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Adjudication Management Process
Adjudication, when required, is a careful and complex process based on CHRC results that may require an
examination of court or other related records where additional information may assist in determining the
Applicant’s status. Federal regulations
outline the process and requirements for CHRC adjudication of
The provisions apply solely to offenses that result in convictions. The CHRC results can and in many
instances are used by airports to deny issuance of credentials when no federal disqualifying crime is
evidenced. As noted above, airports may have badge issuance policies consistent with state or local law
that are more restrictive than federal requirements. In some circumstances, the disposition of a charge may
not be provided or may not be clear on the criminal record supplied to the airport by the FBI. FBI data is
currently dependent on state and local reporting of arrest and conviction data and there can be a time lag in
Absence of complete information with respect to disposition of an offense may require additional research
or documentation for resolution by the Trusted Agent or it may require the applicant to clarify the final
disposition of a charge. Documentation may be required to substantiate reduction of a disqualifying crime
to a charge that is a non-disqualifying crime, proof that the charge was dismissed, or that the charged
individual was exonerated or found ‘not guilty’. A liaison between the airport and local law enforcement
may be utilized to assist with questions regarding the results obtained during the vetting process. Airport
Trusted Agents may also seek the services of an attorney or an outside firm for resolution of issues
associated with adjudication.
Note: For smaller airports, or airports which have limited adjudication requirements, the
implementation of an automated adjudication system may not be worthwhile and a manual process
may be adequate.
STAs are adjudicated by the TSA and also inform the decision whether to issue a credential. Airport
operators make the final determination as to whether or not an Applicant will be disqualified or issued
credentials and allowed unescorted access to security-related areas. The airport operator’s denial of access
and associated permissions do not necessarily affect an employer’s option to employ an individual in a
public, non-sterile environment for other duties. It only affects the ability of that employee to access certain
areas of the airport and, in some cases, a purely ‘identity’ credential may be issued.
Note: A manual process may be considered for this function.
state that no airport operator shall allow credentialed individual’s unescorted access
to the SIDA or secured areas prior to their successful completion of appropriate training as outlined within
each airport’s TSA-approved Airport Security Program (ASP). While there are no federal guidelines as to
how often security training is required, a best practice is to require training at badge renewal and when
significant changes to operations or operational areas occur.
During the life span of the credential, the material covered in the training may change. Re-training enforces
the critical nature of security and safety. For other required training, the frequency is dictated by ‘purpose’,
10 Title 49 CFR 1542.209 [Refer: § 2.5.1]
Title 49 CFR 1542.213 (b)
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