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TSA Can Improve Aviation Worker Vetting, DHS OIG, 2015

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TSA Can Improve Aviation
Worker Vetting
(Redacted)

OIG-15-98
June 4, 2015

DHS OIG HIGHLIGHTS


TSA Can Improve Aviation Worker Vetting
June 4, 2015

Why We
Did This
We conducted this
review to identify
enhancements to the
Transportation Security
Administration’s (TSA)
vetting of workers with
access to secure areas of
commercial airports for
links to terrorism,
criminal history, and
lawful status. We also
assessed the accuracy
and reliability of data
TSA uses for vetting.

What We
Recommend
TSA should request and
review additional
watchlist data, require
that airports improve
verification of
applicants’ right to
work, revoke credentials
when the right to work
expires, and improve the
quality of vetting data.

What We Found
TSA’s multi-layered process to vet aviation workers for
potential links to terrorism was generally effective. In addition
to initially vetting every application for new credentials, TSA
recurrently vetted aviation workers with access to secured
areas of commercial airports every time the Consolidated
Terrorist Watchlist was updated. However, our testing showed
that TSA did not identify 73 individuals with terrorism-related
category codes because TSA is not authorized to receive all
terrorism-related information under current interagency
watchlisting policy.
TSA had less effective controls in place for ensuring that
aviation workers 1) had not committed crimes that would
disqualify them from having unescorted access to secure
airports areas, and 2) had lawful status and were authorized
to work in the United States. In general, TSA relied on airport
operators to perform criminal history and work authorization
checks, but had limited oversight over these commercial
entities. Thus, TSA lacked assurance that it properly vetted all
credential applicants.
Further, thousands of records used for vetting workers
contained potentially incomplete or inaccurate data, such as
an initial for a first name and missing social security
numbers. TSA did not have appropriate edit checks in place to
reject such records from vetting. Without complete and
accurate information, TSA risks credentialing and providing
unescorted access to secure airport areas for workers with
potential to harm the nation’s air transportation system.

TSA Response
TSA concurred with all six recommendations.

For Further Information:
Contact our Office of Public Affairs
at (202) 254-4100, or email us at

DHS-OIG.OfficePublicAffairs@oig.dhs.gov

www.oig.dhs.gov

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Department of Homeland Security


Table of Contents
Results of Audit .....................................................................................2
Background……….……… ..................……………………………………………4
TSA Can Enhance Its Process for Vetting Aviation Workers ....................9
TSA Can Improve the Reliability of Its Vetting Data ....…………………...14
Recommendations …………………………………………………………………..16

Appendixes
Appendix
Appendix
Appendix
Appendix
Appendix

A:
B:
C:
D:
E:

Transmittal to Action Official ……………………………20
Scope and Methodology…………………………………...21
TSA Comments to the Draft Report...………………….23
Major Contributors to This Report... ...............……..30
Report Distribution…………………..…………………….31

Abbreviations
CBP
CFR
CHRC
CSG
DAC
DHS
EAB
FBI
IR&A
NCTC
OIG
SAVE
SIDA
SSN
TIDE
TSA
TVS
USCIS
VAD
www.oig.dhs.gov

Customs and Border Protection
Code of Federal Regulations
Criminal History Records Check
Consolidated Screening Gateway
Designated Aviation Channeler
Department of Homeland Security
Encounter Analysis Branch
Federal Bureau of Investigation
Investigations, Referrals & Analysis
National Counterterrorism Center
Office of Inspector General
Systematic Alien Verification for Entitlements Program
Secure Identification Display Area
Social Security Number
Terrorist Identities Datamart Environment
Transportation Security Administration
Transportation Vetting System
United States Citizenship and Immigration Service
Vetting Analysis Division
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Results of Audit

