AVIATION SECURITY

Actions Needed to 

Address Challenges 

and Potential 

Vulnerabilities Related 

to Securing Inbound 

Air Cargo

Report to Congressional Requesters

May 2012

GAO-12-632

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-632, a report to 

congressional requesters 

May 2012 

AVIATION SECURITY 

Actions Needed to Address Challenges and Potential 

Vulnerabilities Related to Securing Inbound Air 

Cargo

Why GAO Did This Study

In 2010, passenger flights transported 

about 3.6 billion pounds of cargo into 

the United States from foreign 

locations. According to TSA, the 

introduction of explosive devices in air 

cargo shipments is a significant threat, 

and DHS was mandated to establish a 

system to screen 100 percent of cargo 

transported on all passenger aircraft 

traveling to, from, or within the United 

States by August 2010. Individuals 

identified as matches to the No Fly List 

are generally prohibited from boarding 

commercial aircraft because it has 

been determined they pose a threat to 

civil aviation or national security. GAO 

was asked to examine (1) TSA actions 

taken since October 2010 to enhance 

the security of inbound air cargo 

transported on both passenger aircraft

and all-cargo carriers; and (2) any 

associated challenges TSA faces. 

GAO reviewed relevant requirements 

and documents, interviewed federal 

officials, and visited three airports 

based on cargo volume. The visits 

provided insights, but were not 

generalizable to the entire industry. 

This is a public version of a sensitive 

security report GAO issued in March 

2012, which also addressed U.S. 

Customs and Border Protection’s and 

TSA’s use of the No Fly List to secure 

inbound air cargo. 

What GAO Recommends

GAO recommends, among other 

things, that DHS assess the costs and 

benefits of requiring all-cargo carriers 

to report inbound air cargo screening 

data. DHS concurred with GAO’s 

recommendation and is taking actions 

to address it. 

What GAO Found

The Transportation Security Administration (TSA) has taken three primary 

actions since October 2010 to enhance security of inbound cargo on passenger 

and all-cargo aircraft. First, from October 2010 through May 2011, TSA issued 

new risk-based security requirements to focus more detailed screening measures 

on high-risk shipments, including prohibiting the transport of air cargo on 

passenger aircraft from Yemen and Somalia due to threats stemming from those 

areas and enhancing screening procedures for all cargo carriers. Second, the 

Secretary of Homeland Security established an Air Cargo Security Working 

Group—which included passenger and all-cargo representatives—to help identify 

ways to enhance the security of the air cargo system. In April 2011, the group 

recommended actions to enhance security such as developing mutually 

recognized standards for cargo screening technology, but the Department of 

Homeland Security (DHS) has not yet determined whether to implement them. 

Finally, in December 2010, DHS initiated an Air Cargo Advance Screening pilot, 

which is ongoing, to more readily identify high-risk cargo for additional screening 

prior to departing from foreign airports to the United States. 

TSA has not yet met the 100 percent screening mandate as it applies to inbound 

air cargo due to several persistent challenges. For example, about one-third of 

air carriers that commented on TSA’s proposal to screen all inbound cargo by the 

end of calendar year 2011 expressed concerns about being able to meet this 

date without causing significant disruptions in the air cargo supply chain. In 

response to these concerns, TSA proposed a new date of December 2012. TSA 

officials also said that it is difficult to verify the accuracy of the self-reported 

screening data provided by passenger air carriers used to determine the extent 

to which screening has been conducted in foreign countries. Further, there is no 

requirement for all-cargo carriers to report data comparable to passenger air 

carrier screening data, even though most inbound cargo is shipped into the 

United States by all-cargo carriers. TSA has not yet weighed the costs and 

benefits of requiring all-cargo carriers to submit screening data, and by doing so, 

TSA could determine whether this additional data could enhance its efforts to 

identify potential risks for inbound air cargo, develop cost effective strategies and 

measures to manage these risks, and provide additional assurance that all-cargo 

carriers are complying with TSA’s enhanced screening requirements. 

View GAO-12-632. For more information, 

contact Steve Lord at (202) 512-4379 or 

lords@gao.gov. 
Page i GAO-12-632 Air Cargo Security 

Letter 1 

Background 7

TSA Has Taken Actions to Enhance the Security of Cargo on 

Inbound Aircraft Since October 2010 12

Challenges Persist in Meeting Screening Mandate, and Additional 

Efforts Could Facilitate Oversight of Carriers’ All-Cargo 

Screening Efforts 16

All-Cargo Carriers Reported Challenges Meeting New Screening 

Requirements 22

Conclusions 24

Recommendation for Executive Action 24

Agency Comments and Our Evaluation 25

Appendix I Comments from the Department of Homeland Security 28

Appendix II GAO Contact and Staff Acknowledgements 30

Figures

Figure 1: Various Means of Shipping Air Cargo 8

Figure 2: Flow of Inbound Air Cargo Transported to the United 

States 9

Contents

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-12-632 Air Cargo Security 

United States Government Accountability Office 

Washington, DC 20548

May 10, 2012

Congressional Requesters:

In 2010, passenger flights transported about 3.6 billion pounds of inbound 

air cargo—cargo arriving in the United States by air from foreign 

locations.1 During the same period, all-cargo carriers—generally, aircraft 

configured solely for the transport of cargo (e.g., FedEx and United Parcel 

Service)—transported approximately 7.2 billion pounds of inbound air 

cargo.2 The October 2010 discovery of explosive devices in air cargo 

packages on all-cargo aircraft bound for the United States from Yemen 

provided a vivid reminder that civil aviation remains an attractive terrorist 

target and highlights the continuing need to ensure that air cargo 

screening standards and practices effectively address emerging threats. 

According to the Transportation Security Administration (TSA), the 

security threat posed by terrorists introducing explosive devices in air 

cargo shipments transported on passenger and all-cargo aircraft is 

significant, and the risk of such an attack remains high.3

TSA is the federal agency responsible for securing the nation’s civil 

aviation system, which encompasses the transport of passengers and 

cargo by aircraft to, from, and within the United States. TSA’s 

responsibilities for securing air cargo include establishing security 

requirements governing domestic and foreign passenger air carriers that 

transport cargo, and overseeing the implementation of air cargo security 

requirements by air carriers through compliance inspections conducted by 

TSA transportation security inspectors. All air carriers, domestic and 

foreign, operating to, from, or within the United States, must maintain 

security measures in accordance with TSA-approved security programs 

and any applicable TSA-issued security directives or emergency 

amendments. 4

 

1 Based on 2010 Bureau of Transportation Statistics (BTS) data.

TSA is also responsible for reviewing information on all 

2 Based on 2010 BTS data. All-cargo aircraft are aircraft configured solely for the transport 

of cargo.

3

 Prior to the Yemen incident, TSA considered the primary threat to all-cargo aircraft to be 

stowaways hijacking the aircraft and using it as a missile to cause mass destruction.

