The International Air Cargo Association (TIACA) is urging the U.S. Transportation Security Administration (TSA) to expedite its evaluation of new technologies to support the pending 100% cargo screening mandate, scheduled to take effect in August 2010.
In its comments to TSA regarding its “Interim Final Rule of Air Cargo Screening (IFR),” TIACA says it is concerned that much of the equipment currently certified for use for screening is inadequate and ill-suited for processing palletized air cargo. Existing technologies, TIACA says, are mostly only appropriate for the passenger screening environment.
Air cargo screening requirements detailed in the IFR rely on existing technologies, notably TSA-approved methods of screening that include x-ray, explosives trace detection, explosives detection systems, explosives detection canine teams, and physical inspection along with verification of the description of the cargo on the shipping manifest. The rule adds: “TSA may approve additional methods to ensure that the cargo does not pose a threat to transportation security and to assist in meeting the requirements of the 9/11 Act. TSA will continue to consider different technologies or methods for screening cargo transported on passenger or cargo flights. TSA would approve these additional methods and technologies based on their applicability and effectiveness in screening specific commodities.”
“New technologies geared towards the air cargo environment and capable of screening at the consolidated level are urgently needed,” says Ulrich Ogiermann, chairman of TIACA. “The availability of such technologies could have a significant impact on how the 100% screening threshold is met. We therefore urge TSA to ensure transparency in its review procedures , expedite its evaluation of new technologies and seek to deploy new technologies ahead of the August 2010 deadline.”
TIACA has broadly welcomed TSA’s vision for implementing the air cargo screening requirements of the Implementing the Recommendations of the 9/11 Commission Act of 2007 and, in particular, for clearly defining the scope of the rule with respect to foreign-originating flights: “This rule applies only to cargo loaded in the United States. It does not apply to either U.S. aircraft operators or foreign air carriers when they load cargo outside the U.S. and transport it into the U.S., nor to U.S. or foreign all-cargo operations.” U.S. and foreign carriers that load U.S.-bound cargo in other countries must carry out security measures set out in their TSA-approved or accepted security programs.
TIACA also commends TSA for using the rule to harmonize, “to the extent practicable, all requirements for air cargo screening and chain of custody,” as the lack of harmonization has, in the past, created confusion and occasional dislocation in the air cargo supply chain.
While accepting the general rationale behind TSA’s requirement that personnel with unescorted access to air cargo must obtain Security Threat Assessments (STAs) as a means of securing the supply chain, TIACA questions the decision to impose a five-year expiration date on STAs, requiring a reapplication and payment of another fee. TIACA says a more reasonable solution is to design the STA database in an organic manner, to retain information on all STA applicants and recipients, and to periodically cross-check that information with any new information/red flags generated from the various terrorist and law enforcement databases used by TSA to vet individuals.
TIACA also notes that its members and other companies may have overpaid for STAs in the past based on the proposed cost stated in the IFR of approximately $13-$21. The association calls for any overpayments to be refunded to the companies concerned or credited to future STA applications.
TIACA strongly supports TSA’s decision to implement the Certified Cargo Screening Program (CCSP) as a critical component for meeting the 100% screening mandate, and encourages all parties in the air cargo supply chain to evaluate whether to participate in the program. It says screening cannot be the sole responsibility of airlines and it did not support the efforts of some entities to federalize all air cargo screening, making it a TSA function and locating it solely on airport grounds.
“We believe federalization or airline-only screening would unduly crowd this function onto airport grounds, potentially creating significant bottlenecks, and would impose a one-size-fits-all approach to air cargo screening,” Ogiermann says. “While this might be feasible in certain locales, it would likely produce commercial gridlock at many US airports. The flexibility allowed under CCSP is a better fit with the diverse needs of the air cargo supply chain.”
TIACA supports the general concept of CCSP but is concerned about the costs likely to be incurred due to the new screening obligations. Companies that become certified screeners will need to acquire costly equipment for each certified facility. This is significant, particularly given the current economic downturn which has reduced air cargo volumes by roughly 25% and threatens the viability of many companies.
It also warns that TSA’s decision to allow third-party validation of CCSFs could further increase costs and decrease incentives for CCSP participation if it is not carefully implemented. If there are only a few approved third party validators, there would be limited competition, potentially allowing these companies to price their services very aggressively, which in turn might discourage shippers and others in the air cargo supply chain from undergoing CCSF validation.
TIACA urges TSA to do everything possible to encourage participation in CCSP. This will likely require monitoring the possible impact of pricing on CCSP participation and making any necessary adjustments. TIACA will continue to work closely with TSA in support of its objectives.