TIACA ENDORSES TSA’s CERTIFIED CARGO SCREENING PROGRAM 

Under the Implementing the Recommendations of the 9/11Commission Act of 2007, all cargo shipped on passenger airplanes must be screened as of August 2010. The Act also established an interim mandate of 50% screening, which has been effective since February 2009, and which has been implemented with little disruption to the air cargo supply chain. However, the realities of a comprehensive screening requirement are far more demanding, and the potential for supply chain disruption is real and of great concern to TIACA. 

Unless substantial screening occurs early in the air cargo supply chain, airlines will be required to screen significant volumes. Cargo must be screened on a piece-level basis and must be accomplished by a method approved by the legislation (physical search, x-ray, explosive trace detection, explosive detection system, TSA-operated canines, or any detection equipment certified by TSA). Due to space and resource limitations, “de-palletizing”, screening and reconsolidating shipments could prove a substantial challenge, and could lead to significant delays once the 100% requirement goes into effect. 

Recognizing that airlines have neither the space nor resources that would be necessary to screen all cargo tendered to them at their airport locations, TSA created the Certified Cargo Screening Program (CCSP) to allow for screening by other parties in the air cargo supply chain. Participation is open to a variety of supply chain entities, including manufacturers, warehouses, third party logistics operators, distribution centers, and forwarders. 

TIACA strongly endorses the 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. We do not believe that screening can be the sole responsibility of the airlines, nor do we 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. While this might be feasible in certain locales, it would likely produce commercial gridlock at many U.S. airports. The flexibility allowed under CCSP is a better fit with the diverse needs of the air cargo supply chain. 

While TIACA supports the general concept of CCSP, we have concerns about the costs likely to be incurred by our members due to the new screening obligations. Those companies that become certified screeners will need to acquire costly equipment for each of their certified facilities. Passenger airlines may face additional equipment acquisition costs as well. 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. We hope the U.S. Congress can consider providing some relief to companies that incur the substantial cost of screening equipment acquisition. For example, establishing tax incentives or credits for such companies could provide significant financial relief. 

We are also quite concerned that much of the equipment currently certified for use is most appropriate for the passenger screening environment and is ill-suited to the air cargo environment where palletized or other consolidated shipments are the norm. We believe TSA should expedite its review of technologies geared towards the air cargo environment. Given the looming August 2010 deadline, it is essential that new technological options be made available very soon. Without new equipment capable of screening consolidated shipments, we may face considerable disruption to air cargo commercial flows in a 100% screening environment, even with the CCSP.