plans must be submitted to the Federal Security Director. The EDSE must be able to detect explosives on-person and in property of aviation workers being screened.
   
  The EDSE Implementation Plan does not need to be approved by the FSD and does not need to be incorporated into the ASP. Airports must resubmit their EDSE Implementation Plan if there are any substantive changes to the plan. Airports have 18 months after submission of the EDSE Implementation Plan before they are required to use EDSE to screen aviation workers.
   
  In response to AAAE questions, TSA reported that TSA Requirements and Capabilty Analysis has not added any airport or aviation worker screening specific EDSE guidance or testing results to the aviation worker screening toolbox on HSIN. TSA also did not have any specific insight into what, if anything, FSDs will do after EDSE plans are submitted on October 25. TSA expects there will be discussion locally in terms of expectations prior to the April 2026 deadline for EDSE use. There is also the possibility the ASP amendment will be updated prior to the April 2026 deadline based on the forthcoming assessment that is required under the amendment. 
   
  Policy Updates – PNA 24-01 Vehicle Access Gates
   
  In July, TSA had issued a proposed national amendment on vehicle access gates (PNA 24-01) for notice and comment. It was the third in a series of amendments aimed at taking the requirements from the Security Directive 18-01 series and moving them into the airport security program. The two previous proposed amendments focused on public lockers in the sterile area and law enforcement officer procedures. TSA continues to adjudicate the comments received on those proposed amendments.
   
  Based on feedback from AAAE, airports and aircraft operators with Exclusive Area Agreements, TSA will be recalling PNA-24-01 today or tomorrow. TSA plans to rewrite the proposed amendment with the intention of better reflecting the existing language in the SD 18-01 series. TSA also plans to add additional options for airport operators based on technology solutions not currently captured in the PNA. TSA will keep the approximately 30 comments already submitted on the PNA and will review the comments when the revised PNA is likely reissued later this year for notice and comment.
   
  TSA Occupational Safety and Health – Narcan Availability
   
  TSA Director for Occupational Safety and Health Andrew Bowie discussed the public availability of naloxone hydrochloride, best known as Narcan, at airport facilities. Narcan can help prevent opioid overdoses, which are considered a public health issue. Federal policy requires Narcan availability at federal facilities. This poses a challenge for TSA, since airports are not federal facilities. As a result, TSA is encouraging FSDs to reach out to airports that do not already have the capability to encourage airports to place or make Narcan publicly available, like AEDs. TSA reported that several airports already have this capability and listed airports of all sizes that have publicly available Narcan (anecdotally based on an internet search).
   
  Enrollment Services and Vetting Programs Update
   
  Rap Back Update: When an applicant is not physically capable of placing their fingers on the fingerprint collection device due to a physical deformity or amputation of some or all fingers, it is not possible to establish a Rap Back subscription because the FBI’s Rap Back service is based on retaining acceptable quality fingerprints. In these cases, airports must request a Manual Name Check (MNC).
   
  As documented in Appendix E of the Rap Back User Guide (RBUG), airport operators can request an MNC through FPRD if the FBI returns two L0008 messages that state, “the fingerprint quality is too low, and candidates were found based on the biographic information submitted.”
   
  The RBUG also outlines an alternative to the submission of fingerprint images. A name based CHRC check can be manually requested if an individual is permanently incapable of physically providing legible fingerprint images due to amputation, illness, or some injury affecting their hands or fingers. This manual process can be initiated through an email to TSA with a password encrypted attachment that includes specific applicant personally identifiable information as described in the RBUG. However, this procedure will not create a case record in FPRD. The airport will then have to maintain a manual record in the applicant’s file to show that the MNC has been submitted and acknowledged by the FBI and do this once every two years.
   
  Finally, in the case of a double amputee, or an individual that cannot place fingers on the fingerprint collection device due to a physical deformity, airports should submit an email to TSA with an encrypted attachment as described in the RBUG Appendix F. There is no requirement to ask the applicant to try and use the fingerprint collection device to capture a fingerprint.
   
