Welsh-Sullivan Group LLC - NPRM Repair Station Security
Welsh-Sullivan Group LLC - Security Solutions for the Global Business
TSA NPRM Part 145 Repair Station Security
 
 
The Transportation Security Administration (TSA) announced publication in the Federal Register of a Notice of Proposed Rule Making (NPRM) to strengthen the Aircraft Repair Station Security program. The proposed rulemaking will establish security requirements for maintenance and repair work conducted on aircraft and aircraft components at domestic and foreign repair stations certified by the Federal Aviation Administration (FAA).
 
As a Certified CFR Part 145 Repair Station, your business will be subject to the new TSA Notice of Propose Rule Making (NPRM) for implementing a standard security program at your facility.  The NPRM is very specific in the security requirements that will be imposed.  The security standard includes:
 
  •           Access controlsfor the facility
  •           Measures foridentifying individuals having access to th facility
  • ·         Procedures forchallenging unauthorized individuals
  • ·         Securityawareness training for employees
  • ·         A designatedfacility security coordinator
  • ·         A writtencontingency security plan
  • ·         Process tobackground all employees and contractors
 
The Welsh-Sullivan Group provides risk, vulnerability and security assessments for General Aviation Airports, FBO’s and corporate flight departments.  We have been working with several clients on the proposed TSA Large Aircraft Security Program (LASP) and would be happy to assist you in assessing your facility for compliance to the security standard being proposed by the TSA for repair stations.
 
We know that most repair facilities have a security program in place and that some security programs are more robust than others. Because of this, it is wise to have an independent third party review your security program for effectiveness and efficiency.  In many cases, we can suggest cost effective solutions to enhance your current security program.  Being a member and past Chairman of the NBAA Security Council, we have a very good understanding of the security issues within the civil aviation community.  As a result, we developed the Aviation Security and Safety Evaluation Tool –ASSETTM which provides an in depth look at security policy, plans, procedures and culture.  ASSETTM will provide you with an evaluation of the effectiveness of your security program as well as the degree of compliance to the TSA NPRM Repair Station Security Standard.
 
The Welsh-Sullivan Group does not sell or install security equipment; we only provide professional security advice and recommendations to our clients. The assessment results are proprietary to your business and will not be shared with any competitor or government agency.
 
Our consultants are former U.S. Secret Service, FBI, FAA, NTSB and general aviation investigators, inspectors and operators with years of physical security experience in government, industry and aviation. Knowing where your security program stands with respect to the Repair Station Security NPRM will allow you to make critical business decisions and stay ahead of your competition. Being compliant to the NPRM may prove to be a competitive advantage and a business driver. Let us help you prepare for the TSA NPRM Repair Station Security Standard.
 
Please feel free to contact me to discuss the merits of having a security assessment conducted at your facility.  I can be reached at 214-315-7070 or by email at welshsullivangroup@yahoo.com
 
The Welsh-Sullivan Group LLC is an NBAA member company.
                                                                                                                               
Sincerely
                                                                                                                                John L. Sullivan
                                                                                                                                President
 
 
NBAA Article on the TSA NPRM for Part 145 Repair Station Security
 
TSA Aircraft Repair Station Security Proposed Rulemaking
NBAA November 19, 2009
 
In response to a directive contained in the Vision 100 - Century of Aviation Reauthorization Act, the Transportation Security Administration (TSA) has issued a Notice of Proposed Rulemaking (NPRM) that seeks to apply new security requirements to all aircraft repair stations certificated under part 145 of Federal Aviation Administration (FAA) regulations. The proposed regulations would require all domestic and foreign part 145 repair stations to adopt and implement a standard security program and to comply with security directives issued by the TSA in order to safeguard the security of the aircraft and components located at the station, the maintenance and repair work performed there, as well as the repair station's facilities. The rule also proposes to clarify the scope of TSA's existing inspection program and to require regulated parties to allow TSA and the Department of Homeland Security (DHS) officials to enter, inspect and test property, facilities and records relevant to repair stations.
 
Comments are due on the TSA propsal by January 19, 2010.
 