4 See 49 U.S.C. §§ 44903(c), 44906. See also 49 C.F.R. §§ 1544.3, 1544.101-1544.105,

1544.305, 1546.3, 1546.101-1546.105.

 
 

Page 2 GAO-12-632 Air Cargo Security 

passengers travelling by commercial aircraft to, from, or within the United 

States against the No Fly and Selectee Lists.5 In general, passengers 

identified as matches to the No Fly List are prohibited from boarding 

commercial flights because they present a threat to civil aviation or 

national security.6 In addition to TSA, U.S. Customs and Border 

Protection (CBP) and foreign governments play a role in securing inbound 

cargo. Unlike TSA, which focuses its efforts on securing cargo prior to 

aircraft departures, CBP determines the admissibility of cargo to the 

United States and is authorized to inspect inbound air cargo for terrorists 

or weapons of mass destruction, or other items such as narcotics and 

illicit materials, upon its arrival in the United States.7

To help enhance civil aviation security, the Implementing 

Recommendations of the 9/11 Commission Act of 2007 (9/11 

Commission Act), enacted in August 2007, mandated that the 

Department of Homeland Security (DHS) establish a system within 3 

years of enactment to screen 100 percent of air cargo transported on all 

passenger aircraft—U.S. and foreign—traveling to, from, or within the 

United States.

Foreign governments 

may also impose separate security requirements on cargo bound for the 

United States from their airports.

8 As of August 2010, TSA reported that it met the mandate 

to screen 100 percent of cargo as it applies to domestic air cargo but did 

not meet the mandate as it applied to inbound air cargo.9

 

5 The No Fly and Selectee Lists are subsets of the consolidated terrorist watchlist 

maintained by the Federal Bureau of Investigation’s Terrorist Screening Center that 

contains the names of individuals with known or suspected links to terrorism.

Although the 

mandate applies to both domestic and inbound cargo, TSA stated that it 

had to address the mandate for domestic and inbound cargo through 

separate systems because of limitations in its authority to regulate 

6 In general, persons who are deemed to be a threat to civil aviation or national security 

but do not meet the criteria of the No Fly List are placed on the Selectee List and are to 

receive additional screening prior to being permitted to board an aircraft. 

7 A weapon of mass destruction could include nuclear, biological, chemical, or radiological 

devices. 

8 See Pub. L. No. 110-53, § 1602(a), 121 Stat. 266, 477-79 (2007) (codified at 49 U.S.C. § 

44901(g)) (providing that the system to screen 100 percent of all cargo transported by 

passenger aircraft shall be established no later than 3 years after enactment).

9 For the purposes of this report, domestic cargo refers to cargo transported by air within 

the United States and from the United States to a foreign location by both U.S. and foreign 

air carriers. 
 

Page 3 GAO-12-632 Air Cargo Security 

international air cargo industry stakeholders operating outside the United 

States.

In 2007 we reported on DHS’s efforts to secure inbound air cargo and 

recommended, among other things, that TSA develop a risk-based 

strategy to address inbound air cargo security and clearly define TSA and 

CBP responsibilities for securing inbound cargo.10 DHS concurred with 

but has not yet taken actions to fully address this recommendation. In 

2010, we also reported on TSA’s efforts to secure air cargo and 

recommended that TSA, among other things, develop a plan for how and 

when the agency intends to meet the mandate as it applies to inbound air 

cargo.11 DHS concurred with the recommendation that TSA develop a 

plan for how and when the agency intends to meet the mandate as it 

applies to inbound cargo. In late March 2012, TSA provided a tactical 

plan including, among other things, a timeline that would require air 

carriers to screen 100 percent of inbound air cargo transported on 

passenger aircraft by December 1, 2012. TSA’s plan to implement the 

screening mandate is a key step in its efforts to secure inbound air cargo 

and it will be important for the agency to continue to monitor passenger 

air carrier efforts to adhere to TSA’s plan for meeting the mandate. In 

2010, we also recommended that TSA establish a mechanism to verify 

data on screening conducted on inbound air cargo.12 DHS concurred in 

part with our recommendation that the agency develop a mechanism to 

obtain and verify the accuracy of screening data and TSA took steps to 

obtain screening data. We discuss the actions TSA has taken to verify 

screening data since 2010 later in this report. Finally, in October 2011, we 

reported on TSA’s efforts to determine whether foreign airports that 

provide service to the United States are maintaining and carrying out 

effective security measures, including those related to air cargo.13

 

10 GAO, Aviation Security: Federal Efforts to Secure U.S.-Bound Air Cargo Are in the 

Early Stages and Could Be Strengthened,

We 

GAO-07-660 (Washington, D.C.: Apr. 30, 

2007).

11 GAO, Aviation Security: TSA Has Made Progress but Faces Challenges in Meeting the 

Statutory Mandate for Screening Air Cargo on Passenger Aircraft, GAO-10-446 

(Washington, D.C.: June 28, 2010). 

12 GAO-10-446. 

13 GAO, Aviation Security: TSA Has Taken Steps to Enhance Its Foreign Airport 

Assessments, but Opportunities Exist to Strengthen the Program, GAO-12-163 

(Washington, D.C.: Oct. 21, 2011). 
 

Page 4 GAO-12-632 Air Cargo Security 

recommended, among other things, that TSA develop a mechanism to 

evaluate the results of completed assessment activities to determine any 

trends and target future activities and resources. DHS concurred with our 

recommendation and stated TSA is taking steps to address it.

The DHS Appropriations Act, 2012, requires the Administrator of TSA to 

submit to the Committees on Appropriations of the Senate and the House 

of Representatives a report that either (1) certifies that the requirement for 

screening all air cargo on passenger aircraft has been met or (2) includes 

a strategy to comply with the screening requirement that includes a plan 

for meeting the screening requirement and that specifies the percentage 

of such air cargo that is being screened and the schedule for achieving 

screening of 100 percent of such air cargo.14

You asked us to review DHS’s progress and challenges in screening and 

securing air cargo transported to the United States. In response to this 

request, this report addresses the following questions:

The Administrator is to 

submit such a report not later than 180 days after enactment (enacted 

December 23, 2011) and every 180 days thereafter until the Administrator 

certifies that TSA has achieved the 100 percent screening mandate.

1. What actions has TSA taken since October 2010 to enhance the 

security of inbound air cargo transported on both passenger and all-cargo 

aircraft?

2. What challenges, if any, has TSA faced in enhancing the security of 

inbound air cargo?

This report is a public version of a prior sensitive report that we provided 

to you in March 2012. DHS deemed some of the information in the prior 

report sensitive security information, which must be protected from public 

disclosure.15

 

14 See Pub. L. No. 112-74, Div. D, § 548, 125 Stat. 786, 977-78 (2011).

Therefore, this report omits sensitive information regarding a 

third question about how agencies secure cargo using the No Fly List. In 

addition, at DHS’s request, we have omitted information on a potential 

vulnerability we identified related to the No Fly List and additional steps 

CBP and TSA could take to strengthen how the agencies use the No Fly 

List to secure inbound air cargo. The information provided in this report is 

15 See 49 C.F.R. pt. 1520. 
 

Page 5 GAO-12-632 Air Cargo Security 

more limited in scope as it excludes such sensitive information, but the 

overall methodology used for both reports is the same.