We reviewed the Transportation Security Administration’s (TSA) controls over
the vetting of aviation workers possessing or applying for credentials that allow
unescorted access to secured areas of commercial airports. Specifically, we
assessed TSA’s process for vetting workers for terrorist links, criminal history,
and lawful status. We also sought to determine the accuracy and reliability of
data TSA uses for vetting.
We determined that TSA had multiple, layered controls for vetting workers for
terrorism. TSA designed its vetting procedures to 1) match new applicants for
credentials, and 2) repeatedly re-vet nearly 1 million existing credential holders
against the Consolidated Terrorist Watchlist within minutes of receiving
updated watchlist data. This process resulted in thousands of watchlist hits
that TSA analysts manually reviewed during fiscal year 2014. TSA also
proactively identified relationships between current credential holders and
watchlisted individuals and nominated over 300 individuals to the watchlist
across all credential programs. In addition, TSA recently made improvements
to the quality of the aviation worker data used for vetting.
Despite these layered controls, our testing showed that TSA did not identify 73
individuals with terrorism-related category codes. According to TSA data, these
individuals were employed by major airlines, airport vendors, and other
employers. TSA did not identify these individuals through its vetting operations
because it is not authorized to receive all terrorism-related categories under
current interagency watchlisting policy. Excluded categories
TSA acknowledged that these individuals were cleared for
access to secure airport areas despite representing a potential transportation
security threat.
TSA had less effective controls in place to ensure that airports have a robust
verification process over a credential applicant’s criminal history and
authorization to work in the United States. TSA did not perform recurrent
criminal records checks similar to its terrorism vetting due to current law and
FBI policies. TSA depended on 467 commercial airports and air carriers to
verify credential holders’ criminal histories through a limited review process,
and relied on the credential holders themselves to report disqualifying crimes
to the airports where they worked. Further, TSA had to deny thousands of
credentials to individuals because it could not verify their lawful status, even
though airports represented that these individuals had passed the airports’
own work authorization verification.
We identified thousands of TSA data records containing potentially incomplete
and inaccurate biographic information. TSA relied on airports to gather
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complete and accurate information from the credential applicants. According to
vetting officials, TSA can only vet workers based on data received from airports.
While TSA had made some improvements to its data collection to meet its
requirements, TSA lacked assurance that it properly vetted all credential
applicants.
We recommended that TSA work with the necessary interagency partners to
determine if its aviation worker credential program warrants the receipt of
additional categories of terrorism-related data, require airports to improve their
verification of applicants’ right to work, and terminate credentials when the
right to work expires. We also recommended that TSA take steps to ensure the
data it uses for aviation worker vetting are complete and accurate.

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Background

TSA was created in 2001 to ensure the safety and free movement of people and
commerce within the Nation’s transportation systems. As part of this mission,
TSA also has statutory responsibility for properly vetting aviation workers such
as baggage handlers and airline and vendor employees with unescorted access
to Secure Identification Display Area (SIDA) and sterile areas of commercial
airports.
Chapter 49 of the Code of Federal Regulations (CFR) and TSA Security
Directive 1542-04-08G require that individuals applying for credentials to work
in secure areas of commercial airports undergo background checks prior to
being granted badges that allow them unescorted access to secure areas. Each
background check includes 1) a security threat assessment from TSA,
including a terrorism check; 2) a fingerprint-based criminal history records
check (CHRC); and 3) evidence of the applicants’ right to work in the United
States. The CHRC determines whether the credential applicant has a
disqualifying criminal offense in the previous 10 years. These crimes fall into
28 categories, including crimes involving air safety as well as violent felonies,
fraud, and bribery.
Under Security Directive 1542-04-08G, TSA relies on airport operators to
collect and verify applicant data for individuals seeking credentials. This data
includes each applicant’s name, address, date of birth, place of birth, country
of citizenship, passport number, and alien registration number (if applicable).
Social security number (SSN) is not currently a required field on the aviation
worker credential application, but is collected if provided by the applicant. TSA
also relies on airport or air carrier employees to collect an applicant’s
fingerprints for the CHRC. Airports use one of three Designated Aviation
Channelers (DAC) to submit prospective aviation worker information and
changes to biographic data for existing workers to TSA. The DACs ensure the
applicant’s biographic and fingerprint information is complete and formatted
properly before forwarding the information to TSA for vetting.
Once it receives biographic data from the Consolidated Screening Gateway
(CSG), the Vetting Analysis Division (VAD) of TSA’s Office of Intelligence and
Analysis uses the Transportation Vetting System (TVS) to match credential
applicants against its extract of the DHS Watchlist Service to identify
individuals with potential links to terrorism. TSA also re-vets airport workers
with unescorted access to secure areas of commercial airports against the
watchlist on a recurring real-time basis. That is, it performs a match of all
existing airport workers every time it receives watchlist updates, which may

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happen many times in a day. 1 TSA’s matching model scores each worker it vets
against the Consolidated Terrorist Watchlist using various rules, such as name
matches; SSN, passport number or alien registration number matches; address
matches; or combinations of different variables. TVS scores potential matches
automatically and presents them to analysts for manual review and analysis.
Analysts then determine whether the potential match represents a true name
match. For true name matches, analysts prepare a preliminary vetting match
report that includes all relevant information related to the match. VAD sends
the report to TSA’s Investigations, Referrals & Analysis (IR&A) to help conduct
a full investigation.
Figure 1 provides an overview of this vetting process. As shown in figure 1,
upon receiving information from VAD, the IR&A team performs additional
research to determine whether a potential match is indeed a real match. If
necessary, IR&A coordinates with other law enforcement or terrorism
prevention agencies to arrive at a final disposition.

