Department of Homeland Security 

Office of Inspector General 

Security of Air Cargo During Ground 


Transportation 


(Redacted)
 

OIG-10-09 November 2009 
Offce of Inspector General

U.S. Department of Homeland Security

Washington, DC 20528

Homeland

Security

NOV - 5 2009

Preface

The Department of Homeland Security (DHS) Office ofInspector General (OlG) was

established by the Homeland Security Act of 2002 (Public Law 1 07 -296) by amendment

to the Inspector General Act of 1978. This is one of a series of audit, inspection, and

special reports prepared as part of our oversight responsibilities to promote economy,

efficiency, and effectiveness within the department.

This report addresses the strengths and weaknesses of the Transportation Security

Administration's efforts to secure air cargo during ground transportation and handling

before it is loaded onto planes for air shipment. It is based on interviews with employees

and offcials of relevant agencies and institutions, direct observations, and a review of

applicable documents.

The recommendations herein have been developed to the best knowledge available to our

offce, and have been discussed in draft with those responsible for implementation. We

trust this report wil result in more effective, efficient, and economical operations. We

express our appreciation to all of those who contributed to the preparation of this repoii.

Richard L. Skinner

;t~c/~

Inspector General
 

Table of Contents/Abbreviations 

Executive Summary.............................................................................................................1
 

Background..........................................................................................................................2 

Results of Audit ...................................................................................................................5 

Air Cargo Security Vulnerabilities ................................................................................5 

Air Cargo Security Inspections....................................................................................10 

Recommendations........................................................................................................14 

Management Comments and OIG Analysis ................................................................16 

Appendixes 

Appendix A: Purpose, Scope, and Methodology.......................................................21 

Appendix B: Management Comments to the Draft Report.......................................23 

Appendix C: Process for Ground Transportation of Air Cargo ................................31 

Appendix D: Security Threat Assessment Requirements..........................................32 

Appendix E: Major Contributors to This Report ......................................................33 

Appendix F: Report Distribution ..............................................................................34 

Abbreviations 

DHS Department of Homeland Security 

FY Fiscal year 

OIG Office of Inspector General 

PARIS Performance and Results Information System
 

TSA Transportation Security Administration 
OIG
 Department of Homeland Security 

Office of Inspector General 

Executive Summary 

This report addresses the effectiveness of the Transportation 

Security Administration’s efforts to secure air cargo while it is 

handled or transported on the ground, prior to being shipped on 

passenger aircraft. 

The Transportation Security Administration could improve its 

efforts to secure air cargo during ground handling and 

transportation. We determined that personnel were sometimes 

accessing, handling, or transporting air cargo without the required 

background checks or training. For example, of the drivers 

we tested were handling or transporting air cargo without the 

required background checks. We also reviewed drivers’ records 

and identified that 23% did not satisfy the required training and 

testing requirements. 

The agency’s inspection process has not been effective in ensuring 

that requirements for securing air cargo during ground 

transportation are understood or followed. The inspection process 

has focused on quantity rather than outcomes and ensuring 

corrective actions. Automated tools to assist inspectors in 

analyzing results and focusing their oversight efforts on high-risk 

areas in air cargo security were not adequate. As a result, air cargo 

is vulnerable to the introduction of explosives and other destructive 

items before it is loaded onto planes, potentially creating risks for 

the traveling public. 

We are making six recommendations to the Transportation 

Security Administration that, when implemented, would strengthen 

the security of air cargo during ground transportation. The agency 

concurred with five recommendations and partially concurred with 

one recommendation. 

Security of Air Cargo During Ground Transportation 

Page 1
 
 

 

Background 

The Transportation Security Administration (TSA) is responsible 

for overseeing aviation security and ensuring the safety of the air 

traveling public. This responsibility includes screening, 

inspecting, and ensuring the security of freight that is to be 

transported on aircraft. TSA estimates that 12 million pounds of 

cargo is loaded onto passenger-carrying planes every day. Air 

cargo includes items such as electronic equipment, automobile 

parts, clothing, medical supplies, fresh produce, and human 

remains. 

Air cargo begins with a shipper who tenders one or more 

packages to an indirect air carrier, also known as a freight 

forwarder. Among other things, indirect air carriers consolidate 

cargo from many shippers and deliver it to air carriers. The 

indirect air carrier’s trucking employees, or authorized 

representatives1

 transport the cargo in locked, sealed, or 

monitored trucks to the airlines for air shipment. Appendix C 

provides more details regarding the air cargo ground 

transportation process. 

TSA regulates air carriers, indirect air carriers, and all-cargo 

carriers through requirements in the agency’s security programs. 

These include the Aircraft Operator Standard Security Program, 

Model Security Program, Indirect Air Carrier Standard Security 

Program, and Full All-Cargo Standard Security Program. The 

regulated entities must ensure that all of their authorized 

representatives comply with the security programs. TSA’s air 

cargo security programs are designed to protect persons and 

property traveling by air against the introduction of any 

unauthorized person, explosive, incendiary, or destructive 

substance or item into cargo onboard an aircraft, while not 

impeding the flow of commerce. 

1

 An authorized representative, such as an agent, contractor, or subcontractor, is an individual who is not 

an employee of a regulated entity but is authorized to act on the behalf of the entity to perform measures 

required by the security programs. 

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To help ensure compliance with the air cargo security 

requirements, TSA relies on the oversight carried out by 

approximately 435 cargo inspectors located throughout the 

United States. Under each security program, inspectors review a 

number of required items as they apply to each regulated entity. 

The cargo inspectors perform the following types of inspections: 

•	 Comprehensive inspections are in-depth analyses of an 

entity’s security operations that address every regulatory 

requirement, and are conducted at least once per year. 

•	 Supplemental inspections provide emphasis for items 

that require more frequent attention. For example, these 

inspections are used to follow up on findings discovered 

during previous inspections, or are based on national or 

local intelligence or trends. Supplemental inspections are 

conducted on an as-needed basis. 

•	 Special emphasis inspections focus on a particular issue 

or area, such as access control. Directed by TSA 

headquarters, these inspections are narrowly focused on a 

regulatory requirement and may be time sensitive. 

The inspectors also provide the opportunity for regulated entities 

to ask questions and seek clarification regarding policies and 

procedures. According to TSA’s Fiscal Year (FY) 2009 

Regulatory Activities Plan, this outreach is a means to enhance 

partnership with industry, stakeholders, and with other 

government agencies. Inspectors should conduct outreach in 

their area of responsibility on an ongoing basis to provide 

guidance regarding transportation security to regulated entities. 

The type of outreach conducted may be related to guidance 

regarding security measures, security meetings, special events, 

exercises, TSA-approved training, and other transportation 

security-related efforts. 

The inspectors document the results of their inspections in TSA’s 

Performance and Results Information System (PARIS). PARIS 

is a tool for managing and analyzing data, monitoring 

compliance, measuring performance, and researching allegations 

Security of Air Cargo During Ground Transportation 

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of noncompliance with statutory or regulatory air cargo security 

requirements. 

