United States Government Accountability Office

GAO Report to Congressional Requesters

AVIATION SECURITY

Foreign Airport 

Assessments and Air 

Carrier Inspections 

Help Enhance 

Security, but 

Oversight of These 

Efforts Can Be 

Strengthened 

May 2007 

 

GAO-07-729 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

May 2007

AVIATION SECURITY

Foreign Airport Assessments and Air 

Carrier Inspections Help Enhance 

Security, but Oversight of These Efforts 

Can Be Strengthened 

Highlights of GAO-07-729, a report to 

congressional requesters 

The Transportation Security 

Administration’s (TSA) efforts to 

evaluate the security of foreign

airports and air carriers that 

service the United States are of

great importance, particularly

considering that flights bound for

the United States from foreign

countries continue to be targets of

coordinated terrorist activity, as 

demonstrated by the alleged 

August 2006 liquid explosives 

terrorist plot. 

For this review, GAO evaluated the 

results of foreign airport and air

carrier evaluations; actions taken 

and assistance provided by TSA 

when security deficiencies were

identified; TSA’s oversight of its

foreign airport and air carrier 

evaluation programs; and TSA’s 

efforts to address challenges in

conducting foreign airport and air 

carrier evaluations. To conduct this 

work, GAO reviewed foreign 

airport and air carrier evaluation 

results and interviewed TSA 

officials, foreign aviation security

officials, and air carrier 

representatives. 

What GAO Recommends

In an April 2007 report that

contained sensitive information, 

GAO recommended, and the

Department of Homeland Security

agreed, that TSA develop controls 

for tracking and documenting 

information and establish outcomebased performance measures to 

strengthen oversight of its foreign 

airport and air carrier evaluation 

programs. 

Of the 128 foreign airports that TSA assessed during fiscal year 2005, TSA 

found that about 36 percent complied with all applicable security standards, 

while about 64 percent did not comply with at least one standard. The 

security deficiencies identified by TSA at two foreign airports were such that 

the Secretary of Homeland Security notified the public that the overall 

security at these airports was ineffective. Of the 529 overseas air carrier 

inspections conducted during fiscal year 2005, for about 71 percent, TSA did 

not identify any security violations, and for about 29 percent, TSA identified 

at least one security violation. TSA took enforcement action—warning 

letters, correction letters, or monetary fines—for about 18 percent of the air 

carrier security violations. TSA addressed most of the remaining 82 percent 

of security violations through on-site consultation. 

TSA assisted foreign officials and air carrier representatives in addressing

identified deficiencies through on-site consultation, recommendations for 

security improvements, and referrals for training and technical assistance.

However, TSA’s oversight of the foreign airport assessment and air carrier 

inspection programs could be strengthened. For example, TSA did not have 

adequate controls in place to track whether scheduled assessments and 

inspections were actually conducted, deferred, or canceled. TSA also did not 

always document foreign officials’ progress in addressing security 

deficiencies identified by TSA. Further, TSA did not always track what 

enforcement actions were taken against air carriers with identified security

deficiencies. TSA also did not have outcome-based performance measures to 

assess the impact of its assessment and inspection programs on the security 

of U.S.-bound flights. Without such controls, TSA may not have reasonable 

assurance that the foreign airport assessment and air carrier inspection 

programs are operating as intended. 

TSA is taking action to address challenges that have limited its ability to 

conduct foreign airport assessments and air carrier inspections, including a 

lack of available inspectors, concerns regarding the resource burden placed 

on host governments as a result of frequent airport visits by TSA and others, 

and host government concerns regarding sovereignty. In October 2006, TSA 

began implementing a risk-based approach to scheduling foreign airport 

assessments, which should allow TSA to focus its limited inspector 

resources on higher-risk airports. TSA is also exploring opportunities to 

conduct joint airport assessments with the European Commission and use 

the results of airport assessments conducted by the European Commission 

to potentially adjust the frequency of TSA airport visits. 

www.gao.gov/cgi-bin/getrpt?GAO-07-729

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Cathleen 

Berrick at (202) 512-3404 or

berrickc@gao.gov. 
Contents 

Letter 1

Results in Brief 5

Background 12

TSA Found That Some Foreign Airports and Air Carriers Complied 

with All Aviation Security Standards, and When Deemed 

Necessary, DHS and TSA Took Enforcement Action on Those 

That Did Not 26 

TSA Assisted Foreign Officials and Air Carrier Representatives in 

Addressing Security Deficiencies, but Can Strengthen Oversight 

of the Foreign Airport Assessment and Air Carrier Inspection 

Programs 34

TSA Is Taking Action to Address Some Challenges That Have 

Limited Its Ability to Conduct Foreign Airport Assessments and 

Air Carrier Inspections 48 

Conclusions 64

Recommendations for Executive Action 65 

Agency Comments and Our Evaluation 66 

Appendix I Objectives, Scope, and Methodology 68 

Results of Fiscal Year 2005 Foreign Airport Assessments and Air 

Carrier Inspections and Actions Taken by TSA in Response to 

Noncompliance 68

Assistance Provided by TSA to Address Security Deficiencies and 

Oversight of Airport Assessment and Air Carrier Inspection 

Efforts 72

Challenges That Affected TSA’s Ability to Conduct Foreign Airport 

Assessments and Air Carrier Inspections and Actions Taken to

Address those Challenges 75 

Appendix II International Civil Aviation Organization Standards 

and Recommended Practices Used by TSA to Conduct 

Fiscal Year 2005 Foreign Airport Assessments 77 

Appendix III TSA Security Requirements for U.S.-Based and 

Foreign Carriers Operating Out of Foreign Airports 93 

Page i GAO-07-729 Aviation Security
Appendix IV U.S. Government Aviation Security Training and 

Technical Assistance Programs for Foreign Entities 96 

Department of State: Anti-Terrorism Assistance Program 96 

U.S. Trade and Development Agency 98 

Department of Transportation—Safe Skies for Africa Program 100 

Department of State—Bureau of International Narcotics and Law 

Enforcement Affairs—Organization of American States InterAmerican Committee against Terrorism 102 

Department of State—Western Hemisphere Affairs—Organization 

of American States—Inter-American Committee against 

Terrorism 104

Department of Justice-International Criminal Investigative Training 

and Assistance Program 105 

Appendix V Comments from the Department of Homeland 

Security 107 

Appendix VI GAO Contacts and Staff Acknowledgments 111 

Related Products 112 

Tables 

Table 1: Positions That Play a Key Role in TSA’s Foreign Airport 

and Air Carrier Inspection Programs 14 

Table 2: Comparison of the Severity of Security Deficiencies and 

Corrective Action Taken at One Secretarial Action Airport 

and One Non-Secretarial Action Airport 30 

Table 3: Budgeted and Available International Inspectors by IFO, 

by Month for Fiscal Year 2005 50 

Table 4: Budgeted Number of Inspectors, Total Scheduled Foreign 

Airport Visits, and Average Number of Scheduled Foreign 

Airport Visits per Inspector, by IFO, for Fiscal Year 2005 51 

Table 5: Description and Status of TSA-European Commission

Aviation Security Working Groups 59 

Table 6: Elements of the Aircraft Operator Standard Security 

Program Applicable to International Operations 93 

Page ii GAO-07-729 Aviation Security
Table 7: Elements of the Foreign Air Carrier Model Security

Program Applicable to International Operations 95 

Figures 

Figure 1: Airport Assessment Activities 17 

Figure 2: Process for Taking Secretarial Action against a Foreign 

Airport 20

Figure 3: Air Carrier Inspection Process 24 

Page iii GAO-07-729 Aviation Security
Abbreviations 

AEA Association of European Airlines 

AOSSP Aircraft Operator Standard Security Program 

APEC Asia-Pacific Economic Conference 

ATA Anti-Terrorism Assistance 

CICTE Inter-American Committee against Terrorism 

DHS Department of Homeland Security 

DOJ Department of Justice 

DOT Department of Transportation 

ECAC European Civil Aviation Conference 

FAA Federal Aviation Administration 

FAARS Foreign Airport Assessment Reporting System 

FSD Federal Security Director 

GPRA Government Performance and Results Act 

IATA International Air Transport Association 

ICAO International Civil Aviation Organization 

ICE Immigration and Customs Enforcement 

ICITAP International Criminal Investigative Training Assistance 

 Program

IFO international field office 

INL Bureau of International Narcotics and Law Enforcement 

 Affairs 

IPSI International Principal Security Inspector 

OAS Organization of American States 

PARIS Performance and Results Information System 

PART Performance Assessment Rating Tool

PSI Principal Security Inspector 

SOP standard operating procedures 

TSA Transportation Security Administration 

TSAR Transportation Security Administration Representative 

USAID United States Agency for International Development 

USTDA United States Trade and Development Agency 

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

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 

Page iv GAO-07-729 Aviation Security
United States Government Accountability Office

Washington, DC 20548 

May 11, 2007

The Honorable John L. Mica 

Ranking Republican Member 

Committee on Transportation and Infrastructure 

House of Representatives 

The Honorable Daniel E. Lungren 

Ranking Member 

Subcommittee on Transportation Security and Infrastructure 

 Protection

Committee on Homeland Security 

House of Representatives 

Flights bound for the United States from foreign countries continue to be 

targets of coordinated terrorist activity, as demonstrated in August 2006 

when British officials uncovered an alleged terrorist plot to detonate liquid 

explosives onboard multiple aircraft departing from the United Kingdom 

for the United States. Similar terrorist activity was uncovered in December 

2003 when U.S. intelligence officials identified terrorists’ intent on carrying 

out attacks on U.S.-bound flights originating from foreign airports. Such 

conditions highlight the continued need for the United States to 

coordinate efforts with foreign governments to help ensure the security of 

U.S.-bound flights. Given that there were more than 650,000 flights to the 

United States from foreign locations during calendar year 2005, the 

security of foreign airports and air carriers that service the United States is 

integral to the security of U.S. commercial aviation. 

The Transportation Security Administration (TSA), the federal agency with 

primary responsibility for securing the nation’s civil aviation system,1

 has 

several efforts under way with other nations to help ensure the security of 

U.S.-bound flights. For example, TSA, through its foreign airport 

assessment program, determines whether foreign airports that provide 

service to the United States are maintaining and carrying out effective 

security measures. Additionally, TSA, through its air carrier inspection 

program, determines whether air carriers, U.S.-based or foreign, that 

service the United States are complying with applicable security 

 1

See 49 U.S.C § 114(d). 

Page 1 GAO-07-729 Aviation Security 
requirements. According to TSA officials, the foreign airport assessment 

and air carrier inspection programs enable TSA to inform the public about

foreign airports that do not maintain and carry out effective security 

measures so that the public can make informed decisions when planning 

their travel.

TSA assesses the effectiveness of security measures at foreign airports 

using the aviation security standards and recommended practices adopted

by the International Civil Aviation Organization (ICAO).2

 ICAO standards 

and recommended practices address operational issues at an airport, such 

as ensuring that passengers and baggage are properly screened and that 

unauthorized individuals do not have access to restricted areas of an 

airport. ICAO standards also address nonoperational issues, such as 

ensuring that a foreign government has implemented a national civil 

aviation security program for regulating security procedures at its airports 

and ensuring that airport officials implementing security controls go 

through background investigations, are appropriately trained, and are 

certified according to a foreign government’s national civil aviation 

security program. Member states have agreed to comply with ICAO 

standards, and are strongly encouraged to comply with ICAO 

recommended practices. While TSA is authorized under U.S. law to 

conduct foreign airport assessments at intervals it considers necessary, 

TSA may not perform an assessment of security measures at a foreign 

airport without permission from the host government. TSA also conducts 

security inspections of foreign and U.S.-based air carriers with service to

the United States from foreign countries to ensure compliance with 

applicable security requirements, including those set forth in the air 

carriers’ TSA-approved security programs.3

 As of October 2006, there were

 2

ICAO was formed following the 1944 Convention on International Civil Aviation (also 

known as the Chicago Convention). In 1947, ICAO became a specialized agency of the

United Nations. A primary objective of ICAO is to provide for the safe, orderly, and 

efficient development of international civil aviation. There are currently 189 signatory 

nations to the ICAO convention, including the United States. Nations that are members to

the ICAO convention agree to cooperate with other member states to meet standardized

international aviation security measures. The international aviation security standards and 

recommended practices are detailed in Annex 17 to the Convention on International Civil 

Aviation adopted by ICAO. 

3

Domestic and foreign air carriers that operate to, from, or within the United States must 

establish and maintain security programs approved by TSA in accordance with 

requirements set forth in regulation at 49 C.F.R. parts 1544 and 1546. See 49 U.S.C. §§ 44903 

44906. In conducting air carrier inspections, TSA may consider compliance with air 

carriers’ TSA-approved security programs as well as any applicable laws, regulations,

security directives, and emergency amendments. See 49 C.F.R. §§ 1544.3 1546.3. 

Page 2 GAO-07-729 Aviation Security 
a total of 924 air carrier stations located in 268 airports around the world 

that service the United States and that TSA may seek to inspect.4

Considering the high volume of flights arriving in the United States from 

foreign locations and the history of terrorist threats against commercial 

aviation, TSA’s foreign airport assessment and air carrier inspection 

programs are important elements in ensuring the security of inbound 

flights. Given the vulnerability of U.S.-bound flights to acts of terrorism, 

this report addresses the following questions: (1) What were the results of 

TSA’s fiscal year 2005 foreign airport assessments and air carrier 

inspections, and what actions were taken, if any, when TSA identified that 

foreign airports and air carriers were not complying with security 

standards? (2) How, if at all, did TSA assist foreign countries and air 

carriers in addressing any deficiencies identified during foreign airport 

assessments and air carrier inspections, and to what extent did TSA 

provide oversight of its assessment and inspection efforts? (3) What 

challenges, if any, affected TSA’s ability to conduct foreign airport 

assessments and air carrier inspections, and what actions have TSA and 

others taken to address these challenges? In April 2007, we issued a report

that contained sensitive security information regarding TSA’s foreign 

airport assessments and air carrier inspections. This report provides the 

results of our April 2007 report with the sensitive security information 

removed. 

