Compliance Scorecard: Working toward 100 percent screening

The Implementing Recommendations of the 9/11 Commission Act of 2007 requires that the Transportation Security Administration (TSA) establish procedures to ensure screening of 100 percent of the cargo shipped on passenger aircraft by August 2010.

Detractors continue to claim that the goal of 100-percent screening is virtually impossible to reach and that it will cause significant shipping delays. In September, a policy analyst for The Heritage Foundation wrote that repealing the 100-percent screening mandate is one of the crucial steps to strengthening the war on terror, calling it one of several “unworkable mandates … that monopolize DHS time and resources for little to no security gain.”

Douglas Callen, former CSO of the TSA and now the principal consultant at Douglas I. Callen & Associates, disagrees with this assessment: “I think cargo is one of the last remaining huge holes in aviation security,” he says. “When we’re taking so much time to screen passengers getting on board the aircraft and their carry-on baggage and luggage, and we’re not screening the cargo going on — it just makes no sense whatsoever. The vulnerability is certainly there. From a security perspective, screening all cargo is a very important thing to do.”

According to the TSA, 50 percent of air cargo on passenger-carrying aircraft is now being screened. All cargo transported on narrow-body (single-aisle) aircraft has been subject to screening since October 2008. But while narrow-body aircraft carry the majority of the passengers flying daily from U.S. airports, wide-body aircraft carry around 75 percent of U.S. cargo, and these are the aircraft still going unscreened.

Cargo transported on these aircraft is consolidated into large shipments of up to 200 pieces, packed together on pallets and shrink-wrapped. It would be impractical and time-consuming to disassemble all these shipments to screen all items at the piece level, then reassemble the pallets for shipping. As of this writing, no TSA-certified technology can accomplish such screening without requiring the breakdown of consolidated shipments. In addition, few airports have the resources or the facilities to do such wide-scale screening on-site.

The TSA has created a program called the Certified Cargo Screening Program (CCSP) to ease the burden of on-site screening. The CCSP is a voluntary program that allows facilities to become TSA certified to screen their own air cargo before they deliver it to the carrier. Manufacturers, distributors, third-party logistics providers, and other organizations that transport cargo by air carrier may apply to become Certified Cargo Screening Facilities (CCSFs). CCSFs must meet TSA’s rules for security and chain of custody, and they must undergo a facility assessment and periodic inspections to maintain their certified status.

Paul Leodler, Director of Security, Western U.S. & Mexico for Cardinal Health, sees the CCSP as the most sensible way for his company to work toward the 100-percent screening mandate. “We’re shipping pharmaceutical product, and we’re responsible for the supply chain until it arrives at the next licensed facility, so until the pharmacy or hospital receives it and signs for it, it belongs to us no matter whose possession it is in,” Leodler says. “We’re responsible for these products by law. So the idea of having a third party opening our products and screening controlled drugs is a real issue for us. Of course there’s a risk of loss there, and a lot of our products are refrigerated and cannot be opened. So it’s not an option for us to allow any other party to screen our shipments. We have to be CCSP certified so we can verify that the products are free of contraband and will not be opened in transit.”

Cardinal has seven facilities in the process of being certified for CCSP and expects that the certification will be complete before the August deadline. Some have argued that the CCSP is not accessible to all organizations because of the cost of screening equipment and preparing the facility for certification. Leodler says that hasn’t been a problem for Cardinal. “It could be costly depending on how you screen, but we do it as inexpensively as possible,” he says. “We actually open the boxes and look inside, so it’s a little labor cost to us, but that’s all. The TSA does require a secure area within the facility for the screening to take place. I can see how in some facilities you may have to build something, but because ours are pharmaceutical distribution facilities, they’re all secure to start with, so that has not been a cost issue for us.”

Even those who disagree with the screening mandate agree, for the most part, that the CCSP is a smart program that has so far been successful. But it may not be an option for all facilities, and that will leave TSA responsible for a notable increase of cargo screening in order to meet the mandate. In preparation for this, TSA has increased its canine and inspection teams significantly over the last three years. In addition, the Department of Homeland Security Appropriations Act of 2010 sent to the President at the end of October provided TSA with more funding to increase the number of inspectors and canine teams and to step up testing and deployment of screening technologies.

New screening technologies will be key to the mandate’s success. “You don’t know day-to-day or flight-to-flight how much cargo you’re going to have to screen until it gets to the carrier. So it’s a logistical issue, it’s a scheduling issue, it’s a volume issue,” Callen says. “It’s important, logical and cost-effective to find good methods of analyzing the problem, the shippers, and the cargo, and responding to that. In order to get around the problem of volume and time, you need to use some kind of smart logic technology. Companies are doing that sort of thing right now — taking a huge problem and bringing it down to a manageable level so you can spend your resources more wisely.”

TSA has launched the Indirect Air Carrier (IAC) Screening Technology Pilot to help identify the technologies that will be the most assistance in achieving 100-percent screening. Through the program, TSA tests screening technology in a live environment.

While the 100-percent screening mandate is certainly a lofty one, the TSA and the shipping community are working to make it a reality.

Marleah Blades is senior editor for the Security Executive Council, a risk mitigation research and services organization for senior security and risk executives from corporations and government agencies responsible for corporate and/or IT security programs. In partnership with its research arm, the Security Leadership Research Institute, the Council is dedicated to developing tools that help lower the cost of security programs, making program development more efficient and establishing security as a recognized value center. For more information about the Council, visit