In 2007, the Congressional Research Service reported that the 

large estimated number of cargo thefts and other cargo crimes 

indicated potential weaknesses in air cargo security.2 The 

Congressional Research Service reported that cargo crime is 

committed either by or with the assistance of cargo workers, and 

therefore, anticipated that increased security measures, such as 

conducting more stringent or more frequent background checks 

of cargo handlers and transporters and enhanced physical 

security of cargo operations areas would likely improve the 

capability to detect criminal activity in air cargo operations. 

In June 2008, TSA’s Office of Intelligence reported that 

transportation was the most threatened sector for terrorist 

activity, and aviation was a high-priority target. TSA noted that 

terrorists would likely continue to seek out vulnerabilities and 

bypass security measures for cargo shipments on passenger 

aircraft. Like the Congressional Research Service, TSA 

identified insiders - individuals with authorized access to 

sensitive areas, equipment, or information - as one of the greatest 

threats to aviation. 

To strengthen air cargo security, TSA recently introduced the 

voluntary Certified Cargo Screening Program. This program 

relies on vetted, validated, and certified cargo screening facilities 

to screen cargo prior to tendering it for transport on passenger 

aircraft. The recommendations of the 9/11 Commission Act of 

2007 mandates the Department of Homeland Security (DHS) to 

establish a system to screen 100 percent of cargo transported on 

passenger aircraft by August 2010. Although the Certified Cargo 

Screening Program will relieve the air carriers from having to 

screen all of the cargo to meet this mandate, air carriers must 

ensure that all cargo has been screened prior to flight. One of the 

new program’s key tasks is controlling and tracking the screened 

air cargo’s chain of custody, which includes a network of 

2

 Congressional Research Service Report for Congress “Air Cargo Security,” Updated July 30, 2007. 

Security of Air Cargo During Ground Transportation 

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regulated entities and their third party carriers responsible for 

ensuring the safety of air cargo. 

Results of Audit 

TSA could improve its efforts to ensure air cargo is secure during ground 

handling and transportation. We determined that personnel were accessing, 

handling, or transporting air cargo without the required background checks or 

training. For example, we 

•	 gained access to air cargo at of the facilities visited, 

•	 identified of the drivers tested were handling or transporting air 

cargo without required background checks, and 

•	 identified 23% of the drivers tested did not satisfy the required training 

and testing requirements. 

Despite identifying and reporting similar vulnerabilities, TSA’s inspection 

process has not effectively ensured improved compliance and awareness of 

TSA’s requirements. The process has focused on quantity rather than outcomes 

and ensuring corrective actions. Automated tools to assist inspectors in 

analyzing results and focusing their oversight efforts on high-risk areas in air 

cargo security were not adequate. As a result, air cargo is vulnerable to the 

introduction of explosives, incendiaries, and other destructive items before it is 

loaded onto planes, potentially creating risks for the traveling public. 

Air Cargo Security Vulnerabilities 

Air carrier employees or their representatives were accessing, handling, 

or transporting air cargo without the required background checks or 

training. During the first three quarters of FY 2008, TSA conducted 

6,767 cargo security inspections, of which 2,031 inspections (30%) 

identified 2,640 air cargo security violations including: 

Security of Air Cargo During Ground Transportation 

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•	 254 violations related to access controls, 

•	 731 violations related to security threat assessments, and 

•	 1,655 violations of security training and testing requirements. 

Our audit also identified security violations in these areas. 

Access Controls 

TSA’s security programs require regulated entities to control 

access to areas where air cargo is stored. In addition to physical 

security, the regulated entities must have procedures in place for 

challenging all unknown persons who enter secure cargo areas. 

However, TSA inspection reports identified 254 instances of 

access control violations, and we gained unescorted access to air 

cargo at of the regulated facilities we visited. For 

example, 

•	 At an indirect air carrier facility, we gained access to air 

cargo through an unmanned door with a defective lock. 

Although an alarm sounded, no warehouse personnel 

responded to challenge our access. We had access to 

multiple storage rooms, including one which contained 

cargo that had been screened and was being shipped that 

evening on a passenger aircraft. 

•	 At another air carrier facility, we gained access to an air 

cargo storage room through an unlocked door. At the 

same facility, we encountered a number of individuals but 

were never challenged. One employee opened a second 

door allowing us access to the tarmac and runway. A 

number of other individuals allowed us to walk around 

without being challenged. 

Without regular vigilance, practice, and enforcement of access 

controls, TSA and the regulated entities provide opportunities for 

individuals to introduce explosives, incendiaries, and other 

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destructive items into air cargo, potentially creating risks for the 

traveling public. 

Security Threat Assessments 

TSA’s security programs require that regulated entities perform 

security threat assessments (background checks) on all 

individuals working for or on behalf of the regulated entities who 

have unescorted access to air cargo. The background checks are 

to be completed before the individuals begin handling or 

transporting air cargo. In lieu of the security threat assessment, 

TSA regulations provide for accepting documents which 

demonstrate that the individual has undergone a background 

check. These equivalent documents include a commercial 

driver’s license with a hazardous material endorsement, a 

Transportation Worker Identification Credential,3

 or a Free and 

Secure Trade4 card. Regulated entities must provide supporting 

documentation to verify that personnel have received the 

required security threat assessment or that the individual has an 

approved equivalent. Appendix D provides more information 

regarding TSA’s security threat assessment requirements. 

TSA inspection reports identified 731 instances where regulated 

entities either did not conduct or provide evidence that 

employees or authorized representatives had undergone 

background checks. We identified drivers 

sampled who were handling and transporting air cargo without 

meeting TSA’s security threat assessment requirement. For 

example, 

•	 A truck driver displayed an employee identification card 

that had his photo, but a coworker’s name. After 

3

The Transportation Worker Identification Credential is a common identification credential that uses 

smart card technology to link an individual to a specific credential. 4

 The Free and Secure Trade program is a joint program between the Canada Border Services Agency 

and the United States Customs and Border Protection. The program offers preauthorized importers, 

carriers and drivers expedited clearance for eligible goods.
 

Security of Air Cargo During Ground Transportation 

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following up on his identity, we determined the truck driver 

had never applied for a security threat assessment and had 

been handling cargo for almost a year and half. 

•	 Five delivery drivers for one indirect air carrier were 

handling and transporting air cargo without security threat 

assessments. 

•	 Three drivers from a regulated entity’s authorized 

representative did not have security threat assessments. 

TSA’s security programs and the regulations do not provide 

assurance that entities accurately verify the identification of 

personnel seeking a security threat assessment. TSA’s security 

programs and 49 CFR 1540.203 require regulated entities to 

verify the identity of each applicant by reviewing two forms of 

identification, one of which must be a government-issued picture 

identification, or other means approved by TSA. In addition, the 

regulations do not require that regulated entities maintain copies 

or list the documents reviewed to ensure each applicant’s identity 

was properly authenticated. Therefore, TSA can not be sure 

proper personnel are handling or transporting air cargo. 

Additionally, the security threat assessment application does not 

require a Social Security number. Instead, this is an optional 

field on the application. While submission of the Social Security 

number is voluntary, 49 CFR 1540.203 indicates that the failure 

to provide the information may delay or prevent completion of 

the threat assessment process. The verification of a Social 

Security number with the applicant’s identification would reduce 

the risk of false identification. 

TSA officials indicated that applicants are not vetted against 

because the regulations do not 

require this. Instead, the applicants' information is vetted against 

terrorist-based lists, such as the No Fly, Selectee, and Terrorist 

Screening Database, also known as the Terrorist Watch List. 

