Preparing A Transport Security Program
Preparing A Transport Security Program
Preparing A Transport Security Program
Disclaimer: This document is designed to provide general guidance to airport operators, operating
under arrangements according to the Aviation Transport Security Act 2004 (the ATSA) and Aviation
Transport Security Regulations 2005 (the ATSR) in developing Transport Security Programs (TSPs) for
submission to the Secretary of the Department of Infrastructure, Transport, Regional Development and
Local Government (The Department) for approval.
This guide should not be used by airport operators as a substitute for obtaining independent
professional advice (including legal advice) regarding their TSP and the TSP’s compliance with the
requirements of the ATSA and the ATSR. This document is subject to change. the Department is not
responsible for the consequence of the use of any outdated version of this guide.
Table of Contents
PREFACE ...............................................................................................................................................3
ABBREVIATIONS.................................................................................................................................3
BACKGROUND.....................................................................................................................................3
PREFACE
This guide has been developed for use in the preparation of TSPs. It is designed to
provide general guidance for airport operators to meet their TSP obligations under the
Aviation Transport Security Act 2004 (ATSA) and Aviation Transport Security
Regulations 2005 (ATSR).
Division 4 of Part 2 of the ATSA sets out the general requirements for TSPs for
aviation industry participants (AIPs). Section 16 of the ATSA describes the required
content of TSPs and section 17 describes the required form of TSPs. Additional
content and form requirements which apply to airport operators are outlined in Part 2
of the ATSR, especially Division 2.2 – Operators of security controlled airports.
ABBREVIATIONS
BACKGROUND
The ATSA and ATSR came into force on 10 March 2005, replacing Parts 3 and 3A of
the ANA, and Part 7 of the Air Navigation Regulations 1947. The ATSA established
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Guidance Paper: Preparing A Transport Security Program
The changes in the law strengthened Australian aviation transport security systems
and enabled a broader and more inclusive approach to aviation security. The ATSA
and ATSR emphasise the need for AIPs to demonstrate a fuller awareness of their
general responsibility to contribute to the maintenance of aviation security: ATSA
s.16(1)(a). The ANA imposed a large number of prescriptive measures, while the
ATSA and ATSR focus more on outcomes.
An Aviation Industry Participant’s TSP should detail measures and procedures for
aviation security based on an AIP’s assessment of its own risk environment.
Note: As a result of amendments to the ATSR, airside facility operators are no longer required to have a TSP.
ATSA s.16(1) states that a TSP for an AIP (which includes an airport operator) must
demonstrate that the participant:
• is aware of the participant’s general responsibility to contribute to the
maintenance of aviation security; and
• has developed an integrated, responsible and proactive approach to managing
aviation security; and
• is aware of, and has the capacity to meet, the specific obligations imposed on
the participant under the ATSA and the ATSR; and
• has taken into account relevant features of the participant’s operation in
developing activities and strategies for managing aviation security.
ATSA s.16(2) states that a TSP for an AIP must set out the following:
• how the participant will manage and co-ordinate aviation security activities
within the participant’s operation (you should consider what communication
and control procedures are in place; whether the roles and specific tasks of
AIP management staff are defined clearly; whether the communication and
control arrangements appear likely to enhance security measures; and
whether there is sufficiently broad representation on relevant Airport Security
Committees (ASCs)); and
• how the participant will co-ordinate the management of aviation security with
other parties (including Commonwealth agencies) who have responsibilities
for, or are connected with, aviation (consider whether the Terms of Reference
for the ASC are described within the TSP; other government agencies are
involved with security; the duties of these agencies are clearly outlined in the
TSP; which management positions are represented on the ASC; and which
position has overall responsibility for management of the TSP);
• the technology, equipment and procedures to be used by the participant to
maintain aviation security (have standard operating procedures been
formulated and implemented?);
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• how the participant will respond to aviation security incidents (measures may
include communication and control, implementation of security measures,
public safety and continuity of essential operations. Are the response roles of
other agencies clearly described?);
• the practices and procedures to be used by the participant to protect security
compliance information (you should consider document (paper and electronic)
control/protection, identification and classification, access control, email
classifications, and document distribution and destruction);
• the other AIPs who are covered by, or operating under, the program (are there
effective communication and control procedures to ensure all AIPs covered
under the TSP can implement their responsibilities under the TSP?);
• the consultation that was undertaken with other AIPs who are covered by, or
operating under, the program.
Further, ATSA s.17 provides that the TSP must be in writing and prepared in
accordance with any requirements set out in the ATSR. When reviewing a TSP from
a security controlled airport for approval, the Department will be assessing whether,
overall, the TSP satisfies the requirements of ATSA s.16(1) and (2) and the ATSR,
and that there is sufficient evidence that the participant has undertaken the
informative, consultative, planning and investigatory processes inherent in those
requirements. Under the ATSA, if the Secretary is not satisfied that the TSP
adequately addresses the relevant requirements, the Secretary must refuse to approve
the TSP (s.19(2)).
Although participants are required to comply with all sections of the ATSA and
ATSR that apply to them, their TSPs need only contain the information that the
ATSA and the ATSR require to be set out in a TSP. TSPs should not contain
measures and procedures that are inconsistent with the ATSA or ATSR.
