United Kingdom Overseas Territories Aviation Circular OTAC 178-7 Security Signs Issue 1 October 2017 Effective on issue GENERAL Overseas Territories Aviation Circulars are issued to provide advice, guidance and information on standards, practices and procedures necessary to support Overseas Territory Aviation Requirements. They are not in themselves law but may amplify a provision of the Air Navigation (Overseas Territories) Order or provide practical guidance on meeting a requirement contained in the Overseas Territories Aviation Requirements. PURPOSE This Circular provides guidance on the requirement for airports to sign clearly the boundaries of airside and security restricted areas. It provides examples of suitable signage and advice on the placement and securing of signs. RELATED REQUIREMENTS This Circular relates to OTAR Part 178 Subparts A & H. CHANGE INFORMATION First issue. ENQUIRIES Enquiries regarding the content of this Circular should be addressed to Air Safety Support International at the address on the ASSI website www.airsafety.aero. OTAC s/n 135
CONTENTS 1. INTRODUCTION... 3 2. REQUIREMENTS... 3 3. INTENTION... 4 4. EXTERNAL AIRSIDE AND SRA BOUNDARIES... 4 5. ENTRANCES TO PASSENGER ACCESS POINTS... 6 6. FIRE DOORS AND EMERGENCY EXITS... 6 7. INSPECTING AND PHOTOGRAPHING SIGNS... 7 OTAC s/n 135 Issue 1 Page 2 of 7
1. Introduction 1.1 A key principle of establishing airside and security restricted areas is that any person who gains unauthorized access to those areas can be successfully removed and prosecuted. 1.2 This OTAC provides information on the legal provisions that enable such removal and prosecution, and guidance on signage that will meet the requirements and where that signage should be placed. 2. Requirements 2.1 The Aviation Security and Piracy (Overseas Territories) Order 2000 ( the ASP(OT)O ) makes it a criminal offence to be in a restricted zone without authorization: 21C (1) A person shall not (a) go, with or without a vehicle, onto any part of a restricted zone of - (i) an aerodrome, or (ii) air navigation installation which does not form part of an aerodrome, except with the permission of the manager of the aerodrome, the authority responsible for the air navigation installation or a person acting on behalf of that manager or authority, and in accordance with any conditions subject to which that permission is for the time being granted, or (b) remain on any part of such a restricted zone after being requested to leave by the manager of the aerodrome, the authority responsible for the air navigation installation or a person acting on behalf of that manager or authority. 2.2 OTAR Part 178.3(b) defines airside and security restricted areas as restricted zones for the purposes of this legislation. 2.3 The ASP(OT)O states that adequate signage must be in place for the prohibition of unauthorized access to have effect. In other words, if adequate signage is not in place, any attempt to use the ASP(OT)O to support prosecution of an individual will fail: 21C (2) Subsection (1)(a) above does not apply unless it is proved that, at the material time, notices stating that the area concerned was a restricted zone were posted so as to be readily seen and read by persons entering the restricted zone. 2.4 OTAR Part 178.177(g) requires that the boundaries of airside and security restricted areas shall be clearly signed and these signs shall also promote effective compliance with local legislation or bye-laws. 2.5 Upon successful conviction of an individual, the ASP(OT)O provides for a fine to be imposed, without limiting the extent of that fine: 21C (3) A person who contravenes subsection (1) above without lawful authority or reasonable excuse shall be guilty of an offence and liable on conviction to a fine. OTAC s/n 135 Issue 1 Page 3 of 7
2.6 Finally, the 2016 amendment to the ASP(OT)O provides for forcible removal of an individual from a restricted zone : 21C (4) A police officer, the manager of an aerodrome or a person acting on behalf of the manager of an aerodrome may use reasonable force to remove a person who fails to comply with a request under subsection (1)(b) above. 3. Intention The intention of the OTAR requirements is that the boundaries of airside and security restricted areas should be sufficiently signed so as to deter unauthorized access and to enable a successful prosecution, under the ASP(OT)O, of any person who enters without authorization. 4. External Airside and SRA boundaries 4.1 In order to be readily seen, as required by the ASP(OT)O, and to be long lasting, external signs should be durable, weatherproof and resistant to fading, typically in some form of printed plastic. 4.2 There is no definite requirement in terms of the size of such signs or the size of lettering; but signs should be big enough to be easily visible and readable in all weather conditions: approximately18 ins x 15 ins is suggested as a minimum. SECURITY RESTRICTED AREA Unauthorized Persons Are Liable to Removal and Arrest Penalty: Fine without Limit AIRSIDE AREA Unauthorized Persons Are Liable to Removal and Arrest Penalty: Fine without Limit OTAC s/n 135 Issue 1 Page 4 of 7
4.3 The wording used should: a. state the nature of the restricted zone i.e. Security Restricted Area or Airside Area; and b. state clearly that unauthorized access is not permitted; and c. state the penalties for accessing without authorization; and d. state the relevant legislation. Note: the airport should take legal advice from the Attorney General s office on which law is best used to ensure successful prosecution. It may be thought preferable to rely on local law(s) as well as, or as an alternative to, the ASP(OT)O. 4.4 Another aspect of being readily seen, as required by the ASP(OT)O, is that there are sufficient signs that a person could reasonably be expected to see one. A good guideline, that has been tested in UK courts, is to have a sign placed approximately every 25 metres (82 feet) along the fence line. 4.5 It is equally important that every vehicle gate, including emergency crash gates, carry the same signs even if they are approved security access gates. OTAC s/n 135 Issue 1 Page 5 of 7
4.6 It is wise to fix signs to fences and gates with some form of tough, durable one-time fixing that cannot be easily unscrewed or cut through. 4.7 If a person removes a sign prior to an attempt at unauthorized entry and then claims that there was no sign in that location, then any attempt at prosecution might fail. Signs should normally be fixed on the inside of the fence or gate to prevent such removal. 5. Entrances to passenger access points 5.1 The signs used for the external boundary can also be used at staff and vehicle access points into the SRA and Airside areas and opening for baggage belts. 5.2 However, slightly modified wording might be considered at passenger search points, as follows. SECURITY RESTRICTED AREA Passengers and Authorized Persons Only Beyond This Point Penalty: Fine without Limit 6. Fire doors and emergency exits Fire doors and emergency exits that are not security controlled access points should be alarmed. They will need different signs on the outside (landside) face and on the inside (within SRA) face. SECURITY RESTRICTED AREA This Door is Alarmed Penalty for Misuse: Fine without Limit Outside (landside) face OTAC s/n 135 Issue 1 Page 6 of 7
WARNING EMERGENCY EXIT ONLY This Door is Alarmed Penalty for Misuse: Fine without Limit Inside (within SRA) face 7. Inspecting and photographing signs 7.1 In the event of an unauthorized access that leads to arrest and prosecution, the onus may well be placed on the airport to provide proof that, at the time of the incident, sufficient warning notices were in place. 7.2 The best way to achieve this is to make a photographic record of signage: a. at the time of installation; b. whenever changes to the signage are made; c. yearly as part of quality management or maintenance programmes. 7.3 These photographic records should be supported by security patrol logs and maintenance inspection records that should record whether all relevant signs are in place and undamaged or not. OTAC s/n 135 Issue 1 Page 7 of 7