Site Access Management for MPI Approved Transitional Facilities

The Compliance Reality for Transitional Facilities

An MPI Approved Transitional Facility (TF) is an approved premises where imported goods are held, inspected, or treated before being granted biosecurity clearance. Cold stores, container yards, freight terminals, and bonded warehouses all fall under this definition.

Operating a TF means you are not just a logistics business. You are an authorised part of New Zealand's biosecurity border — and MPI holds you to that standard. Your site must be managed accordingly: the right people, with the right training, carrying out the right activities, with records to prove it.

For many TFs — particularly those handling air freight — there is a second layer of compliance on top of MPI: the Civil Aviation Authority's requirements for air cargo security. Managing both simultaneously, across a workforce that often includes contractors and casuals, is the day-to-day operational reality.

Three Compliance Layers Every TF Needs to Manage

These three frameworks overlap significantly. A contractor arriving at your TF needs to have completed biosecurity induction, hold current site induction, and — if your facility handles air cargo — may also need to be validated against your aviation security obligations. Managing this manually, through spreadsheets and paper sign-in sheets, is how compliance gaps appear.

How SiteKey Addresses the Site Access Problem

SiteKey is a New Zealand site access and visitor management platform built for operational sites — warehouses, logistics facilities, and distribution centres. For Transitional Facilities, it addresses the practical access control and training verification challenges that sit at the intersection of all three compliance frameworks.

SiteKey's compliance gate is the key feature for TF operators. Rather than relying on a manager to manually check whether an arriving contractor has completed their biosecurity induction or holds current AP training, SiteKey automates it at the gate. If the training isn't current, the gate doesn't open.

• QR pass check-in — staff, contractors, and visitors scan in and out. No clipboards, no paper.
• Training compliance gate — linked to your training platform, SiteKey blocks entry for anyone whose induction or AP training has lapsed.
• Live evacuation list — real-time record of who is on-site, accessible instantly from any device. Audit-ready at all times.
• Contractor pre-registration — contractors complete required training before they arrive. They scan in on day one, verified and ready.
• Automatic sign-out — anyone still showing as on-site at end of shift is automatically signed out. Records stay clean.
• Full audit trail — who was on-site, when, and for how long — exportable for MPI or WorkSafe if required.

Connecting Training to Site Access

Under MPI requirements, activities at a Transitional Facility that require an Accredited Person must be carried out by someone who actually holds current AP accreditation. That sounds obvious — but in practice, tracking who is trained, what their training covers, and whether it's current across a team of contractors and casuals is operationally difficult.

SiteKey's compliance gate can be configured to verify completion of site inductions and training courses hosted on your own learning platform before allowing site access. This means staff and contractors who haven't completed required training can be flagged at the gate — rather than discovered during an MPI audit after the fact. AP accreditation through QCONZ is maintained separately; SiteKey manages site-specific inductions and the broader access control layer.

For businesses that need site induction training built and hosted alongside SiteKey, Capability Solutions can deliver both — the training content and the compliance gate from one supplier, connected end to end.

AirCertifyNZ and CAA Obligations for Air Freight TFs

For Transitional Facilities that operate as Regulated Air Cargo Agents (RACAs), there is a second compliance framework running alongside MPI: the Civil Aviation Authority's Civil Aviation Rule 109 (CAR 109), which governs the security of air cargo entering New Zealand's aviation supply chain.

Under CAR 109, RACAs are responsible for validating and maintaining oversight of their 'known customers' — exporters and freight principals whose cargo they accept and vouch for within the secure supply chain. AirCertifyNZ, a programme run by the Customs Brokers and Freight Forwarders Federation of New Zealand (CBAFF) in collaboration with OneReg and IVS, is designed to help RACAs meet these obligations efficiently. The programme provides a unified, industry-driven approach to known customer validation — simplifying what is otherwise a labour-intensive compliance process for air freight operators.

For TFs that straddle both MPI biosecurity and CAA air cargo security obligations, the operational picture is complex. SiteKey handles the site access and workforce compliance layer — who is on-site, whether they are trained and authorised — while AirCertifyNZ addresses the customer-facing aviation security obligations at the cargo supply chain level. Both are relevant; neither replaces the other.

What Good Looks Like for a TF Operator

A well-run Transitional Facility manages compliance not as a series of separate checklists, but as an integrated system. That means:

• Every person on-site is registered, their training is current, and their presence is recorded automatically
• Staff and contractors complete required inductions before arriving on-site — no manual chasing on the day
• An accurate on-site record exists at all times, exportable for MPI, WorkSafe, or CAA on request
• Contractors arrive pre-registered and pre-inducted — no delays, no paperwork on the day
• Air cargo security obligations are managed through a recognised programme, not ad-hoc record-keeping

This is achievable without expensive enterprise software or large compliance teams. The right tools, configured correctly for your specific facility, handle the routine work — so your people can focus on the operational work that matters.