The body of the TSP is not intended to be an operations manual describing how to do
things in minute detail, but rather an outline of an AIP’s security risk environment,
and what things (ie. measures and procedures) they will do to deter and detect
unlawful interference with aviation. However, TSPs submitted to the Department
often do not contain a level of information likely to be sufficient for the Secretary to
be satisfied that the AIP meets all that is required under the ATSA, particularly ATSA
s. 16. This is particularly the case where reference has been made to other documents,
but those documents are not provided with the TSP. Such issues might be overcome
through the attachments of the relevant document, or alternatively through greater
detail in the TSP, without necessarily attaching the separate document (see ‘TSP
Accompanying Documents’ below).
The TSP must meet the form and content requirements as stipulated by the ATSA and
ATSR. For example, where a Regulation says the TSP ‘must set out’ certain
measures and procedures, the TSP must state or explain its measures and procedures
systematically within the body of the TSP. The participant may wish to provide more
detailed measures and procedures in an accompanying document, as additional
information, but must still meet the basic requirements as set out in the Regulation.
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• Whether you have individually tailored the TSP to take account of your
airport’s specific local risks and the scope of your operations, with security
measures and procedures reflecting risk mitigation strategies identified from
your assessment of your security risk; and
• Whether the TSP meets the content and form requirements of the ATSA and
ATSR.
The Department recognises that each Regulation relating to TSPs may be open to
interpretation in the context of the details of each participant’s operation. It also
recognises that the way in which airport operators will meet their legislative
obligations with respect to TSPs will be relative to their unique operations.
General Guidance
• TSPs should always use correct terminology. It should be internally consistent
throughout the TSP and between maps and text; terminology should be
consistent with the legislation.
• Terms like ‘security restricted zone’, ‘security cleared zone’, ‘non-airside’ and
‘non-landside’ should not be used. Also, the terminology of former legislation
should be avoided.
• If sites such as the Air Traffic Control Tower and the fuel storage facility are
acknowledged as landside security zones, the TSP must outline the
mechanisms for consultation with the owners of those facilities.
• Use of the correct tense is important. The TSP should be in the present tense,
describing the measures that are currently in place, not near future proposals
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• TSPs should not state timeframes that contradict those which are set out in
relevant legislation.
• TSPs should focus on the AIP’s own responsibilities, and not cite other AIPs
as having responsibility for certain measures or procedures.
• If referring to security measures carried out by other AIPs with whom you
interact, you should be aware that such references do not bind that other
participant; they should be the subject of consultation and are not a substitute
for the obligations of the TSP holder under the ATSA and ATSR.
• As highlighted below under ‘TSP Objective’, the TSP should reflect the
security risk assessment, and vice versa. The body of the TSP could bring to
light an issue that should be included in the risk assessment.
• If the Regulations call for ‘measures’ and ‘procedures’, then the TSP must
spell out nothing less than measures and procedures. If the Regulations call
for measures to ‘deter and detect’, then details of the measures for deterrence
and detection must be set out in the TSP.
• Where AIPs have additional plans (such as ASIC plans, CBS plans, airport
emergency plans etc.), which comprehensively address the content and form
requirements of specific regulations, the AIP may attach such plans to the
TSP, as accompanying documents, to meet those regulatory requirements.
However, AIPs should be aware that if additional plans are attached they will
form part of the TSP. Please refer to the section on “TSP Accompanying
Documents” for more details.
• The TSP must reflect current regulatory reality, and not an anticipated reality.
AIPs must complete their TSPs by using the current ATSA and ATSR found
at http://www.comlaw.gov.au Industry will be advised of any regulatory
changes.
• Where the TSP discusses incident reporting, the information must be clear
(citing to whom reporting will be made), and cannot contradict the Notice
About How Incident Reports are to be Made.
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• If the airport operator has satisfied Reg. 2.16(2), and would like to implement
additional measures as part of their TSP, the airport operator should note that
it will be held accountable for all of the additional measures included in their
TSPs. If the airport operator fails to meet those additional measures identified
in the implementation timetable, the airport operator must have a reasonable
excuse to avoid enforcement action.
• If the airport operator has not satisfied Reg. 2.16(2), the airport operator is to
identify when specific measures and procedures would be implemented. If
approval of the TSP is given prior to that time, the Department will not
enforce the provisions of the TSP until after the deadlines specified in the
implementation timetable.
When the Department reviews a TSP, the Department will be considering and
assessing whether, overall, the TSP satisfies the requirements of ATSA ss.16 and 17,
and the relevant provisions of the ATSR. Under ATSA s.19, if the Secretary is not
satisfied that the TSP adequately addresses the relevant requirements, the Secretary
must refuse to approve the TSP. Where this is the case, the Secretary must also give
the participant a written notice of the refusal.
Finally, where AIPs have recruited consultants to develop content for TSPs, you
should be aware that the Department assumes that AIPs who submit TSPs for
assessment have sufficient intellectual property rights to do so.
The Department takes the view that there is a difference in meaning between those
Regulations which provide that the TSP must be ‘accompanied’ by a certain
document [Regs. 2.13(4), 2.13(9), 2.19], and the Regulations which provide that ‘the
TSP must set out, in an accompanying document, [certain information] …’ [Regs.
2.10, 2.11(3), 2.21].