Detailed Analysis of the Aircraft Repair Station Security NPRM 
 
Repair Station Standard Security Program
 
TSA is proposing that each FAA certificated repair station implement and carry out a standard security program issued by TSA to mitigate the risk of their facility being targeted for terrorist activity. However, the TSA recognizes that a "one size fits all" approach is not appropriate for all repair stations and based on their risk analyses, has proposed to not include all of the same security measures for those repair stations with a lower risk profile, such as those repair stations not situated on or adjacent to an airport or those repair stations located on airports that only serve aircraft with a maximum certificated takeoff weight of 12,500 pounds or less.
 
The TSA also noted in the proposed rule that if a repair station is already incorporated within an airport's security program and uses the airport's access control measures, TSA will consider the repair station to be in compliance with the security measures proposed in these regulations. As well, repair stations located at facilities for which the Federal Government has assumed responsibility for security measures, such as a U.S. military base, would not be required to comply with this rule as TSA believes that the security at such a facility would likely meet and exceed the security requirements propsed in this rule.
 
The regulations propose that the following items must be included in a repair station standard security program:
 
 
  1. a description of the measures used to identify individuals who are authorized to enter the repair station to prevent unauthorized individuals from entering the repairstation;
  2. a description of the measures used to control access to the repair station and to detect and prevent the entry, presence, and movement of unauthorized individuals and vehicles into or within the repair station;
  3. a description of the measures used to control access to the aircraft and/or aircraft components to allow only authorized individuals to have such access;
  4. a description of the measures used to challenge any individual entering the repair station to ascertain the authority of the individual to enter or be present in the repair station and measures to escort an individual who does not have unescorted authority while within the repair station;
  5. a description of the measures to train all individuals with authorized access to aircraft and components on the provisions of this part and the security program;
  6. a description of the measures used to verify employee background information through confirmation of prior employment and any other means as appropriate to validate employee information;
  7. the name, 24-hour contact information, duties, and training requirements of the designated security coordinator who will serve as the primary and immediate contact for security-related activities and communications with TSA;
  8. a contingency plan;
  9. a diagram with dimensions detailing boundaries and pertinent physical features of the repair station;
  10. a list and description of all entry points; and
  11. an emergency response contact list.
 
The regulations also would require that the security program be in writing, and signed by the repair station operator, owner, or other authorized person. Each repair station would not have to submit the security program to TSA, but would have to make it available to TSA upon request or during an inspection.
 
 
Repair Station Profile
 
To assess the security risks of a repair station and to establish the priority by whcih repair stations must be inspected, the TSA would require each repair station to provide a brief profile, to include general information such as location, whether the repair station is located on or adjacent to an airport, the total number of employees, and the number of employees with access to large aircraft. The TSA notes that some of this information is available through existing FAA records, but not all of it.
 
 
Security Inspections
 
The proposed regulations would codify TSA's inspection authority and would require repair stations to permit TSA and DHS officials to enter, inspect and test property, facilities and records relevant to repair operations. The purpose of the inspection would be to assess threats to aviation security, enforce TSA security regulations, directives and requirements, evaluate all aspects of the repair station security program, verify whether the security program is being implemented and whether it is effective, as well as to identify and correct security deficiencies.
 
In the event that a security inspection identified deficiencies, the TSA would notify both the repair station and the FAA and the repair station would have 90 days to correct the deficiencies. If the deficiencies are not corrected within 90 days, the TSA would notify the FAA that it must suspend the repair station's certificate until such time as the TSA determines that the deficiencies are resolved. The proposed regulations also contain a process whereby a repair station may further request review of TSA's determination regarding security deficiencies.
 
 
Immediate Risk to Security
 
 
The proposed regulation contains a specific process whereby a repair station that poses an immediate risk to security is identified and the FAA is notified of such a determination. The FAA must revoke the certificate of a station that TSA determines poses an immediate risk to security. Whether the threat is immediate would be evaluated on a case by case basis considering existing and potential circumstances as information is received and analyzed. The proposal provides a repair station with the opportunity to obtain the releasable materials upon which the determination was made and to seek review of such a determination.
 
For additional information on the TSA NPRM, click the below link
 
 http://web.nbaa.org/ops/security/programs/repair-station/part-145-security-nprm-20091118.pdf       
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