In addition to aviation workers, TSA also recurrently re-vets over 13 million other credential
holders in programs such as the Transportation Worker Identification Credential and Federal
Aviation Administration Airmen Certificate.
1

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Figure 1. TSA Vetting Process

Source: Department of Homeland Security (DHS) Office of Inspector General (OIG) analysis of
TSA vetting procedures.
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Based on its additional research, IR&A may direct the airport to:
•
•
•

grant the credential (for a new applicant),
deny the credential (for a new applicant),
revoke an existing credential (in the case of an existing credential holder
who matched against the watchlist as part of the recurrent vetting
process), or

IR&A confers with other
governmental organizations, such as the Federal Bureau of Investigation (FBI),
that have nominated an individual to the watchlist or may have an open case
on the individual. In some instances, other governmental organizations may
request that TSA not direct the airport to deny or revoke a credential because
the denial or revocation may impact an open investigation.

TSA Security Directive 1542-04-08G requires airport operators to perform a
CHRC for all employees who require unescorted access to SIDA and sterile
areas of commercial airports, except for Federal, State, or local government
employees who already have CHRCs performed as conditions of their
employment. To perform the CHRC, applicants submit fingerprint records to
the appropriate airport operators, who in turn provide the fingerprint records to
TSA. TSA sends the fingerprint records to the FBI for a background check. FBI
returns the results to airport operators through TSA. Airport operators are
responsible for conducting reviews of the applicant’s criminal history for
criminal offenses that would disqualify the individual from unescorted access
to secured areas of an airport. Disqualifying offenses are listed in 49 CFR
1542.209 and include espionage; sedition; treason; crimes involving terrorism,
transportation security, or explosives; some violent offenses; and some felonies.
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Chapter 49 of the CFR and TSA Security Directive 1542-04-08G require that
prospective credential applicants undergo immigration checks to ensure that
the individuals have lawful presence and that airport operators verify the
applicant’s authorization to work in the United States. This check occurs in
two stages. First, airport operators collect and review documents validating
that a credential applicant is authorized to work in the United States. For
example, legal permanent residents and certain student visitors may have
authorization to work in the United States, while tourists visiting the United
States under a visitor visa would likely not have the right to work. The airport
then forwards the validated file on the individual to TSA for a second review.
During this review, TSA performs its verification to ensure that the individual
has lawful status to be in the United States. According to TSA’s Security
Directive, airports have to verify an individual’s authorization to work before
sending their record to TSA for the security threat assessment, and not issue
credentials unless the individual is authorized to work.
To check a prospective credential holder’s lawful status, TSA’s Security Threat
Assessment Operations verifies against the U.S. Citizenship and Immigration
Service’s (USCIS) Systematic Alien Verification for Entitlements Program
(SAVE) all individuals listed as being born outside the United States. SAVE
provides the ability for Federal, State, or local benefit and licensing agencies to
verify the immigration status of noncitizen applicants for Federal, State, or
local benefits and licenses.
In 2011, we reported that TSA’s oversight of commercial airports’ badging
process needed improvement, and made recommendations to TSA to help
improve the accuracy and completeness of vetting information, improve identity
verification, and require recurrent vetting of applicant criminal histories. 2 TSA
took some steps to improve in those areas, including issuing guidance to
airports to help improve data quality and encourage airport operators to use
Customs and Border Protection’s (CBP) Identification Verification guide for
periodic training. However, TSA is not currently authorized under law and FBI
policy to conduct recurrent criminal history records checks, although it has
made efforts to gain the authorization to perform recurrent checks.

DHS OIG, TSA’s Oversight of Airport Vetting Process Needs Improvement, OIG-11-95, July 7,
2011.
2

