The Known Consignor Who Outsourced Packing
A manufacturer holds known consignor status and ships electronic components by air. During a validation review, you find that the company moved its final packing and palletising to a nearby third-party warehouse six months ago. The known consignor's security programme still describes packing as occurring at its own site. The third-party warehouse has no security approval, no access control log, and shares a loading yard with a scrap dealer. The manufacturer's shipments have continued to be tendered as known consignor cargo, about 40 consignments per month. The manufacturer's security manager says the components are low-risk and the volume is small.
1. What is the status of the cargo tendered over the last six months, and what must happen now?
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The cargo tendered over the last six months cannot be treated as known consignor cargo. Known consignor status attaches to a specific approved site and to the processes described in the approved security programme. Once final packing and palletising moved to an unapproved third-party warehouse, the site and process no longer matched the approval, so the protection that justified the status was absent.
What must happen:
- Stop tendering as known consignor immediately for any consignment packed at the third-party site.
- Treat affected cargo as requiring screening or other regulated agent acceptance before loading.
- Notify the competent authority of the change and the non-compliance; the approval holder has a duty to report material changes.
- Assess the third party as a potential regulated agent or as a site requiring its own approval, or bring packing back in-house.
- Update the security programme to reflect actual operations before any reinstatement request.
The security manager's argument that the goods are low-risk and the volume small is not a legal basis for the status. Risk and volume affect the depth of controls, not whether the approval condition is met.
2. How should the validation review be structured to prevent a repeat, and what evidence would you require?
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The review should test the programme against reality, not against the document. A structured approach:
- Map the supply chain from component receipt to aircraft tender, naming every site where cargo is handled, packed, stored, or consolidated.
- Compare each site with the approval and flag any unapproved site or process change.
- Interview staff at both sites to confirm what actually happens, not what the programme says.
- Inspect physical controls at the third-party warehouse: perimeter, access control, visitor logging, staff vetting, and segregation from the scrap yard.
- Check records for the last six months: who packed each consignment, where, and under what supervision.
Evidence to require before reinstatement: a revised security programme naming all sites; approval or regulated agent status for the third-party warehouse; access control and visitor logs; staff vetting records; a written procedure for notifying the authority of future changes; and a sample audit trail linking a consignment to the site that packed it. The review should also set a follow-up inspection within a defined period to confirm the changes held.