Compliance Scorecard

Last August, the President signed the Implementing Recommendations of the 9/11 Commission Act of 2007, requiring the Transportation Security Administration (TSA) to establish procedures that ensure screening of 100 percent of the cargo shipped on passenger aircraft by 2010. This means every carton on every pallet must be screened to ensure no explosives are being shipped. TSA is asking that 50 percent of cargo shipped in this manner be screened by February 2009.

Screened by whom? It was originally thought to be the airlines’ responsibility, but with airlines still reeling from the impact of passenger and checked baggage screening, it did not seem likely they would be able to meet another screening requirement on such a short timeline. Instead, the TSA is developing the Certified Cargo Screening Program (CCSP), a voluntary program that will allow manufacturers and shippers to become Certified Cargo Screening Facilities (CCSFs) by meeting rigorous security and chain-of-custody standards. The program’s structure and security requirements are similar to those of the Customs-Trade Partnership against Terrorism (C-TPAT).

The TSA’s CCSP is currently in Phase 1; they are working through nine airports to help participating companies set up pilot screening facilities. In this phase, TSA pays for the required background checks and many other facets of the program, but when the pilot ends — probably this fall — and the rules are finalized, the cost and responsibility of complying will lie in the laps of manufacturers and shippers. Some companies will have to buy detection equipment, sniffers, screeners or swabs, or they will have to hire enough manpower to physically look through all cargo shipped on passenger jets. Clearly, the costs and implications of the CCSP could be enormous for businesses that ship this way.

Since the program is still in its early stages, the precise impact of its future requirements are not yet known. If your organization is C-TPAT-certified, you will probably have a head start to becoming a CCSF if your business chooses to apply. If you are not involved in C-TPAT, find and review a copy of the TSA facility security requirements and recommendations. They will help point you in the right direction.
The best step to take at this stage is to reach out to other executives in your organization, specifically those in charge of the supply chain. They may be unaware of the impact this law could have on their business, or they may know less than you expect. Either way, it is important to begin forming a team now to discuss the company’s options in the face of this new rule.

Greg Halvacs is a member of the Security Executive Council and is senior vice president and CSO for Cardinal Health, an $89 billion dollar pharmaceutical services company. Mr. Halvacs has more than 22 years of experience in the security industry and is a member of ISMA and ASIS. Marleah Blades is Senior Editor for the Security Executive Council.. The Security Executive Council maintains a large and growing list of laws, regulations, standards and guidelines that impact security (https://www.securityexecutivecouncil.com/public/lrvc). For more information, visit www.SecurityExecutiveCouncil.com/?sourceCode=std.

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