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TSA Can Enhance Its Process for Vetting Aviation Workers
TSA’s multiple, layered controls for vetting potential and existing credential
holders against the Consolidated Terrorist Watchlist were generally effective.
TSA performed initial and recurrent vetting, regularly tested the algorithms it
uses for vetting, and proactively identified new terrorism suspects for
nomination to the watchlist. An independent match performed by the National
Counterterrorism Center (NCTC) found that overall, the TSA algorithms used
and the manual review process were effective in identifying prospective and
existing credential holders’ links to terrorism. However, we found that TSA did
not receive certain terrorism-related category codes as part of the watchlist
extract they used for vetting. Consequently, TSA’s vetting process did not
identify 73 aviation workers with active badges that we determined had
terrorism-related category codes.
TSA had less effective controls in place for ensuring that airports vet aviation
workers for disqualifying criminal records and authorization to work in the
United States. TSA relied on airport operators to perform criminal history and
work authorization checks and had limited access to documentation
supporting the airports’ credentialing decisions. As such, TSA lacked
awareness of applicants’ criminal histories. TSA also had to deny credentials to
4,800 individuals that the airports had previously cleared for work in the
United States because it could not verify lawful status for those individuals.
TSA’s Multi-Layered Process to Vet Workers for Links to Terrorism Was
Generally Effective
The vetting and re-vetting procedures that TSA used were generally effective in
identifying credential holders with links to terrorism. For example, since its
inception in 2003, TSA has directed airports to deny or revoke 58 airport
badges as a result of its vetting process for credential applicants and existing
credential holders. According to TSA’s vetting managers, TSA’s recurrent
vetting process has been a crucial tool in ensuring the security of the Nation’s
transportation system. TSA has also taken the following steps to continually
enhance this vetting process:
•	 TSA implemented a quality review process to test and refine the
effectiveness of its scoring model. According to vetting officials, testing
the scoring model allowed TSA to determine what percentage of potential
matches would represent true name matches, and gave TSA the ability to
optimize the number and type of matches it presented to analysts for
manual review.
•	 The VAD tested its name matching algorithms against those of its peers.
According to TSA officials, in 2013, TSA participated in a name-matching
contest sponsored by the Mitre Corporation along with three other DHS
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name-matching systems from CBP and USCIS. TSA’s TVS namematching capabilities ranked first in the contest among DHS entrants
based on an overall quality measure.
•	 In 2010, TSA created the Encounter Analysis Branch (EAB) team to
leverage the vast amount of data it analyzed to proactively identify new
terrorism suspects. For example, the EAB submits newly identified
addresses, phone numbers, or other pertinent identifying information not
currently included in a watchlist record. The EAB also submits new
terrorist watchlist nominations, for example, if TSA determines there is
sufficient information to link a credential holder to a known or suspected
terrorist. According to TSA officials, for the 18-month period ending June
30, 2014, EAB analysis resulted in TSA submitting
terrorist
watchlist nominations and providing new information for
records. In one example, TSA identified an aviation worker who
As a result of TSA’s
nomination, the aviation worker was added to the consolidated terrorist
watchlist.
TSA Did Not Identify 73 Workers with Links to Terrorism
Although TSA’s vetting procedures for terrorism were mostly effective, our
testing determined that TSA did not identify 73 individuals with links to
terrorism. This occurred because TSA is not authorized under current
interagency watchlisting policy to receive certain terrorism-related category
codes as part of the watchlist extract they used for vetting. TSA acknowledged
that individuals in these categories represented a potential transportation
security threat.
To assess the accuracy and effectiveness of TSA’s terrorism vetting procedures,
we asked NCTC to match over 900,000 records of active aviation workers
against NCTC’s Terrorist Identities Datamart Environment (TIDE). 3 Our
analysis of NCTC results determined that TSA did not find 73 individuals
linked to terrorism because the watchlist extract TSA received from the DHS
Watchlist Service and used for vetting did not contain the terrorism codes
associated with those individuals. 4 According to an official at the DHS Office of
Policy, in order to receive additional categories of TIDE records, TSA must work
with DHS to formalize a request to the Watchlisting Interagency Policy
TSA maintains over 2 million aviation worker entities in the TVS vetting system. However, we
did not submit all aviation worker records vetted by TSA to NCTC for matching. We eliminated
inactive badge records that are retained by TSA, as well as badges for individuals who do not
have access to secured areas of airports.
4
The Interagency Policy Committee responsible for watchlist policy determines what terrorismrelated categories are provided to TSA for vetting, while the DHS Watchlist Service provides
allowable information to TSA.
3

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Committee through its Screening Coordination Office. Details on the
individuals and their terrorism codes can be found in table 1.
Table 1: Categories of Aviation Worker Records with Terrorism Links
TerrorismRelated Terrorism Record Category
Category Code

Total Records

Source: DHS OIG analysis of NCTC matching results.