, TSA 

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allows questionable individuals opportunities to obtain approved 

clearances for handling or transporting air cargo. As a result, 

individuals could introduce explosives and other destructive 

items into cargo, posing a risk to the industry and traveling 

public. 

Cargo Security Training 

TSA’s security programs require that all personnel working for 

or on behalf of a regulated entity who have unescorted access to 

air cargo complete initial and recurrent security training, and 

pass an exam with a score of 85% or better. Regulated entities’ 

employees or authorized representatives either did not take the 

initial or annual recurrent security training and pass the required 

examinations or could not provide evidence of meeting these 

requirements. 

TSA inspection reports identified 1,655 violations related to the 

security training and testing requirements. We determined that 

24 of 104 (23%) truck drivers had not completed or could not 

provide evidence to satisfy this requirement. For example, 

drivers at one indirect air carrier had taken only the initial 

training and testing. The security coordinator for another 

indirect air carrier did not test his employees on the annual 

recurrent training. 

The security training and testing violations occurred in part 

because regulated entities were unaware of the requirements, 

including the requirement to have supporting documentation 

available upon TSA’s request. A security manager at one 

location explained that he was unaware of the annual recurrent 

training requirement. The indirect air carrier’s security 

coordinator received a letter from TSA with revisions to the 

security program requirements; however, he thought the change 

applied to the annual recurrent training requirements. According 

to some TSA inspectors, although inspectors are expected to 

conduct outreach in their area of responsibility on an ongoing 

basis to provide guidance regarding transportation security, they 

Security of Air Cargo During Ground Transportation 

Page 9 
 have limited time for in-depth discussions pertaining to training 

or any other security measures. 

By not ensuring that regulated entities’ employees or authorized 

representatives take or pass the required security training, TSA 

limits personnel from effectively safeguarding air cargo against 

the introduction of explosives and other destructive items into 

cargo, posing a risk to the industry and traveling public. 

Air Cargo Security Inspections 

The air cargo security violations we observed during our visits and 

reported by TSA inspectors persist because TSA’s inspection process 

has not been effective in ensuring compliance and awareness of air cargo 

security requirements. Based on our review of summary inspection 

reports for FYs 2007 and 2008 and observations made during our site 

visits, there are repeat patterns of violations that TSA has been unable to 

resolve. TSA does not have a robust inspection process that focuses on 

high risk areas. Automated tools to assist inspectors in identifying, 

documenting, and focusing their oversight efforts on high risk areas in 

air cargo security are not adequately used. As a result, TSA misses 

opportunities to strengthen aviation security through its inspection 

process and reduce the risk to air cargo before it is loaded onto planes. 

TSA’s Inspection Process 

TSA’s FY 2009 Regulatory Activities Plan does not emphasize 

high-risk areas. Instead, the plan requires that each regulated 

entity receive a comprehensive inspection at least once per year, 

and indicates that each nonsupervisory inspector must complete a 

minimum of 29 inspections per quarter. This number may 

include supplemental follow-up inspections for entities that are 

not in compliance. A cargo inspector who satisfies his or her 

annual inspection quota is expected to perform additional 

inspections under the guidance of local airport leadership. 

The Regulatory Activities Plan does not allow inspectors to 

allocate sufficient time to visit entities that do not comply with 

Security of Air Cargo During Ground Transportation 

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security procedures. One inspector said that too much emphasis 

is placed on accomplishing the quantity of inspections each 

quarter, causing the quality of inspections to suffer. Another 

inspector indicated that inspectors’ time and efforts could be 

better used by focusing more on the problem entities and less on 

those that are in compliance. The inspector said that 

comprehensive reviews are almost 30 pages long and very timeconsuming to complete, even for entities that are in compliance. 

The Regulatory Activities Plan does not consider the additional 

time required for inspectors to visit regulated entities and address 

questions regarding the security requirements. During our site 

visits to several entities, personnel expressed confusion about 

some of the security requirements and requested the opportunity 

to ask the inspectors questions on a range of topics. Because of 

the aggressive inspection schedule and quota, as well as the time 

required to document each inspection, inspectors usually visit a 

regulated entity only once a year, unless follow-up is needed as a 

result of the first inspection. 

Analytical Tools Not Effectively Used for Targeting High 

Risk Areas 

Another factor limiting the effectiveness of TSA’s inspection 

activities is that the agency does not effectively use analytical 

tools for targeting inspections to high-risk areas. While PARIS 

has been improved in the past several years, some inspectors are 

reluctant to rely on the system because of its limited reporting 

capabilities and other functional problems. Some inspectors said 

PARIS is slow, lacks necessary functionality, and often crashes. 

For example, some inspectors indicated that PARIS could not 

supply information on past inspections for entities. Therefore, 

they had to obtain the information from the inspector who 

conducted the last review to determine what areas required more 

attention. In addition, inspectors were unable to obtain the 

entities’ address in PARIS and had to rely on other sources 

instead. 

Security of Air Cargo During Ground Transportation 

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The PARIS database cannot automatically analyze data and 

report trends. Therefore, trend analysis requires the user to 

extract, sort, and filter the data using programs such as Excel or 

Access and post the information on TSA’s SharePoint for 

airports to use. According to TSA headquarter officials, airports 

may use analytical reports developed from PARIS data; however, 

not all are doing so. A majority of the supervisory inspectors at 

the airports we reviewed indicated that they did not rely on 

PARIS trends and analysis when planning inspections. Some 

airports develop and manage their own local databases outside of 

PARIS to assign and track inspection activities. 

Furthermore, data entered in PARIS may not accurately identify 

the extent of violations. Inspectors at each airport determine 

what information should be detailed when documenting the 

inspections in PARIS, making the inspection data inconsistent 

and difficult to analyze accurately. We reviewed inspection 

reports and determined that cargo inspectors documented varying 

amounts and types of information to support their conclusions, 

making it difficult to determine the severity of the situation and 

how many individuals did not meet the requirements. For 

example, when there were multiple violations, some inspectors 

would document each individual who did not meet the security 

threat assessment or the training requirements. Other inspectors 

would simply note that an entity or authorized representative as a 

whole did not meet the security threat assessment or training 

requirements. 

Reliance on PARIS is limited because TSA does not provide 

sufficient guidance, training, and awareness to the inspectors 

regarding the use of PARIS, the quality and quantity of 

information entered into PARIS, and the available analysis. 

After the initial core training, which includes approximately one 

day of PARIS instructions, TSA does not provide advanced 

training to help the inspectors learn to use PARIS more 

efficiently and effectively. One TSA official acknowledged that 

inspectors do not fully understand how to use PARIS effectively 

to assist them during the inspection process. Although inspectors 

have access to find and create many standard reports from 

Security of Air Cargo During Ground Transportation 

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PARIS data, some may not have had the necessary training and 

therefore are unaware that PARIS can generate reports to assist 

with inspections. 

According to TSA officials, the PARIS operational issues are 

related to the agency’s infrastructure problems. These officials 

indicated that some of the issues could be alleviated if inspectors 

reduced the number of unnecessary files saved on their 

computers. 