To address these objectives, we obtained and reviewed TSA guidance for 

conducting and reporting the results of foreign airport assessments and air 

carrier inspections. We also obtained and analyzed the results of 128

foreign airport assessments and 529 air carrier inspections conducted by

TSA during fiscal year 2005 to determine the extent to which foreign 

airports and air carriers operating overseas complied with aviation 

security standards.5

 We assessed the reliability of TSA’s air carrier 

inspection data for fiscal year 2005 and concluded that the data were 

sufficiently reliable for the purposes of our review. We also interviewed 

TSA’s Office of Security Operations and its Transportation Sector Network 

 4

An air carrier station refers to those locations at an airport where an air carrier conducts 

its operations.

5

Complete foreign airport assessment and air carrier inspection results for fiscal year 2006 

were not available when we initiated our review. 

Page 3 GAO-07-729 Aviation Security 
Management officials, both in headquarters and the field,6

 who are 

responsible for planning, coordinating, overseeing, and carrying out 

foreign airport assessments and air carrier inspections, to obtain 

information on TSA’s efforts to help foreign officials address airport 

security deficiencies and TSA’s efforts to overcome challenges identified

by TSA officials in conducting foreign airport assessments and air carrier 

inspections. Additionally, we visited three European, three Asian, and one 

other North American country where we met with host government 

aviation security officials, air carrier representatives, airport officials, 

aviation industry representatives, and TSA officials to obtain their 

perspectives on TSA’s foreign airport assessment and air carrier 

inspection programs. We also accompanied TSA officials during an airport 

assessment and air carrier inspection at an airport in the Caribbean. In 

addition, we interviewed 16 foreign aviation security officials stationed in 

their countries’ embassies in Washington, D.C., to obtain their 

perspectives on TSA’s foreign airport assessment and air carrier 

inspection programs. However, information obtained from our interviews 

with host government and aviation industry representatives cannot be 

generalized beyond those contacted because we did not use a probability 

sampling method to select these officials for interviews. We also 

conducted phone interviews with four Federal Security Directors (FSD)7

and seven TSA aviation security inspectors based in U.S. airports to 

discuss their involvement in foreign airport assessments and air carrier 

inspections. Information from these interviews cannot be generalized to all 

FSDs in U.S. airports or to domestic inspectors who support foreign 

airport assessments and air carrier inspections because we did not use a 

probability sampling method to select these officials for interviews. We 

also met with officials from ICAO, the Asia-Pacific Economic Conference 

(APEC), the Association of European Airlines (AEA), the European 

Commission, the European Civil Aviation Conference (ECAC), and the 

International Air Transport Association (IATA) regarding their 

perspectives on TSA’s foreign airport assessment and air carrier 

inspection programs and the process and standards they use, if any, to 

 6

TSA’s international field offices are located in Dallas, Frankfurt, Los Angeles, Miami, and 

Singapore. 

7

FSDs are the ranking TSA authorities responsible for the leadership and coordination of

TSA security activities at commercial airports in the United States. 

Page 4 GAO-07-729 Aviation Security 
conduct their own airport assessments.8

 Additionally, we interviewed 

officials from the Department of State, Department of Justice, Department 

of Transportation, and the U.S. Trade and Development Agency to learn 

about the aviation security training and technical assistance they provide 

to foreign governments. 

We conducted our work from October 2005 through March 2007 in 

accordance with generally accepted government auditing standards. More 

details about the scope and methodology of our work are contained in 

appendix I. 

Based on the results of TSA’s fiscal year 2005 foreign airport assessments 

and air carrier inspections, some foreign airports and air carriers complied 

with all relevant aviation security standards, while others did not, and 

when deemed necessary, the Secretary of Homeland Security and TSA 

took enforcement action against those that were not in compliance. Of the 

128 foreign airports with air carriers that provide service to the United 

States and that TSA assessed during fiscal year 2005, TSA found that at the 

completion of the assessment, 46 (about 36 percent) complied with all 

ICAO standards and recommended practices, whereas 82 (about 64 

percent) did not meet at least one ICAO standard or recommended 

practice. The most common area of noncompliance for foreign airports 

was related to quality control—mechanisms to assess and address security 

vulnerabilities at airports. For example, one airport did not meet quality 

control standards because it did not have a mechanism in place to ensure

that airport officials implementing security controls were appropriately 

trained and able to effectively perform their duties. According to TSA, 

access control measures and passenger and checked baggage screening 

are critical elements of effective security at foreign airports because these 

Results in Brief 

 8

APEC is a multilateral organization that aims to sustain economic growth in the AsiaPacific region through a commitment to open trade, investment, and economic reform.

APEC’s transportation subgroups work to achieve a balance between trade and security 

issues related to the operation of regional transportation systems. AEA represents more 

than 30 airlines and works in partnership with stakeholders in the aviation industry to 

ensure the sustainable growth of the European airline industry in a global context. ECAC, 

created in 1955, currently has 42 members and seeks to promote aviation safety, security, 

and economic development of its members. One way ECAC contributes to this effort is by

conducting audits of airports and air carriers when requested to do so by a country in

accordance with aviation security standards agreed upon by ECAC members. IATA is 

composed of over 260 airlines and aims to help airlines simplify processes and increase

passenger convenience while reducing costs and improving efficiency. 

Page 5 GAO-07-729 Aviation Security 
measures are intended to prevent terrorists from carrying dangerous 

items, such as weapons and explosives, onto aircraft. However, even if a 

foreign airport does not meet multiple aviation security standards, 

including critical standards, TSA may determine that such deficiencies do 

not warrant review by the Secretary of Homeland Security.9

 Nonetheless, if 

TSA determines that secretarial action may be warranted and the 

Secretary of Homeland Security, based on TSA’s assessment, determines 

that a foreign airport does not maintain and carry out effective security 

measures, then he or she must take action. These actions may include 

issuing a letter to foreign government officials stating that they have 90

days to improve security measures to meet ICAO standards or notifying 

the public that a foreign airport does not maintain and carry out effective 

security measures. For example, during fiscal year 2005, the Secretary of 

Homeland Security determined that 2 of the 128 foreign airports that TSA 

assessed were not maintaining and carrying out effective security 

measures. In response, DHS notified the general public of these 

determinations by the Secretary. During fiscal year 2005, of the 529 

inspections of air carriers operating out of foreign airports, there were 373 

inspections (about 71 percent) for which TSA did not identify any security 

violations and 156 inspections (about 29 percent) for which TSA found 

that the air carrier did not comply with at least one TSA security 

requirement. There were a total of 419 instances of noncompliance 

identified during these 156 inspections.

10 In some cases, the security 

deficiencies identified during these inspections were corrected or 

addressed immediately. When security deficiencies were not resolved 

immediately, TSA inspectors, at times, recommended enforcement action. 

Enforcement action included issuing letters of warning or correction to air 

carriers or imposing civil penalties—monetary fines—on air carriers. Of 

the 419 security violations identified during fiscal year 2005 air carrier 

inspections, 259 (about 62 percent) were corrected or addressed 

immediately, and 76 (about 18 percent) were recommended for 

enforcement action. TSA could not readily identify the enforcement 

actions that were taken for the remaining 84 (20 percent) security 

 9

According to TSA’s Foreign Airport Assessment Program Standard Operating Procedures,

if security concerns and deficiencies identified by TSA during assessments are considered 

“not serious enough for secretarial action (e.g., the measure barely satisfies the minimum 

international standard and could be improved),” TSA may develop an action plan for

addressing these deficiencies without seeking a determination for further action from the

Secretary of Homeland Security. 

10Specific details regarding the nature of security deficiencies TSA identified during air 

carrier inspections are sensitive security information and are not discussed in this report. 

Page 6 GAO-07-729 Aviation Security 
violations. Enforcement actions taken by TSA as a result of fiscal year 

2005 air carrier inspections consisted of 26 enforcement actions and 14 

letters of correction.11 Civil penalties ranging from $18,000 to $25,000 were 

recommended for 7 enforcement actions. Although TSA has not conducted 

its own analysis of foreign airport assessment and air carrier inspection 

results, TSA officials stated that our analysis of the results was consistent 

with their assumptions regarding the most prominent security deficiencies

identified among foreign airports and air carriers. However, TSA officials 

stated that it is difficult to draw conclusions about the results—such as 

whether the results are generally positive or negative—considering the 

differences in the capabilities and willingness of foreign officials to 

address security deficiencies. TSA officials further stated that the 

cumulative results of the assessments and inspections may be helpful in 

identifying the aviation security training needs of foreign aviation security 

officials. While TSA does not have its own program to provide aviation

security training and technical assistance to foreign aviation security 

officials, TSA officials stated that they could use the results of TSA’s 

foreign airport assessments to refer foreign officials to training and 

technical assistance programs offered by ICAO and several other U.S. 

government agencies. 

During fiscal year 2005, TSA helped improve security at foreign airports by 

assisting foreign officials and air carrier representatives in addressing 

security deficiencies identified during TSA assessments and inspections. 

However, TSA’s oversight of the foreign airport assessment and air carrier 

inspection programs could be strengthened. TSA assisted foreign officials 

in addressing security deficiencies identified during airport assessments in 

various ways, including providing on-site consultation to help foreign 

officials immediately address security deficiencies, making 

recommendations to help foreign officials sustain security improvements, 

and helping foreign governments obtain aviation security training and 

technical assistance. To help air carriers address security deficiencies that

were identified, TSA often provided on-site consultation. For example, 

during one inspection, TSA inspectors identified a security deficiency

related to catering carts, after which the inspectors immediately notified 

the air carrier of the deficiency and made a recommendation for better 

 11The number of enforcement actions is not equal to the number of violations identified 

because TSA can issue one enforcement action for multiple violations, and TSA could not 

readily identify what action, if any, was taken for some violations. 

Page 7 GAO-07-729 Aviation Security 
securing catering carts in the future.12 TSA also assigned a principal 

security inspector to each U.S. carrier and foreign carrier that provides 

service to the United States whose responsibility was to counsel air 

carriers and provide clarification on TSA security requirements when 

necessary. TSA has several controls in place to ensure that the agency is 

meeting internal requirements for implementing the foreign airport 

assessment and air carrier inspection programs, such as requiring 

inspectors to use standard operating procedures for coordinating with 

host government officials for scheduling, conducting, and reporting the 

results of foreign airport assessments. However, additional controls—

including controls for tracking, documenting, and measuring the impact of 

TSA’s assessment and inspection activities—would help strengthen its 

oversight of these programs. First, TSA does not have controls in place to 

track the status of scheduled foreign airport assessments and air carrier 

inspections, including whether the assessments and inspections were 

actually conducted or whether they were deferred or canceled, which 

could make it difficult for TSA to ensure that scheduled assessments and 

inspections are completed. Second, TSA does not always document the 

results of follow-up conducted by TSA international staff to determine 

progress made by foreign governments in addressing security deficiencies

identified by TSA. Documentation of such follow-up would enable TSA to

have access to updated information on the security of foreign airports that 

provide service to the United States. Third, TSA does not always track the 

status of air carrier inspections from initiation through completion, which

prevents TSA from determining whether appropriate action was taken 

against air carriers that violated security requirements. Finally, TSA does

not have outcome-based performance measures in place to measure the 

impact that its efforts have had on helping foreign airport officials and air 

carrier representatives comply with aviation security standards and 

requirements. Federal standards for internal controls and associated 

guidance suggest that agencies should document key decisions in a way 

that is complete and accurate, and that allows decisions to be traced from 

initiation, through processing, to after completion. Starting in August 2006, 

TSA officials began to develop controls for tracking the status of 

scheduled foreign airport visits, such as tracking the number of days 

remaining until inspectors are to visit a particular foreign airport. 

However, in February 2007, TSA officials acknowledged that additional 

refinements to the tracking system were needed. TSA officials also stated 

 12The specific details of the catering cart security deficiency identified by TSA inspectors 

are sensitive security information and, therefore, are not discussed in this report. 

Page 8 GAO-07-729 Aviation Security 
that developing performance measures to assess the impact of assessment 

and inspection-related efforts on security at foreign airports would be 

useful, but they identified several concerns about developing such 

measures. For example, TSA officials stated that whether foreign officials 

improve security at their airports is not within TSA’s control and, 

therefore, developing a performance measure related to TSA’s 

contributions to improving foreign airport security may not be

appropriate. However, other federal agencies, such as the Department of 

State, have developed performance measures for foreign assistance 

programs for which the outcome is not entirely within the agency’s 

control. Even without full control over such measures, it would be useful

for TSA to develop outcome-based measures for its foreign airport 

assessment and air carrier inspection programs—such as the percentage 

of security deficiencies that were addressed as a result of TSA on-site 

assistance and TSA recommendations for corrective action—to identify 

any aspects of these programs that need improvement. Also, with 

additional oversight of the foreign airport assessment and air carrier 

inspection programs, TSA would have better assurance that these 

programs are operating as intended.

