Security regulation affects the world, remains relatively unknown
A validator must be trained and certified in order to do validations for the many carriers who fly cargo into the EU. So it had to fall upon someone to train these people.
“It was quite clear that governments weren’t going to create independent validators en masse, which is one of the key prerequisites for carriers becoming ACC3 after 1 of July,” says Woodall, IATA’s project leader cargo security, independent validation and international regulatory engagement. “The regulators thought that the commercial powers or entities would step into this gap and see business opportunities in becoming training providers.”
But neither governments nor companies created training programs, he says. So it fell upon IATA. The organization’s training school, the Center of Excellence for Independent Validators, gained accreditation in April 2013 and ran the first class in May.
With just 14 months until ACC3 took effect, IATA’s first validators came off the production line. The organization is the only EU-approved entity to train validators.
There were approximately 5,000 validations to carry out before July 1.
“The whole industry should be grateful for that, the fact that IATA took the initiative because otherwise, I don’t know what would have happened,” Cooreman says.
Not just anyone can become an independent validator or pass IATA’s course. In order for candidates to be accepted for validator training, they must complete a five-year background check to the satisfaction of the European states and demonstrate competence in aviation security, Woodall says.
IATA candidates must be pre-approved by a European government. They then undergo a five-day, 40-hour course that culminates in a six-hour exam. After candidates score a minimum of 80 percent on the test, the European country that preapproved their attendance in the course accredits them as independent validators.
Once they gain that status, they can go out and validate carriers’ security operations.
The IATA course has trained 101 people, but after accounting for five observers who didn’t take the exam, the 15 percent who failed and states officials who aren’t available for hiring, Woodall estimates that 75 validators are on the open market for the use of companies.
Cooreman says DHL initially felt concerned about a tight time window, but there are now a sufficient number of validators.
IATA has stopped running independent validator training courses because the supply of preapproved candidates from EU countries has dried up, Woodall says.
“Whether we’ll all able to meet the target of July 2014 remains to be seen and whether there are sufficient validators to meet the demand should it reach its peak level also remains to be seen,” he says. “But at some point, if the supply of validators isn’t sufficient, the fault will largely sit with the European regulators for not having preapproved sufficient candidates for us to train. We’ve got more training slots than we’ve got candidates, so IATA cannot be criticized for not generating enough validators if the states themselves haven’t preapproved and sent them to us.”
Woodall advises companies to contact validators, if they haven’t done so already. ACC3 allows for the pooling of validators, meaning multiple entities can contract a single validator and share his time in a single location at the same time. That uses the limited number of validators more efficiently.
“As we get closer to the deadline, more and more people will contact validators,” Woodall says. “It’s possible there will be a blockage in the pipe.”
A question looming for ACC3 is how many companies are prepared for and know about the regulation.
“In the shorter term, airlines that have not prepared to meet the ACC3 requirements may struggle to get their validations completed in time, and could face supply chain disruption,” says Jim McCaffrey, IAG Cargo’s vice president safety and compliance.
Cooreman says based on DHL Express’ encounters with non-European airlines and authorities, there is not always a “full understanding” of the regulation.