Handheld Devices Not Used to Support Inspections 

In 2006, TSA purchased 315 personal digital assistant devices to 

help automate some of the inspection process. However, the 

devices were never used as intended. TSA spent at least 

$259,000 for the devices to assist inspectors with taking notes 

and answering prompts from a downloadable version of PARIS. 

Because use of the equipment would reduce the time inspectors 

needed to be in the office entering data, inspectors could spend 

more time in the field performing tests or providing support to 

ensure security requirements are understood and implemented. 

TSA also planned for the inspectors to maintain security 

programs on the handheld devices, making the security 

regulations readily available during the inspection process. 

According to TSA officials, security issues prevented the agency 

from using the personal digital assistants as planned. After TSA 

purchased the devices, another federal agency lost a computer 

containing personal data, elevating concerns regarding the use of 

all external data and communication devices holding sensitive 

security information. As a result, TSA instructed the inspectors 

not to use the personal digital assistants until the agency could 

implement the required security changes. TSA has decided to 

purchase other devices and no longer plans to use the personal 

digital assistant equipment. 

Security of Air Cargo During Ground Transportation 

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Air Transportation at Risk 

Without an effective inspection process for ensuring compliance 

with air cargo security requirements, TSA is unable to properly 

identify and address vulnerabilities, which continue to occur year 

after year. The aggressive inspection work plan does not focus 

on high-risk entities, and the agency has challenges with 

effectively automating the inspection process, both of which 

hinder TSA’s ability to ensure compliance with cargo security 

requirements. As a result, TSA misses opportunities to 

strengthen aviation security against the introduction of 

unauthorized explosive, incendiary, and other destructive 

substances or items into aircraft cargo, potentially creating a risk 

to the safety of the traveling public. 

Recommendations 

We recommend that the Acting Assistant Secretary of the 

Transportation Security Administration: 

Recommendation #1: Mitigate access control vulnerabilities 

by: 

a) Requiring more tests for access vulnerabilities and 

provide corrective actions to the regulated entities; 

b) Placing more focus on entities that are not following 

the access control requirements; and 

c) Requiring inspectors to spend more time promoting 

awareness of access control vulnerabilities and their 

impact on cargo security. 

Recommendation #2: Improve the security threat assessment 

process by: 

a) Requiring regulated entities to maintain copies of 

documents reviewed for authenticating the identity of 

an applicant; 

b) Revising the application form to include language 

noting that failure to provide a Social Security 

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Page 14 
number may delay or prevent completion of the security 

threat assessment process; and 

c) Requiring TSA’s Office of Transportation Threat 

Assessment and Credentialing to vet applicants 

. 

Recommendation #3: Enhance training and testing 

requirements by providing more specific guidance to regulated 

entities regarding the training and testing requirements. 

Additionally, TSA should revise the Regulatory Activities Plan 

to allow more time for inspectors to review these requirements. 

Recommendation #4: Revise the Regulatory Activities Plan to 

allow more time for inspectors to: 

a) Incorporate a risk-based approach that emphasizes the use 

of historical data and analysis; and 

b) Provide support and education to the regulated entities to 

ensure that cargo security requirements are understood 

and implemented. 

Recommendation #5: Provide better guidance, training, and 

awareness to all users of the Performance and Results 

Information System, especially the Transportation Security 

Inspectors for Cargo. Specifically, develop an action plan for the 

TSA officials responsible for the Performance and Results 

Information System to educate the inspectors and ensure optimal 

use of the available data and analysis. The action plan should 

also describe: 

a) The quality and quantity of information that should be 

collected and reported to promote data consistency 

among field locations; 

b) Types of information and reports available for inspectors 

to generate from the system as an effective management 

tool; and 

c) The available analysis in SharePoint to improve riskbased planning reporting capabilities. 

Security of Air Cargo During Ground Transportation 

Page 15 
 

Recommendation #6: Provide Cargo Inspectors with automated 

tools that will allow them to dedicate more time with the 

regulated entities. Specifically, establish an action plan, with 

performance milestones, to address the issues preventing the 

agency from using the personal digital assistant devices, or 

similar tools to provide more efficient inspection activities. 

Management Comments and OIG Analysis 

TSA concurred with five of the recommendations and partially 

concurred with one of the recommendations in the report. TSA has 

already begun to formulate plans to implement the recommendations 

contained in the report. TSA did not provide a complete response on 

how the agency will address the intent of two recommendations. 

Management Comments to Recommendation 1: 

TSA Concurs. TSA agrees that access control is a vital part of air cargo 

security and that aircraft operators, air carriers, and indirect air carriers 

must prevent unauthorized access to cargo. Inspectors verify 

compliance with TSA’s access control requirements during all 

comprehensive inspections. Additionally, specific requirements 

regarding access control for employees or authorized representatives are 

outlined in the applicable cargo security programs. TSA’s Office of 

Security Operations intends to incorporate additional access control 

testing protocols in the FY10 Regulatory Activities Plan. 

TSA has also worked to address access control vulnerabilities through 

clear policy requirements for securing air cargo while it is being stored, 

sorted, screened, and transported. For instance, entities participating in 

the Certified Cargo Screening Program, have strict facility and 

transportation access control procedures that include physical security 

measures such as fences and cameras. TSA is working with outside 

vendors to explore new transportation security technology, such as 

testing an electronically serialized locking mechanism as a tamper 

evident seal. This device is equipped with programmable specific serial 

numbers with tracking capability, thereby providing enhanced 

conveyance-level security to Certified Cargo Screening Facility screened 

cargo. 

Cargo inspectors currently spend a significant portion of time providing 

outreach to Indirect Air Carriers and Certified Cargo Screening 

Facilities. During the outreach visit, cargo inspectors review all 

Security of Air Cargo During Ground Transportation 

Page 16 
requirements of the applicable Code of Federal Regulations and the 

Standard Security Program, including ground movement and access 

control to air cargo. Finally, TSA is conducting Cargo Vulnerability 

Assessments at the larger airports. TSA is committed to mitigating these 

vulnerabilities. Vulnerability assessment results are being used to 

improve policy and operational procedures. 

OIG Analysis: We recognize TSA’s efforts to address the 

vulnerabilities identified with access control; however, TSA did not 

respond to the need for more focus on those entities not following access 

control requirements. This recommendation is resolved and will remain 

open until TSA provides an action plan or directive that places more 

emphasis on inspecting those entities not complying with access control 

requirements. Additionally, TSA indicated that cargo inspectors spend a 

significant portion of time providing related outreach to Indirect Air 

Carriers and Certified Cargo Screening Facilities. Based on our review, 

Indirect Air Carriers demonstrated the need for more time. TSA’s 

response did not discuss how the agency will address the identified need 

for increased cargo inspectors outreach activities. Once TSA provides 

the FY10 Regulatory Activities Plan, we will determine whether the 

additional access control testing protocols will address the need for more 

testing in this area. 

Management Comments to Recommendation 2: 

TSA will evaluate the process to require 

 for air cargo workers, the costs of necessary system and database 

changes to capture biometrics, and the number of new-hire adjudicators 

to execute evaluations. Additionally, the agency will review the 

required increase in fees to cover the vetting process. 