To answer the first and second objectives, we reviewed and analyzed 

TSA’s air cargo security policies and procedures, screening program 

documents, and security directives and emergency amendments issued 

in response to the October 2010 bomb attempt, as well as industry 

comments to TSA’s proposed screening program changes and date for 

implementing the mandate as it applies to inbound cargo. We assessed 

TSA’s efforts against DHS risk management criteria and Standards for 

Internal Control in the Federal Government.16

We also interviewed TSA air cargo program officials and representatives 

from six domestic and foreign passenger air carriers to obtain their views 

on TSA’s efforts to implement the screening mandate including TSA’s 

proposed security program changes. We selected the six passenger air 

carriers to obtain a representation of air carriers serving different 

international regions. Moreover, these six air carriers are among the 

passenger air carriers that transported the greatest volume of 

international cargo by weight in 2010, including cargo transported 

inbound to the United States. We also interviewed two of the largest 

passenger air carrier industry associations representing foreign and 

domestic air carriers to obtain their views on TSA’s security program 

changes for meeting the screening mandate as it applies to inbound air 

We also interviewed TSA 

and CBP air cargo program officials to discuss progress and challenges 

in securing inbound air cargo, including agency efforts taken in response 

to the October 2010 bomb attempt. In addition, we conducted site visits to 

three airports in the United States, selected because they are within the 

top five commercial airports that handle the greatest cargo volume in the 

United States. Although our site visits were based on a nonprobability 

sample and cannot be generalized to the entire air cargo industry, this 

sample allowed us to observe domestic cargo screening operations and 

programs in various parts of the country with differing air cargo volumes 

and commodities, which also provided insights on inbound cargo 

screening operations. We did not observe CBP inbound air cargo 

screening operations as part of our site visits because we focused on the 

agency’s efforts to target elevated-risk inbound air shipments.

 

16 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 

(Washington, D.C.: November 1999). 
 

Page 6 GAO-12-632 Air Cargo Security 

cargo. Their views cannot be generalized to all foreign and domestic air 

carriers but provided insights. For all-cargo carriers, we interviewed 

representatives of four all-cargo air carriers, three of which we 

interviewed at the three airports we visited, to obtain their views on, 

among other things, TSA’s efforts to enhance inbound air cargo security 

in response to the October 2010 bomb attempt. We selected these four 

all-cargo carriers to obtain a representation of all-cargo carriers that 

transport varying volumes of international cargo by weight, and two of the 

four all-cargo carriers we interviewed are responsible for transporting 

approximately 25 percent of inbound air cargo. Because we selected a 

nonprobability sample of all-cargo carriers, the results of these interviews 

cannot be generalized to other all-cargo carriers. However, this sample 

allowed us to understand all-cargo operations and provided important 

perspective on all-cargo air carrier efforts to secure inbound cargo. In 

addition, we interviewed two industry associations that represent all-cargo 

carriers, including the two largest international all-cargo carriers.

We conducted this performance audit from February 2011 through May 

2012 in accordance with 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 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
 

Page 7 GAO-12-632 Air Cargo Security 

Roughly 10 billion pounds of cargo are transported on inbound flights to 

the United States per year. Approximately 76 passenger air carriers and 

70 all-cargo carriers transport cargo to the United States and 

approximately 300 foreign airports in 100 countries provide last point of 

departure flights to the United States.17

 

17 Approximately 17 foreign airports with nonstop flights to the United States (known as 

last points of departure) serve only all-cargo carriers. 

This cargo ranges in size from 1 

pound to several tons and ranges in type from perishable commodities to 

machinery. Air cargo can include such varied items as electronic 

equipment, automobile parts, clothing, medical supplies, fresh produce, 

and human remains. As seen in figure 1, cargo can be shipped in various 

forms, including unit load devices (ULD) that allow many packages to be 

consolidated into one large container or pallet that can be loaded onto an 

aircraft; wooden skids or crates; as well as individually wrapped/boxed 

pieces known as loose or break bulk cargo.

Background
 

Page 8 GAO-12-632 Air Cargo Security 

Figure 1: Various Means of Shipping Air Cargo

Participants in the international air cargo shipping process can include 

shippers, such as individuals or manufacturers; freight forwarders or 

regulated agents, who consolidate shipments and deliver them to air 

carriers; air carrier cargo handling agents, who process and load cargo 

onto aircraft on behalf of air carriers; and passenger and all-cargo carriers 

that store, load, and transport air cargo. Figure 2 depicts the two primary 

ways a shipper may send inbound air cargo to the United States.
 

Page 9 GAO-12-632 Air Cargo Security 

Figure 2: Flow of Inbound Air Cargo Transported to the United States 

The Aviation and Transportation Security Act (ATSA), enacted into law 

shortly after the September 11, 2001, terrorist attacks, established TSA 

and gave the agency responsibility for securing all modes of 
 

Page 10 GAO-12-632 Air Cargo Security 

transportation, including the nation’s civil aviation system, which includes 

air carrier operations (domestic and foreign) to, from, and within the 

United States.18 Among other things, ATSA requires that TSA provide for 

the screening of all passengers and property, including cargo, transported 

on passenger aircraft originating in the United States.19 ATSA further 

requires that a system be in operation, as soon as practicable, to screen, 

inspect, or otherwise ensure the security of the cargo transported by allcargo aircraft—generally, aircraft configured solely for the transport of 

cargo—to, from, and within the United States but did not establish a firm 

deadline for the implementation of such a system.20

The 9/11 Commission Act defines screening for purposes of the air cargo 

screening mandate as a physical examination or the use of nonintrusive 

methods to assess whether cargo poses a threat to transportation 

security.

Consistent with ATSA 

and subsequent statutory requirements, including the 9/11 Commission 

Act, TSA has focused its efforts on establishing a system to secure cargo 

on passenger aircraft. Following the October 2010 bomb attempt 

originating in Yemen, TSA expedited efforts to further secure cargo on allcargo aircraft inbound to the United States to include mitigating threats 

posed by the introduction of an improvised explosive devices in cargo, in 

addition to the original focus on detecting and preventing stowaways 

intent on hijacking the aircraft and using it as a weapon.

21 Specific screening methods outlined in the 9/11 Commission 

Act include X-ray systems, explosives detection systems (EDS), 

explosives trace detection (ETD), explosives detection canine teams 

certified by TSA, physical search together with manifest verification, and 

additional methods approved by the TSA Administrator.22

 

18 See generally Pub. L. No. 107-71, 115 Stat. 597 (2001). 

However, solely 

performing a review of information about the contents of cargo or verifying 

the identity of the cargo’s shipper does not constitute screening for 

19 See Pub. L. No. 107-71, § 110(b), 115 Stat. at 614-16 (codified as amended at 49 

U.S.C. § 44901). 