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• Where the Regulations provide that ‘the TSP must set out, in an accompanying
document, [certain information]’ the information provided, although in a
separate document, is to be treated as constituting part of the TSP. This
document is subject to the same formal variation and revision requirements as
the TSP.
The practical effect of this distinction is that AIPs may need to consider whether the
documentary material which has been provided with their TSP lodged for assessment
is material that is required by the Regulations to form part of the TSP or is instead
material which is separate to the TSP.
While the Department recognises that at this point in time it is not necessary for AIPs
to have supplied all of the accompanying material not forming part of the TSP to the
Department, the Department is aware that in a number of cases AIPs have in fact
done so or intend to do so. TSP assessors have therefore been requested to consider
whether any material submitted in addition or as a supplement to the TSP may in fact
satisfy the requirements set out in those Regulations requiring that the TSP be
‘accompanied by’ a document setting out prescribed information.
Assessors have also been requested to consider any material that has been submitted
to address those Regulations requiring that certain information be set out in an
‘accompanying document’. In circumstances where such information has not been
provided, this will be relevant to the consideration of whether the TSP can, as a
matter of fact, satisfy the requirements of s.16 of the ATSA.
Finally, the Department notes that, in some circumstances, an AIP may have chosen
to submit certain information by way of a separate document, rather than in the body
of the TSP. The Department wishes to advise AIPs that this information will
nevertheless form part of the body of the TSP for assessment purposes if it is
information that must be ‘set out’ in the body of the TSP, in accordance with the
Regulations. Any such documents, although they may be physically separate from the
TSP, will also be subject to the TSP variation and revision requirements set out in the
ATSA.
CONTENT OF A TSP
Scope of TSP
The TSP must cover any aviation security-related activity on the airport that is not
covered by the TSP of any other AIP (Reg. 2.09).
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• are aware of, and have the capacity to meet, the specific obligations imposed
on the AIP under the ATSA; and
Also, under Reg. 2.05, a TSP must contain a ‘Statement of Undertaking’, signed by
the participant. When the participant signs, the participant is stating that the
participant believes that the TSP gives effect to the above obligations. This is not a
statement that the participant will implement a TSP. An appropriate person should
sign the Statement, and include it in the TSP.
You should ensure that your security risk assessment is not outdated, such that there
are changes in circumstances that may change your security measures and procedures.
TSP Objective
The TSP must contain an outline of the objectives of the TSP and must be
accompanied by a document which contains a local security risk context statement
(this document may be attached as an appendix (Reg. 2.10(a))).
The local risk context statement is to include a statement outlining your local security
risk context, including consideration of location, seasonal and operational factors.
Mention could be made of previous threats, incidents, criminal activity or vandalism,
relating to international, domestic, cargo and/or general aviation. If you feel that no
seasonal factors have security implications for your operations, a brief note to that
effect should suffice.
• a list of general threats and generic security risk events to people, assets,
infrastructure and operations; and
The TSP should reflect the security risk assessment, and vice versa. If the security
risk assessment reveals a significant body of threat affecting the AIP, the TSP should
spell out measures and procedures appropriate to counter that threat. Similarly, a
small regional AIP, situated far from large population centres, may have a much
smaller risk environment. The measures and procedures cited in its TSP should also
mirror that environment. The TSP should always specify satisfactory mitigating
strategies to reflect the AIP’s current security risk assessment.
AIPs are not required by legislation to complete a full security risk assessment, nor to
attach a risk assessment plan to their TSP. The Regulations only require participants
to set out, by way of an accompanying document ‘a statement outlining the local
security risk context of the [AIP] including consideration of its location and seasonal
and operational factors’.
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An airport operator’s local security risk context statement should be substantial, and
should provide a benchmark for the level of security and the kinds of security
measures and procedures proposed. The information set out in the accompanying
document (which includes the local security risk context statement) should be clear
and thorough, however, probably not at the level of detail required in a full risk
assessment plan.
It may be appropriate for an operator to adapt the executive summary of its risk
assessment plan and utilise it for the local security risk context statement.
Security Management
(Security Contact Officer (SCO), staff, other agencies/contractors, training,
awareness)
Under Reg. 2.11(1), TSPs for airport operators must set out the procedures for
managing security at the airport, including:
c) the roles and responsibilities of other staff who have been assigned
security duties and responsibilities; and
TSPs must include a description of the roles and responsibilities of SCOs, security
staff, contractors and responding agencies. An SCO should be the first point of
contact for security matters. The roles and responsibilities of the SCO should include:
• undertaking liaison with other AIPs and responding agencies (eg, Police, Fire
Brigade, Emergency Services etc) on aviation security matters.
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TSPs must include a description of other persons (other than the SCO and security
staff) who have been assigned security duties and responsibilities (Reg 2.22(2)).
Employees should be specified by position, and not by their names. Contractors’
positions must be included. The duties and responsibilities of such employees,
contractors and other persons should be described, in addition to the knowledge, skills
and experience required for the security-related aspects of their positions and the
training or qualifications that satisfy the requirements of the position (Reg. 2.22(3)).
TSPs must also include a description of the role and responsibilities of other
Commonwealth, State or Territory agencies and local authorities that have security
duties at the airport (eg. local councils, State or Territory Police, government agencies
or statutory authorities). The operator should outline how these duties relate to the
TSP, and demonstrate the processes in place to call on these authorities during a
heightened security alert (Reg.2.11(1)(d)).
