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TSA’s Indirect Air Carrier (“IAC”) Program

The Transportation Security Administration (TSA) is charged with managing security issues relating to the movement of cargo on aircraft. Since air transportation of cargo is heavily regulated, anyone transporting cargo to an air carrier must be admitted into the Indirect Air Carrier (IAC) program.

An indirect air carrier is a person or company that wishes to engage indirectly in air transportation of property.  In order to be admitted, each indirect air carrier must implement a security program that meets the TSA’s requirements and is renewed annually.

Due to the advantages of transporting cargo via air carriers, such as the quick and cost-effective movement of goods as well as the opening up of international markets for logistics and freight forwarding companies, many companies are interested in the IAC Program. Due to the fact that the program falls 49 C.F.R. Parts 15 and 120, dealing with Sensitive Security Information, however, limited information about the program is available to the public.  This, in turn, can result in obstacles for interested companies to understand the eligibility and application process.

In order to make sure that all of the program’s requirements are met, the IAC program requires all employees, contractors, or other agents that perform security functions to be properly trained and managed. Thus, it is vital that companies maintain proper control and training over third party contractors that it uses to perform these functions. Likewise, it is important for companies to allocate the proper resources to manage the program.

Companies that are interested in joining the IAC program can apply online on the Indirect Air Carrier Management System. The approval process usually takes three to four months. More information about the program can be obtained from the TSA’s website.

Once the online application is completed, applicants will then be required to submit documents via email to the IAC Regional Compliance Coordinator (RCC) as explained in 49 C.F.R. Part 1548.7. This regulation should be carefully reviewed as any missing information can result in processing delays. These documents include the submission of Security Threat Assessments (STA) for each proprietor, partner, officer, director, and owner of the company as set forth in 49 C.F.R. 1548.16.

The procedures governing Security Threat Assessments (STAs)  are contained in 49 C.F.R. 1540.201, 49 C.F.R. 1540.203, and  49 C.F.R. 1540.205.  STAs can be denied or revoked if the individual is “known to pose or is suspected of posing a threat: (1) To national security; (2) To transportation security; or (3) Of terrorism.”

Once approved, the applicant can begin acting as an IAC so long as all of the security requirements are met and the proper training and STAs are complete. As explained above, the program requires annual renewals in order to ensure compliance.

Indirect Air Carrier Attorneys

If you have any questions regarding eligibility or the application process with respect to admittance into the IAC Program or if you have any questions relating to the denial or revocation of your Security Threat Assessment, contact the Indirect Air Carrier Attorneys at Brett O’Brien Law today for a free consultation.

About the Author

Brett O'Brien, Esq.
Brett O'Brien, Esq.
author

Brett O’Brien specializes in security clearance appeals. He has dedicated his career to learning the entire security clearance process from start to finish. He started his journey by working for the federal government before entering private practice. Learn more about Brett here.

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