TSA concurs. TSA agreed that the concerns with the agency’s security 

threat assessment process should be immediately addressed and partially 

concurred with the recommendations regarding the Social Security 

number . TSA has published an 

Interim Final Rule on Air Cargo Screening, 74 FR 47672, 

47701(September 16, 2009) that requires that each aircraft operator 

maintain copies of an applicant’s documents used to verify identity and 

work authorization. TSA also updated the security threat assessment 

application process and noted that “Failure to furnish this information, 

including your Social Security number will result in delays in processing 

your application and may prevent completion of your security threat 

assessment.” 

Security of Air Cargo During Ground Transportation 

Page 17 
 

 

OIG Analysis: TSA’s response indicates that the agency shares our 

concerns regarding the security threat assessment process. This 

recommendation is resolved, but will remain open until the agency 

updates the OIG on the condition of its proposed corrective actions. 

TSA should provide details regarding what supporting documentation 

will be maintained for the security threat assessment applicants, and 

what actions will be taken based on results of the evaluations focused of 

the process for ensuring . 

Management Comments to Recommendation 3 

TSA Concurs. TSA concurs that training and testing of air cargo 

security requirements are important and will continue to ensure proper 

regulatory oversight. TSA specifies training and testing requirements in 

its security programs, which stipulate the minimum training content, 

training frequency, training log requirements, testing frequency, and 

passing scores for tests. 

TSA is beginning to standardize training and testing, which it plans to 

require for all regulated parties. Cargo inspectors verify compliance 

with TSA training and testing requirements during inspections. Noncompliant entities are counseled on how to obtain the proper security 

training and testing. TSA cargo inspectors verify compliance with 

training and testing requirements as part of all comprehensive 

inspections. 

OIG Analysis: Based on TSA’s response, this recommendation is 

resolved, but will remain open until we have obtained and reviewed the 

FY10 Regulatory Activities Plan and the details on the standardized 

training and testing. TSA should provide supporting documentation to 

show how the agency will ensure all regulated entities receive the new 

training and pass the tests. TSA should also specify how the cargo 

inspectors will verify that the regulated entities ensure their authorized 

representatives are properly trained and tested. 

Management Comments to Recommendation 4 

TSA Concurs. TSA is currently developing the FY10 Regulatory 

Activities Plan to include a risk-based approach to inform inspections. 

The new approach will provide a risk score per regulated entity per 

location, which means that regulatory personnel will be able to access 

risk scores specific to their airport. Inspections will be driven based on 

each entity’s score, local and national intelligence, and responses to 

significant national events or identification of systematic vulnerabilities. 

Security of Air Cargo During Ground Transportation 

Page 18 
OIG Analysis: This recommendation is resolved, but will remain open 

until we have obtained and reviewed the FY 2010 Regulatory Activities 

Plan to ensure the risk-based approach is clearly presented in the 

guidance. TSA should also provide details regarding the agency’s 

improved efforts to work closely with aviation industry stakeholders to 

provide support and education. 

Management Comments to Recommendation 5 

TSA Concurs. TSA’s Air Cargo Compliance Division has continued to 

perform quality control review audits of PARIS entries submitted by 

field elements. The inspection quality control reviews focus on 

compliance with the National Inspection Manual and Regulatory 

Activities Plan requirements. TSA headquarters shares this information 

with Assistant Federal Security Directors for Inspections upon request 

and allows them to take appropriate actions when necessary to ensure 

the PARIS entries submitted by their staff are in compliance with the 

National Inspection Manual and Regulatory Activities Plan 

requirements. 

TSA provides cargo inspectors with PARIS training and guidance 

materials to more efficiently use PARIS and generate reports on data 

contained in PARIS. Training is also provided on the conversion of data 

extracted from PARIS into Excel spreadsheet pivot tables. This training 

provides cargo inspectors with the ability to generate more useful reports 

on inspection, investigation outreach, and incident data, and analyze and 

organize the reports in a fashion tailored to their needs. The training is 

provided through the cargo inspector’s initial, on the job, and recurrent 

training. Also, the PARIS program office has developed a 

comprehensive series of user guides and on-line demos. 

TSA provides a PARIS application Help Desk Phone Line, an 

information technology single point of contact, and support from PARIS 

staff members. The agency also relies on its contractor-based support 

system that TSA uses for its enterprise information technology 

applications. Inspectors can also use the PARIS Blog and SharePoint 

for communications regarding air cargo related risks. 

OIG Analysis: TSA’s response identified the agency’s efforts to 

provide training on the use of PARIS; however, it does not address the 

underlying concern that cargo inspectors may not fully understand and 

use the available resources to understand PARIS capabilities. While 

TSA provides support, training, and guidance to more efficiently use 

Security of Air Cargo During Ground Transportation 

Page 19 
PARIS, more needs to be done to ensure its use is maximized. This 

recommendation is resolved, but will remain open until TSA can provide 

evidence that field cargo inspectors are knowledgeable on generating 

useful PARIS reports. TSA should provide an action plan and 

supporting documentation to demonstrate how local airports are 

effectively utilizing PARIS and generating useful reports to assist with 

inspection activities. 

Management Comments to Recommendation 6 

TSA Concurs in part. TSA is moving forward with a plan to provide 

more modern and advanced tools to assist the inspectors and their 

activities. TSA no longer plans to use the personal digital assistant 

equipment. Instead, TSA has procured other automated devices that will 

be distributed to the cargo inspectors by the conclusion of FY 2009. For 

example, TSA has acquired blackberries with a camera feature; 

document hand scanners; test phones for special emphasis inspections 

and small package testing; and laptops for all Cargo Inspectors. In 

addition to securing new productivity tools, TSA has been working to 

streamline the record-keeping requirements associated with 

documenting inspections. 

OIG Analysis: This recommendation is resolved, but will remain open 

until TSA provides evidence to show the agency has completed the 

distribution of the procured tools listed in the agency’s response. 

Specifically, TSA should provide the distribution schedule for all items 

and evidence that these tools are being fully utilized to avoid the 

experienced waste identified with the personal digital assistant 

equipment acquisitions. 

Security of Air Cargo During Ground Transportation 

Page 20 
 

Appendix A 

Purpose, Scope, and Methodology 

The objective of our audit was to determine the effectiveness of 

TSA’s efforts to ensure the security of air cargo during ground 

transportation and handling before it is loaded onto planes. 

We obtained and reviewed applicable federal laws and regulations, 

TSA’s standard security programs, security directives, the 2008 

and 2009 Regulatory Activities Plans, the National Inspection 

Manual, the Air Cargo Strategic Plan, and other related documents. 

We interviewed TSA personnel from the Offices of Transportation 

Threat Assessment and Credentialing, Office of Security 

Operations, Office of Chief Counsel, and the Transportation Sector 

Network Management Division. 

During our survey work and audit fieldwork, we visited five 

airports: Chicago O’Hare International, Washington-Dulles 

International, Minneapolis St. Paul International, Miami 

International, and Los Angeles International. During our site 

visits, we interviewed and accompanied TSA cargo inspectors to 

observe operations and interview personnel at aircraft operators, 

all-cargo operators, and indirect air carrier facilities. 

At two of the airports, we judgmentally selected air carriers and 

obtained a nonstatistical sample of airway bills to trace back to 

indirect air carriers to determine whether the drivers on the airway 

bill documentation had met TSA’s security program requirements, 

including the security threat assessment and security training. This 

test included a review of security threat assessment and training 

requirements for 104 truck drivers from 36 indirect air carriers. 