TSA is taking action to address challenges that have limited its ability to 

conduct foreign airport assessments and air carrier inspections, including 

a lack of available inspectors, concerns regarding the resource burden 

placed on host governments as a result of frequent airport visits by TSA 

and others, and concerns unique to specific host governments, such as 

sovereignty—more specifically, concerns that TSA assessments and 

inspections infringe upon a host government’s authority to regulate

airports and air carriers within its borders. According to TSA officials, TSA 

deferred approximately 30 percent of the foreign airport visits—including 

airport assessments and air carrier inspections—that were scheduled for 

fiscal year 2005, due to the lack of available inspectors and concerns 

raised by host government officials. TSA officials stated that two key 

factors affected the availability of inspectors during fiscal year 2005. First, 

TSA was operating with fewer inspectors than the agency budgeted for 

fiscal year 2005. Specifically, three of the five international field offices 

were operating with fewer inspectors than they were budgeted during at 

least 9 months out of the fiscal year. According to TSA, the shortage of 

inspectors was due to the high turnover rate for inspectors and the lengthy 

process for hiring additional inspectors to fill vacant positions. Second, 

TSA scheduled more foreign airport visits—which includes both airport 

assessments and air carrier inspections—than the budgeted number of 

inspectors could have reasonably conducted. According to TSA, each 

inspector can reasonably conduct between 8 and 12 foreign airport visits 

Page 9 GAO-07-729 Aviation Security 
per year depending on the amount of time inspectors remain on site to 

help foreign authorities address any security deficiencies. However, all 

five international field offices scheduled more than 12 foreign airport visits 

per inspector during fiscal year 2005; one international field office 

scheduled more than 24 visits per inspector. TSA officials said that their 

internal policy regarding the frequency with which the agency is to 

conduct foreign airport assessments and air carrier inspections drove their 

decision to schedule more foreign airport visits than inspectors could 

reasonably have conducted. According to TSA officials, this internal policy 

was developed by the Federal Aviation Administration, which was 

responsible for conducting foreign airport assessments and air carrier 

inspections prior to TSA. TSA officials also stated that the Federal 

Aviation Administration had more available inspectors to conduct 

assessments and inspections than TSA. Given the lack of available 

international inspectors, TSA also used domestic inspectors—that is, 

inspectors who typically conduct security inspections at U.S. airports—to 

conduct 33 percent of the scheduled foreign airport visits for fiscal year 

2005. However, TSA officials stated that the use of domestic inspectors is 

undesirable because these inspectors lack experience conducting 

assessments in the international environment. During October 2006, TSA

began implementing a risk-based approach to scheduling foreign airport 

assessments to better allocate its limited inspector resources by focusing 

on foreign airports that pose the greatest security risk to U.S.-bound air 

travel. Another potential benefit to TSA’s new risk-based approach to 

scheduling is that it may allow TSA to reduce its reliance on domestic 

inspectors. Our analysis shows that TSA’s risk-based approach is 

consistent with generally accepted risk management principles. TSA has 

also taken steps to address concerns regarding the resource burden placed

on host governments as a result of frequent airport visits. Host government

officials in three of the seven foreign countries we visited, and 

representatives of various air carrier associations, stated that countries are 

subjected to multiple assessments and inspections each year by TSA, 

ICAO, the European Commission, and others, and because foreign 

government officials and air carrier representatives have to escort the 

various inspectors during the assessment and inspections, the frequency of 

airport visits is burdensome on the host government and air carriers. TSA’s 

risk-based approach for scheduling airport assessments should help 

address some host governments’ concerns regarding the resource burden.

TSA has also begun to explore other opportunities to alleviate the 

resource burden placed on host governments. Specifically, when the 

opportunity is available, TSA is considering conducting joint assessments 

and using the results of some host government or third party assessments 

to adjust the frequency of TSA visits; collectively, these efforts may reduce

Page 10 GAO-07-729 Aviation Security 
the number of airport visits experienced by some countries. However, TSA 

officials stated that they are cautious about using the results of other 

entities’ assessments because TSA has not independently evaluated the 

quality of the assessments conducted by these other entities and because 

these other entities base their assessments on different aviation security 

standards than TSA. TSA headquarters officials stated that working with 

host governments to harmonize aviation security standards as well as the 

process used to conduct assessments—that is, developing similar 

standards and assessment processes that provide the same level of 

security—would facilitate TSA’s use of host government and third party 

assessment results. TSA has made efforts to harmonize security standards 

and inspection processes with the European Commission, although, as of

February 2007, a time frame for completion of these efforts had not yet 

been established. TSA has also harmonized some security standards—

particularly those related to the screening of liquids, gels, and aerosols—

with several European countries, Australia, and Canada. In addition to 

working to address concerns regarding the resource burden placed on

host governments as a result of frequent airport visits, TSA has taken steps 

to address some country-specific challenges that have limited TSA’s ability 

to conduct foreign airport visits. For example, TSA said that officials from 

one country viewed TSA’s airport assessments as an infringement on their 

country’s sovereignty, and therefore would not allow TSA to conduct 

assessments of airports in their country. However, TSA officials negotiated

with officials in this country so that assessments are conducted under the 

guise of a TSA “visit” to—versus an “assessment” of—the airport, although 

officials from that country prohibit TSA inspectors from assessing airport 

perimeter security and the contents of their national aviation security 

programs. TSA officials stated that when unique concerns arise in the 

future, they will continue to work with countries on a case-by-case basis to

try to address their concerns. 

In our April 2007 report that contained sensitive security information, we 

made several recommendations to assist TSA in strengthening oversight of

the foreign airport assessment and air carrier inspection programs. These 

include developing and implementing controls to track the status of 

scheduled foreign airport assessments and air carrier inspections from 

initiation through completion, including reasons why assessments and 

inspections were deferred or canceled; developing and implementing a 

standard process for tracking and documenting host governments’ 

progress in addressing security deficiencies identified during airport 

assessments; and developing performance measures to evaluate the 

impact that TSA assistance and enforcement actions have had on 

improving foreign airport and air carrier compliance with applicable 

Page 11 GAO-07-729 Aviation Security 
aviation security standards. We provided a draft of this report to the 

Department of Homeland Security (DHS) for review. DHS, in its written 

comments, concurred with our findings and recommendations, and stated

that the recommendations will help strengthen TSA’s oversight of foreign 

airport assessments and air carrier inspections. DHS described some 

actions that TSA is taking to implement these recommendations, including 

enhancing its tracking system to include the reason for deferment or 

cancellation of an airport assessment or an air carrier inspection; 

developing a system whereby outstanding deficiencies noted during an 

assessment will be tracked along with deficiency specific information, 

deadlines, and current status; and developing outcome-based performance 

measures for the foreign airport assessment program and air carrier 

inspection activities. 

Shortly after the September 11, 2001, terrorist attacks, Congress passed, 

and the President signed into law, the Aviation and Transportation 

Security Act, which established TSA and gave the agency responsibility for 

securing all modes of transportation, including the nation’s civil aviation 

system, which includes domestic and international commercial aviation 

operations.13 In accordance with 49 U.S.C. § 44907, TSA assesses the 

effectiveness of security measures at foreign airports served by a U.S. air 

carrier, from which a foreign air carrier serves the United States, that pose

a high risk of introducing danger to international air travel, and at other 

airports deemed appropriate by the Secretary of Homeland Security.14 This 

provision of law also identifies measures that the Secretary must take in 

the event that he or she determines that an airport is not maintaining and

carrying out effective security measures based on TSA assessments.15 TSA 

also conducts inspections of U.S. air carriers and foreign air carriers 

Background 

DHS Responsibilities for 

Ensuring the Security of 

U.S.-Bound Flights from 

Foreign Countries 

 13See Pub. L. No. 107-71, 115 Stat. 597 (2001). 

1449 U.S.C. § 44907. Prior to the establishment of DHS in March 2003, authority for

conducting foreign airport assessments resided with the Secretary of Transportation. 

Although assessments were originally conducted by the Federal Aviation Administration, 

TSA assumed responsibility for conducting the assessments following the enactment of the 

Aviation and Transportation Security Act in November 2001. In March 2003, TSA

transferred from the Department of Transportation to DHS. 

15 See 49 U.S.C. § 44907(d)-(e). 

Page 12 GAO-07-729 Aviation Security 
servicing the United States from foreign airports pursuant to its authority 

to ensure that air carriers certificated or permitted to operate to, from, or 

within the United States meet applicable security requirements, including

those set forth in an air carrier’s TSA-approved security program.16

The Secretary of DHS delegated to the Assistant Secretary of TSA the 

responsibility for conducting foreign airport assessments but retained 

responsibility for making the determination that a foreign airport does not 

maintain and carry out effective security measures. Currently, TSA’s 

Security Operations and Transportation Sector Network Management 

divisions are jointly responsible for conducting foreign airport 

assessments and air carrier inspections. Table 1 highlights the roles and 

responsibilities of certain TSA positions within these divisions that are 

responsible for implementing the foreign airport assessment and air 

carrier inspection programs. 

 16Domestic and foreign air carriers that operate to, from, or within the United States must 

establish and maintain security programs approved by TSA in accordance with 

requirements set forth in regulation at 49 C.F.R parts 1544 and 1546. See 49 U.S.C §§ 44903 

44906. Prior to TSA being established in February 2002, the Federal Aviation 

Administration conducted these air carrier inspections. 

Page 13 GAO-07-729 Aviation Security 
Table 1: Positions That Play a Key Role in TSA’s Foreign Airport and Air Carrier Inspection Programs 

Office/division Position Duties

Security Operations Aviation Security 

Inspector 

Inspectors are primarily responsible for performing and reporting the results of 

both foreign airport assessments and the air carrier inspections, and will 

provide on-site assistance and make recommendations for security 

enhancements. Inspectors are also deployed in response to specific incidents 

or to monitor for identified threats. Inspectors are based in one of TSA’s five 

international field offices (IFO)

a

.

Transportation Sector 

Network Management 

Transportation Security 

Administration 

Representative (TSAR) 

TSARs communicate with foreign government officials to address 

transportation security matters and to conduct foreign airport assessments.

Specifically, the TSARs serve as on-site coordinators for TSA responses to 

terrorist incidents and threats to U.S. assets at foreign transportation modes. 

TSARs also serve as principal advisors on transportation security affairs to 

U.S. ambassadors and other embassy officials responsible for transportation 

issues to ensure the safety and security of the transportation system. For the 

foreign airport assessment program, TSARs are often involved in arranging 

pre-assessment activities, assessment visits, and follow-up visits. Additionally, 

TSARs are responsible for completing portions of the airport assessment 

reports and reviewing completed assessment reports. TSARs also help host 

government officials address security deficiencies that are identified during 

assessments. 

Transportation Sector 

Network Management 

International Security 

Principal Inspector (IPSI) 

IPSIs are responsible for assisting foreign air carriers in complying with TSA 

security requirements by providing counseling and clarification to airlines on 

TSA requirements and providing requested information to TSA about these air 

carriers. 

Transportation Sector 

Network Management 

Principal Security 

Inspector (PSI) 

PSIs are responsible for assisting U.S.-based air carriers in complying with

TSA security requirements by providing oversight to airlines on TSA 

requirements and providing requested information to TSA about these air 

carriers. 

Source: TSA. 

a

IFO managers are responsible for the overall planning of assessment visits that take place in their 

respective regions. TSA’s IFOs are located in Dallas, Miami, Frankfurt, Singapore and Los Angeles. 

b

TSARs are located in Athens, Bangkok, Beijing, Brussels, Buenos Aires, Dallas, Frankfurt, London, 

Madrid, Manila, Miami, Paris, Rome, Singapore, Sydney, Tokyo, and Washington, D.C. 

TSA’s Process for 

Assessing Aviation 

Security Measures at 

Foreign Airports 

TSA conducts foreign airport assessments to determine the extent to 

which foreign airports maintain and carry out effective security measures 

in order to ensure the security of flights bound for the United States. 

Specifically, TSA assesses foreign airports using 86 of the 106 aviation

security standards and recommended practices adopted by ICAO, a United 

Page 14 GAO-07-729 Aviation Security 
Nations organization representing nearly 190 countries.17 (See app. II for a 

description of the 86 ICAO standards and recommended practices TSA 

uses to assess security measures at foreign airports.18) While TSA is 

authorized under U.S. law to conduct foreign airport assessments at 

intervals it considers necessary, TSA may not perform an assessment of 

security measures at a foreign airport without permission from the host 

government. During fiscal year 2005, TSA scheduled assessments by 

categorizing airports into two groups. Category A airports—airports that 

did not exhibit operational issues in the last two TSA assessments—were

assessed once every 3 years, while category B airports—airports that did 

exhibit operational issues in either of the last two TSA assessments, or 

were not previously assessed—were assessed annually. Based on 

documentation provided by TSA, during fiscal year 2005, TSA assessed 

aviation security measures in place at 128 foreign airports that participated

voluntarily in TSA’s Foreign Airport Assessment Program.19

TSA’s assessments of foreign airports are conducted by a team of 

inspectors, which generally includes one team leader and one team 

member. According to TSA, it generally takes 3 to 7 days to complete a 

foreign airport assessment. However, the amount of time required to 

 17 International aviation security standards and recommended practices are detailed in 

Annex 17 and Annex 14 to the Convention on International Civil Aviation, as adopted by 

ICAO. An ICAO standard is a specification for the safety or regularity of international air 

navigation, with which member states agree to comply; whereas, a recommended practice

is any desirable specification for safety, regularity, or efficiency of international air 

navigation, with which member states are strongly encouraged to comply. Member states 

are expected to make a genuine effort to comply with recommended practices. TSA has 

chosen the 86 standards that it sees as most critical. See 49 U.S.C. § 44907(a)(2)(C) 

(requiring that TSA conduct assessments using a standard that results in an analysis of the 

security measures at the airport based at least on the standards and appropriate 

recommended practices of ICAO Annex 17 in effect on the date of the assessment). 

18 Segments of Annex 17 to the Convention of International Civil Aviation, Safeguarding 

International Civil Aviation Against Unlawful Acts of Interference, Seventh Edition,

April 2002 and Annex 14, Aerodrome Design and Operations, Volume I, have been 

reproduced in appendix II with permission of the International Civil Aviation Organization. 

19 Based on documentation provided by TSA, TSA also conducted five foreign airport 

surveys during fiscal year 2005. Surveys are generally conducted at foreign airports that are 

scheduled to provide new service to the United States. Unlike airport assessments, airport 

surveys only address whether foreign airports are meeting critical ICAO standards and 

recommended practices, such as those associated with passenger and checked baggage

screening. Also unlike assessment reports, survey reports do not identify whether foreign 

officials took steps to address security deficiencies that were identified at the airport.

Because of these differences, we did not include the results of the foreign airport surveys 

in our analysis. 

Page 15 GAO-07-729 Aviation Security 
conduct an assessment varies based on several factors, including the size 

of the airport, the number of air carrier station inspections to be 

conducted at the airport,20 the threat level to civil aviation in the host 

country, and the amount of time it takes inspectors to travel from the 

international field office (IFO) to the airport where the assessment will 

take place. An additional 2 weeks is required for inspectors to complete 

the assessment report after they return to the IFO. 