Aviation Worker
Record Matches

73

As shown in table 1, codes TSA did not receive for vetting include
According to the DHS
Screening Coordination Office, codes
are TIDE-only codes
that are not included in the Terrorist Screening Database and cannot currently
be used for vetting purposes. 5 In addition, interagency watchlisting guidance
does not allow codes
to be provided to TSA for aviation worker
vetting. TSA’s VAD recognized that not receiving these codes represented a
weakness in its program. VAD officials informed us that as part of its analysis
efforts, VAD had independently identified derogatory information on some
individuals, and subsequently determined that these individuals belonged to
the missing categories. VAD officials informed us that without receiving these
categories, TSA could not guarantee that it could consistently identify all
questionable individuals. TSA officials believed that receiving these categories
would at least give them an opportunity to monitor these individuals.
In 2014, the TSA Administrator signed an internal TSA policy memo to partially
address this potential weakness. In addition to category codes
identified above, the TSA Administrator authorized his staff to request category
codes
for vetting. TSA’s policy memo states that individuals in
such categories could pose potential threats to aviation security if TSA is not
given a chance to examine the information and assess any potential associated
risk.

Classified derogatory information for subjects with an international nexus to terrorism is
maintained in TIDE. Terrorist records that meet minimum substantive derogatory and
identifying criteria requirements are exported to the Terrorist Screening Database, which serves
as the U.S. Government’s consolidated terrorist watchlist.
5

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TSA Relies on Airports for Criminal History and Work Authorization
Checks
Compared to the generally effective controls TSA had in place to link
individuals with terrorism information, TSA lacked effective controls to ensure
that aviation workers did not have disqualifying criminal histories and that
they possessed lawful status and the authorization to work in the United
States. Under current law and FBI policy, TSA is not authorized to perform
recurrent criminal checks of aviation workers because aviation worker vetting
is considered to be for non-criminal justice purposes. Therefore, TSA did not
recurrently vet workers for criminal histories similar to the recurrent vetting it
performed for terrorism information. Instead, it relied on airport operators to
perform criminal history and work authorization checks with limited quality
reviews. Ultimately, TSA had to deny credentials for 4,800 individuals whose
work authorizations had been previously approved by airports because it was
unable to verify their lawful status in the United States.
TSA did not have an adequate monitoring process in place to ensure that
airport operators properly adjudicated credential applicants’ criminal histories.
Chapter 49 of the CFR, part 1542 and TSA Security Directive 1542-04-08G
require airports to complete a fingerprint-based CHRC before approving an
individual for unescorted access. While TSA facilitated the CHRC for aviation
worker applicants, over 400 commercial airports maintained the ultimate
authority to review and determine whether an individual’s criminal history
contained disqualifying crimes under Federal law. 6 However, TSA officials
informed us that airport officials rarely or almost never documented the results
of their CHRC reviews electronically. TSA inspectors may view the hardcopy
results of a CHRC during TSA’s annual security inspection at commercial
airports. However, this is a limited review of as few as one percent of aviation
workers. Without sufficient documentation, TSA cannot systematically
determine whether individuals with access to secured areas of the airports are
free of disqualifying criminal events.
TSA and the airports are not legally authorized to conduct recurrent criminal
history vetting, except for the U.S. Marshals Service Wants and Warrants
database. Instead, airports relied on individuals to self-report disqualifying
crimes. As individuals could lose their job if they report the crimes, individuals
had little incentive to do so. Current FBI law and policy prohibit TSA from
conducting recurrent criminal checks of aviation workers because aviation
worker vetting is considered to be for non-criminal justice purposes. However,
TSA has planned a pilot of the FBI’s “Rap Back” program in order to address
the weakness of not having a recurrent criminal history records check. Under
6

