8. Waivers

Overview

A waiver is a written approval granted to either exempt a facility from a specific TAPA requirement or to accept an alternative compliance solution. A waiver may be requested if an LSP/Applicant cannot meet a specific requirement in the FSR and can justify alternative measures. Waivers are valid for the period of the certification.

All waiver requests for a specific security requirement (either in part or whole) must be submitted via a TAPA Waiver Request form to the Independent Audit Body (IAB)/Authorized Auditor (AA) by the LSP/Applicant (see Appendix B: TAPA Waiver Request form). The requesting LSP/Applicant takes full responsibility for the accuracy of information provided in the waiver request.

Each waiver request must then be submitted through the IAB/AA to the TAPA Regional Waiver Committee for approval. It is the responsibility of the IAB/AA to decide if the request is complete and justifies processing by TAPA; this includes verification of mitigating factor(s) and/or alternative security controls.

Should TAPA officials and/or Buyers challenge that waiver conditions have changed, TAPA will complete a formal investigation and LSP/Applicant understands that the waiver may be revoked by TAPA

Waiver Business Process

If an LSP cannot meet a specific requirement in the FSR, the waiver process below is implemented.

If Waiver Is Denied

If the TAPA Regional Waiver Committee does not approve the waiver request, the LSP/Applicant is required to implement the full security requirements of the FSR.

If Waiver Is Granted

If the TAPA Regional Waiver Committee approves the waiver request, the following actions will be taken:

Waivers for High Value Cages (HVC)

TAPA will consider a waiver to all or part of the HVC requirements if all of the following preconditions are met:

 The waiver request is submitted using the official TAPA Waiver Request form and is endorsed by the IAB/AA.

 The waiver request includes an attached declaration signed by the LSP/Applicant stipulating that no Buyers require an HVC.

 The waiver request includes details of any mitigating measures to ensure that vulnerable goods are not at unnecessary risk of theft or loss.

 Appropriate mitigation actions to minimize risk (where an HVC is not available) are considered and documented in the annual Risk Assessment. Note: TAPA may request to review the Risk Assessment.