IAC Air Cargo Security Training FAQs

IAC (Air Forwarder) Security Responsibilities

1. Who establishes and enforces air cargo security responsibilities?
   In the U.S., the Transportation Security Administration ("TSA") does this pursuant to a combination of published regulations (49 CFR and unpublished (need-to-know) Security Directives and Information Circulars.

2. What security responsibilities does an IAC have based on published regulations?
   Among other things, an IAC must:
   1. Adopt and implement a TSA-approved air cargo security program (refer to 49 CFR 1548.5).
   2. Assure that its employees and agents (e.g., truckers) carry out the requirements of its security program and otherwise comply with TSA air cargo security regulations when handling cargo that will subsequently be tendered to a commercial air carrier. (Refer to 49 CFR 1548.5(c).)
   3. Protect what the TSA has defined as Sensitive Security Information ("SSI") from disclosure to individuals who do not have a need-to-know such information in order to perform security-related job responsibilities. (refer to 49 CFR 1520).
   4. Assure that both its employees' and agents' (sub-contracted service providers, also known as authorized representatives ("ARs")) personnel have each passed an TSA Security Threat Assessment ("STA") or have another TSA-approved security credential before being given unescorted access to cargo that such person knows or has reason to believe will subsequently be tendered to a commercial airline (refer to 49 CFR 1548.15).
   5. Assure that both its employees and agents (AR personnel) have been trained in their particular security responsibilities so they will be able to properly perform such responsibilities (refer to 49 CFR 1548.11).  This training must be repeated annually.  The TSA has clarified that a person, such as a truck driver, who performs services for multiple IACs need receive this training only once per year from one IAC.

