With Cargo Screening Mandates Approaching, TSA Proposes Changes to Security Programs  

U.S. cargo screening requirements  

In passing the Implementing Recommendations of the 9/11 Commission Act of 2007, the U.S. Congress required that, as of February 3, 2009, 50% of cargo shipped on passenger aircraft be screened. That standard increases to 100% on August 3, 2010, three years after enactment of the law.  

To attempt to meet the congressional mandate, TSA is taking three steps:  

o requiring that all cargo shipped on narrow-body aircraft be screened at the piece level. This requirement, which has been in effect since October 1, applies to all flights originating from U.S. airports;  

o implementing a Certified Cargo Screening Program under which TSA-approved indirect air carriers and shippers may screen cargo at the piece level prior to tendering to passenger carriers. The airlines will not have to re-screen such cargo and will be able to count CCSP-screened cargo towards meeting the 9/11 Act mandates. TSA anticipates that screening under this program may begin during the final quarter of 2008; and 

o revising existing standard security programs (SSPs) that apply to the various parties regulated by TSA. The agency is currently in the process of releasing these programs for industry comment. As detailed below, TIACA anticipates submitting comments on key issues raised by five of the programs. 

Revised SSPs - TIACA to develop comments 

On September 23, TSA issued proposed revisions to three SSPs. Industry comments are due by October 23 on the Indirect Air Carrier Standard Security Program (IACSSP) and the Aircraft Operator Standard Security Program (AOSSP). TSA also released a revised Foreign Air Carrier Model Security Program (MSP), with a deadline of November 7 for comments (the longer deadline is attributable to the need to allow additional time for non-U.S. parties regulated under the program to comment). Still to come are a revised Full All-Cargo Aircraft Operator Standard Security Program (FACAOSSP) and the All-Cargo International Security Program (ACISP), with anticipated releases by mid-October and comment deadlines in November. 

TIACA is reviewing the revised SSPs and will be submitting comments to TSA that highlight member concerns. In doing so, we are being careful to comply with TSA’s security classification requirements, which restrict access to the SSPs to those with “sensitive security information” (SSI) clearances and a need to know the contents of a specific program. (This means, for example, that passenger airlines regulated under the AOSSP do not have access to the IACSSP and vice versa.) 

Because of SSI restrictions, TIACA will be unable to share publicly its SSP comments. However, TIACA members may contribute to the process of developing comments by sharing their concerns about the revised SSPs directly with Sue Presti, TIACA’s representative in Washington, D.C., who is drafting the TIACA’s statements. TIACA members with SSI clearances and access to one or more of these SSPs should feel free to communicate their suggested comments to Sue at spresti@cox.net.