As shown in figure 1, regarding the process for conducting a foreign 

airport assessment, before TSA can assess the security measures at a 

foreign airport, the Transportation Security Administration Representative 

(TSAR) must first obtain approval from the host government to allow TSA 

to conduct an airport assessment and to schedule the date for an on-site 

visit to the foreign airport. During the assessment, the team of inspectors 

uses several methods to determine a foreign airport’s level of compliance 

with international security standards, including conducting interviews 

with airport officials, examining documents pertaining to the airport’s 

security measures, and conducting a physical inspection of the airport. For 

example, the inspectors are to examine the integrity of fences, lighting, 

and locks by walking the grounds of the airport. Inspectors also make 

observations regarding access control procedures, such as looking at 

employee and vehicle identification methods in secure areas, as well as 

monitoring passenger and baggage screening procedures in the airport. At 

the close of an airport assessment, inspectors brief foreign airport and 

government officials on the results of the assessment. TSA inspectors also 

prepare a report summarizing their findings on the airport’s overall 

security posture and security measures, which may contain 

recommendations for corrective action and must be reviewed by the 

TSAR, the IFO manager, and TSA headquarters officials. 

 20 According to TSA, the airport assessment period is extended by 8 to 12 hours for each air

carrier inspection that is conducted. 

Page 16 GAO-07-729 Aviation Security 
Figure 1: Airport Assessment Activities 

The TSAR is to communicate with the host 

government to obtain approval to conduct an 

assessment and to schedule an on-site visit 

to the foreign airport.

The assessment team is to conduct an entry 

briefing with Department of State, host 

government officials, and host airport 

officials.

The assessment team is to provide a

synopsis of the results from the assessment 

during an exit briefing with Department of 

State officials, host government officials, and 

host airport officials.

The assessment team is to return to the IFO 

to write a report summarizing findings on the 

foreign airport’s overall security posture and 

security measures.

The TSAR, IFO manager, and TSA 

headquarters official are to review the report 

findings to ensure that inspectors addressed 

and properly identified all relevant ICAO 

standards.

The assessment team leader is to hold a pre 

trip briefing to prepare for the on-site visit to 

the foreign airport. During this briefing, the 

team is to discuss the itinerary, assessment, 

and inspection assignments; discuss

expectations for team members; and review 

findings from the previous assessment.

The assessment team is to conduct an 

on-site visit to the foreign airport to assess

security measures in place by using ICAO 

standards.

Assessment team is to conduct interviews

with airport officials.

Assessment team is to examine documents

regarding a foreign airport’s security 

measures.

Assessment team is to conduct a physical 

inspection of the airport.

Source: GAO analysis of information provided by TSA.

If the inspectors report that an airport’s security measures do not meet 

minimum international security standards, particularly critical standards, 

such as those related to passenger and checked baggage screening and 

Page 17 GAO-07-729 Aviation Security 
access controls, TSA headquarters officials are to inform the Secretary of 

Homeland Security.21 If the Secretary, based on TSA’s airport assessment 

results, determines that a foreign airport does not maintain and carry out

effective security measures, he or she must, after advising the Secretary of 

State, take secretarial action. Figure 2 describes in detail the types of 

secretarial action the Secretary may take during such instances. There are 

three basic types of secretarial action: 

• 90-day action—The Secretary notifies foreign government officials 

that they have 90 days to address security deficiencies that were 

identified during the airport assessment and recommends steps 

necessary to bring the security measures at the airport up to ICAO 

standards.22

• Public notification—If, after 90 days, the Secretary finds that the 

government has not brought security measures at the airport up to 

ICAO standards, the Secretary notifies the general public that the 

airport does not maintain and carry out effective security measures.23

• Modification to air carrier operations—If, after 90 days, the 

Secretary finds that the government has not brought security measures 

at the airport up to ICAO standards: 

• The Secretary may withhold, revoke, or prescribe conditions on the 

operating authority of U.S.-based and foreign air carriers operating 

at that airport, following consultation with appropriate host 

 21According to TSA’s Foreign Airport Assessment Program Standard Operating Procedures,

if security concerns and deficiencies are considered “not serious enough for secretarial 

action (e.g., the measure barely satisfies the minimum international standard and could be

improved),” TSA may develop an action plan for addressing the deficiencies identified 

without seeking a determination from the Secretary of Homeland Security.

22The Secretary may bypass the 90-day action and immediately provide public notification 

or withhold, revoke, or prescribe conditions on an air carrier’s operating authority if the 

Secretary determines, after consultation with the Secretary of State, that a condition exists 

that threatens the safety or security of passengers, aircraft, or crew traveling to or from the 

airport. § 44907(d)(2)(A)(ii). 

23 Public notification includes publication of the airport’s identity in the Federal Register, 

posting and displaying the airport’s identity prominently at all U.S. airports at which 

scheduled air carrier operations are provided regularly, and notifying news media of the 

airport’s identity. 49 U.S.C. § 44907(d)(1)(A). U.S. and foreign air carriers providing 

transportation between the United States and the airport shall also provide written notice 

that the airport is not maintaining and carrying out effective security measures on or with 

the ticket to each passenger buying a ticket. § 44907(d)(1)(B). 

Page 18 GAO-07-729 Aviation Security 
government officials and air carrier representatives, and with the 

approval of the Secretary of State. 

• The President may prohibit a U.S.-based or foreign air carrier from 

providing transportation between the United States and any foreign 

airport that is the subject of a secretarial determination. 

• Suspension of service— The Secretary, with approval of the Secretary

of State, shall suspend the right of any U.S.-based or foreign air carrier to 

provide service to or from an airport if the Secretary determines that a 

condition exists that threatens the safety or security of passengers, 

aircraft, or crew traveling to or from the airport, and the public interest 

requires an immediate suspension of transportation between the United 

States and that airport.24

 24 Invoking this action does not require that the Secretary base the determination upon 

TSA’s airport assessment results, though an assessment may provide the basis for invoking

this action. 

Page 19 GAO-07-729 Aviation Security 
Figure 2: Process for Taking Secretarial Action against a Foreign Airport 

Step 1: Inspectors find airport does not meet minimum international aviation security standards.

Step 2: TSA officials from the Compliance Division brief the Assistant Secretary, Assistant Administrator for Security Operations, and Assistant Administrator for Transportation Sector Network Management. 

Step 3: TSA officials prepare an action memo and supporting documents on airport’s ineffective security measures for the Secretary 

of Homeland Security and recommend that the Secretary take action.

Step 4: Secretary of Homeland Security determines airport does not maintain and carry out effective security measures and recommends corrective action to foreign government.

90-day action letter

Team of inspectors conducts interim 

assessment of foreign airport to determine 

status of security deficiencies and identify 

additional U.S. assistance needed.

TSA posts notices at U.S. airports stating that 

the foreign airport does not maintain and 

carry out effective security measures and may 

withhold, revoke, or impose conditions on the 

operating authority of foreign and domestic 

carriers serving this airport with flights to the 

United States.

Team returns to the host country to do final 

airport assessment.

Team of inspectors conducts interim 

assessment of foreign airport to determine the 

status of security deficiencies and identify 

additional U.S. assistance needed.

Team prepares a report for briefing Secretary 

of Homeland Security on current conditions at 

airport.

Occurs when the Secretary of Homeland 

Security determines conditions at airport 

threaten the safety or security of passengers, 

aircraft, or crew traveling to or from the 

airport, and the public interest requires an 

immediate suspension of transportation 

between the United States and the airport.

Public notification/ modification to air 

carrier operations Suspension of air service

Team returns to conduct airport assessments

at the request of the host country.

Secretary of Homeland Security determines

whether airport maintains effective security.

Team prepares a report for briefing Secretary 

of DHS on conditions at airport.

If yes:

Secretarial action 

lifted 

If no:

Secretary must 

issue public 

notification

Public notification or modification to air carrier 

operations is lifted if airport carries out 

effective security measures.

Source: GAO analysis of information provided by TSA.

Page 20 GAO-07-729 Aviation Security 
Along with conducting airport assessments, the same TSA inspection team 

also conducts air carrier inspections when visiting a foreign airport to 

ensure that air carriers are in compliance with TSA security 

requirements.25 Both U.S. and foreign air carriers with service to the United

States are subject to inspection. As of February 2007, TSA guidance 

required TSA to inspect each U.S. air carrier station once a year, except 

for those airports in which TSA has determined to be an “extraordinary” 

location,26 where inspections are to occur twice a year. Foreign air carriers 

are to be inspected twice in a 3-year period at each foreign airport, except 

in extraordinary locations, where they are to be inspected annually.27

According to documentation provided by TSA, during fiscal year 2005, TSA 

conducted 529 inspections of foreign and U.S. air carriers serving the 

United States from foreign airports. When conducting inspections, TSA 

inspectors examine compliance with applicable security requirements, 

including TSA-approved security programs,28 emergency amendments to 

the security programs, and security directives.29 Air carrier security 

programs are based on the Aircraft Operator Standard Security Program 

for U.S.-based air carriers and the Model Security Program for foreign air 

carriers, which serve as guidance for what an air carrier needs to include 

in its own security program. The Aircraft Operator Standard Security 

Program is designed to provide for the safety of passengers and their 

belongings traveling on flights against acts of criminal violence, air piracy, 

and the introduction of explosives, incendiaries, weapons, and other 

TSA’s Process for 

Inspecting Air Carriers 

with Service to the United 

States from Foreign 

Airports 

 25TSA may conduct air carrier inspections separately from airport assessments because 

foreign airports are generally assessed no more than once a year by TSA, while some air 

carriers are inspected twice a year by TSA. 

26Extraordinary locations are identified through threat analysis conducted by TSA’s Office 

of Intelligence and are contained in the Aircraft Operator Standard Security Program. The 

list of extraordinary locations is sensitive security information and, therefore, is not 

included in this report. 

27Over the course of our review, TSA was in the process of developing new guidelines for

determining the frequency of overseas air carrier inspections. The draft guidelines would 

require TSA to inspect both U.S. and foreign air carriers once a year, unless the air carrier 

operates out of a foreign airport that TSA determines has a relatively high vulnerability 

level, in which case TSA would inspect the air carrier twice a year. TSA had not finalized 

the draft air carrier inspection guidelines as of February 2007. 

28TSA requires that each air carrier adopt and implement a TSA-approved security program

for all scheduled passenger and public charter operations at locations within the United

States, from the United States to a non-U.S. location, or from a non-U.S. location to the

United States. See 49 C.F.R. pts. 1544-46. 

29See 49 C.F.R. §§ 1544.3, 1546.3.

Page 21 GAO-07-729 Aviation Security 
prohibited items onboard an aircraft. Likewise, the Model Security 

Program is designed to prevent prohibited items from being carried 

aboard aircraft, prohibit unauthorized access to airplanes, ensure that 

checked baggage is accepted only by an authorized carrier representative, 

and ensure the proper handling of cargo to be loaded onto passenger 

flights. When TSA determines that additional security measures are 

necessary to respond to a threat assessment or to a specific threat against 

civil aviation, TSA may issue a security directive or an emergency 

amendment to an air carrier security program that sets forth additional 

mandatory security requirements.30 Air carriers are required to comply 

with each applicable security directive or emergency amendment issued 

by TSA, along with the requirements already within their security 

programs and any other requirements set forth in applicable law. 

Appendix III provides additional information on security requirements for 

U.S. and foreign air carriers serving the United States from foreign 

airports. 

Although U.S.-based and foreign air carriers are guided by different 

standards within the Aircraft Operator Standard Security Program and the 

Model Security Program, inspections for both of these entities are similar. 

As in the case of airport assessments, air carrier inspections are conducted 

by a team of inspectors, which generally includes one team leader and one 

team member. An inspection of an air carrier typically takes 1 or 2 days, 

but can take longer depending on the extent of service by the air carrier. 

Inspection teams may spend several days at a foreign airport inspecting air 

carriers if there are multiple airlines serving the United States from that 

location. During an inspection, inspectors are to review applicable security 

manuals, procedures, and records; interview air carrier station personnel;

and observe air carrier employees processing passengers from at least one 

flight from passenger check-in until the flight departs the gate to ensure 

that the air carrier is in compliance with applicable requirements. 

Inspectors evaluate a variety of security measures, such as passenger 

 30When circumstances require that air carriers take immediate action to mitigate a known 

or potential threat or vulnerability, TSA may issue security directives to impose additional

security requirements on U.S. air carriers and emergency amendments to impose additional 

requirements on foreign air carriers. See 49 C.F.R. §§ 1544.105(d), 1544.305, 1546.105(d). 

Page 22 GAO-07-729 Aviation Security 
processing including the use of No-Fly and Selectee lists,31 checked 

baggage acceptance and control, aircraft security, and passenger 

screening. Inspectors record inspection results into TSA’s Performance 

and Results Information System (PARIS) system, a database containing 

security compliance information on TSA-regulated entities. If an inspector 

finds that an air carrier is violating any applicable security requirements, 

additional steps are to be taken to record those specific violations and, in

some cases, pursue them with further investigation. Figure 3 provides an 

overview of the air carrier inspection and documentation process, 

including the options for what type of penalty, if any, should be imposed 

on air carriers for identified security violations. 

 31The No-Fly list contains the names of individuals that pose, or are suspected of posing, a 

threat to civil aviation or national security and are precluded from boarding an aircraft. The 

Selectee list includes those individuals of interest that do not meet the criteria to be placed 

on the No-Fly list. Individuals on the Selectee list will be subjected to additional screening.

There is also a separate selectee process—the Computer-Assisted Passenger Prescreening 

System—by which individuals who meet certain criteria are selected for additional 

screening. 