20 See 49 U.S.C. § 44901(f). 

21 See 49 U.S.C. § 44901(g)(5).

22 An EDS machine uses computed tomography technology to automatically measure the 

physical characteristics of objects in baggage. The system automatically triggers an alarm 

when objects that exhibit the physical characteristics of explosives are detected. An ETD 

machine is used to chemically analyze trace materials after a human operator swabs 

checked baggage to identify any traces of explosive material. 
 

Page 11 GAO-12-632 Air Cargo Security 

purposes satisfying the mandate. Pursuant to the mandate, the system 

for screening air cargo must provide a level of security commensurate 

with the level of security for the screening of checked baggage.23

TSA’s Transportation Sector Network Management (TSNM) Air Cargo 

Division is responsible for developing air cargo regulations, establishing 

program regulations for the development of technological solutions, and 

policies that enhance the security of the air cargo supply chain while 

maintaining TSA’s commitment to ensure the flow of commerce. In fiscal 

year 2011, TSA’s budget for air cargo programs was approximately $115 

million, with $26 million dedicated to domestic and inbound air cargo 

security efforts, $74 million dedicated to air cargo inspectors and 

proprietary canines, and $15 million dedicated to the National Explosives 

Detection Canine Team Program. Approximately $124 million was made 

available to TSA to support its air cargo programs for fiscal year 2012.24

Risk management is a tool for informing policymakers’ decisions about 

assessing risks, allocating resources, and taking actions under conditions 

of uncertainty. We have reported that risk management entails a 

continuous process of managing risk through a series of actions, 

including setting strategic goals and objectives, assessing risk, evaluating 

alternatives, selecting initiatives to undertake, and implementing and 

monitoring those initiatives. We have previously reported that a risk 

management approach can help to prioritize the programs designed to 

combat terrorism. Risk management, as applied in the transportation 

security context, can help federal decision makers determine where and 

how to invest limited resources within and among the various modes of 

transportation.25

 

23 For example, TSA requires that all checked baggage transported on passenger aircraft 

from a U.S. airport be screened using an explosives detection system or by explosives 

trace detection, and air carrier security programs address baggage screening 

requirements for aircraft bound for the United States from foreign locations. See 49 U.S.C. 

§§ 44901(d), (g)(2). See also 49 C.F.R. §§ 1544.203, 1544.213, 1546.203. 

 The DHS National Infrastructure Protection Plan (NIPP) 

includes a risk management framework that consists of six steps, which 

24 See H.R. Rep. No. 112-331, at 969-70, 72 (Dec. 15, 2011) (conference report). 

25 For information on DHS’s and TSA’s risk management framework, see GAO, 

Transportation Security: Comprehensive Risk Assessments and Stronger Internal 

Controls Needed to Help Inform TSA Resource Allocation, GAO-09-492 (Washington, 

D.C.: Mar. 27, 2009). 
 

Page 12 GAO-12-632 Air Cargo Security 

closely reflects GAO’s risk management framework.26 Like GAO’s 

framework, the NIPP’s risk management framework is a repetitive 

process that continuously uses the results of each step to inform the 

activities in both subsequent and previous steps over time. The NIPP risk 

management framework is designed to produce a systematic and 

comprehensive understanding of risk and ultimately provide for security 

investments based on this knowledge of risk.

TSA has taken three primary actions to enhance security of inbound 

cargo on passenger and all-cargo aircraft following the October 2010 

bomb attempt originating in Yemen.

TSA issued new screening requirements aimed at enhancing the 

security of cargo on passenger and all-cargo aircraft. Beginning in 

October 2010 through May 2011, TSA required new risk-based security 

procedures aimed at focusing more detailed screening measures on highrisk shipments. These security measures included, among other things, 

prohibiting the transport of air cargo on passenger aircraft from Yemen 

and Somalia due to threats stemming from those areas.27

Moreover, the Yemen incident raised questions about the effectiveness of 

technology and screening protocols used to screen air cargo because 

suspected packages were screened multiple times, using multiple 

methods, at various locations yet the threat items were detected only after 

foreign law enforcement officials opened the shipments based on a tip 

from an intelligence source. According to TSA, the threat item used in the 

incident likely would not have been detected by air carriers using TSA 

screening protocols in place at that time because screening requirements 

for all-cargo carriers focused on preventing and detecting stowaways or 

contraband items and not on detecting explosive devices and, for 

passenger air carriers, screening requirements primarily focused on 

detecting assembled explosive devices rather than on the types of 

specific components used to construct the explosive device associated 

with the Yemen incident. Following the October 2010 bomb attempt, DHS 

 

26 The six steps contained in the NIPP are (1) Set security goals; (2) Identify assets, 

systems, networks, and functions; (3) Assess risks (consequences, vulnerabilities, and 

threats); (4) Prioritize; (5) Implement protective programs; and (6) Measure effectiveness. 

27 Requirements also apply to all-cargo carriers. 

TSA Has Taken 

Actions to Enhance 

the Security of Cargo 

on Inbound Aircraft 

Since October 2010
 

Page 13 GAO-12-632 Air Cargo Security 

simulated the conditions of the incident in a laboratory setting, and TSA 

found that existing approved technologies are capable of detecting the 

materials used in the bomb attempt when used by screeners trained in 

protocols for identifying those specific materials. Subsequent to these 

tests, and as noted above, TSA implemented new risk-based security 

procedures to enhance the effectiveness of TSA screening requirements.

In addition, officials from all four all-cargo carriers we spoke with stated 

that in some cases they implement their own inbound air cargo security 

measures, in addition to those required by TSA requirements, to 

safeguard their staff, cargo shipments, and aircraft. Officials from three of 

the six passenger air carriers we spoke with also provided examples of 

additional security measures they implement.28

DHS instituted working groups with air cargo industry stakeholders 

to identify ways to enhance air cargo security. Following the October 

2010 bomb attempt originating in Yemen, in January 2011, the Secretary 

of Homeland Security established an Air Cargo Security Working Group, 

composed of four subgroups, to obtain advice and consultations from air 

cargo security stakeholders—including passenger and all-cargo 

representatives—on ways to enhance the security of the air cargo 

system.29

 

28DHS deemed details on specific measures taken by air carriers as sensitive security 

information. Thus, they are not included in this report. 