We conducted a review and analysis of the following 11 airports 

that transported a large amount of freight: 

• Los Angeles International 

• John F. Kennedy International 

• Chicago O’Hare International 

• Miami International 

• Hartsfield-Jackson Atlanta International 

• San Francisco International 

Security of Air Cargo During Ground Transportation 

Page 21 
Appendix A 

Purpose, Scope, and Methodology 

• Washington-Dulles International 

• Newark-Liberty International 

• Houston Intercontinental 

• Honolulu International 

• Minneapolis St. Paul International 

We interviewed personnel responsible for the PARIS database 

from the Office of Security Operations Compliance Inspection and 

Enforcement Team. We received a demonstration of the system's 

capabilities and requested specific searches and reports to 

determine what information is available to TSA inspectors 

and officials. We obtained TSA summary reports documenting the 

total number and type of inspections each airport performed on 

cargo at each location from January through September 2008. We 

also obtained several reports summarizing the numbers and types 

of violations that inspectors disclosed during their inspections. We 

judgmentally selected and analyzed inspection reports to determine 

the types of violations identified by the inspectors, actions taken to 

resolve the issues, and the level of detail that the inspectors 

provided in the reports. 

We conducted this performance audit according to generally 

accepted government auditing standards. Those standards require 

that we plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe the 

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. We conducted 

fieldwork between January and April 2009 under the authority of 

the Inspector General Act of 1978, as amended. 

. 

Security of Air Cargo During Ground Transportation 

Page 22
 
Appendix B

Management Comments to the Draft Report

U.S. Department of Homeland Security

601 Sou,. 12th Stret

Arlington, VA 20598

OCT 0 5 2009

IK.~..\ i~;Ãik") Transportation

\i~!t1 Security

\~",~,~~c.~ Administration

INFORMATION

MEMORANDUM FOR: Richard Skinner

Inspector General

Departent of Homelandc Securi~Y;1 . ", ;

FROM: Gale D. ROSSidesNa-lO.~~

Acting Admin~

SUBJECT: Draft Report: "Security of Air Cargo during Ground

Transportation," July 2009

Purose

This memorandum constitutes the Transportation Security Administration's (TSA) formal

agency response to the Deparment of Homeland Security (DHS) Offce of Inspector General

(OIG) draft report; "Security of Air Cargo during Ground Transportation" dated July 2009.

Background

The Offce of the Inspector General conducted this investigation to evaluate the effectiveness of

TSA's efforts to secure cargo while it is handled or transported on the ground, prior to being

shipped on passenger aircraft. OIG found that TSA's inspection process has focused on quantity

rather than outcomes and ensuring corrective actions. Automated tools to assist inspectors in

analyzing results and focusing their oversight efforts on high-risk areas in air cargo security were

not adequate. orG makes six recommendations to strengthen the security of air cargo ground

transportation.

Discussion

The lmplementing the Recommendations o/the 9/11 Commission Act 0/2007 requires TSA to

establish a system for industr to screen 100 percent of cargo transported on passenger aircraft in

the United States to provide a level of security that is commensurate with the level of security

for the screening of passenger baggage. The legislation also set an interim milestone of 50

percent screening to be reached by Februry 2009. By August 2010, cargo not screened in

accordance with TSA-approved processes and procedures cannot be uplifted to a passenger

aircraft in the United States.

This is an extensive requirement and, TSA understands there is simply not suffcient capacity or

space in airports to meet its demands without carrier delays, cargo logjams, and increased transit

Security of Air Cargo During Ground Transportation

Page 23
Appendix B

Management Comments to the Draft Report

2

times. Therefore, TSA has established a multi-dimensional strategy to reconcile the requirements

of the mandate, the security needs of passengers, and the needs ora U.S. economy reliant upon

the air cargo industry.

In addition to TSA's existing security regime, we have established three programs to assist in

meeting the 100 percent screening mandate and have made excellent progress:

. 100 Percent Narow-Body Screening - 100 percent of cargo uplifted on narow-body

passenger aircraft has been screened since October 2008. This program accounts for 96

percent of passenger flghts originating in the US and its territories, and covers

approximately 25 percent of the cargo uplifted in the US.

. The Certified Cargo Screening Program (CCSP) - A voluntary program designed to

enable certain vetted, validated, and certified facilities to screen cargo prior to delivering

the cargo to the air carrier. To date, the majority of air cargo screening is done by air

cariers thrugh CCSP.

o TSA has certified 477 cargo screening facilities through the program.

o An interim final rule to accelerate the deployment of the program was published

in the Federal Register on September 16,2009, and wil take effect on November

16,2009. During initial deployment ofCCSP, the onsite facility assessment has

been performed by a TSA Field Team staff. TSA expects that during full rollout,

assessments wil be performed by a TSA-approved validation firm.

. Indirect Air Carier (rAC) Screening Technology Pilot - an initiative established to test

screening technology in a live environment.

o Paricipants in this program are working directly with TSA to provide information

and data on cargo, commodity-types, and a certain cargo screening technology.

Information collected from this pilot will impact future TSA decisions on

acceptable screening technologies.

o There are 91 participating locations receiving approximately $40.6 milion in

technology assistance.

. TSA Explosives Detection Canine Programs - TSA certified explosives detection canine

teams are available to screen cargo throughout the network.

o 465 law enforcement parter canine teams devote a par of their time to screening

cargo; 6 additional teams wil graduate in fiscal year (FY) 2009

o 84 TSA proprietary canine teams are fully dedicated to screening cargo. 36 more

teams are authorized and planed for deployment in FY 20 i 0, 19 of which have

been hired and are curently in training.

TSA agrees that access control is a vital par of air cargo security. rn addition to our operational

oversight, we wil continue to work to address access control vulnerabilities through clear policy

requirements for securing air cargo while it is being stored, sorted, screened, and transported.

We are in agreement that the concerns that have been identified with the agency's security threat

assessment process should be addressed, and we are providing more guidance and tools to

stadardize training. TSA's Offce of Security Operations (OSO) FY 20'10 Regulatory Activities

Plan (RA) incorporates a risk-based approach to inspections. rl1 FY 2009, OSO Air Cargo

Compliance has continued to perform Quality Control (Qc) and review audits of Performance

and Results rnformation System (PARrS) entries submitted by field elements. Lastly, TSA wil

Security of Air Cargo During Ground Transportation

Page 24
Appendix B

Management Comments to the Draft Report

3

provide cargo inspectors with automated tools that wil allow them to dedicate more time with

regulated entities.

Overall, we believe that the recommendations contaned in the report will provide additional

benefit to TSA. TSA has already begun to formulate plans to implement the recommendations

contained in the report. Our specific response to each recommendation follows.

Recommendation #1: Mitigate access control vulnerabilties by:

a) Requiring more tests for access vulnerabilties and provide corrective actions to the

regulated entities;

b) Placing more focus on entities that are not following the access control

requirements; and

c) Requiring inspectors to spend more time promoting awareness of access control

vulnerabilties and their impact on cargo security.

TSA Concurs: TSA agrees that access control is a vital par of our layered approach to air cargo

security.

a) TSA's Offce of Security Operations (OSO) intends to incorporate additional

access control testing protocols in the FY 2010 Regulatory Activities Plan (RAP).

