A Master Crew List (MCL) is a list the Transportation Safety Administration (TSA) mandates every charter (non-scheduled commercial) operator have on file when flying to or within the U.S. Whenever APIS is transmitted by a charter operator using their carrier code, this information is vetted against the on-file MCL. This process ensures that information provided for APIS is correct. MCL requirements apply to all charter operators, regardless of aircraft registry, for all flights to and within the U.S.

The following is an overview of what you need to know:

1. MCL basics

MCL requirements were introduced back in late 2001 when APIS, in UN EDIFAC format, was implemented for general aviation (GA). Once it was determined that charter operators had to submit APIS, just like scheduled commercial airlines, it was determined that they must also keep a MCL on file with TSA. Whenever APIS is filed, this is compared against information on the MCL. Private operators, by contrast, report APIS in a different way – via eAPIS – and have no requirement to maintain MCLs. A MCL covers all crew on the gen-dec — anyone listed as CR1 or CR2 — including pilots, flight mechanics and flight attendants.

2. Carrier Code IDs

All charter operators flying to or within the U.S. must have Carrier Code IDs. TSA and CBP base their checks on carrier codes and these codes are how they know who a particular MCL is for. Carrier codes are applied for via a CBP APIS account manager. It usually takes about 48 hours to obtain a three digit (a mixture of numbers and/or letters) carrier code but, in some cases, requests are processed in less than 48 hours. Information needed to generate a carrier code includes operator name, address and contact info.

3. Crew may be listed on multiple MCLs

Once registered on a MCL, a crew member may operate any aircraft under that operator’s carrier code. Crew may also fly for multiple operators, under different MCLs and carrier codes, if listed on the respective MCLs. Carrier codes are operator specific but you may fly any aircraft, even leased aircraft, associated with that operator.

4. MCL information/documentation

When submitting an initial MCL full names of all crew, dates of birth, country/city of birth, residential addresses, licenses, passport numbers and expiry dates must be provided. This is submitted to TSA who will send you an acknowledgment. It generally takes about 24 hours for TSA to vet crew information and enter your MCL in the system.

5. Register only one passport per crew member

When submitting MCL information you only register the primary passport that the crew member will be using. If a crew member uses different passports, or changes passports, the MCL must be updated or the operator will receive an alert when APIS is filed. For U.S. permanent residents “Green Cards” are considered the primary travel document but only the passport is registered on the MCL and this is the only document vetted.

6. MCL and APIS mismatches

There’s potential for APIS and MCL mismatches if operators or 3rd-party providers do not update MCL information or if they send in old information when filing APIS. TSA will capture any errors or missing information and a mismatch alert will be sent when APIS is filed. The operator will then have an opportunity to correct the APIS or MCL error online, so the information matches. When filling APIS and the system recognizes a crew member not on the MCL it will provide an opportunity to add the crew name while you’re online. When you add crew information this automatically updates on your MCL. If APIS/MCL mismatches are not addressed or corrected there could be potential fines involved. And, if a crew member noted on an APIS transmission is on a no-fly list you’ll need to substitute the crew member.

7. MCL updates and penalties

It’s always important to ensure MCL information is correct and up-to-date. If information changes, such as a passport number/expiry or residential address etc, this should be immediately updated — either via your 3rd-party provider or directly. There’s a benefit in having MCL updates managed by the same provider that’s already filing your APIS transmissions. We recommend MCL-related information be reviewed on a regular basis, at least every few months, and new crew members added to the MCL without delay. While we’ve not come across situations where an operator has been blacklisted, fined or reprimanded for not updating a MCL it’s always best to avoid potential APIS alerts and associated issues.

Final thoughts

Looking to the future we do not know if current MCL requirements will remain in place. There’s a certain redundancy in the way TSA and CBP collect and vet flight crew information as a MCL just confirms information submitted via APIS. Both agencies are always looking at ways to streamline and improve efficiency of inter agency processes and current MCL requirements may, potentially, change in future.

Questions?

If you have any questions about this article contact me at elonholmes@univ-wea.com.