YOUR QUESTIONS ANSWERED POLICE SUCCESS STANDARDS FAQs #42 Question 2.
FSR Access Control: I visited my supplier’s warehouse, which is a TAPA FSR Level A facility. Part of the warehouse is being used for general offices. Is this allowed under the FSR requirements?
Answer: The access controls and personnel access to the warehouse are covered by many requirements in the FSR. The intent is to control access by keeping out those without the authority to be there and to ensure those with authorised access follow the established protocols to support a safe and secure working environment. In answering your question, we need to consider if the office workers are required to comply with the same rules that all other workers in the warehouse are obliged to follow? If yes, then that is a good starting point. We would then advise you to check and see if a risk assessment has been completed to ensure security risks were considered. A good risk assessment would identify any concerns and the need for additional mitigation. An auditor could say they felt this group of workers posed a risk to personnel or goods in the warehouse even though the procedures and access controls are being followed. As stated many times, the TAPA FSR Standard sets the “minimum” standards for an operation, but the operator is free to impose additional requirements as they deem necessary. The main message here would be for the facility operator to use the risk assessment process, take appropriate action and discuss any concerns with their auditor.
Question 3.
FSR High Value Cage: My new supplier says they have a waiver from TAPA and do not need a high value cage (HVC) in their FSR Level A warehouse. I will store some very high value parts in this warehouse and assumed they would have a secure storage facility. Is this something I need to address with my supplier or TAPA? What are my options?
Answer: This can be answered by referencing Section 6 of the FSR Standard, which states:
• For HVC waivers, the appropriate mitigation actions to minimise risk (where an HVC is not available) must be considered and documented in the annual Risk Assessment.
Question 4.
FSR Exit Searches: Why does TAPA not require mandatory exit searches when exiting the warehouse?
Answer: The FSR exit search requirements have evolved over many years. Earlier versions of the Standard required a physical and/or electronic search. As costs for searching increased, personnel working conditions changed and product security improved, the traditional “stop it at the door” methods evolved in later revisions of the Standard to using risk assessment and management judgement, so personnel searches are used only as a deterrent. As you can see from the FSR requirement, exit searches for a Level A facility are dictated by the facility “exit search procedure”.
7.4.25
If allowed by local law, LSP/Applicant must develop and maintain a documented procedure for exit searches. Activation of the procedure is at the discretion of the LSP/Applicant and/or as per Buyer/LSP/Applicant agreement. At a minimum, the procedure must address the LSP’s/Applicant’s right to search criteria should a need arise to introduce searches when they are normally not required (e.g., when workforce pilferage is suspected).
Some locations will deem exit searches of their own staff and visitors are required at all times, while others may consider that searches are only appropriate following a security incident, which warrants personnel being searched on exiting the facility. What TAPA is looking for is the existence of the documented policy and evidence that it will be followed in the event the criteria documented in the policy is triggered.
• The waiver request includes an attached declaration signed by the LSP/Applicant stipulating that no Buyers require an HVC.
Therefore, if a new buyer is introducing valuable and/or vulnerable goods for the operator to process, then ideally a new Risk Assessment should be completed.
In this case, as the Buyer is a new client of the operator, they are not bound to accept the previous agreements or declarations. Initially, you should try to resolve any differences in expectations by negotiation.
• If the operator is willing to provide an HVC but seeks compensation, this is a commercial matter between both parties.
• If the operator will not or cannot provide an HVC, then TAPA can be approached by either party for a resolution decision. Both parties will be asked in advance to accept the solution that TAPA provides.
• The best advice is to ensure the Buyer’s security requirements are fully explained and considered by the facility operator before the contract is agreed. Sometimes, just stating the security level may not be sufficient.
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