The RAP is the basis for a Traporttion Security rnspectors (TSls) anual work

plan. These additional tests wil augment the curent system in place. 080 wil

continue to inspect drivers on their training and knowledge of their security

functions.

Inspectors verify complial1ce with TSA's access control requirements during all

comprehensive inspectiol1s. In addition, TSA performed a special emphasis

inspection (SEI) during FY 2009 Q2 specifically concentrated on access control.

The objective of this SEl was to determine, through realistic testing, if foreign air

cariers, aircraft operators, and indirect air cariers (lACs) properly control access

to cargo as required under trnsportation security regulations il1 49 Code of

Federal Regulations (CFR) and appropriate cargo security programs. Aircraft

operators, foreign air carers and lACs must prevent unauthorized access to cargo

in accordance with 49 CFR Sections 1544.205(c), 1544.228, i 546.205(c),

1546.213, 1548.5, and 1548.15. Additionally, specific requirements regarding

access control for employees or authorized representatives are outlined in the

applicable cargo security programs. The SEI protocol stipulated that all instances

of non-complial1ce receive a formal investigation. Cases could be resolved with

either administrative or civil penalty action. Counseling alone could not be used

as a means to close any violations discovered. Finally, SEI results are being used

to identify trends in vulnerabilties, assist in identifying corrective measures (e.g.,

policy or operational), and formulate additional access cOl1trol testing protocols.

Security of Air Cargo During Ground Transportation

Page 25
Appendix B

Management Comments to the Draft Report

4

b) TSA is working with our parners to identifY new access cOl1trol mechanisms.

Through parnership with outside vendors we are exploring new conveyance

security technology. For instace, TSA has authorized a pilot at Detroit

Metropolitan Wayne County Airport called M-Iock. The M-Iock is an

electronically serialized locking mechanism which TSA is testing as a taper

evident seaL. This device is equipped with programmable specific serial numbers

which are displayed on an LED screen with GPS tracking capability, thereby

providing enhanced conveyance-level security to Certified Cargo Screening

Facilty (CCSF)-screened cargo. Curently, TSA is conducting Cargo

Vulnerabilty Assessments at all Cat X and Cat r airports. TSA is committed to

mitigating these vulnerabilties. Vulnerability assessment results are being used

to improve policy and operational procedures. rn addition to our operational

oversight, TSA has worked to address access control vulnerabilities though clear

policy requirements for securing air cargo while it is being stored, sorted,

screened, and transported. Entities paricipating in the Certified Cargo Screening

Program (CCSP), for instance, have strict facility and conveyance access control

procedures that include physical security measures (e.g., fences, cameras),

employee identification media, chain of custody technology applied to the

screened cargo, and secured conveyances (e.g., locked, sealed, or vehicles under

escort) .

c) As of the date of this report, TSrs have conducted over 2,060 outreach efforts

directly related to air cargo security. TSrs currently spend a significant portion of

time providing outreach to rl1direct Air Carriers and CCSFs both prior to their

becoming certified and after. Prior to an rAC becoming approved, they must

submit to a Tsr Outreach visit. During this visit the TSI reviews all requirements

of the applicable Code of Federal Regulations and the Standard Security Program

itself. This includes ground movement and access control to air cargo. TSls

review the facilty and trucks to determine if in their current state, they would

adequately be able to meet requirements. rf not, the TSI wil work with the entity

to achieve the appropriate level of ground movement and access control securty

prior to approvaL.

In regard to CCSFs, TSA also has a lengty application process that requires

constant interaction and outreach provided by Principal Cargo Security Analysts

(PCSAs). These TSA personnel work with an entity to help them achieve the

required security level through outreach and education. A CCSF must be

"certified" by a PCSA prior to entrance into the program

Recommendation #2: Improve the security threat assessment process by:

a) Requiring regulated entities to maintain copies of documents reviewed for

authenticating the identity of an applicant;

Security of Air Cargo During Ground Transportation

Page 26
Appendix B

Management Comments to the Draft Report

5

b) Revising the application form to include language noting that failure to provide a

social security number may delay or prevent completion of the security threat

assessment process and;

c) Requiring TSA's Offce of Transporttion Threat Assessment and Credentialing to

vet applicants

TSA Concurs: TSA agrees that the concerns that have been identified with the agency's

securty threat assessment process should be addressed and parially concurs with the

recommendations on social security number (SSN)

a) TSA concurs. TSA has just published an Interim Final Rule on Air Cargo Screening, 74

FR47672, 47701 (September 16,2009) (Air Cargo Screening rFR) that requires that each

aircraft operator maintain copies of the applicant's documents used to verify identity and

work authorization.

b) Curently, language in the Privacy Act Notice found in 49 CFR §1540.203(b)(2)(viii)

regarding security threat assessments provides that: "Failure to furnish your SSN may

result in delays in processing your application, but will not prevel1t completion of your

Securty Threat Assessment." However, TSA's recently published Air Cargo Screening

IFR contans the language that the IG recommends: "Failure to furnish this information,

including your Social Securty Number (SSN) wil result in delays in processing your

application and may prevent completion of your security threat assessment." 74 FR at

47683.

c) TSA recognizes the importance of utilizing the best method possible to capture and

evaluate the history of those who will have ready access to our l1ation's air cago

trasDorttiOl1 system. TSA wil evaluate the process to require

for air cargo populations, the costs of necessary system/database changes that

would capture biometrics, and the number of new-hire adjudicators to execute the

evaluation process. Additionally, we wil review the required increase of fees to cover

the vetting process.

Recommendation #3: Enhance training and testing requirements by providing more

specific guidance to regulated entities regarding the training and testing requirements.

Additionally, TSA should revise the Regulatory Activities Plan to allow more time for

inspectors to review these requirements.

TSA Concurs: TSA specifies trainil1g and testing requirements in the aircraft operator, rAC,

and CCSP securty programs. The security programs clearly stipulate the minimum training

content, frequency of trainil1g, training log requirements, testing frequency, and passing scores

for tests. In addition, TSA provides the rACs with TSA-approved training materials and tests for

their Securty Coordinators, direct employees, and authorized represel1tatives. We are curently

developing comparable materials for the aircraf operators and CCSFs. rn addition, TSA is

beginning the process of developing stadardized training and testing, which it plans to require

for all regulated paries.

Security of Air Cargo During Ground Transportation

Page 27
Appendix B

Management Comments to the Draft Report

6

TSls verify compliance with TSA training and testing requirements during inspections. Noncompliant entities are counseled on how to obtai the proper securty training and testing. rn

addition, TSls routinely conduct outreach to the regulated air cargo community.

TSA will be revising the FY 2010 RA. TSA concurs that training and testing of air cargo

securty requirements are important and will continue to ensure proper regulatory oversight as

such. TSA cargo il1spectors verify compliance with training and testing requirements as part of

all comprehensive air carer, rAC, and CCSF inspections.

Recommendation #4: Revise the Regulatory Activities Plan to aUow more time for

inspectors to:

a) Incorporate a risk-based approach that emphasizes the use of historical data and

analysis.

b) Provide support and education to the regulated entities to ensure that cargo security

requirements are understood and implemented.