Page 23 GAO-07-729 Aviation Security 
Figure 3: Air Carrier Inspection Process 

· Reviews documentation and security 

 program;

·Interviews air carrier employees about 

security practices and procedures;

· Observes processing of a U.S.-bound 

 departure

Inspector reviews results of previous

inspections

Inspector conducts on-site visit at 

foreign airport

Air carrier Inspection results entered into 

PARIS for each security requirement

In compliance Not in compliance

Open finding record 

in PARIS

Closed with 

counseling

Violation with 

investigation

Enforcement investigation 

record opened

No action taken

No action taken Letter of correction Warning notice Civil penalty (fine)

Recommend civil penalty 

and amount

Investigation by TSA Office 

of Chief Counsel and final 

disposition

Letter of 

correction

Recommend 

administrative action

Review and approval by 

supervisory inspector

Warning 

notice

Source: GAO analysis of information provided by TSA.

When an inspector identifies a violation of a security requirement, a record 

of the violation is opened in PARIS. According to guidance issued by TSA 

to inspectors, there are various enforcement tools available to address 

instances of noncompliance discovered during an inspection:

Page 24 GAO-07-729 Aviation Security 
• On-the-spot counseling is generally to be used for noncompliance that 

is minor and technical in nature, and can be remedied immediately at 

the time it is discovered. When this course of action is taken, the 

inspector notes that the noncompliance issue was closed with TSA 

counseling in the finding record and no further action is required. 

• Administrative action is generally to be used for violations or alleged 

violations that are unintentional, not the result of substantial disregard 

for security, where there are no aggravating factors present, or firsttime violations. An administrative action results in either a letter of 

correction or a warning notice being issued to the air carrier.

• Civil penalties in the form of fines are generally to be used in response 

to cases involving egregious violations, gross negligence, or where 

administrative action and counseling did not adequately resolve the 

noncompliance. Fines can range between $2,500 and $25,000 based on 

the severity of the violation.32 If the violation is severe enough, TSA may 

also recommend revocation of the air carrier’s certification to fly into 

the United States, but this action has not yet been taken by TSA. 

If a violation is resolved with on-the-spot counseling, that fact is recorded 

in the finding record of PARIS and the matter is closed. However, if the 

inspector opts to pursue administrative action or a civil penalty against the

air carrier, an enforcement investigation record is opened, and an 

investigation is conducted. Based on the investigation findings, the 

inspector recommends either an administrative action or a civil penalty, 

depending on the finding and the circumstances. If the investigation does 

not provide evidence that a violation occurred, the matter is closed with 

no action taken. 

If the inspector makes a recommendation for an administrative action, the 

supervisory inspector or IFO manager will typically review the 

recommendation and, if appropriate, approve and issue the action. The 

supervisory inspector may also recommend that the action be changed to

 32TSA has statutory authority to issue fines and penalties to individual air carriers for not 

complying with established security procedures. See 49 U.S.C. § 46301. In general, the 

penalty for an aviation security violation is found at 49 U.S.C. § 46301(a)(4), which states 

that the maximum civil penalty for violating chapter 449 of title 49, United States Code, (49

U.S.C. § 44901 et seq.) or another requirement under title 49 administered by the Assistant 

Secretary, TSA, shall be $10,000. The maximum civil penalty shall be $25,000 in the case of

a person operating an aircraft for the transportation of passengers or property for 

compensation. 

Page 25 GAO-07-729 Aviation Security 
no action or to a civil penalty. In the case of the latter, the case will be 

referred to the Office of Chief Counsel for further review. 

In those cases where the inspector recommends that a civil penalty be 

assessed on the air carrier, it is referred to the Office of Chief Counsel for 

review. The office is responsible for ensuring that the action is legally 

sufficient, and that the recommended fine is consistent with agency

guidelines. TSA’s Office of Chief Counsel makes the final determination 

for any legal enforcement action. The office may approve the proposed 

action or make a recommendation for other actions, including 

administrative action or no action at all. 

Based on the results of TSA’s foreign airport assessments, during fiscal 

year 2005, some foreign airports and air carriers complied with all relevant 

aviation security standards, while others did not. The most common area 

of noncompliance for foreign airports was related to quality control—

mechanisms to assess and address security vulnerabilities at airports. The 

Secretary of Homeland Security determined that the security deficiencies 

at two foreign airports assessed during fiscal year 2005 were so serious 

that he subsequently notified the general public that these airports did not 

meet international aviation security standards. In addition to assessing the 

security measures implemented by the airport authority at foreign airports, 

TSA also inspected the security measures put in place by air carriers at 

foreign airports. When security deficiencies identified during air carrier 

inspections could not be corrected or addressed immediately, TSA 

inspectors recommended enforcement action. TSA officials stated that 

while it is difficult to determine whether the assessment and inspection 

results are generally positive or negative, the cumulative foreign airport 

assessment and air carrier inspection results may be helpful in identifying 

the aviation security training needs of foreign aviation security officials. 

TSA does not have its own program through which aviation security 

training and technical assistance are formally provided to foreign aviation 

security officials. However, TSA officials stated that they could use the 

results of TSA’s foreign airport assessments to refer foreign officials to 

training and technical assistance programs offered by ICAO and several 

other U.S. government agencies. 

TSA Found That 

Some Foreign 

Airports and Air 

Carriers Complied 

with All Aviation 

Security Standards, 

and When Deemed 

Necessary, DHS and 

TSA Took 

Enforcement Action 

on Those That Did 

Not 

Page 26 GAO-07-729 Aviation Security 
Of the 128 foreign airports TSA assessed during fiscal year 2005, TSA data 

show that at the completion of these assessments, 46 (about 36 percent) 

complied with all ICAO standards reviewed by TSA,33 while 82 (about 64 

percent) did not meet at least one ICAO standard reviewed by TSA.34 For 

these 82 foreign airports, the average number of standards not met was 

about 5, and the number of standards not met by an individual airport 

ranged from 1 to 22. Foreign airports were most frequently not meeting 

ICAO standards related to quality control. TSA data show that about 39 

percent of foreign airports assessed during fiscal year 2005 did not comply 

with at least one ICAO quality control standard, which include

mechanisms to assess and address security vulnerabilities at airports. For 

example, one airport did not meet an ICAO quality control standard 

because it did not have a mechanism in place to ensure that airport 

officials implementing security controls were appropriately trained and 

able to effectively perform their duties. In another instance, an airport did 

not comply with an ICAO quality control standard because, during its 

previous two assessments, inspectors found that the airport did not 

require or have records of background investigations conducted for 

individuals implementing security controls at the airport. Another area in 

which airports were not meeting ICAO quality control standards was the 

absence of a program to ensure the quality and effectiveness of their 

National Civil Aviation Security Program. TSA officials stated that quality 

control deficiencies may be prevalent among foreign airports in part 

because there is no international guidance available to aviation security 

officials to help them develop effective quality control measures. However, 

TSA officials stated that ICAO and other regional aviation security 

organizations offer training courses to help aviation security officials 

worldwide in developing effective quality control measures. 

TSA Data Identified That 

More than One-Third of 

Foreign Airports Complied 

with All Relevant ICAO 

Standards during Fiscal 

Year 2005, and the 

Remaining Airports Had 

Security Deficiencies 

 33TSA assessed foreign airports against 64 required ICAO standards and 22 recommended

ICAO practices for aviation security. For the purpose of this report, we refer to both 

standards and recommended practices as standards. 

34TSA found that 104 of the 128 foreign airports initially did not meet at least 1 ICAO 

standard. The average number of ICAO standards not met by these 104 airports was about

6, and the range of standards not met by an individual airport was 1 to 24. However, by the 

completion of TSA’s assessment, 22 of these 104 airports had taken corrective action that

enabled them to meet all ICAO standards; thus leaving 82 airports that did not meet at least 

1 ICAO standard at the completion of the assessment period. In addition to conducting 

airport assessments of foreign airports, TSA also conducts surveys of foreign airports.

Surveys are conducted at airports that plan to provide new service to the United States. 

Page 27 GAO-07-729 Aviation Security 
TSA data also identified that at the completion of the assessment, nearly

half of the foreign airports assessed during fiscal year 2005 did not meet at

least one of the 17 ICAO standards that TSA characterized as “critical” to 

aviation security.35 According to TSA, access control, screening of checked

baggage, and screening of passengers and their carry-on items are critical

aspects of aviation security because these measures are intended to 

prevent terrorists from carrying dangerous items, such as weapons and 

explosives, onto aircraft. TSA data identified that some foreign airports 

assessed during fiscal year 2005 did not meet at least one access control 

standard. TSA data also identified that some foreign airports did not meet 

ICAO standards related to checked baggage screening. One of the baggage 

screening deficiencies TSA identified involved foreign airports not taking 

steps to prevent checked baggage from being tampered with after the 

baggage had been screened, prior to the baggage being placed on the 

aircraft. TSA data also identified that some foreign airports assessed 

during fiscal year 2005 did not meet ICAO standards related to passenger 

screening. One of the passenger-screening problems identified by TSA 

involved screening personnel not resolving hand-held metal detector or 

walk-through metal detector alarms to determine whether the individuals 

being screened were carrying prohibited items. 

The Secretary of 

Homeland Security Took 

Action against Foreign 

Airports That Did Not 

Maintain and Carry Out 

Effective Security 

Measures 

Even if a foreign airport does not meet multiple aviation security 

standards, including critical standards, TSA may determine that such 

deficiencies do not warrant review by the Secretary of Homeland Security. 

However, if TSA determines that secretarial action may be warranted and 

the Secretary of Homeland Security, based on TSA’s assessment, 

determines that a foreign airport does not maintain and carry out effective 

security measures, he or she must take secretarial action. Since the 

inception of DHS in March 2003, the Secretary of Homeland Security has 

taken action against five foreign airports he determined were not 

maintaining and carrying out effective security measures, four of which 

received 90-day action letters. The Secretary notified the public of his 

determination with respect to two of these airports—Port-au-Prince 

 35At the beginning of the assessment, TSA found that 88 airports did not meet at least one 

critical ICAO standard. However, by the end of the assessment period, 27 airports took

corrective action that allowed them to meet all critical standards, leaving 61 foreign 

airports not meeting at least one critical ICAO standard after TSA completed its 

assessment.

Page 28 GAO-07-729 Aviation Security 
Airport in Haiti36 and Bandara Ngurah Rai International Airport in Bali, 

Indonesia37—both of which were assessed during fiscal year 2005. 

TSA officials told us that the decision to take secretarial action against an

airport is not based solely on the number and type of security deficiencies 

identified during TSA airport assessments.38 Rather, the secretarial action

decision is based on the severity of the security deficiencies identified, as

well as past compliance history, threat information, and the capacity of the 

host government to take corrective action.39 For example, there were other

foreign airports assessed during fiscal year 2005 that did not comply with 

about the same number and type of critical ICAO standards as the five 

airports that received secretarial action. However, according to the former 

Deputy Director of TSA’s Compliance Division, secretarial action was not 

taken against these airports either because the security deficiencies were 

determined to be not as severe, the host country officials were capable of 

taking immediate corrective action to address the deficiencies, or TSA did 

not perceive these airports to be in locations at high risk of terrorist 

activity. Table 2 demonstrates how two foreign airports—one for which 

secretarial action was taken and the other for which no secretarial action

was taken—have about the same number and types of critical deficiencies, 

but differ in the severity of the deficiencies and their capability to take

immediate corrective action to address identified deficiencies.

 36See 70 Fed. Reg. 3,378 (Jan. 24, 2005). Based on subsequent assessments by TSA, the 

Secretary found that Port-au-Prince International Airport maintains and carries out

effective security measures. See 71 Fed. Reg. 42,103 (July 25, 2006). 

37See 71 Fed. Reg. 3,107 (Jan. 19, 2006). The airport in Bali was subjected to both a public 

notification and a 90-dayaction, whereas for Haiti, the Secretary by-passed the 90-day 

action and immediately notified the public that the airport in Haiti did not maintain and

carry out effective security measures. The identity of the foreign airports that were 

subjected to 90-day actions, but did not also subjected to public notification, is classified. 

38The number of ICAO standards not met by the five secretarial action airports at the 

completion of TSA’s assessment ranged from 11 to 18, and the number of critical standards 

not met by these airports range from 3 to 6. The assessment reports for these airports

included some standards that did not provide information whether or not the standard had 

been met at the completion of TSA’s assessment. Therefore, those standards were 

excluded when calculating these range values.

39TSA officials stated that noncompliance with an ICAO standard, which is required, has 

more influence on a secretarial action determination than noncompliance with an ICAO

recommended practice, which is only suggested. 

Page 29 GAO-07-729 Aviation Security 
Table 2: Comparison of the Severity of Security Deficiencies and Corrective Action Taken at One Secretarial Action Airport 

and One Non-Secretarial Action Airport 

Secretarial action airport Non-secretarial action airport 

ICAO standard not

met by the airport 

4.7.1—Each Contracting State shall ensure that security restricted areas are established at each airport 

serving international civil aviation and that procedures and identification systems are implemented in respect 

of persons and vehicles. 

Severity of the 

deficiency 

• Security guards failed to check identification 

(ID) badges properly for pedestrians and 

vehicles entering restricted areas. 

• Guards allowed 54 vehicles to enter a 

restricted area requiring vehicles operators to 

only show a letter identifying them as a very 

important person (VIP). 

• Guards were not conducting walking or mobile 

patrols of areas around or in the airport. 

• Guards did not prevent persons without proper 

identification from entering restricted areas. 

• The airport did not have a program in place to

audit the identification system.

• Vehicles that did not have proper permits were parked 

in a restricted area. 

• A door that leads from the ticket counter to the airside

was left open and unattended. 

Immediate corrective 

action taken by the 

airport to address the 

deficiency 

• No immediate action was taken to address the 

deficiency. 

• The airport director immediately removed the vehicles 

from the restricted area and informed vehicle 

operators that they would not be allowed to park in the 

restricted area until they obtained an authorized 

vehicle permit. 

ICAO standard not

met by the airport 

4.3.1—Each Contracting State shall establish measures to ensure that originating passengers and their

cabin baggage are screened prior to boarding an aircraft engaged in international civil aviation operations. 