TSPs should contain descriptions of the training that an SCO would be required to
undertake, as well as criteria for their selection (Reg. 2.22(1)). Any aviation security
training programs provided to others with security roles should be described.
To maintain a robust security culture in the aviation industry, AIPs should conduct
security awareness training to meet the requirements of Regs. 2.21(2)(e) and 2.22(4),
which highlight the importance of alertness to security threats, and responsibility to
report incidents. This security awareness training should be demonstrated in the TSP:
the training course content is not required, an outline of the type of training will
suffice.
Consultation
TSPs need to reflect an integrated, coordinated and proactive approach to aviation
security. Consultation between participants is a significant practical step in ensuring
this outcome.
Inclusion with TSPs of evidence that such consultation has occurred will provide OTS
with an assurance that participants have consulted with other relevant AIPs in relation
to those parts of the TSP that affect them. This does not have to be advice of
agreement between the parties, but is illustrative of appropriate sharing of information
between participants.
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Security of Information
ATSA s.16(2)(e) requires that a TSP must set out the practices and procedures to be
used by the AIP to protect security compliance information. In addition, Reg. 2.11(4)
requires that a TSP must set out measures to ensure that the TSP and other security
information are protected against unauthorised access, amendment and disclosure.
The Department suggests that together with measures and procedures for protecting
the TSP from unauthorised access (eg. safe storage of hard and electronic copies etc.),
airport operators should describe how relevant people who have access to the airport
are made aware of their security obligations. It should be noted that a person can be
prosecuted for breaching Reg. 2.06. In addition, airport operators need to consider a
range of circumstances when information might, in fact, need to be shared. This
could include external auditors scrutinising the material.
Operators should outline procedures for controlling and protecting the TSP and other
security information, including compliance information. Such measures could
include:
• Safe storage of the TSP, for both hard and electronic copies of the document,
such as computer security policies;
• Reference to the security classification of the document;
• Who is authorised to access the information in the security risk assessment
and TSP;
• Who is authorised to issue copies of the TSP;
• Who is authorised to amend the TSP;
• Measures for returning and destroying outdated TSP documentation (both
hard and electronic copies); and
• Measures to record the issue of copies of the TSP (both hard and electronic
copies).
An example format for recording the issue of TSP copies is provided below.
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Procedures
A TSP must set out quality control measures, including a schedule of, and procedures
for, internal security program audits and reviews. This is required under Reg. 2.12.
Recommendation VIII of the Wheeler Review of Airport Security and Policing was
that TSPs have a more frequent system of reporting, ensuring airports regularly
review their own security gaps and weaknesses, and document the measures being
taken to address them. The requirement at Reg. 2.12(1) is adequate for the time
being. However, the Department suggests that airports consider Wheeler
Recommendation VIII when drafting this section of their TSPs.
Audits
An audit is defined in Reg. 2.01(2) as an examination by an AIP of security measures
under their TSP to find out whether the measures have been correctly implemented.
An audit should involve an in-depth examination of all aspects of an AIP’s TSP, to
determine whether they are being implemented continually and to an appropriate
standard.
Information about the AIP’s schedule of security audits may include frequency of the
audits, the types of audits undertaken, and the staff involved. They could be regular
scheduled audits, unscheduled spot audits, internal or external.
The TSP should show that the AIP has taken into account the potential for conflict of
interest if internal auditors are used. It is preferred that audits be conducted by
external, independent persons. However, if this is not possible, a person from within
the organisation may be selected, provided they are not directly responsible for the
implementation of the TSP.
Reviews
A review of an AIP’s TSP is defined in Reg. 2.01(2) as an evaluation by the
participant of security measures or procedures under its TSP to find out whether the
measures and procedures are adequate.
The aim of the review is to assess how effective the current TSP is in meeting the
ATSA’s objectives. Reviews should be undertaken regularly, with clearly defined
procedures and parameters. You should ensure that the TSP includes a procedure for
consultation to be undertaken to ensure security measures and procedures are
adequate and the TSP is being appropriately implemented (Reg. 2.12(1)(c)).
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Guidance Paper: Preparing A Transport Security Program
The AIP’s review procedures should also describe the circumstances that will require
a review of the TSP (eg a change in the security environment), including those
surrounding an occurrence of an aviation security incident (Reg. 2.12(1)(d)). The
review procedures should include adequate consultation with other AIPs, recognising
that security outcomes are reached through the cooperation of all participants.
Operational details
Description of Airport
Under Reg. 2.13(1), in addition to maps showing the airport boundaries and security
zones, the TSP must set out:
c) the types of aircraft operations that operate to and from the airport, including
regular public transport, cargo, general aviation and joint-user facilities and
other significant operations that may require security considerations;
f) a description of the airside and landside operations for which the airport
operator has responsibility;
h) whether access into landside and airside areas and zones and internal security
of such areas and zones is controlled at all times or not (consideration should
be given to mobile or foot patrols. Is the fencing likely to achieve the desired
security outcomes as described within the security risk assessment?); and
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Under Reg. 2.13(2), an airport TSP must identify all AIPs that have a facility at, or are
located within, the airport, and are covered by their TSP or another AIP’s TSP.