  TSA continues to receive questions from airport and aircraft operators regarding CHRC certification letters from aircraft operators. These certifications must include the subscription date (as outlined in AOSSP Section 20.6 and 16.6 of the FACAOSSP). Airport operators should note that any enrollment date on those certifications is likely in the past which is acceptable. There is no requirement to have an updated enrollment date, as the certification is a one-time requirement.
   
  Security Threat Assessment (STA) Update: STA processing is taking between 15 and 30 days. TSA is experiencing increased volume during what they refer to as the summer surge for applications. On the call, TSA provided the following reminders to facilitate STA processing:
   
  When possible, TSA wants the naming convention for the STA to match what is on the List A document (such as a U.S. Passport) if presented. If there are discrepancies between identity documents presented, TSA wants each different naming convention and will send data corrections for each different convention.
   
  If TSA returns that an applicant has an alias/AKA, please enter the alias/aka exactly as TSA directs. If the requested change is not made, TSA cannot adjudicate the case.
   
  For applicants with Permanent Resident Cards (PRC), the Place of Birth (Country) cannot be U.S. The PRC will list the Country of Birth. Please refer to TSA’s STA Best Practice Guide or send questions to your Designated Aviation Channeler (DAC) or the Aviation Workers Inbox.
   
  TSA will occasionally communicate data corrections directly to airport operators. When TSA Enrollment Services and Vetting Programs do this, they include local TSA Compliance in the correspondence. Case data correction emails between airports and TSA are normal and generally highlight that the case(s) requiring notice may require identification documents or that data needs to be added or corrected. Examples include providing changes to alias (AKA) name, Alien Registration Number (ARN), or Social Security Number (SSN). These notifications are not an indicator of a compliance violation or communication of such, even though TSA includes local TSA Compliance on the correspondence.
   
  TSA reminded airports to ensure Trusted Agents are double checking the identification documents that are being submitted. Validating the identification documents during submission can save valuable time and prevent STAs from being returned due to incorrect information.
   
  TSA continues to receive questions from airport operators about Birth Certificate/Birth Abstract and other types of documents with the “Birth” naming convention. The below are general guidelines for document requirements for “Birth Certificates/Birth Certification Cards/Certified Abstracts of Birth”:
   
  1.    Issued by a city, county/state.
  2.    Lists FULL names of individual and parents.
  3.    Has a signature from a city/country/state registrar/Government Official?
  4.    Contains an official seal.
   
  As promised on the call, TSA provided AAAE the following additional and more detailed information regarding Birth Certificates/Birth Abstracts/Certificates of Live Birth:
   
  •    Issued by the city, county, or state of birth.
  •    Lists applicant’s full name, date of birth, and place of birth.
  •    Lists parent(s)’ full names:
  • Full name means first and last name/surname.
  • A valid birth record that contains only the mother’s name (first and last) is acceptable. The maiden name of the mother is acceptable if the first and last name are present.
  • A valid birth record that contains only a field(s) for the mother’s full name is acceptable.
  • If the father’s information is present, any of the following is acceptable:
    • Father’s first and last name/surname
    • Father’s surname only
    • Father’s surname plus first initial only
    • Father’s initials only
  • Has the signature of the city, county, or state registrar/government official. This includes but is not limited to:
    • Registrar
    • County Clerk
    • Recorder
    • County Health Officer
      • If a registrar’s signature is only partially viewable, but is recognizable as a signature, adjudicators can accept the document if it meets all other requirements.
    • Has the date filed with registrar's office.
    • Adjudicators will proceed with the case, provided that the U.S. birth document:
      • Meets all other requirements.
      • Is accompanied by other required documents (acceptable photo ID, relevant name-change documents).
    • Delayed Birth Certificates/Delayed Records of Birth (which by definition are issued more than one year after birth) remain acceptable if they a) meet the other birth documentation requirements and b) list the documentary evidence used to create the record).
      • (Generally, states require supporting evidence with name and DOB to create a delayed certificate. The evidence varies by state, but examples include military discharge records, signed religious records, school enrollment/transcripts, selective service records, SSA records, Census Bureau records, etc.)
    • If a delayed birth record was filed/created more than one year after birth and does not cite or is not accompanied by documentary evidence, it is unacceptable.
    • Has the seal of issuing authority (seals may appear, but are not required to be printed, as an embossed or raised overt security feature)
      • “Seal” means seal, logo, or watermark of the issuing authority. It does not need to be a raised/embossed seal.
      • If a seal is only partially viewable, but is recognizable as a seal, adjudicators can accept the document if it meets all other requirements.

