There is a big change coming for export air cargo. From 9 April 2009 cargo loaded onto an international passenger aircraft for a scheduled flight must have a security declaration (minor exceptions exist).
The major associations whose members will be affected are the Board of Airline Representatives (BARNZ) and the Customs Brokers and Freight Forwarders Federation (CBAFF), and they have been working with the Civil Aviation Authority (CAA) and cargo terminal operators (CTOs) to assist in implementing this new regime.
A security declaration can only be issued by a regulated air cargo agent (RACA) or by a CTO. Airlines and CTOs are very clear that they want the maximum amount of cargo arriving at CTOs’ premises at the airport to be accompanied by a security declaration from a RACA.
Cargo arriving without a security declaration will need to be screened at the CTO’s premises. This will take time, and will cost. Delays may occur and flights missed. So while CTOs are moving to provide some screening capability, they want the amount of screening that has to be done at the airport to be minimised, otherwise close-off times will be significantly affected.
The majority of airlines have advised forwarders that from 9 April they will only accept cargo from RACAs, and so the pressure has come on forwarders to become RACAs.
Becoming a RACA
Civil Aviation Rule 109 spells out what a forwarder needs to do to become a RACA. In short, the application to be registered is made to the CAA and an exposition is required which must provide information about the forwarder’s organisation, key personnel and the procedures that will be put into place for:
- Assessing and maintaining the competence of personnel who are involved in handling air cargo.
- Receiving cargo from known customers and checking documents.
- Receiving cargo from unknown customers and applying controls or processing.
- Storing cargo that has been subject to security controls.
- Issuing declarations of security.
- Delivering cargo/mail to a CTO and ensuring non-tampering provisions are in place for the road transport link.
While it is not essential to have screening capability to become a RACA, it appears that for the larger RACAs it will be beneficial to have such a capability.
Known vs unknown customers
The new regime is designed to operate through RACAs having a register of known customers. The cargo from the known customers to the RACA is to be accompanied by a statement of content, and provided it has been transported in a tamper-evident manner that meets the requirements of the rule, it can be issued with a security declaration by the RACA and sent on to the CTO.
Cargo received by a RACA which is not from a known customer needs to be screened if it is to be sent to the CTO with a security declaration. If it is being sent to the CTO without a security declaration, it doesn’t have to been screened, but will be subject to screening at the CTO, with costs and longer lead times as well as the possibility of delays.
An onerous process
Already several of the airlines have advised industry that they will only accept cargo arriving from a RACA with a security declaration. Consequently it is not surprising that the race is on for forwarders to become RACAs, and many are finding the paperwork and requirements quite onerous.
This new supply chain security regime will be a major step in improving the security and safety of aircraft passengers, crew and air cargo. It will bring New Zealand into line with other developed nations, and will prepare us for future steps which appear to be increasingly likely, including the screening of all cargo before it is loaded onto an aircraft.
Stewart Milne retired as the
executive director of BARNZ in 2008,
a position he held for 10 years |
