This is necessary to introduce consistency. Some sectors of the aviation security industry were in breach of the Private Security Industry Authority Act 2001 (PSIA), the legislation regulating the private security industry (including the SIA licensing provisions), which requires certain security functions to be licensable. Staff contravening the PSIA are liable to committing an offence. Exemptions also avoid dual regulation of the aviation security industry under the NASP and the PSIA.
The Department for Transport submitted an application for an exemption from the requirement for certain aviation security personnel engaged in roles outside the airport SRA to obtain a SIA licence. The PSIA gives the Secretary of State powers to exempt staff who are subject to 'suitable alternative arrangements'. These are defined in the PSIA as arrangements that are "equivalent, for all practical purposes so far as the protection of the public is concerned, to those applying to persons applying for and granted licences".
This equivalence is determined by a comparison with the SIA's licensing requirements. Suitable alternative arrangements for the purposes of a licensing exemption necessitate imposing a baseline vetting requirement of a background check (which is comparable with the SIA licensing regime) in order for the request for an exemption to be granted. The alternative to not seeking an exemption would be for aviation security staff to obtain a SIA licence. This would be vastly more onerous in cost and time consuming. The cost of obtaining a CRC is less financially burdensome. Moreover, securing a SIA exemption maintains a single regulatory approach for respective sectors of industry and clear lines of responsibility.