Nearly two decades ago, our nation was the target of air-borne terrorists in four planes who flew aircraft into and destroyed both towers of the World Trade Center in New York City, and also broadsided a wing of the Pentagon in suburban Washington, DC.
In essence, the United States and our air services were taken advantage of and used in an attack against American citizens. After one of the most somber and grim days in America’s history, came an influx of governmental regulations and mandates that were meant to protect its citizens from future terrorist attacks. In an ever-changing world of extremists and rogue individuals is a constantly changing amount of ways that explosives can be concealed within cargo.
We are still living with the consequences of these events, both for commercial air passengers, and the air shipment of cargo. Cargo shipped via air is carried in both in the belly-hold of passenger aircraft, as well as on dedicated freighters. Currently, cargo has become so vital, that during this CODIV-19 crisis, airlines are busily converting former passenger aircraft into cargo carriers.
On the cargo side, things moved a bit slower, but now, there is a full suite of processes and products that have made the shipment of cargo, both belly cargo as well as freighter, safer and more secure. But as with all things in this world, things change, and the bad guys are still looking for cracks in our security process. And one of these cracks is the need for 100% cargo screening on dedicated freighters.
A Short History of Laws and Processes Now in Force
The 9/11 Commission Act of 2007, required that by February 3rd, 2009, 50% of all cargo carried on passenger aircraft in the United States had to go through a security screening.
Since October 2008, the Transportation Safety Administration (TSA) has required 100% screening for all cargo carried on narrow-bodied passenger planes, which accounts for 95% of all flights in the US. Since August 2010, the 100% screening requirement has applied to all flights, including flights into the USA.
To ensure the movement of cargo is not impaired, the TSA developed the Certified Cargo Screening Program (CCSP), a voluntary program designed to move some of the screening processes to shippers, third-party logistics providers (3PLs), air forwarders, and independent screening services.
Those companies that want to take part in this program can apply to operate Certified Cargo Screening Facilities (CCSFs). Cargo screened at a CCSF and then transported through a secure chain of custody will not need to be inspected at the airport, which means no delay in transportation to the customer.
CCSP was being rolled out in a phased approach. The first phase was rolled out with a small group of logistics companies in number cities in 2008, including San Francisco, Chicago, and Philadelphia.
Cargo Screening K9s Are An Essential Part of the Solution to TSA’s 100% Cargo Screening Mandate
After 9/11 the United States became much more aware of the possibilities and places in which explosives could be hidden. One largely targeted area is the airline industry. In an effort to make the industry and those working in it safer, legislation was created that required all cargo to be 100% screened. Through the program’s life, modifications have been made across the board to improve efficiency. K9 and handler teams are the newest and most logical step in combating multiple efficiency issues within the Certified Cargo Screening Program (CCSP) and keeping up with the flow of commerce’s rapid pace.
What is the Certified Cargo Screening Facility?
Cargo Screening Facilities (CCSF). These facilities are third-party and voluntary. Any agency who wants to join the CCSP and become a CCSF simply needs to apply.
To be a Certified Cargo Screening Facility (CCSF), organizations must screen cargo in accordance to a TSA approved security program which follows a strict set of rules ensuring chain of custody from the CCSF to the airport is upheld. Facilities certified under the CCSP must follow rules created by the TSA.
Roughly three hundred companies have become Certified Cargo Screening Facilities under this new direction and new companies are added to the list daily.
The Alternatives
Although the technical devices used by the CCSP and CCSF are useful and efficient at detecting possible explosive devices within air cargo, they are not efficient in regards to large air cargo such as palletized items. Palletized items do not fit within many of the screening machines, and therefore have to be taken apart and put back together. The process heavily disrupts the efficiency of the CCSP and puts kinks in the flow of commerce.
The solution to this specific problem came in the form of man’s best friend: canines. The TSA started the canine solution by creating the National Explosive Detection Canine Team Program (NEDCTP). When this program failed to provide enough trained canine and handler teams, the TSA opted for an extended solution by allowing third-party canine teams to get certified by TSA’s screening requirements and work within certified facilities. The Third-Party Canine-Cargo (3PK9 or 3PK9-C) Program was created in 2018 to bridge the gap between the public and private sector. By undergoing a certification process aligned with TSA’s standards. Over time, the 3PK9 program has transformed and the most recent version is called the Certified Cargo Screening Facility-K9 (CCSF-K9).
Where Do We Go from Here?
The new international security standards for the transport of air cargo on all-cargo aircraft are slated to take effect in 2021. The Transportation Security Administration is accepting through July 9 information from the air cargo industry (including manufacturers, shippers, suppliers, warehouses, e-commerce fulfillment centers, third-party logistics providers, and air carriers) on how to reduce the burden of complying with these standards.
By June 30, 2021, member countries of the International Civil Aviation Organization must ensure that all international air cargo transported on commercial aircraft is either (1) screened to a level intended to identify and/or detect the presence of concealed explosive devices or (2) under appropriate security controls throughout the cargo supply chain to prevent the introduction of concealed explosive devices.
TSA states that while its existing regulatory structure permits it to impose a 100 percent screening requirement for all-cargo aircraft, such a requirement would increase the cost of air cargo transportation. TSA is therefore seeking to identify alternatives that maximize security benefits without imposing excessive, unjustified, or unnecessary costs.
Specifically, TSA is considering the development of a new regulation, order, or security program that would enable manufacturers, warehouse operators, or other shipping or logistics services providers to be recognized by TSA as having a system of security controls sufficient to allow them to introduce cargo into the secure supply chain for all-cargo aircraft without a need for screening. TSA is seeking public comment on the operational concerns, costs, and benefits of such a program, which would align conceptually with TSA’s Certified Cargo Screening Standard Security Program.
The elements of this challenge have a parallel with what ground carriers call, the last mile of a delivery; and the last mile is for the cargo industry via the TSA is to reach 100% cargo screening. The agency has made dramatic and measurable progress in protecting air travel. However, checking 100% of cargo is no easy accomplishment. The variation and permutations of how cargo can be shipped, disguised, hidden and routed are infinite and while the ways to check via technology or K-9’s are impressive, they are not infallible.
As mentioned above, and to their credit, the TSA is asking for ideas from the industry on what ideas the stakeholders have that may improve the process, or reduce the time and the cost of compliance because that “last mile” may turn out to be expensive and time consuming. *
*From JDSUPRA, Trade Consultants, August 2020
Specifically, TSA is considering (among other options) whether it could “rely on other security controls … [that] could be applied to entities not currently regulated by TSA” within the supply chain to ensure a level of security commensurate with the screening of cargo before transport. This would “enable manufacturers, warehouse operators, or other shipping or logistics services providers to be recognized by TSA as having a system of security controls that are sufficient to allow them to introduce cargo into the secure supply chain for all-cargo aircraft, without a need for screening.” Such a screening mandate could present new business opportunities for manufacturers, warehouse operators, and logistics and shipping companies that have the capability to implement secure supply chain controls.