TSA Concurs: TSA's FY 2010 RAP addresses these concerns.

a) TSA's FY 2010 RAP il1corporates a risk-based approach to inform inspections. We have

developed a risk score for every entity reguated under a TSA air cargo security program.

Our approach provides a risk score per regulated entity per location, which means that

Regulatory personnel wil be able to access risk scores specific to their airport. Risk

scores are updated quarerly. rnspections will be driven based on the entities score: red,

yellow, or green indicators. Il1spections will also be driven by local and national

intellgence as well as responses to signficant national events or identification of

systematic vulnerabilties; and

b) TSA will continue to work closely with aviation industry staeholders to provide support

and education.

Recommendation #5: Provide better guidance, training and awareness to aU users of the

Penormance and Results Information System, especiaUy the Transportation Security

Inspectors for Cargo. Specifically, develop an action plan for the TSA offcials responsible

for the Performance and Results Information System to educate thc inspectors and ensure

optimal use of the available data and analysis. The action plan should also describe:

a) The quality and quantity of information that should be collected and reported to

promote data consistency among field locations;

b) Types of information and reports availahle for inspectors to generate from the

system as an effective management tool; and

c) The available analysis in Share Point to improve risk-based planning reporting

capabilties.

Security of Air Cargo During Ground Transportation

Page 28
Appendix B

Management Comments to the Draft Report

7

TSA Concurs:

a) In FY 2009, TSA's OSO Air Cargo Compliance has continued to perform Quality

Control (Qc) review audits of PARIS entries submitted by field elements. Each quarter,

OSO Cargo Compliance selects PARIS inspection report for airprts and Cargo TSrs in

each area to review for QC. The inspection QC reviews focus on compliance with the

National rnspection Manual (NIM) and RAP requirements. The goal is to review at least

one report from each Cargo TSI at each airprt by the end of the fiscal year.

Headquaters (HQ) shares this information with Assistant Federal Security Director's for

rnspections upon request and allows them to take appropriate actions when necessary to

ensure the PARIS entries submitted by their staff are in compliance with the NIM and

RAP requirements.

b) In addition, TSA's OSO Compliance Programs provide PARrS training and guidance

materials. This training involves tips on how to more effciently use P ARrs and on

generating reports on data contained in PARrS. Training is also provided on the

conversion of data extracted from P ARrS into Excel Spreadsheet "Pivot Tables." This

traning provides TSrs with the ability to generate more useful reports on inspection,

investigation outreach and incident data, and analyze and organize the reports in a fashion

tailored to their needs. This is primarly faciltated through thee efforts. First, newly

hired TSrs receive PARIS training during the "Transportation Security rnspector Basic

Training Program," a comprehensive four week training regime at TSA's Security

Enforcement Training Academy. This training is conducted via presentation and hands

on exercises. Ths training is continued during the new Tsrs offcial 011 the job training

(OJT). Second, experienced TSrs receive a refresher durng recurrent training. Recurrent

trainil1g is held at least once a quarer at various airports throughout the country with the

goal of all experienced inspectors attending at least one session a year. Third, the PARIS

program offce has developed a comprehensive series of user guides and on-line demos.

Furtermore, in the interest of facilitating swift and effecti ve communications between

the PARIS User Community and the PARrS Support staff at HQ, TSA OSO, Inspection

Enforcement and Analysis Branch established a PARIS application Help Desk Phone

Line in the TSA Phone Network. Field personnel can call HQ personnel and speak to a

P ARrS support staff member. This additional communication chanel is intended to

offer an additional conveniel1t means for PARIS users to talk to one of the expert who

support the PARS program. It does not replace the agency's informatiol1 technology

(IT) single point of contact (Le., SPOC) and the contractor-based support system that

TSA uses for its enterprise rT applications. Rather, it is an opportunity for us to bring

increased support to the PARrs user communty as it relates to the PARrS application

itself. The SPOC remains the first contact for any functional anomalies. Field Inspectors

can also reach the help desk support through the PARrS Blog.

c) The Offce of Compliance publishes periodic reports into Sharepoint, an internal

electronic tracking system. This system is available to all inspectors who perform

oversight as well as staff who analyze inspection reports.

Security of Air Cargo During Ground Transportation

Page 29
Appendix B

Management Comments to the Draft Report

8

Recommendation #6: Provide Cargo Inspectors with automated tools that wil allow them

to dedicate more time with the regulated entities. Specifically. establish an action plan.

with perfonnance milestones. to address the issues preventing the agency from using the

personal digital assistant devices to provide more effcient inspection activities.

TSA Concurs in Part: TSA believes that the personal digital assistant devices (PDAs) are

antiquated technology and are not effcient. We are moving forward with a plan to provide more

modern and advanced tools to our regulatory workforce to improve productivity. These include,

but ar not limited to:

. Blackberries, with camera feature, for all inspectors.

. Document hand scaners. This device allows Tsrs to make copies of records. We

have secured one per airport.

. Test phones for special emphasis inspections and small package testing. One test

phone per airport with assignment of a new number every 6 months.

. Laptops for all cargo inspectors.

. Dedicated cargo vehicles. We improved the ratio of one vehicle for every two

inspectors at the airport.

. One GPS unit per cargo vehicle.

. Air cards for communal use among Regulatory personneL.

These tools have already been procured and will be dispersed to the TSIs by the conclusion of

FY 2009.

In addition to securing new productivity tools, TSA's OSO has been working to streamline the

record keeping requirements associated with documenting inspections. For instance we revised

the PARIS prompts for the passenger and all cago air carrer and lAC inspection types.

Specifically we reduced the l1umber of prompts by 40-50 percent while stil capturing all the

requirements. This reduces the amount of entry time per PARIS inspection record, and allows

the rnspector more discretion on the level of detail to input.

Security of Air Cargo During Ground Transportation

Page 30
Appendix C 

Process for Ground Transportation of Air Cargo 

. 

Security of Air Cargo During Ground Transportation 

Page 31 
Appendix D 

Security Threat Assessment Requirements 

. 

Security of Air Cargo During Ground Transportation 

Page 32 
Appendix E 

Major Contributors to This Report 

Patrick O’Malley, Director 

Cecilia Barela, Desk Officer 

Sandra Ward Greer, Project Lead 

Andrew Herman, Auditor 

Kathleen Hyland, Auditor 

Amy Nase, Auditor 

Raul Quintero, Program Analyst 

James Bess, Referencer 

. 

Security of Air Cargo During Ground Transportation 

Page 33
 
Appendix F 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff for Operations 

Chief of Staff for Policy 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

DHS Component Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

. 

Security of Air Cargo During Ground Transportation 

Page 34
 
Additional Information and Copies 

To obtain additional copies of this report, call the Office of Inspector General 

(OIG) at (202) 254-4199, fax your request to (202) 254-4305, or visit the OIG web 

site at www.dhs.gov/oig. 

OIG Hotline 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of 

criminal or noncriminal misconduct relative to department programs or 

operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• E-mail us at DHSOIGHOTLINE@dhs.gov; or 

•	 Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600 

Attention: Office of Investigations – Hotline 

245 Murray Drive, SW, Building 410 

Washington, DC 20528 

The OIG seeks to protect the identity of each writer and caller. 
ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

OIG HOTLINE 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.