Trucker Air Cargo Security Responsibilities—STA and Training

1. As a trucker, why do I have to comply with TSA security requirements?
   The directly-regulated parties under TSA air cargo security regulations are air carriers (airlines), forwarders ( air carriers) and airport operators. As a trucker, you fall under TSA security regulations when you are hired by one of these regulated parties as an (sub-contractor) to transport or otherwise handle air cargo. In particular, when a forwarder hires you, the requirement for a Security Threat Assessment ("STA") and training become applicable.  Also, the requirement not to disclose Sensitive Security Information (SSI) applies to every person subject to U.S law, not just to parties the TSA directly regulates (refer to 49 CFR 1520).
2. How do truck drivers and other trucking company personnel with unescorted access to cargo apply for a Security Threat Assessment ("STA")?
   This must be done through an IAC (air forwarder).  Each driver must complete and sign a detailed paper applicable form. A trucking company needs to work with an IAC to obtain this form and subsequently submit the information to the TSA for processing.
   Note: An STA is not required if a person already has a Customs FAST card, airport SIDA badge, TWIC or HAZMAT endorsement to a CDL issued after June 2005.
3. Our trucking company provides service to a number of different IACs.  How do I communicate to each IAC that the particular driver(s) and other personnel handling their air cargo has a required security credential?
   This is a challenge given the many-to-many relationships between IACs and trucking companies, and further many-to-many relationships that sometimes occur between trucking companies and owner-operator drivers.  The TSA provides IAC managers with the ability to check STA status against an STA number, but there is currently no provision for checking other security credentials.  Because of driver personnel turn-over and new IAC relationships which arise without prior arrangement when a pick-up is needed, static lists of driver information are not an efficient way to provide this information.
   Because of this many-to-many need for IACs to instantly access driver security credential and training status, GISTnet now offers an efficient on-line system ("IAC-AR-IS") for truckers to make this information available to IACs—See Information Sharing System: Why, how & Other FAQs.
4. What does this training for drivers and other sub-contracted personnel consist of and how long does it take?
   The subject matter to be trained is specified in 49 CFR 1548.11 and further specified in non-published TSA documents.   As is typically the case, the training consists of a presentation of the information to be learned by an instructor or other means, followed by an assessment which a person must pass to complete the training.  The required training and assessment for a truck driver will typically require 1-3 hours, depending on the method of delivery and a persons existing understanding of the subject matter.  Annual refresher training will typically take less time.
5. As a trucking company, how can we obtain this training for our drivers and other personnel who have air cargo security responsibilities?
   In general, this training must also be obtained or arranged for through an IAC (air forwarder). There are several different methods of training delivery:
   1. An IAC can directly conduct training for its truckers and other agents.
   2. An IAC can provide needed training and assessment materials to a trucking company or other agent, from which training and assessment can be conducted by such company with results reported back to the IAC.
   3. An IAC can authorize a third-party training provider, acting on its behalf as agent ("authorized representative" for training), to train and assess your company personnel.  This is the arrangement under which GISTnet provides IAC air cargo security training to both IACs and trucking company personnel.
6. How does GISTnet go about training trucking company personnel?
   Gistnet training and assessment is delivered via the Internet using a web browser, and is taken whenever and wherever convenient for the person assigned to the training.  We use a self-paced "no fault" learning method in which a person is presented with needed information in the form of a series of frames with text and graphics, and even audio narration for learners who prefer to hear rather than read. Every few frames there are questions to assure understanding, with immediate instructive feedback whenever an incorrect response is selected. This way, a person is prepared to pass the assessment on the first take.
   And the system keeps a detailed record of the assessment result (date/time stamp and how each question was answered) should the TSA or an IAC ever wish to audit training records.
   An IAC (any IAC) must authorize us to make our security training available to a trucking company or other agent through a simple on-line process.   We will then work with a designated person at the company to be trained to assign their personnel to the training.   Our system provides progress tracking and reminder notifications to help assure assigned training is promptly completed, and further provides reminders when annual refresher training is due for each person.  Upon completion of the training, a paper certificate may be printed out for presentation to the trained person. If a trucking company is also using the GISTnet information sharing system, training completions automatically post to this system as well.  
7. What does GISTnet charge for training trucking company personnel?
   Driver/agent training is currently $15 per person, with volume purchase discounts beginning at 10 uses of the training. Please see our security training catalog for more information.
8. If we can get the needed training and assessment materials from an IAC without charge, why should our company pay GISTnet to provide the training?
   Training materials alone do not constitute training, and training is never "free." When training is conducted by an instructor, there is the need for a qualified person, time to prepare and conduct the training and assessment, and time to review assessment results with each person trained. By automating the training, all these steps, plus the needed record-keeping, are combined into a process that is:
   • more convenient (no scheduling needed),
   • lower cost (no instructor needed,
   • less time away from work, and, for many people,
   • more effective (more interactive, more feedback).
   • Training delivered using GISTnet also saves considerable administration time because it:
     • automates record keeping,
     • provides "at a glance" training status of all personnel, including detailed, question-by-question assessment record for each person,
     • makes assignment of refreser training a breeze---and an even bigger bargain at an automatic 50% fee discount,
     • facilitates information sharing between agents ( trucking companies, etc.) and any number of IACs,
     • For owner-operators providing service to more than one trucking company, its also provides visibility to all employers of a driver's training when delivered through the system and/or posted to the GISTnet information sharing system.
9. Does GISTnet offer this security training in Spanish?
   We expect to offer a Spanish (bi-lingual) version by first-half, 2008.
10. Our trucking company provides service to a number of different IACs.  How do I communicate to each IAC that the particular driver(s) and other personnel handling air cargo have required training and an approved security credential?
    This is a challenge given the many-to-many relationships between IACs and trucking companies, and further many-to-many relationships that sometimes occur between trucking companies and owner-operator drivers.  Because of driver personnel turn-over and new IAC relationships which arise without prior arrangement when a pick-up is needed, static lists of driver information are not an efficient way to provide this information.
    Because of this many-to-many need for IACs to instantly access driver security credential and training status, GISTnet now offers an efficient on-line system for truckers to make this information available to IACs—See Information Sharing System: Why, how & Other FAQs.