According to TSA officials, TSA inherited criminal history procedures that were developed
prior to the formation of TSA. TSA has drafted a proposed rule intended to strengthen criminal
history vetting. The proposed rule remains in the clearance process as of May 2015.
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the program, TSA and/or the airports will receive automated updates from the
FBI for new criminal history matches associated with individuals who have
undergone criminal history records checks so that they might provide these
results to airports for action. TSA is planning this pilot program for multiple
airports in late 2015. Given recent incidents where aviation workers were
charged with crimes such as smuggling illegal drugs or guns, recurrent vetting
of criminal histories may help TSA identify criminals before they can pose a
risk to transportation security.
As previously discussed, TSA’s Security Directive required that airport
operators first validate an individual’s authorization to work in the United
States before forwarding the individual’s records to TSA for additional
clearance. Based on TSA data, however, airports may not be consistently
verifying that credential applicants possess the immigration status necessary
to work in the United States. Typically, a person “authorized to work” has
lawful status in the United States. If airport operators accurately performed the
verifications prior to sending the applicants’ records to TSA, there should be
minimal discrepancies between an “authorized to work” check and a lawful
status check.
However, according to program officials, TSA has had to send nearly 29,000
inquiries to credential applicants since program inception in 2004. These
inquiries were necessary because TSA had questions about the applicants’
lawful status. Of those individuals, over 4,800 were eventually denied
credentials because TSA determined that they did not prove lawful status even
after appeal. This occurred despite the fact that these individuals had already
received clearance from the airports as being authorized to work. The
magnitude of individuals “authorized to work” for whom TSA cannot confirm
lawful status may indicate a control weakness in the airports’ work verification
process that should be addressed. 7
TSA’s Office of Security Operations performed annual inspections of
commercial airport security operations, including reviews of the documentation
that aviation workers submitted when applying for credentials. However, due to
workload at larger airports, this inspection process may look at as few as one
percent of all aviation workers’ applications. In addition, inspectors were
generally given airport badging office files, which contained photocopies of
aviation worker documents rather than the physical documents themselves. An
official from this office told us that a duplicate of a document could hinder an
inspector’s ability to determine whether a document is real or fake, because a
photocopy may not be matched to a face, and may not show the security
elements contained in the identification document.
Since airports are required to collect and review documents validating an individual’s right to
work in the United States, those documents should contain evidence of lawful status as well.
7

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Additionally, we found that TSA did not require airports to restrict the
credentials of individuals who may only be able to work in the United States
temporarily. Security Directive 1542-04-08G contains no requirement that
airport operators limit the expiration date of an individual’s credential to the
last date they are eligible to work in the United States. Under the Security
Directive, TSA required airports to verify work authorizations upon badge
renewal every 2 years, or whenever another credential was requested. If an
individual’s authorization to work expired within a year or a month of the
individual obtaining the credential, the individual would continue to be cleared
for the credential because the airports did not put an expiration date on the
credential consistent with the term of the work authorization. Without ensuring
that an individual’s credential is voided when he or she is no longer authorized
to work, TSA runs the risk of providing individuals access to secure airport
areas even though they no longer have the authorization to work in the United
States.

TSA Can Improve the Reliability of Its Vetting Data
TSA relied on airports to submit complete and accurate aviation worker
application data for vetting. However, we identified thousands of aviation
worker records that appeared to have incomplete or inaccurate biographic
information. Incomplete or inaccurate aviation worker data can hinder TSA’s
ability to identify individuals who may pose a risk to transportation security.
Vetting Databases Contain Incomplete or Inaccurate Biographic
Information
Although TSA had implemented robust procedures, its vetting of terrorism
information may be impacted by incomplete and inaccurate data. TSA Security
Directive 1542-04-08G requires that TSA not initiate a security threat
assessment of an applicant or current badge holder until the airport operators
submit all biographic information for an individual, including the following:
•	
•	
•	
•	

full legal first, middle and last name,
gender,
date of birth, and
alien registration number or I-94 Arrival/Departure form number for
non-U.S. citizens.

Despite these requirements, we identified records in TSA vetting databases that
contained potentially inaccurate or missing data. Specifically, we identified over
1,500 records in TSA’s screening gateway where an individual’s first name
contained two or fewer characters; over 300 contained a single character. We
identified an additional 75,000 records where individuals with active aviation
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worker credentials were listed in the CSG as being citizens of non-U.S.
countries, but did not have passport numbers listed. Out of those records, over
14,000 also did not list alien registration numbers. According to TSA, the
passport number is a desired field to collect, but is not required.
Through analysis of TSA data, we determined that nearly 87,000 active aviation
workers did not have SSNs listed. Pursuant to the Privacy Act, TSA is not
authorized to require the collection of SSNs, although TSA’s data matching
model identified the SSN as a strong matching element. TSA encouraged
applicants to submit their SSNs during the application process; however, to the
extent individuals applying for aviation worker credentials do not list their
SSNs, TSA may be unable to identify additional strong matches for analysts to
manually review.
For full details of potentially incomplete or inaccurate biographic information,
refer to table 2.
Table 2: Potentially Incomplete or Inaccurate Biographic Information
Provided to TSA
Data Issue
First Names with 2 Characters or
Less
No Alien Registration Number for
Immigrants
No Passport Number for
Immigrants8
No SSNs

Potentially Incomplete/Inaccurate
Records
1,500
14,000
75,000
87,000

Source: DHS OIG analysis of TSA data.