The Air Cargo Security Working Group briefed the Secretary of 

Homeland Security, the Commissioner for CBP, and the TSA 

Administrator in April 2011 on proposed solutions, and recommended that 

TSA reevaluate the agency’s implementation plan, timeline, and 

resources related to the National Cargo Security Program (NCSP) 

recognition program, a TSA effort to recognize the security programs of 

foreign countries. Other proposed solutions included establishing an 

29 DHS’s Air Cargo Security Working Group consists of four subgroups: (1) Information 

subgroup, whose objective is to, among other things, enhance intelligence and information 

sharing among federal stakeholders and between the U.S. government and private sector 

entities; (2) technology and capacity building subgroup, whose objective is to review 

technology standards and develop suggestions for addressing technology limitations; (3) 

global cargo programs subgroup, whose objective is to review and explore opportunities 

for enhanced public-private coordination as DHS works to address statutory requirements 

for screening 100 percent of inbound air cargo; and (4) global mail subgroup, whose 

objective is to, among other things, identify potential vulnerabilities for global mail and 

propose alternative processes and procedures to ensure the safety of mail transported by 

air. 
 

Page 14 GAO-12-632 Air Cargo Security 

international trusted shipper program to perform cargo security and 

screening throughout the international supply chain, before its transport 

from last point of departure airports, and developing mutually recognized 

standards for cargo screening technology. Given that DHS is currently 

considering actions to take in response to the recommendations and 

which ones to implement, it could not provide us with specifics on the 

implementation of the Air Cargo Security Working Group 

recommendations. According to DHS, the Air Cargo Security Working 

Group may meet again in 2012, to discuss its role in supporting the 

implementation of the recommendations but a date has not yet been 

established. Following this meeting, the members plan to work on a 

standalone basis through the four subgroups and advise the Secretary of 

Homeland Security upon her request.

DHS initiated an Air Cargo Advance Screening (ACAS) pilot. DHS 

initiated this pilot in December 2010 to more readily identify high-risk 

cargo for additional screening prior to all-cargo and passenger aircraft 

departing from foreign airports to the United States. The aim of the pilot, 

which is ongoing, is to determine whether it is feasible for air carriers to 

submit air cargo manifest data to CBP prior to departure from all foreign 

last point of departure airports to allow CBP to analyze, target, and, if 

needed, issue instructions to air carriers to provide additional cargo 

information or take additional security measures before such cargo is 

loaded onto aircraft. DHS initially focused on all-cargo express carriers 

and companies due to the elevated risk highlighted by the October 2010 

incident.30 As of December 2011, the pilot included select airports from a 

number of countries and regions. Under current CBP requirements, CBP 

must receive manifest data for air cargo shipments from air carriers no 

later than 4 hours prior to the flight’s arrival in the United States or no 

later than the time of departure (“wheels up” and en route directly to the 

United States) from locations in North America, including Canada, 

Mexico, the Caribbean, Central America, and parts of South America 

north of the Equator.31

 

30 All-cargo express carriers and companies focus on transporting cargo under quick time 

frames. 

Under the pilot program, however, participants 

provide manifest data prior to loading cargo aboard aircraft.

31 See 19 C.F.R. § 122.48a(b).
 

Page 15 GAO-12-632 Air Cargo Security 

While the pilot initially focused on four all-cargo express carriers, the 

agencies began expanding the pilot to include passenger air carriers in 

the fall of 2011. Four passenger carriers have committed to joining the 

pilot. According to DHS officials, early results demonstrate that all-cargo 

express carriers and companies are able to submit manifest data, in 

some cases, a number of hours in advance of existing CBP requirements 

for receipt of manifest data described above. However, DHS officials 

stated that it will be difficult to obtain manifest data far in advance as the 

pilot expands to include additional carriers, such as passenger air 

carriers, and other geographic locations due to the need to develop 

additional protocols with entities (carriers and freight forwarders) that may 

not have previously transmitted data to DHS. Further, five of six 

passenger air carriers we spoke with stated that submitting this 

information far in advance will be challenging because passenger air 

carriers typically receive manifest data from freight forwarders just hours 

before departure. To address these challenges, DHS officials explained 

that they are meeting with freight forwarders—which have shipment 

information before air carriers—to discuss the feasibility of having 

forwarders submit manifest information directly to CBP as part of the 

ACAS pilot. Because these efforts are in the initial stages, it is too early to 

determine the extent to which CBP and TSA will be able to obtain 

advance cargo manifest data prior to departure from passenger air 

carriers and its impact on strengthening security.
 

Page 16 GAO-12-632 Air Cargo Security 

Air carriers and TSA face challenges that, among other things, could limit 

TSA’s ability to meet the mandate to screen 100 percent of inbound air 

cargo transported on passenger aircraft and to provide reasonable 

assurance that screening is being conducted at reported levels. All cargo 

carriers subject to TSA regulation also reported facing challenges in 

implementing new TSA screening requirements implemented after the 

October 2010 Yemen incident.

Passenger Air Carriers Reported Logistical Challenges 

Implementing Proposed Screening Requirements. In January 2011, 

TSA proposed additional changes to passenger aircraft security 

requirements outlined in the Aircraft Operator Standard Security Program 

(AOSSP) and the Model Security Program (MSP) to further enhance the 

security of air cargo departing foreign locations by requiring 100 percent 

screening of cargo previously exempt from screening. Current TSA 

requirements call for air carriers to screen a certain percentage of all 

cargo. 32

 

32 Details on TSA’s screening requirements are deemed sensitive security information and 

not included in this report.

 TSA’s proposed changes were to go into effect on December 

31, 2011, and would have required passenger air carriers to screen 100 

percent of cargo. TSA proposed these changes as part of the agency’s 

efforts to meet the 9/11 Commission Act mandate for 100 percent 

screening of inbound air cargo transported on passenger aircraft by the 

end of calendar year 2011—2 years earlier than the TSA administrator 

reported to Congress in November 2010.

Challenges Persist in 

Meeting Screening 

Mandate, and 

Additional Efforts 

Could Facilitate 

Oversight of Carriers’ 

All-Cargo Screening 

Efforts

Challenges Exist In 

Meeting Screening 

Requirements for Inbound 

Cargo Transported on 

Passenger and All-Cargo 

Aircraft
 

Page 17 GAO-12-632 Air Cargo Security 

In commenting on TSA’s proposal to achieve 100 percent screening of 

inbound cargo by the end of calendar year 2011, passenger air carriers 

expressed concerns about being able to meet the 100 percent screening 

mandate as it applies to inbound cargo by December 31, 2011, stating 

that it would cause significant disruptions in the air cargo supply chain by 

requiring, among other things, 100 percent screening, including screening 

of cargo previously exempt from screening. In comments submitted to 

TSA, 6 of 19 foreign air carriers and one industry association were 

opposed to the new proposed date due to insufficient time to implement 

the proposed requirements and potential detrimental impact to air carrier 

operations in the form of higher costs and slower screening times. Five of 

these 6 foreign air carriers are among the passenger air carriers that 

transport the greatest volume of international cargo by weight, and the 

association represents hundreds of air carriers whose flights comprise 

over 80 percent of international air traffic. In addition, 5 of 19 foreign 

airlines and the 2 industry associations representing foreign airlines 

reported that they opposed TSA’s proposed changes to screen 100 

percent of cargo previously exempt from screening, stating that this would 

delay the processing of cargo and potentially disrupt the flow of 

commerce. Moreover, 3 of the 6 passenger air carriers we spoke with 

stated that they would no longer be able to transport certain types of 

cargo if TSA were to require 100 percent screening of cargo previously 

exempt from screening.