Severity of the 

deficiency 

• Screeners allowed individuals who set off 

walk-through metal detector alarms to pass 

through the screening checkpoint without 

determining the cause for the alarms. 

• Screeners were not using the hand-held metal 

detector correctly. 

• Screeners were conducting full-body pat-down 

searches incorrectly. 

• X-ray screeners were inattentive and did not 

routinely identify carry-on bags for further 

inspection. 

• Screeners allowed individuals who set off walkthrough metal detector alarms to pass through the 

screening checkpoint without determining the cause 

for the alarms.

• Screeners were not using the hand-held metal 

detector correctly. 

• Screeners did not physically inspect all cell phones. 

• Screeners did not rotate positions at the checkpoint. 

• The airport did not sufficiently staff the security 

checkpoint. 

Immediate corrective 

action taken by the 

airport to address the 

deficiency 

• Even after TSA inspectors demonstrated how

to properly screen passengers and resolve 

metal detector alarms, screeners were still not 

able to screen passengers and carry-on items 

correctly. 

• After TSA inspectors demonstrated how to properly 

resolve metal detector alarms, prior to the completion 

of the assessment, the inspectors observed that 

screeners were screening passengers and their carryon items correctly. 

Source: GAO analysis of TSA foreign airport assessment results. 

According to TSA, secretarial actions are lifted when the Secretary, in part 

based on TSA’s assessment of the airport, determines that the airport is 

carrying out and maintaining effective security measures. TSA lifted the 

Page 30 GAO-07-729 Aviation Security 
secretarial action at Port-au-Prince airport in Haiti in July 2006, 19 months 

after the public notification was issued. During this 19-month period, TSA 

assisted Haitian officials in developing a national civil aviation security 

plan and provided training on how to properly screen passengers and their

carry-on baggage. According to the former Deputy Director of TSA’s 

Compliance Division, although TSA determined earlier during 2006 that all 

of the security deficiencies at the airport had been addressed by Haitian 

officials, based on specific intelligence information regarding threats to 

the airport in Haiti, the Secretary delayed lifting the secretarial action until 

July 2006. As of February 2007, the public notification for the airport in 

Bali was still in place. TSA officials stated that they are in frequent contact

with Indonesian officials to discuss Indonesia’s progress in addressing 

security deficiencies at the airport. TSA officials also stated that they are 

awaiting Indonesian officials’ request for TSA to conduct an airport 

assessment to determine whether the security deficiencies at the airport in

Bali have been addressed. 

More than Two-Thirds of 

Fiscal Year 2005 Air 

Carrier Inspections

Identified Compliance with 

All TSA Security 

Requirements, while the 

Remaining Inspections 

Identified Some Security 

Deficiencies 

In addition to assessing the security measures implemented by the airport

authority at foreign airports, TSA also inspected the security measures put 

in place by air carriers at foreign airports. According to air carrier 

inspection data maintained by TSA, during fiscal year 2005, of the 529 

inspections of air carriers operating out of foreign airports, there were 373 

inspections (about 71 percent) for which the air carrier complied with all 

TSA security requirements, and 156 inspections (about 29 percent) for 

which the air carrier did not comply with at least one TSA security 

requirement.40 For these 156 inspections, the average number of TSA 

requirements not met was about 3, and the number of TSA requirements 

not met by an individual inspected air carrier ranged from 1 to 18. The 

total number of security requirements against which air carriers were 

inspected generally ranged from about 20 to 80, depending on the location

of the foreign airport in which the air carrier operated, the extent of a 

carrier’s operation at the airport, and whether the carrier was a U.S.-based

or foreign-based carrier.41 During fiscal year 2005 air carrier inspections, 

 40Specifically, 108 of the 385 U.S. air carrier inspections and 48 of the 144 foreign air carrier 

inspections resulted in violations of at least one TSA security requirement. 

41During fiscal year 2005, there were a total of 78 security requirements that TSA could 

have imposed on U.S.-based air carriers operating at foreign airports and a total of 55

security requirements that TSA could have imposed on foreign air carriers. However,

depending on the location of the foreign airport in which the air carrier operated and the 

extent of an air carrier’s operations at the airport, not all of the security requirements were

applicable to all air carriers. 

Page 31 GAO-07-729 Aviation Security 
TSA identified security deficiencies in several areas, including aircraft 

security and passenger and checked baggage screening.42 

Because TSA has authority to regulate air carriers that provide service to 

the United States from foreign airports, TSA inspected air carriers against 

specific security requirements established by TSA and included in the air 

carriers’ TSA-approved security programs. TSA officials told us that they

view operational security requirements for air carriers as critical—as 

opposed to documentary requirements associated with the air carrier’s 

approved security program—because these requirements are designed to 

prevent terrorists from carrying weapons, explosives, or other dangerous 

items onto aircraft. 

TSA Took Enforcement 

Action against Some Air 

Carriers with Security 

Deficiencies That Could 

Not Be Addressed 

Immediately 

When TSA inspectors identify deficiencies that cannot be corrected or 

addressed immediately, the inspectors are to recommend enforcement 

action. Based on data provided by TSA, TSA inspectors identified 419 

violations (security deficiencies) as a result of the 156 air carrier 

inspections conducted during fiscal year 2005 where TSA identified at 

least one security deficiency. Data from TSA showed that 259 violations 

(about 62 percent) were corrected or addressed immediately. TSA 

inspectors submitted 76 violations (about 18 percent) for investigation 

because the violations were considered serious enough to warrant an 

enforcement action.43 TSA can impose three types of enforcement action 

on air carriers that violate security requirements—a warning letter, a letter 

of correction, or a monetary civil penalty. Based on information included

in TSA’s investigation module within PARIS, for the 47 investigations we 

could link to fiscal year 2005 inspections,44 warning letters were issued in 

26 cases, and letters of correction were issued in 14 cases. Fines ranging 

from $18,000 to $25,000 were recommended in the 7 cases where 

inspectors recommended civil penalties be imposed. Of those, fines 

ranging from $4,000 to $15,000 were ultimately levied in 3 cases, in 1 case a 

 42The percentage of air carrier inspections that resulted in these and other types of security 

deficiencies is sensitive security information and, therefore, is not discussed in this report.

43TSA could not readily identify what enforcement actions were recommended for the 

remaining 84 (about 20 percent) security violations identified during fiscal year 2005 air

carrier inspections. 

44The number of enforcement actions is not equal to the number of violations identified 

because TSA can issue one enforcement action for multiple violations and TSA could not 

readily identify what action, if any, was taken for some violations. 

Page 32 GAO-07-729 Aviation Security 
warning notice was issued instead of a civil penalty, and in 2 cases no 

action was taken.45 As of December 2006, 1 case remained unresolved. 

TSA Officials Cite 

Difficulties in Drawing 

Conclusions about Foreign 

Airport Assessment and 

Air Carrier Inspection 

Results 

TSA officials stated that it is difficult to draw conclusions about the 

cumulative foreign airport assessment and air carrier inspection results—

such as whether the results are generally positive or negative—because 

the primary concern is not whether security deficiencies are identified. 

Instead, TSA officials are more concerned about whether foreign countries 

have the capability and willingness to address security deficiencies. 

According to TSA, some foreign countries do not have the aviation 

security expertise or financial resources to adequately address security 

deficiencies. TSA officials also stated that some foreign countries do not 

regard aviation security as a high priority, and therefore do not intend to 

correct security deficiencies identified during TSA assessments. Further, 

TSA officials stated that foreign officials’ capability and willingness also 

influence the extent to which air carriers comply with security 

requirements. Although TSA has not conducted its own analysis of foreign 

airport assessment and air carrier inspection results, TSA officials stated 

that our analysis of the results was consistent with their assumptions 

regarding the most prominent security deficiencies identified at foreign 

airports and among air carriers. Additionally, TSA officials stated that the

cumulative foreign airport assessment and air carrier inspection results 

may be helpful in identifying the aviation security training needs of foreign

aviation security officials. TSA does not have an internally funded program 

in place that is specifically intended to provide aviation security training 

and technical assistance to foreign aviation security officials. However, 

TSA officials stated that they coordinate with other federal agencies, such

as the Department of State and the U.S. Trade and Development Agency, 

to identify global and regional training needs and provide instructors for 

the aviation security training courses these federal agencies offer to 

foreign officials. (See app. IV for a description of the aviation security 

training and technical assistance programs offered by U.S. government 

agencies.) While TSA does not always determine which foreign countries 

would receive aviation security training and technical assistance offered 

by other federal agencies, TSA officials stated that they could use the 

cumulative results of TSA’s foreign airport assessments to refer foreign 

officials to these assistance programs. 

 45 An additional fiscal year 2005 enforcement action based on a fiscal year 2004 inspection 

was resolved with a letter of correction issued in lieu of a $25,000 civil penalty. 

Page 33 GAO-07-729 Aviation Security 
TSA used various methods to help foreign officials and air carrier 

representatives address security deficiencies identified during TSA 

assessments and inspections. However, opportunities remain for TSA to 

enhance oversight of its foreign airport assessment and air carrier 

inspection programs. To help foreign airport officials and host government 

officials address security deficiencies identified during foreign airport 

assessments, TSA inspectors provided on-site consultation to help address 

security deficiencies in the short term, made recommendations for 

addressing security deficiencies over the long term, and recommended 

aviation security training and technical assistance opportunities for 

foreign officials to help them meet ICAO standards. During fiscal year 

2005, TSA resolved 259 of the 419 security deficiencies identified during 

TSA inspections through on-site consultation. Additionally, TSA assigned 

all U.S. air carriers and foreign air carriers to a principal security inspector

and international principal security inspector, respectively, to provide 

counseling or clarification regarding TSA security requirements. Although 

TSA has assisted foreign airport officials and air carrier representatives in 

addressing security deficiencies, TSA did not track the status of scheduled 

airport assessments and air carrier inspections, document foreign 

governments’ progress in addressing security deficiencies at foreign 

airports, track enforcement actions taken in response to air carrier 

violations, and measure the impact of the foreign airport assessment and 

air carrier inspection programs on security. Such information would have 

provided TSA better assurance that the foreign airport assessment and air

carrier inspection programs are operating as intended. 

TSA officials stated that while the primary mission of the foreign airport 

assessment program is to ensure the security of U.S.-bound flights by 

assessing whether foreign airports are complying with ICAO standards, a

secondary mission of the program is to assist foreign officials in 

addressing security deficiencies that TSA identified during its foreign 

airport assessments. As part of the foreign airport assessment program, 

TSA officials assisted foreign authorities in addressing security 

deficiencies in various ways, including

• providing on-site consultation to help airport officials or the host 

government immediately address security deficiencies, 

TSA Assisted Foreign 

Officials and Air 

Carrier 

Representatives in 

Addressing Security 

Deficiencies, but Can 

Strengthen Oversight 

of the Foreign Airport 

Assessment and Air 

Carrier Inspection 

Programs 

TSA Assisted Foreign 

Officials in Addressing 

Security Deficiencies at 

Foreign Airports in Various 

Ways, and Foreign 

Officials Generally Viewed 

TSA’s Assistance as

Beneficial 

• making recommendations to airport officials or the host government 

for corrective action intended to help sustain security improvements, 

and 

• helping to secure aviation security training and technical assistance for 

foreign governments. 

Page 34 GAO-07-729 Aviation Security 
Based on our review of TSA foreign airport assessment reports, during 

fiscal year 2005, TSA provided on-site consultation to help foreign officials 

immediately address security deficiencies that were identified during 

airport assessments and made recommendations to help foreign officials 

sustain security improvements in the longer term. One type of security 

deficiency identified during TSA’s fiscal year 2005 foreign airport 

assessments involved a particular passenger checkpoint screening 

function.46 As a short-term solution to this security deficiency, on at least 

two occasions, TSA inspectors provided on-site training to instruct 

screeners on proper passenger screening techniques. As a longer-term 

solution, the assessment reports identify that in some cases, TSA 

inspectors recommended that the airport conduct remedial training for 

screeners and routinely test screeners who work at the passenger 

checkpoint to determine if they are screening passengers correctly. 

Another security deficiency identified at foreign airports during fiscal year 

2005 related to the security of airport perimeters.47 After identifying this 

deficiency, inspectors consulted with foreign airport officials who, in a 

few cases, took immediate action to address the deficiency. According to

the assessment reports, in some cases, TSA inspectors recommended 

measures that would help the airport sustain perimeter security in the 

longer term. In cases when a short-term solution may not be feasible, TSA

inspectors may have only recommended longer-term corrective action. For 

example, in some cases, TSA inspectors recommended that foreign airport 

officials embark upon a longer-term construction project to address a 

particular type of security deficiency.

48 

On-Site Consultation and 

Recommendations for 

Corrective Action 

During fiscal year 2005, TSA also assisted foreign governments in securing

training and technical assistance provided by TSA and other U.S. 

government agencies to help improve security at foreign airports, 

particularly at airports in developing countries. For example, four of the 

seven TSA Representatives—TSARs—-with whom we met said that they

had assisted foreign governments in obtaining training either through the 

State Department’s Anti-Terrorism Assistance Program or through the U.S. 

Trade and Development Agency’s aviation security assistance programs. 

Aviation Security Training 

and Technical Assistance 

 46The specific passenger checkpoint screening deficiency identified by TSA is sensitive 

security information and, therefore, is not identified in this report. 

47The specific airport perimeter security deficiency identified by TSA is sensitive security 

information and, therefore, is not identified in this report. 

48The specific security deficiency for which TSA inspectors recommended the construction 

project is sensitive security information and, therefore, is not identified in this report. 

Page 35 GAO-07-729 Aviation Security 
The goals of the Anti-Terrorism Assistance Program are to (1) build the 

capacity of foreign countries to fight terrorism; (2) establish security 

relationships between U.S. and foreign officials to strengthen cooperative 

anti-terrorism efforts; and (3) share modern, humane, and effective antiterrorism techniques. The State Department addresses the capacitybuilding goal of the Anti-Terrorism Assistance Program by offering a 

selection of 25 training courses to foreign officials, 1 of which focuses on 

airport security. The State Department provided the airport security 

course, which is taught by TSA instructors, to seven foreign countries 

during fiscal year 2005—Bahamas, Barbados, Dominican Republic, 

Kazakhstan, Philippines, Qatar, and United Arab Emirates. The U.S. Trade 

and Development Agency also provides aviation security training and 

technical assistance to help achieve its goal of facilitating economic 

growth and trade in developing countries. During fiscal year 2005, the U.S.