In addition to the data completeness issues that we identified, TSA had
independently determined that airports may not be providing all aliases used
by applicants undergoing security threat assessments. Complete and accurate
aliases are important to the accuracy and effectiveness of TSA’s vetting
processes. As such, TSA had issued correspondence to airports stating that
legal name changes, birth name changes, maiden names, and spelling
variations must be listed on the credential applications, and that TSA would
reject applications where it determined a second name existed that was not
listed on the application. However, in some instances, TSA may not have been
aware that aliases existed for specific individuals. To the extent that airports do
not ensure that aliases are captured and provided to TSA, TSA terrorism
vetting may be limited for those individuals.
While TSA considered passports to be excellent proof for identity verification and work
authorization, it allows individuals to present other documents in place of passports.
8

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TSA has taken steps to address some of these weaknesses. Specifically, TSA
made system enhancements between 2012 and 2014 designed to improve the
quality of data that it received from airports. These enhancements included
policies such as rejecting dates of birth that indicate an individual is 14 years
of age or under, or older than 105 years, or encouraging airports to submit
electronic copies of required immigration paperwork with applications, in order
to expedite the threat assessment process. These enhancements will become
effective for new or reissued badges, which should happen within 2 years as
required by TSA’s Security Directive.

Recommendations
We recommend that the TSA Acting Administrator:
Recommendation 1. Follow up on TSA’s request to determine if its credential
vetting program warrants the receipt of additional categories of terrorism
related records.
Recommendation 2. Issue guidance requiring that TSA’s annual security
inspection process include verification of original documentation supporting
airport adjudication of an applicant’s criminal history and work authorization.
Recommendation 3. Pilot FBI’s Rap Back program and take steps to institute
recurrent vetting of criminal histories at all commercial airports.
Recommendation 4. Require airports to put an end date to credentials of
individuals allowed to work in the United States temporarily.
Recommendation 5. Analyze TSA’s denials of credentials due to lawful status
issues to identify airports with specific weaknesses, and address these
weaknesses with airport badging officials as necessary.
Recommendation 6. Implement all necessary data quality checks necessary to
ensure that all credential application data elements required by TSA Security
Directive 1542-04-08G are complete and accurate.

TSA Response
We obtained written comments on a draft report from the Acting Deputy
Administrator for TSA. We have included TSA’s comments, in their entirety, in
appendix C. TSA concurred with all of the recommendations.

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OIG Analysis of TSA Comments
Management Comments to Recommendation 1
TSA concurs with recommendation 1. TSA officials said TSA is coordinating
with DHS to formulate its request to receive additional Terrorist Identities
Datamart Environment (TIDE) records to carry out its statutory duties to
assess threats to transportation. TSA anticipates completion of this action by
the close of calendar year 2015.
OIG Analysis
The described actions satisfy the intent of this recommendation. This
recommendation will remain open and resolved until TSA provides its formal
written request to the Interagency Policy Committee for additional terrorismrelated records, or evidence that such a request cannot be implemented.
Management Comments to Recommendation 2
TSA concurs with recommendation 2. TSA officials said TSA will take action to
update the Compliance Program Manual to include a requirement for
Transportation Security Inspectors to witness airport badging office review of
applicant criminal history record checks (CHRC) and lawful status during a
comprehensive inspection. The update is expected to be completed by
September 30, 2015.
OIG Analysis
The described actions satisfy the intent of this recommendation. This
recommendation will remain open and resolved until TSA provides an updated
Compliance Program Manual containing additional requirements for the annual
review of airport badging office checks of CHRCs and lawful status.
Management Comments to Recommendation 3
TSA concurs with recommendation 3. TSA officials said TSA plans to initiate an
FBI Rap Back pilot in late 2015 to help ensure full implementation across all
eligible TSA-regulated populations in the future.
OIG Analysis
The described actions satisfy the intent of this recommendation. This
recommendation will remain open and resolved until TSA provides evidence
that it has initiated a Rap Back pilot at commercial airports to provide
recurrent vetting of aviation workers.
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Management Comments to Recommendation 4
TSA concurs with recommendation 4. TSA officials said TSA will publish
guidance, no later than September 30, 2015, to all federalized airports to
ensure that airport badge offices deactivate badges promptly when an
individual’s temporary authorization to work in the United States is
terminated.
OIG Analysis
The described actions satisfy the intent of this recommendation. This
recommendation will remain open and resolved until TSA provides evidence it
has issued guidance to federalized airports to ensure airport badging offices
deactivate badges with temporary work authorizations that have terminated.
Management Comments to Recommendation 5
TSA concurs with recommendation 5. TSA officials said TSA will work with
airport operators to further analyze denials related to lawful status and will use
a risk-based approach to identify and address specific weaknesses, as
necessary, by September 30, 2015. To conduct the analysis, TSA will review
applicable records in TSA systems to identify denials based on lawful status,
validate reasons for the denials, and issue guidance to airports to address any
noted weaknesses.
OIG Analysis
The described actions satisfy the intent of this recommendation. This
recommendation will remain open and resolved until TSA provides evidence of
its review and any guidance issued to airports to address noted weaknesses.
Management Comments to Recommendation 6
TSA concurs with recommendation 6. TSA officials said TSA will continue to
work with airport operators to identify and correct data anomalies, and
implement lessons learned to improve the quality of data received from airport
operators for vetting purposes. TSA will review and analyze data submissions
from airport operators and issue additional guidance to airport operators to
address noted weaknesses by September 30, 2015.
OIG Analysis
The described actions satisfy the intent of this recommendation. This
recommendation will remain open and resolved until TSA provides evidence of
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its review of airport operator data submissions and any guidance issued to
airport operators to address noted weaknesses.