Two of the six passenger air carriers we spoke with expressed concern 

about new requirements calling for the screening of all inbound air at the 

last point of departure because it would cause disruptions in the chain of 

custody throughout the air cargo supply chain without providing any 

additional security benefit. Specifically, they stated that some inbound air 

cargo is already screened at points of origin and that the new 

requirements would in effect result in rescreening of already screened 

cargo. Additionally, one of six passenger air carriers and one industry 

association—representing U.S. air carriers that transport more than 90 

percent of all U.S. airline and passenger cargo traffic—commented on the 

challenges in screening ULD pallets or containers, which are the primary 

means of transporting air cargo on wide-body passenger aircraft on both 

domestic and inbound aircraft. Since TSA has not approved or qualified 

any equipment to screen cargo transported on ULD pallets or containers, 

these air carriers and associations commented that breaking down ULDs 
 

Page 18 GAO-12-632 Air Cargo Security 

in order to rescreen cargo would cause further delays and inefficiencies.33

In addition, TSA reported that a number of passenger air carriers 

informed the agency that they would have difficulty implementing 

additional security measures outlined in the security directives and 

emergency amendments to the AOSSP and MSP.

For example, three foreign air carriers commented that it is highly 

impractical to unload screened cargo from ULDs, rescreen that cargo, 

and then reload the ULDs and that doing so would reduce operational 

efficiencies, result in delays, and expose cargo to damage and theft.

34 According to TSA 

officials, air carriers request alternative security measures when they are 

unable to comply with the exact language contained in the TSA-issued 

security program, but can meet the intent of the requirement through an 

alternative security measure, which must result in an equal or better 

security outcome. 35

To address these issues an industry group and one air carrier suggested 

TSA establish/recognize international supply chain security programs akin 

to the Certified Cargo Screening Program (CCSP), which is a voluntary 

cargo screening program for air cargo industry participants that allows 

screening to take place at various points along the air cargo supply chain 

in the United States.

These passenger carriers—both domestic and 

foreign—have requested alternative security measures to implement the 

security directives and emergency amendments, which TSA has 

approved.

36

 

33 As we reported in June 2010, about 96 percent of inbound air cargo is transported to 

the United States on wide-body aircraft. TSA officials stated that they continue to work 

with technology vendors to identify technology capable of screening ULD pallets and 

containers, but according to officials, technologies to detect items deemed threats in 

pallets and containers are not expected to be available for several years.

This suggestion is similar to the one put forth by 

the DHS working group made up of air cargo industry stakeholders which 

proposed establishing an international trusted shipper program to perform 

34 DHS deemed the reasons why passenger air carriers would have difficulty 

implementing additional security measures as sensitive security information. Thus, it was 

omitted from this report.

35 See, e.g., 49 C.F.R. §§ 1544.105(b)(3); 1544.305(d); 1546.105(b). 

36 To support the requirement on industry to screen 100 percent of air cargo transported 

on passenger aircraft from U.S. airports, TSA developed the CCSP. The CCSP allows 

screening of domestic cargo at points throughout the supply chain by an approved 

Certified Cargo Screening Facility (CCSF) prior to the arrival of the cargo at the airport.
 

Page 19 GAO-12-632 Air Cargo Security 

cargo security and screening throughout the international supply chain, 

before its transport from last point of departure airports. These 

stakeholders contend that such a program could assist air carriers in 

implementing the 100 percent screening mandate as was done in the 

United States under the CCSP.

According to TSA officials the agency plans to respond to the challenges 

raised by industry stakeholders by revising the proposed requirements, 

which may include, among other things, risk-based security procedures 

similar to those TSA issued following the October 2010 bomb attempt 

originating in Yemen. TSA plans to publish the revised security 

requirements in early May 2012. TSA anticipates that the new proposed 

requirements will become effective in June 2012. In commenting on the 

sensitive security version of our report, DHS stated that TSA finalized a 

tactical plan, with a proposed timeline, to achieve 100 percent screening 

of inbound air cargo transported on passenger aircraft. In late March 

2012, TSA provided us with the tactical plan that included, among other 

things, a timeline that would require air carriers to screen 100 percent of 

inbound air cargo transported on passenger aircraft by December 1, 

2012. TSA’s plan to implement the screening mandate is a key step in its 

efforts to secure inbound air cargo and it will be important for the agency 

to continue to monitor passenger air carriers’ efforts to adhere to TSA’s 

plan for meeting the mandate.

TSA Faces Challenges Verifying Screening Data on Inbound 

Passenger Cargo. TSA relies on data submitted to the agency by air 

carriers to determine the amount of inbound air cargo screened in 

accordance with TSA screening requirements. As noted above, in 

January 2011, TSA announced that it was planning to meet the 9/11 

Commission Act mandate as it applies to inbound air cargo transported 

on passenger aircraft by the end of calendar year 2011. TSA officials 

determined that it was feasible to accelerate its plans at that time based 

on screening data reported by air carriers in late 2010 and air carrier 

feedback. TSA officials subsequently determined in the spring of 2011 

that air carriers were screening cargo at lower levels than previously 

reported due to industry stakeholder confusion regarding TSA’s proposed 

requirements for screening inbound air cargo. As of September 2011, 

TSA officials stated that current air carrier-reported screening 

percentages—which they estimate to be about 80 percent—are based on 

actual data reported by air carriers, but agreed that it is difficult to verify 

the accuracy of the screening data reported by air carriers with 

reasonable assurance. As of December 2011, the air carrier data have 

not been independently verified for accuracy since TSA has not 
 

Page 20 GAO-12-632 Air Cargo Security 

developed a mechanism to cross-reference local screening logs—which 

include screening information on specific shipments—with screening 

reports submitted by air carriers to TSA that do not contain such 

information. In addition, TSA counts all inbound air cargo from foreign 

countries that require 100 percent screening and that are recognized 

under the NCSP as screened for the purposes of meeting the mandate. 

However, while TSA officials stated that they discuss screening 

percentages with foreign government officials, the agency does not have 

a mechanism to conduct additional data verification to assess whether 

screening is conducted at, above, or below the required levels.