Note: This Regulation, in most cases, will no longer be relevant. An example which may still
have relevance is an airline which also operates as a RACA. In most cases, an airport
operator may respond to this requirement with ‘N/A – there are no AIPs that have a facility at,
or are located at the airport that, although required to have a TSP, are covered by the airport
or another operator’s TSP’.
If the airport TSP covers another AIP that is required to have a TSP or be covered by
the airport TSP, the TSP must list the contact details for each such participant. Where
the TSP follows the Department’s “Template for writing a Transport Security
Program (TSP) - Airport Operators” format, this may be included as Appendix E).
Under Reg. 2.13(4), the TSP for an airport operator must be accompanied by a
document that sets out the following:
g) name of the security contact officer and his or her business phone number,
fax number, email address and a 24-hour security contact number.
Reg. 2.13(8) provides that an airport operator’s TSP must require the airport operator
to maintain a system enabling all AIPs with a facility at, or located within, the airport
to be contacted if an aviation security incident occurs. The TSP should outline the
procedures for contacting those AIPs in the event of an aviation security incident. It
is recommended that operators also include procedures for ensuring that relevant
participants can be contacted in a timely manner in case of an aviation security
incident.
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Security Zones
Please note that in relation to airport security zones, airport operators must
ensure that their TSP is not inconsistent with Divisions 3.2, 3.3 and 3.4 of the
ATSR. If your airport is a ‘designated airport’ (an airport that requires
counter-terrorist first response function), your TSP must also not be
inconsistent with Division 3.5 of the ATSR. 1
If a new airside or landside security zone is to be established at the airport, you must,
under Reg. 2.14(1), set out in your TSP:
c) if applicable, the period when, or the circumstances in which, the zone will be
in force; and
Under Reg. 2.14(2), your TSP must also set out security measures and procedures to
monitor and control access to landside and airside security zones, including measures
to detect and deter unauthorised access to these zones.
Any current airside and landside security zones (as laid out in the Notice Establishing
Airside and Landside Security Zones, effective since 10 March 2005), must be
described in terms of Reg. 2.14(1).
You should provide a map clearly showing control of all access points and any airside
or landside security zones within the security controlled airport. Where the TSP
follows the Department’s “Template for writing a Transport Security Program (TSP)
- Airport Operators”, the map may be included as Appendix G to the TSP.
Note: Reg 2.09 provides that your TSP must cover any aviation-security related
activity on the airport that is not covered by the TSP of any other aviation industry
participant. The Department takes the view that it is not appropriate for the same
aviation-security related activity to be covered by two AIPs’ TSPs. For example, it is
appropriate for Air Services Australia’s TSP to deal with security related activities
concerning the air traffic control tower. If Air Services Australia’s TSP deals with
those activities, any conflicting provisions in your TSP dealing with activities
concerning the tower should be removed. Your TSP may need to be varied if it deals
with security-related activities concerning the air traffic control tower. However, any
consultation that has taken place should be indicated in your TSP.
1
Note: the following airports are designated airports - Adelaide Airport, Alice Springs Airport,
Brisbane Airport, Cairns Airport, Canberra Airport, Coolangatta Airport, Darwin Airport, Hobart
Airport, Melbourne Airport, Perth Airport and Sydney Airport.
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Forms of Maps
Under Reg. 2.15, the airport operator’s TSP must include a map which clearly
delineates the airside and landside areas and any airside security zones and landside
security zones for the airport. This map should be attached to the TSP. Where the
TSP follows the Department’s “Template for writing a Transport Security Program
(TSP) - Airport Operators”, the map may be included as Appendix F.
For the purpose of gazetting the boundaries of a security controlled airport (ATSA
s.28), multiple A4-sized maps aggregating to cover the entire boundary of the security
controlled airport (including the airside area) should be provided. The map(s) must
adhere to points a) to f) above. In addition, AIPs may apply 12% greyscale shading to
delineate airside areas. While this is not mandatory, it is recommended by the
Department for the purposes of satisfying Reg. 2.15(e). As the map(s) is for gazettal,
it must not show any security zones.
In addition to the requirement for a map of the security controlled airport for gazettal,
Regs 2.15(2), (3) and (4) require several other maps to be included in the TSP. The
additional maps do not need to be detailed plans. General outlines of areas for clarity
of security responsibilities will suffice (see Reg. 3.02 for types of landside security
zones).
Maps of airside/landside security zones should be of a scale to ensure that zones are
clearly able to be distinguished, including clear illustrations of whether buildings are
within or outside of security zones. For the purpose of providing maps with the TSP
(as required by Reg. 2.15), there are no size restrictions when submitting the TSP
electronically, provided that the boundaries on the electronic version of the maps are
clear.
Maps should always make sense. In the past, some airport operators have submitted
maps that are not clear. Legends in previously submitted maps have depicted airside
as white, while the map itself shows both airside and landside as white. The security
controlled airport boundary on some maps is a challenge for the eye, becoming lost
among terminal buildings and car parks. A hangar that shows as partly airside, partly
landside should be accompanied by an explanation. If not, you should question this.
Following the production of a new map version, any old dates surviving the change
create ambiguity; airport operators should remove them.
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Under Reg. 2.15(2), your TSP must include a map of the location of regular and
isolated aircraft parking positions. This map should be attached to the TSP. Where
the TSP follows the Department’s “Template for writing a Transport Security
Program (TSP) - Airport Operators”, the map may be included as Appendix H.