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Washington, D.C

Appendix A
Transmittal to Action Official

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Appendix B
Scope and Methodology
The Department of Homeland Security Office of Inspector General (OIG) was
established by the Homeland Security Act of 2002 (Public Law 107-296) by
amendment to the Inspector General Act of 1978. This is one of a series of
audit, inspection, and special reports prepared as part of our oversight
responsibilities to promote economy, efficiency, and effectiveness within the
Department.
The objectives of our review were to identify potential enhancements to the TSA
vetting process for individuals with access to secure areas of commercial
airports and to determine the accuracy and reliability of data TSA uses to vet
those individuals.
We reviewed applicable laws, regulations, and security directives concerning
TSA’s responsibilities in the vetting of individuals with access to secure areas of
commercial airports. In addition, we reviewed prior OIG audit reports and U.S.
Government Accountability Office reports on commercial airport security.
We conducted site visits in Colorado Springs, Colorado; Annapolis Junction,
Maryland; and Herndon and Arlington, Virginia. During these site visits we
interviewed TSA officials and walked through the control processes and
procedures for vetting individuals applying for credentials granting unescorted
access to secure areas of commercial airports. The processes and procedures
we examined included automated and manual procedures for vetting
individuals against terrorism information; the adjudications process for
immigration and criminal history checks; the coordination, disposition, and
monitoring of terrorism cases; and the identification of new terrorism subjects
using nonobvious link analysis. We did not interview DHS Office of Policy’s
Screening Coordination Office.
We received full databases of individuals holding or applying for secure access
credentials from the CSG and the VAD. We analyzed individuals’ biographic
data for accuracy and other data errors, and matched CSG data against VAD
data to determine whether there was evidence that all individuals holding or
applying for credentials were being vetted against terrorism information. We
also collaborated with the National Counterterrorism Center to perform a data
match of aviation worker’s biographic data against TIDE to determine if TSA
identified all individuals with potential links to terrorism.
We conducted this performance audit between May 2014 and February 2015
pursuant to the Inspector General Act of 1978, as amended, and according to
generally accepted government auditing standards. Those standards require
that we plan and perform the audit to obtain sufficient, appropriate evidence to
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provide a reasonable basis for our findings and conclusions based upon our
audit objectives. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based upon our audit objectives.

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Appendix C
TSA Comments to the Draft Report

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Appendix D
Major Contributors to This Report
Tuyet-Quan Thai, Director, Forensics Division
Scott Wrightson, Audit Manager, Forensics Division
Charles Twitty, Referencer

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Appendix E
Report Distribution
Department of Homeland Security
Secretary
Deputy Secretary
Chief of Staff
Deputy Chief of Staff
General Counsel
Executive Secretary
Director, GAO/OIG Liaison Office
Assistant Secretary for Office of Policy
Assistant Secretary for Office of Public Affairs
Assistant Secretary for Office of Legislative Affairs
TSA Audit Liaison
Office of Management and Budget
Chief, Homeland Security Branch
DHS OIG Budget Examiner
Congress
Congressional Oversight and Appropriations Committees

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ADDITIONAL INFORMATION AND COPIES
To view this and any of our other reports, please visit our website at: www.oig.dhs.gov.
For further information or questions, please contact Office of Inspector General Public Affairs
at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. Follow us on Twitter at: @dhsoig.

OIG HOTLINE
To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and click on the red
"Hotline" tab. If you cannot access our website, call our hotline at (800) 323-8603, fax our
hotline at (202) 254-4297, or write to us at:
Department of Homeland Security
Office of Inspector General, Mail Stop 0305
Attention: Hotline
245 Murray Drive, SW
Washington, DC 20528-0305

 

 

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