In order to more accurately identify the level of screening being 

conducted on inbound air cargo, we recommended in June 2010 that TSA 

develop a mechanism to verify the accuracy of all screening data through 

random checks or other practical means.37

Harmonizing U.S. and Foreign Air Cargo Security Standards Is 

Difficult. TSA has developed an NCSP recognition program that would 

review and recognize the air cargo security programs of foreign countries 

if TSA deems those programs as providing a level of security 

commensurate with TSA’s air cargo security standards. As of November 

2011, TSA has recognized 2 countries as providing a level of security 

commensurate with current U.S. air cargo security standards, and 

continues to evaluate the comparability of air cargo security programs for 

several other countries. TSA also recognizes 2 additional countries under 

TSA concurred in part with our 

recommendation and issued changes to air carriers’ standard security 

programs that require air carriers to report inbound cargo screening data 

to TSA. TSA officials told us that in May 2010 the agency created a 

reporting requirement for air carriers to provide screening data on a 

monthly basis. TSA also stated that inspectors review screening data, 

among other things, when inspecting air carriers as part of the agency’s 

air carrier compliance inspections. However, since TSA still has not 

developed a mechanism to verify the accuracy of the data reported by air 

carriers, the agency has not yet fully met the intention of our 

recommendation. It will be important for TSA to continue to work towards 

ensuring verification of inbound air cargo screening data submitted by air 

carriers and that inbound air cargo is screened in accordance with the 

mandate.

 

37 GAO-10-446. 
 

Page 21 GAO-12-632 Air Cargo Security 

the legacy program that preceded the NCSP recognition program and the 

agency is evaluating these countries against the current NCSP standards 

for renewal. TSA officials stated that the NCSP recognition program is a 

key effort in meeting the 100 percent screening mandate because it will 

eliminate the need for air carriers to comply with two country’s security 

programs. However, according to TSA officials, evaluating foreign 

countries’ air cargo security programs is challenging because the agency 

is dependent upon countries’ willingness and ability to work with TSA 

officials to ensure their programs are commensurate to those of the 

United States. As of November 2011, TSA was coordinating with 16 

countries, including 12 of the top 20 passenger air cargo volume 

countries, which according to TSA officials and based on BTS data, 

represent 51 percent of the inbound air cargo volume by weight to the 

United States.

We previously reported that given the challenges TSA faces in meeting 

the screening mandate for inbound air cargo, the agency would be better 

positioned to meet the mandate by developing a plan to account for these 

challenges. As such, in June 2010, we recommended that TSA develop a 

plan, with milestones, for how and when the agency intends to meet the 

mandate as it applies to inbound cargo. TSA concurred with the 

recommendation and stated that the agency was drafting milestones as 

part of a plan to generally require air carriers to conduct 100 percent 

screening by a specific date. TSA has not yet fully implemented this 

recommendation but agency officials stated that it plans to do so by 

December 2012. In light of the number of challenges facing TSA in its 

efforts to address the screening mandate for inbound air cargo, we 

continue to believe that our recommendation has merit and that it will be 

important for TSA to document such a plan.
 

Page 22 GAO-12-632 Air Cargo Security 

A number of foreign and domestic all-cargo carriers subject to TSA 

regulation initially notified the agency that they would have difficulty in 

implementing the new TSA screening requirements introduced after the 

October 2010 incident, including a requirement to screen all cargo using a 

certain type of screening technology, because all-cargo carriers stated 

that they do not have such technology at all locations.38 Moreover, a 

number of domestic all-cargo carriers requested TSA approval to 

implement alternative security procedures (as an alternative to 

requirements in security directives and emergency amendments) since 

they stated that it would be challenging to implement these new security 

measures. As previously discussed, according to TSA officials, air 

carriers request alternative procedures when they are unable to comply 

with the exact language contained in the requirement, but can meet the 

intent of the requirement through an alternative procedure, which must 

result in an equal or better security outcome. TSA approved all of these 

requests, as of December 2011. For example, some all-cargo carriers 

received TSA approval to use different procedures or different models—

or versions—of screening equipment to screen cargo in lieu of using 

equipment on TSA’s list of approved screening equipment. Officials from 

all-cargo carriers explained that they only deploy screening technology to 

airports that they deem to be high risk and consequently did not have 

TSA-approved screening technology available for use at other last point 

of departure foreign airports that they deem lower risk.

TSA relies on data submitted by passenger carriers to determine the 

amount of air cargo screened on inbound passenger aircraft but there is 

no requirement for all-cargo carriers to report comparable screening data 

to TSA even though most of the cargo shipped from abroad into the 

United States is shipped on all-cargo carriers. Thus, TSA does not know 

the extent to which all-cargo carriers are screening cargo or meeting the 

enhanced screening requirements introduced after the October 2010 

incident in Yemen. In 2010, all-cargo carriers transported approximately 

67 percent (7.2 billion pounds) of the total cargo (10.8 billion pounds) 

transported to the United States.39

 

38 Following the October 2010 incident, TSA implemented a new requirement to screen 

cargo transported on all-cargo aircraft for explosives using the same TSA-approved 

screening methods for cargo transported on passenger aircraft. 

According to officials from two global 

39 Based on 2010 BTS data by freight configuration for all-cargo carriers. Passenger 

aircraft transported the remaining 33 percent (3.6 billion) of air cargo pounds. 

All-Cargo Carriers 

Reported Challenges 

Meeting New 

Screening 

Requirements

Reporting Screening Data 

Could Facilitate Oversight 

of All-Cargo Carriers’ 

Compliance with Security 

Requirements
 

Page 23 GAO-12-632 Air Cargo Security 

all-cargo carriers we spoke with, responsible for transporting 

approximately 25 percent of inbound air cargo on all-cargo flights, 

submitting such information to TSA would be feasible because they are 

already collecting this data internally. However, officials from the other 

two all-cargo carriers we interviewed stated that reporting screening data 

to TSA would be challenging because of staffing limitations at foreign 

airports necessary to compile and submit the screening data or because 

such data may not be available.

TSA officials explained that the agency does not currently require that allcargo carriers submit screening data to demonstrate compliance with 

enhanced screening requirements because the agency has focused its 

efforts on collecting data from passenger air carriers in support of meeting 

the 100 percent mandate. In addition, TSA officials stated that the agency 

is attempting to gain some visibility over all-cargo carrier operations 

through the ACAS pilot.40

DHS’s risk management policy directs its components to adopt risk 

management practices in order to, among other things, inform decisions 

to enhance security and manage homeland security risks.

TSA officials stated that as part of the pilot 

program’s future expansion, the agency may consider opportunities to 

capture additional inbound air cargo information, but has not yet weighed 

the costs and benefits of requiring such all-cargo carriers to submit data 

on their screening efforts because the agency has focused its efforts on 

establishing the pilot program. The pilot program is a key effort to identify 

high-risk cargo prior to aircraft departing from foreign airports, but the pilot 

is not intended to provide TSA with screening data, which if collected and 

verified, could provide additional assurance that all-cargo carriers are 

complying with the agency’s enhanced screening requirements.

41

 

40 As of January 2012, the ACAS pilot included 4 of the 70 all-cargo carriers that service 

the United States and is focused on about 84 geographic locations.