Isolated parking positions, for example, may be used by aircraft that have been the
subject of unlawful interference. Ideally, the designated isolated parking position
should be a reasonable distance from the passenger terminal and facilities such as fuel
farms. Those assessing your TSP will have these issues in mind.
If a screened air service operates from your airport, Reg. 2.15(3) requires that the TSP
must include a map of the airport terminal(s) showing the location of all screening
points and landside security zones including sterile areas. This map should be attached
to the TSP. Where the TSP follows the Department’s “Template for writing a
Transport Security Program (TSP) - Airport Operators”, the map may be included as
Appendix I.
If a screened air service operates from your airport, Reg. 2.15(4) requires that the TSP
must include a description and map of the apron(s) for the purposes of Reg. 4.02(3).
This map should be attached to the TSP. Where the TSP follows the Department’s
“Template for writing a Transport Security Program (TSP) - Airport Operators”, the
map may be included as Appendix J.
These maps do not need to show detailed plans. General outlines of terminal areas for
clarity of security responsibilities will suffice.
Although the airport operator may have general security responsibility for the entirety
of the security controlled airport, more specific access control and physical security
measures and procedures are the responsibility of the leaseholder if they are required
under the legislation to have a TSP. In the case of airport terminals, the airport
operator may wish to outline, under the physical security and access control section of
their TSP, those parts of airport terminals that are covered by the TSP of another AIP.
The TSP for an airport operator must set out the security measures and procedures to
be used within the airport to control access at the airport, including specific measures
to deter and detect unauthorised access to the airside area, and any airside security
zones and landside security zones. Access control arrangements may include
photographic identification systems for authorised access, vehicle inspection and
entry arrangements, doors and gates, and assets secured by padlocks or coded access
arrangements.
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Guidance Paper: Preparing A Transport Security Program
Under Reg. 2.16(1)(a), the TSP must set out the security measures and procedures to
control access at the airport, and maintain the integrity of access control systems.
These could include, for example:
• computerised systems;
Under Reg. 2.16(1)(b), (c) and (d), the TSP must set out security measures and
procedures to deter and detect unauthorised access into the airside area, and airside
and landside security zones by people, aircraft, vehicles or things.
Under Reg. 2.16(1)(e), the TSP must set out the security measures and procedures to
be applied to unattended aircraft. Although primary responsibility for unattended
aircraft will lie with the aircraft operator, airport operators’ security measures and
procedures must make reference to unattended aircraft. Such measures and
procedures could include training provided to staff so they are aware of the
requirement to report to their SCO or supervisor of any unattended aircraft. Measures
could also include procedures for identifying unattended aircraft, who has
responsibility for this; procedures for reporting to the SCO, the aircraft operator, and
the Department; and procedures for securing an aircraft found to be unattended.
Under Reg. 2.16(1)(f) and (g), your TSP must set out security measures and
procedures to assess, identify and respond to unknown substances; and investigate,
secure and remove unattended or suspect vehicles, aircraft or things, including
baggage and cargo.
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Guidance Paper: Preparing A Transport Security Program
Under Reg. 2.16(1)(f), operators are not required to have staff trained to identify
substances etc through analysis or other scientific means or to physically handle these
items. Rather, it is the intention that operators and their staff are able to determine that
an item is unusual or potentially dangerous. Subsequently, they should know how to
inform and request the response of specialist agencies such as the fire brigade or Law
enforcement authorities and to minimise access to items by other people.
Under Reg. 2.16(1)(h), your TSP must set out security measures and procedures to
ensure the security of passwords, keys and key lists, electronic access cards and other
security privileges.
Under Reg. 2.16(2), your TSP must specify which measures and procedures have
already been implemented, and include a timetable for implementing measures and
procedures not yet implemented. (Where the TSP follows the Department’s “Template
for writing a Transport Security Program (TSP) - Airport Operators”, the timetable
may be attached to the TSP as Appendix K).
Under Reg. 2.17(1), airports with screened air services must set out in their TSP:
b) the names of the screening authorities that will undertake those functions.
If a screened air service does not operate from the airport, the TSP may state ‘N/A –
screening is not required at this airport under ATSA/ATSR’.
Measures and procedures set out in the TSP for screening and clearing of persons and
baggage must include:
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Guidance Paper: Preparing A Transport Security Program
Screening measures and procedures must comply with the applicable standards, as
outlined in the document Methods, Techniques and Equipment to be used for
Screening, which the Secretary of the Department may specify by written notice (Reg.
4.17). Many airport operators choose to articulate their screening measures and
procedures by writing “As per the MTES”, when completing a TSP. This can be
problematic because not all Regulations are covered in the MTES. However, the
following Regulations are indeed covered by the MTES. Airport operators may cite
in their TSPs "As per Part x of the MTES" for the following Regulations:
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Airport operators will need to spell out their measures and procedures, in their TSPs,
for the following Regulations:
Reg. 2.17(2)(a)
Reg. 2.17(2)(f)
Reg. 2.17(2)(g)
Reg. 2.17(2)(h)(iv)
Reg. 2.17(2)(h)(v)
Reg. 2.17(2)(h)(vi)
Reg. 2.17(2)(i)
Reg. 2.18(1)(a)(i)
Reg. 2.18(1)(b)
Reg. 2.17(2)(d)
Reg. 2.17(2)(h)(i)
Reg. 2.18(1)(c).