Trade and Development Agency provided aviation security training for 

government officials in Haiti, Malaysia, and sub-Saharan Africa. During the 

same year, the agency held regional workshops for various countries 

worldwide on developing quality control programs. Government officials 

from two of the five countries we visited identified the importance of 

obtaining quality control training, particularly given that they have not yet

established their own quality control function. Appendix IV includes a 

detailed description of aviation security training and technical assistance 

provided to foreign officials by the State Department and the U.S. Trade 

and Development Agency, as well as other U.S. government agencies. 

Government and airport officials from five of the seven foreign countries 

we visited and officials from 5 of the 16 foreign embassies we visited 

stated that TSA’s airport assessments and the resulting assistance 

provided by TSA have helped strengthen airport security in their countries. 

For example, officials from one country said that TSA assessments 

enabled them to identify and address security deficiencies. Specifically, 

officials stated that the government could not independently identify 

security deficiencies because it did not have its own airport assessment 

program—a condition that TSA officials told us exists in many countries. 

Airport officials in another country stated that TSA’s airport assessments 

and on-site assistance led to immediate improvements in the way in which 

passengers were screened at their airport, particularly with regard to the

pat-down search procedure. Embassy officials representing another 

country also stated that TSA’s assessments reinforce the results of other 

assessments of their airports. In addition, these officials stated that they

appreciated the good rapport and cooperative relationships they have with

TSA inspection officials. Airport officials in another country we visited 

stated that TSA assisted them in developing their aviation security 

Foreign Officials We 

Contacted Generally Viewed 

TSA’s Assistance as Beneficial 

Page 36 GAO-07-729 Aviation Security 
management program, and that the results of TSA’s assessments provided

them with examples of where they need to concentrate more efforts on 

meeting ICAO standards. Government officials in this same country said 

that the TSAR has helped them to comply with ICAO standards related to 

the contents of a member state’s national aviation security program. At the 

recommendation of the TSAR, these officials also planned to participate in

an aviation security workshop provided by the Organization of American 

States,49 which they also felt would be beneficial in helping the government 

formulate its national aviation security programs and associated security 

regulations.

TSA Provided Assistance 

to Air Carriers That Did 

Not Comply with 

Applicable Security 

Requirements 

In addition to assisting foreign officials in addressing security deficiencies

identified during airport assessments, TSA also assisted air carrier 

representatives in addressing security deficiencies that were identified 

during air carrier inspections. Of the 419 instances in which TSA 

inspectors identified noncompliance with TSA security requirements 

during fiscal year 2005, TSA data show 259 were resolved through 

counseling—that is, the security deficiencies were resolved as a result of

on-site assistance or consultation provided by TSA. For example, during 

one inspection, TSA observed that the security contractor employed by the 

air carrier was not properly searching the aircraft cabin for suspicious, 

dangerous, or deadly items prior to boarding. TSA instructed the 

contractor to fully inspect those locations that were not searched 

properly, and obtained assurance that the air carrier would provide 

information to the contractors to ensure proper searches were conducted. 

In another instance, inspectors identified a security deficiency related to

catering carts. The inspectors notified appropriate catering facility 

officials, who stated that the security deficiency was highly unusual and 

that it would not happen again. The inspectors also informed the air 

carrier of the finding and recommended that during the carrier’s internal 

audits, they ensure that catering carts are properly secured. 

In addition to counseling provided by inspectors when deficiencies are 

identified, TSA assigns each air carrier to either a PSI, for U.S.-based air 

carriers, or an IPSI, for foreign air carriers with service to the United 

States, to assist air carriers in complying with TSA security requirements. 

 49The Organization of American States is made up of 35 member states, including the

independent nations of North, Central, and South America and the Caribbean, and is a 

forum for strengthening democracy, promoting human rights, and confronting shared

problems among its members, such as poverty, terrorism, illegal drugs, and corruption. 

Page 37 GAO-07-729 Aviation Security 
Although PSIs and IPSIs do not participate in air carrier inspections, they 

do receive the inspection results for the air carriers that they work with. 

According to the three PSIs and four IPSIs with whom we met, PSIs and 

IPSIs provide counsel to the air carriers and provide clarification when 

necessary on TSA security requirements. For example, they provide air 

carriers with clarification on the requirements contained in security 

directives and emergency amendments issued by TSA. Several of the 

foreign air carriers we met with told us that the IPSIs are generally 

responsive to their requests. In other instances, when an air carrier cannot 

comply with a TSA security requirement—such as when complying with a 

TSA security requirement would cause the air carrier to violate a host 

government security requirement—the air carrier will work with the IPSI 

or PSI to develop alternative security procedures that are intended to 

provide a level of security equivalent to the level of security provided by 

TSA’s requirements, according to the PSIs and IPSIs with whom we met. 

These alternative procedures are reviewed by the PSI or IPSI and then 

approved by TSA headquarters officials.50

Opportunities Exist for 

TSA to Strengthen 

Oversight of the Foreign 

Airport Assessment and 

Air Carrier Inspection 

Programs 

TSA has several controls in place to ensure that the agency is 

implementing the foreign airport assessment and air carrier inspection 

programs as intended. However, there are opportunities for TSA to 

improve its oversight of these programs to help ensure that the status and 

disposition of scheduled foreign airports assessments and air carrier 

inspections is documented and to assess the impact of the assessment and 

inspection programs. Regarding the foreign airport assessment program, 

TSA required inspectors and TSARs to follow standard operating 

procedures when scheduling and conducting foreign airport assessments. 

These procedures outline the process for coordinating with host 

government officials to schedule assessments, conduct foreign airport 

assessments, and report the results of the assessments. TSA also provided 

inspectors with a job aide to help them ensure that all relevant ICAO 

standards are addressed during an assessment. The job aide prompts 

inspectors as to what specific information they should obtain to help 

determine whether the foreign airport is meeting ICAO standards. For 

example, in assessing measures related to passenger-screening 

checkpoints, the job aide prompts the inspector to describe the means by 

which the airport ensures there is no mixing or contact between screened

 50During fiscal year 2005, air carriers made 22 requests for alternative procedures. TSA 

approved 18 requests and 4 requests were withdrawn by the air carrier. 

Page 38 GAO-07-729 Aviation Security 
and unscreened passengers. In addition to the standard operating 

procedures and the job aide, TSA requires inspectors to use a standard 

format for reporting the results of foreign airport assessments and has 

implemented a multilayered review process to help ensure that airport 

assessment reports are complete and accurate. 

With regard to the air carrier inspection program, TSA uses the automated 

Performance and Results Information System to compile inspection 

results. PARIS contains results of air carrier inspections conducted by TSA 

at airports in the United States as well as inspections conducted at foreign 

airports. For air carrier inspections conducted at foreign airports, a series 

of prompts guides inspectors regarding what security standards U.S. 

carriers and foreign carriers operating overseas must meet. PARIS also 

includes a review process whereby completed inspection results can be 

reviewed by a supervisory inspector before being approved for release 

into the database. 

While TSA has controls such as these in place for the foreign airport 

assessment and air carrier inspection programs to ensure consistent 

implementation and documentation, we identified four additional controls

that would strengthen TSA’s oversight of the foreign airport assessment 

and air carrier inspection programs: 

• tracking the status of scheduled airport assessments and air carrier 

inspections, 

• documenting foreign governments’ progress in addressing security 

deficiencies,

• tracking air carrier violations, and 

• measuring the impact of the foreign airport assessment and air carrier 

inspection programs. 

TSA has established some controls for tracking the status of scheduled 

airport assessments and air carrier inspections, but additional controls are

needed. TSA provided us with a list of foreign airport assessments that 

were scheduled to take place during fiscal year 2005 and identified which 

of the assessments were actually conducted and which assessments were 

deferred or canceled. We compared the list of scheduled assessments 

provided by TSA to the fiscal year 2005 airport assessment reports we 

reviewed and identified several discrepancies. Specifically, there were 10 

airport assessments that TSA identified as having been conducted, but 

when we asked TSA officials to provide the reports for these assessments, 

they could not, and later categorized these assessments as deferred or 

canceled. Conversely, there was 1 airport assessment that TSA identified

Additional Controls Are 

Needed to Track the Status of 

Scheduled Airport 

Assessments and Air Carrier 

Inspections 

Page 39 GAO-07-729 Aviation Security 
as having been deferred, but according to the assessment reports we 

reviewed, this assessment was actually conducted during fiscal year 2005.

There were also five foreign airports for which TSA provided us with the 

fiscal year 2005 assessment report, but were not included on TSA’s list of 

assessments scheduled for fiscal year 2005. Further, there were three 

foreign airports listed under one IFO as having been deferred, whereas 

these same airports were listed under another IFO as having been 

canceled during fiscal year 2005.51 TSA also did not maintain accurate 

information on the status of air carrier inspections scheduled for fiscal 

year 2005. TSA provided us with a list of all air carrier inspections 

conducted during fiscal year 2005. We compared the list to the results 

contained in the PARIS database and found numerous inconsistencies. 

Specifically, we identified 46 air carrier inspections at 18 airports that 

were not included on TSA’s list, but were included in PARIS as having 

been conducted during fiscal year 2005. 

Federal standards for internal controls and associated guidance suggest 

that agencies should document key decisions in a way that is complete 

and accurate, and that allows decisions to be traced from initiation, 

through processing, to after completion. TSA officials acknowledged that 

they have not always maintained accurate and complete data on the status

of scheduled foreign airport assessments and air carrier assessments, in 

part due to the lack of a central repository in which to maintain 

assessment information and the lack of standardization in the way in 

which each IFO manager maintains assessment information. Additionally, 

IFOs had not always documented the reasons why assessments and 

inspections were deferred or canceled. TSA officials stated that in August

2006 they began standardizing and refining the existing databases used by 

IFO staff for tracking the status of foreign airport assessments and air 

carrier inspections by including data elements such as the dates of 

previous and planned assessments. TSA officials also stated that IFO staff 

are now encouraged to identify the reasons why assessments and 

inspections were deferred or canceled in the comment section of the 

database. While TSA has made some improvements to the way in which it 

tracks the status of scheduled foreign airport assessments and air carrier 

inspections, there are opportunities for additional refinements to TSA’s 

tracking system. For example, according to our review of TSA’s fiscal year 

2007 foreign airport assessment and air carrier inspection schedules, TSA 

 51The areas of responsibility for the IFOs are mutually exclusive. Therefore, a foreign 

airport assessment should be listed only under one IFO.

Page 40 GAO-07-729 Aviation Security 
did not provide an explanation for why 13 of 34 foreign airport visits—that 

is, either assessments or inspections—had not been conducted according 

to schedule. TSA officials acknowledged that their assessment and 

inspection tracking system is a work in progress and that they need to

make additional decisions regarding the tracking system, such as which 

data elements to include. Without adequate controls in place for tracking 

which scheduled assessments and inspections were actually conducted

and which were deferred or canceled, it may be difficult for TSA to ensure 

that all scheduled airport assessments and air carrier inspections are 

actually conducted. 

TSARs—the primary liaisons between the U.S. government and foreign 

governments on transportation security issues—are responsible for 

following up on progress made by foreign officials in addressing security 

deficiencies identified during TSA assessments. Although the TSARs we 

interviewed stated that they conducted such follow-up, the TSARs did not 

consistently document the progress foreign governments had made in 

addressing airport security deficiencies. We found 199 instances in the 128 

fiscal year 2005 foreign airport assessment reports we reviewed where it 

was written that the TSAR would follow up or was recommended to 

follow up on the progress made by foreign officials in addressing security 

deficiencies identified during airport assessments. However, TSA may not 

be able to determine whether TSARs had actually followed up on these 

security deficiencies because TSARs did not consistently document their 

follow-up activities. We interviewed 8 of the 20 TSARs stationed at 

embassies throughout the world and one Senior Advisor and DHS attaché. 

Six of those TSARs stated that they followed up on outstanding security 

deficiencies in various ways,52 depending on the severity of the deficiency 

and the confidence that the TSAR had in the host government’s ability to 

correct the deficiency. For example, one TSAR told us that for less critical 

security deficiencies, she may inquire about the foreign government’s 

status in addressing the deficiency via electronic mail or telephone call.

On the other hand, for a critical deficiency, the TSAR said she may follow 

up in person on the host government’s progress in addressing the 

deficiency. However, another TSAR stated that she only follows up on the 

foreign government’s progress in addressing national program issues. She 

stated that she does not follow up on operational security deficiencies—

TSA Did Not Consistently 

Document Foreign 

Governments’ Progress in 

Addressing Security 

Deficiencies 

 52 Three of the TSARs did not mention conducting follow-up activities during their 

interview, in part because we did not specifically ask about conducting follow-up activities 

during these interviews. 

Page 41 GAO-07-729 Aviation Security 
such as screening of passengers and checked baggage—because she 

believes this is the responsibility of the TSA inspection staff. While 4 of the 

8 TSARs we interviewed told us that they were able to follow up on the 

status of most or all security deficiencies within their area of 

responsibility, not all of these TSARs reported the results of their followup to TSA inspection staff, in part because they were not required to do so.

In addition, TSARs stated that when they did document the results of their 

follow-up, it was not done consistently. For example, follow-up results 

were sometimes documented in weekly trip reports (generally electronic 

mail messages) TSARs send to their immediate supervisor in TSA 

headquarters or in action plans.53 In addition, these weekly reports did not 

always contain information from the TSARs’ follow-up activities with host 

government or airport officials. Federal standards for internal controls and 

associated guidance suggest that agencies should document key activities 

in such a way that maintains the relevance, value, and usefulness of these 

activities to management in controlling operations and making decisions. 