As part of this 

policy, DHS components are to incorporate risk management processes 

to identify potential risks, and develop and analyze alternative strategies 

to manage risks considering projected costs, benefits, and ramifications 

of each alternative to manage or mitigate the risk. By assessing the costs 

and benefits of requiring all-cargo carriers to submit screening data to 

TSA in accordance with DHS’s policy on risk management, the agency 

could determine whether these additional data could enhance the 

41DHS, DHS Policy for Integrated Risk Management (May 27, 2010).
 

Page 24 GAO-12-632 Air Cargo Security 

agency’s efforts to identify potential risks to inbound air cargo and 

develop cost effective strategies and measures to manage these risks. In 

addition, Standards for Internal Control in the Federal Government 

underscore the need for developing effective controls for meeting 

program objectives and complying with applicable regulation and 

capturing information needed to meet program objectives.42 These 

standards also include designing controls to assure that ongoing 

monitoring occurs in the course of normal operations and determining that 

relevant, reliable, and timely information is available for management 

decision-making purposes. TSA could better determine what actions are 

needed, if any, to ensure that all-cargo carriers are complying with the 

agency’s enhanced screening requirements by assessing the costs and 

benefits of requiring all-cargo carriers to report data on screening 

conducted. 

DHS and TSA have taken steps to better secure inbound air cargo in the 

wake of the October 2010 bomb attempt in Yemen. However, TSA 

continues to face a number of challenges that complicate its efforts to 

meet the 9/11 Commission Act screening mandate as it relates to 

inbound air cargo transported on passenger aircraft. These challenges 

influenced the agency’s decision to propose a new date for screening 100 

percent of inbound cargo on passenger aircraft of December 2012. 

Moreover, while TSA has taken steps to enhance cargo screening on all 

cargo carriers, TSA does not have full visibility over their efforts to screen 

air cargo since it does not require all-cargo air carriers to report any data 

on their screening efforts. Assessing the costs and benefits of requiring 

all-cargo carriers to submit screening data could help TSA determine 

whether these additional data could enhance the agency’s efforts to 

identify potential risks to inbound air cargo and develop cost-effective 

strategies and measures to manage these risks.

To help DHS address challenges in meeting the air cargo screening 

mandate as it applies to inbound air cargo, mitigate potential air cargo 

security vulnerabilities, and enhance overall efforts to screen and secure 

inbound air cargo, we recommend that the Secretary of Homeland 

Security direct the Administrator of TSA to assess the costs and benefits 

 

42 GAO/AIMD-00-21.3.1. 

Conclusions

Recommendation for 

Executive Action
 

Page 25 GAO-12-632 Air Cargo Security 

of requiring all-cargo carriers to report data on the amount of inbound air 

cargo screening being conducted.

We provided a draft of this report to DHS, TSA, and CBP for review and 

comment. DHS provided written comments which are reprinted in 

appendix I. In commenting on our report, DHS stated that it concurred 

with the recommendation and identified actions taken or planned to 

implement it.

DHS concurred with the recommendation that TSA assess the costs and 

benefits of requiring all-cargo carriers to report data on the amount of 

inbound air cargo screening being conducted. DHS stated that as part of 

the ACAS pilot, TSA is taking steps to require carriers to provide 

confirmation that screening has been conducted in accordance with 

TSA’s enhanced screening requirements. DHS also stated that when fully 

implemented, the ACAS pilot will provide the capability to report high-risk 

inbound air cargo shipments screened by all-cargo carriers. We support 

TSA’s actions to identify and report on high-risk cargo being screened 

using ACAS capabilities. Given that the ACAS pilot is currently limited to 

a relatively small number of participants, expanding the pilot to include a 

greater number of all-cargo carriers that transport air cargo to the United 

States could provide TSA with additional assurance that all-cargo carriers 

are complying with the agency’s enhanced screening requirements. Such 

action, when fully implemented, would further address the intent of our 

recommendation.

In its comments, DHS also referred to a second recommendation to the 

Administrator of TSA and Commissioner of CBP related to how the 

agencies use the No Fly List to secure inbound air cargo. Because DHS 

deemed the details of this recommendation and its response as sensitive 

security information, they are not included in the public version of the 

report.

Finally, in commenting on our report, DHS provided an update on TSA’s 

efforts to implement the mandate to screen 100 percent of inbound air 

cargo transported on passenger aircraft. DHS stated that TSA has 

finalized a tactical plan, with a proposed timeline, to achieve 100 percent 

screening of inbound air cargo transported on passenger aircraft. The 

plan involves, among other things, a timeline for implementing a revised 

security program by summer 2012 that would require air carriers to 

screen 100 percent of inbound air cargo transported on passenger aircraft 

by December 1, 2012. The plan also involves use of the ACAS pilot by 

Agency Comments 

and Our Evaluation
 

Page 26 GAO-12-632 Air Cargo Security 

passenger air carriers to submit data and proposed amendments to 

TSA’s carrier security requirements. TSA’s plan to implement the 

screening mandate is a key step to securing inbound air cargo and it will 

be important for the agency to continue to monitor its efforts to ensure 

that passenger air carriers adhere to TSA’s plan for meeting the mandate.

DHS and the Federal Bureau of Investigation’s Terrorist Screening Center 

also provided us with technical comments, which we incorporated as 

appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the Secretary of 

Homeland Security; the TSA Administrator; and the Commissioner of 

Customs and Border Protection; appropriate congressional committees; 

and other interested parties. In addition, the report will be available at no 

charge on the GAO website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-4379 or lords@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. Key contributors to this report are acknowledged in 

appendix II.

Stephen M. Lord

Director, Homeland Security and Justice Issues
 

Page 27 GAO-12-632 Air Cargo Security 

List of Requesters

The Honorable Joseph I. Lieberman

Chairman

The Honorable Susan M. Collins

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Peter T. King

Chairman

The Honorable Bennie G. Thompson

Ranking Member

Committee on Homeland Security

House of Representatives

The Honorable Sheila Jackson Lee

House of Representatives

The Honorable Edward Markey

House of Representatives
Appendix I: Comments from the Department of 

Homeland Security 

Page 28 GAO-12-632 Air Cargo Security 

Appendix I: Comments from the Department 

of Homeland Security
Appendix I: Comments from the Department of 

Homeland Security 

Page 29 GAO-12-632 Air Cargo Security 
Appendix II: GAO Contact and Staff 

Acknowledgements

Page 30 GAO-12-632 Air Cargo Security 

Stephen M. Lord, (202) 512-4379 or lords@gao.gov

In addition to the contact named above, Steve D. Morris, Assistant 

Director, and Joel Aldape, Analyst-in-Charge, managed this review. 

Carissa Bryant made significant contributions. Thomas F. Lombardi 

provided legal support. Stanley J. Kostyla and Richard Hung assisted with 

design and methodology. Jessica Orr provided assistance in report 

preparation.

Appendix II: GAO Contact and Staff 

Acknowledgements 

GAO Contact

Acknowledgments

(441070)
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