The first nine in the above list are NOT covered by the MTES at all. The final three
in the above list (Regs. 2.17(2)(d), 2.17(2)(h)(i) and 2.18(1)(c)) are only partially
covered by the MTES, so they too will need to be fully addressed by airport
operators’ TSPs. The reasons are as follows:
• Reg. 2.17(2)(d) - Parts 2.7 and 2.8 of the MTES discuss the treatment of ‘suspect’
passengers, but no provision is made for how this may be done. The same applies
to the screening of personal effects, under the same sub-regulation (Parts 2.24-
2.28 of the MTES).
Note: For more information about VIPs, see ‘Information About VIPs’, p. 30
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Guidance Paper: Preparing A Transport Security Program
The airports where CBS is required (or in some cases, will be required on and from 1
August 2007) are set out in Reg. 4.29.
If CBS is not required by legislation at your airport, the TSP may state ‘N/A –
checked baggage screening is not required at this airport under ATSA/ATSR’.
Under Reg. 2.18(1), if CBS is conducted at the airport by the airport operator itself,
the TSP must include the measures, equipment and procedures to carry out screening
including the:
Where the airport operator conducts CBS itself, it does not need to attach its CBS plan
to the TSP, provided that it lists substantial measures and procedures in the TSP, and
those measures and procedures meet the requirements set out above.
If a screened air service operates from the airport, but the airport operator does not
carry out CBS, the TSP must specify the screening authority that does so (Reg.
2.18(2)).
Where the TSP follows the Department’s “Template for writing a Transport Security
Program (TSP) - Airport Operators ”, this information can be included in Appendix
E.
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Guidance Paper: Preparing A Transport Security Program
For Regulations regarding weapons and prohibited items specifically, refer to Part 4,
Divisions 4.2 and 4.3 of the ATSR.
For a list of weapons and prohibited items as defined under the ATSA, refer to ATSA
s.9 and Regs. 1.07 and 1.09.
The TSP should describe how you will respond to the detection of any firearms, other
weapons and prohibited items within your operation.
Under Reg. 2.20(1)(c), the TSP must include procedures for handling and movement
of firearms and other weapons.
The airport operator should differentiate between procedures followed by staff, other
authorities and passengers within the airport. You should provide details on the
procedures that will be used on the ground to ensure the security of firearms and other
weapons, including storage.
Under Reg. 2.20(1)(d), the TSP must include procedures for using firearms and other
weapons in the airside area or landside security zones. The TSP should also include
procedures that apply for using firearms and other weapons in bird hazard control.
Under Reg. 2.20(1)(e), the TSP must include methods for ensuring that staff with a
need to know are aware of the restrictions on possessing and using firearms, other
weapons and prohibited items within the airport.
Reg. 2.20(2) provides that airport operators must ensure that procedures in the TSP to
handle or transport firearms, other weapons and prohibited items are consistent with
relevant Commonwealth, State or Territory laws.
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Guidance Paper: Preparing A Transport Security Program
The TSP should demonstrate that the airport operator has allowed for the national
counter-terrorism alert level to remain elevated indefinitely. The operator should
include measures immediately available, as well as measures for long-term
implementation.
Under Reg. 2.21(1), you must set out, in an accompanying document to your TSP,
additional security measures and procedures available to reflect your capacity to
respond, in the event of a heightened security alert (High or Extreme).
These may include, but do not have to be limited to, increased security guards,
increased patrols, 24-hour watches, extra lighting or closing the airport. Where the
TSP follows the Department’s “Template for writing a Transport Security Program
(TSP) - Airport Operators”, these measures may be shown at Appendix L.
Under Reg. 2.21(2)(a), the TSP must set out, in an accompanying document,
procedures for responding to and investigating aviation security incidents, including
threats and breaches of security.
The procedures should also describe how incidents and breaches will be
communicated to and coordinated with relevant authorities.
(a) taking control of an aircraft by force, or threat of force, or any other form of intimidation;
(c) causing damage to an aircraft that is in service that puts the safety of the aircraft, or any person on
board or outside the aircraft, at risk;
(d) doing anything on board an aircraft that is in service that puts the safety of the aircraft, or any
person on board or outside the aircraft, at risk;
(e) placing, or causing to be placed, on board an aircraft that is in service anything that puts the safety
of the aircraft, or any person on board or outside the aircraft, at risk;
(f) putting the safety of aircraft at risk by interfering with, damaging or destroying air navigation
facilities;
(h) committing an act at an airport, or causing any interference or damage, that puts the safe operation
of the airport, or the safety of any person at the airport, at risk.
(2) However, unlawful interference with aviation does not include lawful advocacy, protest, dissent
or industrial action that does not result in, or contribute to, an action of a kind mentioned in
paragraphs (1)(a) to (h).
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Guidance Paper: Preparing A Transport Security Program
Under Reg. 2.21(2)(b), the TSP must set out, in an accompanying document,
procedures for reporting aviation security incidents, or security breaches including
occurrences that threaten the security of the airport.
Part 6, Division 4 of the ATSA sets out the requirements for AIPs to report incidents.
ATSA s. 104 requires airport operators to report incidents to:
• the Australian Federal Police or the Police Force of a State or Territory; and
An incident that relates to the airport of another operator must be reported to that
other operator. An incident that relates to the aircraft of an aircraft operator must be
reported to the aircraft operator (s.104(2) – (3) of ATSA).