 
Safe Skies Update
 
Jessica Grizzle provided the following update on behalf of Safe Skies.
 
PARAS 0060 Strategies for Developing an Aviation Worker Screening Program is available on the Safe Skies website. Example SOPs and Post Orders are also available to ASCs upon request to jessica.grizzle@sskies.org.
 
Safe Skies is currently accepting Problem Statements for FY 2025 PARAS projects. Problem Statements form the basis of all PARAS projects and are descriptions of security problems or questions for which airports need an answer. A short description of potential topics can be submitted here. Please contact Jessica Grizzle at jessica.grizzle@sskies.org or 865-740-3145 for full submission guidance. The submission deadline is Monday, September 9.
 
The research team for PARAS 0057 Airport Credentialing Office Planning and Design is seeking information from Category II airports that have built new credentialing offices or remodeled existing offices in the last several years. Please contact Jessica.grizzle@sskies.org for more information regarding research participation.
 
The following ASSIST reports are available in the Safe Skies conference on HSIN or by request to anna.hamilton@sskies.org. The ASSIST reports include two technologies evaluated specifically for aviation worker screening. Safe Skies ASSIST now has a total of 6 reports related to aviation worker screening technology solutions.  
 
SSDA—24-025 Wicket Facial Authentication Biometric Access Control System – Punta Gorda Airport
SSDA—24-019 NineID® XS1D Facial Recognition Access Control System – Hilton Head Island Airport
SSDA—24-020 Alocity F3D100 Facial Recognition Access Control System – Hilton Head Island Airport
SSDA—24-021 Liberty Defense HEXWAVE™ Aviation Worker Screening System – Oakland International Airport
SSDA—24-022 Xtract One SmartGateway™ Aviation Worker Screening System – Oakland International Airport
 
FAA Aviation Safety Inspectors
 
Representatives from the Federal Aviation Administration (FAA) discussed the need for uninterrupted access for Aviation Safety Inspectors (ASIs), which includes the approximately 3,800 flight standards ASIs and approximately 100 HAZMAT ASIs (HMASIs) across the country. TSA and FAA entered into a Memorandum of Understanding (MOU) outlining roles and responsibilities for ensuring uninterrupted access for ASIs after recent incidents caused delays or denied access for ASIs conducting their critical safety mission. TSA cannot share the MOU with airports or airport associations.
 
FAA is reaching out to FSDs and Deputy FSDs at approximately 35 airports to discuss expedited access for ASIs, review unescorted access procedures for ASIs, and recognition of the ASI credential Form 110A. ASIs are not exempt from aviation worker screening requirements, per the MOU, but may be offered front-of-the-line accommodations. AAAE encouraged FAA to also include airport operators in the conversation and outreach since FAA indicated they were including airports on a case-by-case basis.
 
Next TSA Conference Call
 
The next monthly TSA conference call for airport stakeholders is scheduled for Thursday, September 5 at 1:00 p.m. ET. TSA plans to invite representatives from the Department of Justice (DOJ) Civil Liberties to discuss documentation requirements and procedures for foreign nationals and refugees.