Incident reports must follow the format prescribed by the Secretary. If the TSP
includes an example, refer to Notice About How Incident Reports are to be Made.
Under Reg. 2.21(2)(c), the TSP must set out, in an accompanying document,
procedures for evacuation and emergency management in case of an aviation security
incident, security threat or breach of security, including:
• an aircraft hijacking;
ATSA s. 67 sets out the circumstances in which the Secretary may direct that
additional security measures will be taken or complied with. A direction made under
this section is a ‘special security direction’.
Under Reg. 2.21(2)(d), the TSP must set out procedures for responding to any special
security direction given by the Secretary, including procedures to communicate
directions within the airport, eg. to passengers and other persons within the boundary
of the airport.
If appropriate, these procedures could include, but do not have to be limited to:
Under Reg. 2.21(2)(e), the TSP must set out, in an accompanying document,
procedures for raising the awareness and alertness of staff to security threats and their
responsibility to report aviation security incidents and breaches.
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Guidance Paper: Preparing A Transport Security Program
Under Reg. 2.21(2)(f), the TSP must set out, in an accompanying document, the
details of any other security contingency procedures and plans related to heightened
security alerts.
Security Training
The ATSR set out training and qualification requirements for airport security guards
and screening officers at Part 5, Divisions 5.2 and 5.3.
Under Reg. 2.02, the airport operator must appoint an SCO who is an employee of the
airport operator, in accordance with the TSP. The responsibilities of an SCO are:
Under Reg. 2.22(2), the TSP must specify, by reference to their positions, the
employees, contractors and other persons (other than the SCO) who have been
assigned particular security duties and responsibilities.
b) the knowledge, skills and other requirements for the security-related aspects of
their positions; and
Under Reg. 2.22(4), the TSP must describe the aviation security training programs
that will be given to the staff with a need to know. If relevant, TSPs may include
training under the ‘Securing Our Regional Skies’ capability building program.
For example, the airport operator may describe any other security-related training to
be provided to appropriate personnel, including contingency plan exercises and
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Barriers
Under Reg. 2.23(1), only the following airports are required to include details of
barriers in their TSP:
• Adelaide Airport;
• Brisbane Airport;
• Cairns Airport;
• Canberra Airport;
• Coolangatta Airport;
• Darwin Airport;
• Hobart Airport;
• Melbourne Airport;
• Perth Airport;
• Sydney Airport.
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Introduction
Importance of this issue
Proper treatment of all VIPs when undergoing security screening is a critical issue for
OTS. Previous incidents have shown that not only can these incidents have immediate
aviation security concerns; a mishandled incident can affect Australia’s broader
bilateral relationships at a whole-of-Government level.
What is a VIP?
There is no one definition of what constitutes a VIP. Different categories of VIPs are
entitled to different treatment, and they will all have different expectations of the
security screening process. According to the ATSA, VIPs can include the Queen of
Australia, the Royal Family, Heads of State, Heads of Government, other Guests of
Government and their aides and entourage. Diplomats are also entitled to certain
VIP-type privileges.
Policy Position
The Government’s position is that all persons travelling on a screened air service must
be screened and cleared. The ATSR provide one automatic exemption for the Queen
of Australia.
The Act also provides the Secretary the capacity to exempt people from screening on
a one-off basis3. However, the circumstances would have to be exceptional since
exemptions only undermine the robustness of Australia’s security arrangements.
Accordingly, the Australian Government strongly encourages all VIPs to undergo
normal security screening processes at Australian airports.
Passenger and carry-on baggage screening consists of three stages – Primary and
Secondary Screening and Explosive Trace Detection.
Screening and clearing is legislated by the ATSA and ATSR. The procedures are
detailed in the notice specifying the MTES.
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• A screening officer must not use more force, or subject a person to greater
indignity, than is necessary and reasonable.
• Where secondary screening techniques are required, a person has the right to
request that this be carried out in a private room by a screening officer of the
same sex.
• Known/unknown departures
o Not all VIP departures will be known in advance, and not all VIPs will
be accompanied by CERHOS officers or other minders.
o Not all requests for VIP treatment will be able to be verified on the
spot.
• Entourage/Minders
o Previous incidents have shown that while the actual VIP is prepared to
undergo screening with a minimum of fuss, members of their
entourage can create a situation by demanding particular treatment,
and inflaming the situation.
• What is Dignity?
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Guidance Paper: Preparing A Transport Security Program
• Cultural issues
o Different cultural sensitivities will impact the type of treatment
expected by particular VIPs.
o Other countries treat particular VIPs differently and may offer
automatic exemptions for a wider group than Australia does.
• ETD Issues
o The random and continuous nature of the ETD process sometimes
presents particular challenges to the VIP screening process.
o Some VIPs (and people generally) may feel they have been targeted or
treated unfairly if selected for ETD. This has been the cause of
previous complaints and confrontations.
o It is often exacerbated by the fact that the VIP’s entourage will stand
back and let them pass through screening first. As such, the VIP is
often a prime candidate for ETD selection.
o ETD is an integral part of the screening process, and individual
exemptions can not be granted.
• Being aware that this is an issue that can have large implications.
Prior arrangements:
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Flexibility in Screening:
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