TSA headquarters officials acknowledged that it is important to 

consistently document foreign governments’ status in addressing security 

deficiencies identified during TSA assessments, because this information 

could be helpful to TSA inspection staff when determining where to focus 

their attention during future assessments. Additionally, documenting 

foreign governments’ progress toward addressing deficiencies would 

enable TSA to have current information on the security status of foreign 

airports that service the United States. TSA established a working group in

September 2006 to explore how the results of TSAR follow-up should be 

documented and used by TSA inspection staff. Because of the logistical 

challenges of coordination among working group members who are 

located around the world, TSA has not set a time frame for when the 

working group is expected to complete its efforts. 

 53TSARs may assist foreign officials in developing action plans to address deficiencies

identified by TSA during airport assessments. According to TSA guidance, TSARs are to 

assist foreign officials in developing action plans when the security deficiencies identified 

are significant, but do not pose an immediate or serious threat to aviation security. During 

fiscal year 2005, TSA developed an action plan for 1 foreign airport. Action plans are to

include (1) the security deficiencies identified at the airport, (2) the corresponding

recommended corrective actions agreed upon by TSA and host government officials to 

address each deficiency, (3) host government officials’ progress in implementing corrective

actions, (4) date when host government is expected to complete the corrective action, and 

(5) the host government office or agency responsible for implementing the corrective 

action. 

Page 42 GAO-07-729 Aviation Security 
TSA does not maintain air carrier inspection data in a way that would 

enable the agency to determine what enforcement actions were taken in 

response to identified security violations and thus could not readily 

determine whether appropriate penalties, if any, were given to air carriers 

that violated security requirements. We found two factors that contributed 

to this situation. First, information on violations and findings was not 

consistently recorded, and second, TSA does not link enforcement actions

to inspection findings. For example, when an inspector identifies a 

violation during an inspection, that information is recorded in the 

inspections database in PARIS and a record is to be opened in the findings 

database.54 The findings database record includes information related to 

the violation, including whether the violation was closed with counseling 

or an investigation was opened. However, we found that information is not 

maintained in a way that enables TSA to readily determine the

enforcement action that was taken in response to a particular violation. 

For example, the findings database did not include information on the 

action taken by TSA inspectors for all security violations that were 

identified in the inspections database. Specifically, the inspections 

database indicated that during fiscal year 2005, 419 air carrier violations 

were identified during 156 inspections. However, the findings database 

only identified the actions taken by TSA inspectors for 335 violations. On 

further analysis we found that of the 156 inspections where violations 

were identified, the number of violations for 79 (51 percent) of those 

inspections were not properly recorded in the findings database. We 

determined that for 66 inspections, the number of violations identified in 

the findings database was less than the number of violations identified in 

the inspections database. Therefore, there is no record of what action was 

taken, if any, by TSA inspectors to address the additional violations 

identified during these inspections. We also determined that for 13 

inspections, the number of violations identified in the findings database 

was greater than the number of violations identified in the inspections 

database. Another reason TSA could not readily identify what enforcement 

actions were taken in response to specific security violations was that TSA 

often issued one enforcement action for multiple security violations, 

where inspectors were not required to identify each individual violation 

that was addressed by a particular enforcement action. Without being able 

to readily identify what enforcement action was taken in response to 

TSA Did Not Adequately 

Maintain Information to Link 

Enforcement Actions with 

Specific Air Carrier Security 

Violations 

 54PARIS is a Web-based method for entering, storing, and retrieving performance activities 

and information on TSA-regulated entities, including air carriers. PARIS includes profiles

for each entity, inspections conducted by TSA, and investigations that are prompted by 

incidents or inspection findings. 

Page 43 GAO-07-729 Aviation Security 
specific security violations, TSA has limited assurance that the inspected

air carriers received appropriate penalties, if deemed necessary, and that 

identified security violations were resolved. TSA officials told us that they 

are currently developing updates to PARIS that will automatically open a 

finding each time a violation is recorded in the inspection database. By 

doing so, this will require a link between a violation and the planned 

course of action to resolve the violation. However, TSA has not 

established a time frame for when these updates will be implemented. 

TSA is taking steps to assess whether the goals of the foreign airport 

assessment and air carrier inspection programs are being met, but 

identified several concerns about doing so. As previously discussed, the 

goal of the foreign airport assessment and air carrier inspection programs 

are to ensure the security of U.S.-bound flights by evaluating the extent to

which foreign governments and air carriers are complying with applicable

security requirements. The Government Performance and Results Act of 

1993 requires executive branch departments to use performance measures

to assess progress toward meeting program goals and to help decision 

makers assess program accomplishments and improve program 

performance. Performance measures can be categorized either as outcome 

measures, which describe the intended result of carrying out a program or 

activity, or as output measures, which describe the level of activity that 

will be provided over a period of time, or as efficiency measures, which 

show the relationship between outcome or output of a program and the 

resources used to implement program activities—inputs. 

TSA Did Not Have OutcomeBased Performance Measures 

to Assess the Impact of the 

Foreign Airport Assessment 

and Air Carrier Inspection 

Programs 

TSA developed the following output and efficiency measures to evaluate 

its international aviation regulatory and enforcement efforts, which 

include foreign airport assessments and air carrier inspections: 

• percentage of countries with last-point-of-departure service to the 

United States that are provided aviation security assistance at the 

national or airport level,

• percentage of countries that do not have last-point-of-departure service 

to the United States that are provided aviation security assistance at 

the national or airport level, and 

• average number of international inspections conducted annually per 

inspector. 

While output measures are useful in determining the number of foreign 

countries for which TSA has provided aviation security assistance and the 

rate at which such assistance is being provided, outcome-based measures 

would be particularly useful because they could be used to determine the

Page 44 GAO-07-729 Aviation Security 
extent to which TSA has helped to improve security at foreign airports 

that service the United States. However, TSA officials identified several 

challenges in developing outcome measures, particularly measures for the 

foreign airport assessment program. TSA officials said that it is difficult to

develop meaningful outcome measures because TSA does not have control 

over whether foreign authorities implement and meet ICAO standards. 

Additionally, TSA officials stated that if the agency develops outcome 

measures for the foreign airport assessment program, it would suggest 

that TSA has control over whether foreign airports meet ICAO standards, 

which these officials believe may give the appearance that TSA does not 

respect the sovereignty of the countries it assesses. TSA officials further 

stated that if foreign officials perceive that TSA has no regard for their 

country’s sovereignty, foreign officials may prohibit TSA from conducting 

assessments in their countries. We recognize that whether or not foreign 

governments meet ICAO standards is not within TSA’s control and that 

foreign officials’ concerns about sovereignty are important. However, TSA 

officials have acknowledged that the assistance the agency provides and, 

in rare cases, secretarial actions contribute to whether foreign 

governments meet ICAO standards. Also, there is precedent within the 

federal government for developing outcome-oriented performance 

measures to evaluate efforts that are not within an agency’s control but 

can be influenced by the agency. For example, the State Department 

developed performance measures and targets for its Anti-Terrorism 

Assistance Program to evaluate the agency’s impact on helping foreign 

countries improve their anti-terrorism capabilities. Specifically, during 

fiscal year 2006, the State Department set a performance target that two of 

the six countries that received assistance through the Anti-Terrorism 

Assistance Program would achieve a capability to effectively deter, detect, 

and counter terrorist organizations and threats and sustain those 

capabilities. Another performance target for the program that is beyond 

the State Department’s control is for all 191 United Nations member states 

to implement a particular United Nations resolution that requires all states 

to take sweeping measures to combat terrorism. 

TSA headquarters officials, including the Director of Compliance and Area

Directors, who oversee implementation of the foreign airport assessment 

program, questioned whether it would be appropriate to measure 

improvements made by foreign countries as a result of the assessment 

program. They stated that the primary purpose of the foreign airport 

assessment program is not to help foreign officials improve security at 

their airports; rather, the primary purpose of the foreign airport 

assessment program is to identify—not correct—security deficiencies at

foreign airports and inform the Secretary of Homeland Security of such 

Page 45 GAO-07-729 Aviation Security 
deficiencies. These officials also stated that the agency’s efforts to assist 

foreign officials in addressing security deficiencies are voluntary and, 

therefore, do not warrant performance measurement. Although TSA may 

not be required to assist foreign officials in addressing security 

deficiencies identified during foreign airport assessments, TSA is in fact 

using its inspector and TSAR resources to this end. Consistent with the 

Government Performance and Results Act of 1993, developing 

performance measures and associated targets, such as the percentage of

security deficiencies that were addressed as a result of TSA on-site 

assistance and TSA recommendations for corrective action, would enable

TSA to evaluate the impact of its assistance on improving security at 

foreign airports and be held more accountable for the way in which it uses 

its resources. TSA could also evaluate the impact that secretarial actions 

have on helping foreign airports address security deficiencies in order to 

meet ICAO standards. 

Another challenge faced by TSA officials in developing outcome-based 

measures for the foreign airport assessment program is the lack of an 

automated system to collect and compile assessment results. TSA officials 

stated that in the absence of an automated system to input data and 

information obtained from airport assessments, they do not have enough 

resources to manually compile and analyze airport assessment data that

could be used to feed into outcome measures. Currently, TSA 

headquarters maintains airport assessment reports either electronically or

in hard copy, which makes it difficult to conduct systematic analysis of 

assessment results across foreign airports and over time to evaluate the 

impact TSA’s airport assessment program has had on helping foreign 

countries meet ICAO standards. TSA officials told us that $1 million was 

budgeted to develop a secured, automated database—the Foreign Airport 

Assessment Reporting System—to track airport assessment results. 

However, TSA officials stated that the development of the Foreign Airport 

Assessment Reporting System has been slow due to challenges TSA has 

experienced in linking the existing electronic systems in which previous 

airport assessment reports are stored with the new database. However, 

upon completion of the Foreign Airport Assessment Reporting System, 

which is scheduled for fiscal year 2008, TSA expects that the database will 

enhance standardization of assessment reports as well as accessibility to 

the results of previous foreign airport assessments. TSA also expects that 

the Foreign Airport Assessment Reporting System will enable TSA to 

conduct analysis of foreign airport assessment results. 

As with the foreign airport assessment program, TSA has also not 

developed outcome-based performance measures for its overseas air 

Page 46 GAO-07-729 Aviation Security 
carrier inspection program. However, TSA officials have begun to collect 

and analyze data on air carrier inspections that could be used to measure 

the impact of TSA’s inspection program on helping air carriers comply 

with TSA security requirements. During fiscal year 2006, TSA officials who 

manage PARIS began analyzing air carrier inspection results in an effort to 

assist the agency in evaluating the impact that enforcement actions—

including on-site counseling, administrative actions, and civil penalties—

have had on ensuring air carrier compliance with TSA security 

requirements. These officials plan to assess whether there is a relationship 

between the severity of civil penalties and the reoccurrence of security 

violations. The analysis that is being conducted by these officials is 

consistent with our reviews of agency compliance inspection programs, 

which have cited the need for evaluations of enforcement activities and 

the effectiveness of using sanctions such as civil penalties to increase 

compliance.55 However, while the TSA officials managing PARIS are 

conducting such analysis of performance information, officials who 

manage the air carrier inspection program did not intend to use the results 

of this analysis to develop performance measures or to influence program 

decisions. According to TSA officials, considering that overall compliance 

rates are very high among air carriers, and the number of enforcement 

actions taken by TSA is relatively low, there may not be enough data to

conduct meaningful analysis of the impact of enforcement actions. In 

addition, TSA officials said that they were not convinced that air carrier 

compliance is influenced by enforcement actions, especially since air 

carriers are known to intentionally set aside funds when developing their 

annual budgets in anticipation that they will be fined for some type of

security violation during the year. One TSA official stated that air carrier 

compliance with TSA security requirements is not always within the air 

carrier’s control and is largely influenced by the security measures in place

at the airport, as well as restrictions placed on air carriers by host 

government laws and regulations. When analyzing the fiscal year 2005 air 

carrier inspection results, we identified only one instance where 

noncompliance due to a conflict between TSA requirements and host 

government law resulted in an inspector requesting that enforcement 

action be taken against the air carrier.

56 However, TSA chose not to take 

 55GAO, Aviation Security: Better Management Controls are Needed to Improve FAA’s

Safety Enforcement and Compliance Efforts, GAO-04-646 (Washington D.C.: July 2004), 

and GAO, Pipeline Safety: Management of the Office of Pipeline Safety Enforcement 

Program Needs Further Strengthening, GAO-04-801 (Washington D.C.: July 2004). 

56In this instance, host government law precluded the air carrier from complying with TSA 

requirements for checked baggage screening. 

Page 47 GAO-07-729 Aviation Security 
enforcement action against the air carrier and instead decided to work 

with the host government to resolve the conflict. Despite the concerns 

raised by TSA officials, using the analysis of air carrier inspection results 

to develop performance measures, TSA managers may not be able to 

identify which approaches for improving air carrier compliance are 

working well and which approaches could be improved upon. 

TSA is taking action to address challenges—particularly the lack of 

available inspectors and various host government concerns—that have

limited its ability to conduct foreign airport assessments and air carrier 

inspections according to schedule. TSA has developed a risk-based 

approach to scheduling foreign airport assessments, and is in the process 

of developing a risk-based approach for scheduling air carrier inspections, 

to enhance the agency’s ability to focus its limited inspector resources on 

higher-risk airports. The risk-based scheduling approach is also expected

to reduce the number of visits TSA conducts at low-risk foreign airports, 

which may help address some host governments’ concerns regarding the

resource burden that results from frequent airport assessments by TSA 

and others. Harmonization—that is, mutual recognition and acceptance—

of TSA, host government, and third party (e.g., European Commission) 

aviation security standards and assessment and inspection processes may 

also help TSA address host government concerns regarding resource 

burden. Specifically, when the opportunity is available, TSA is considering 

conducting joint assessments with some host governments or third parties, 

such as the European Commission, which would reduce the number of 

airport visits experienced by some countries. In addition to addressing 

concerns regarding the resource burden placed on host governments as a 

result of frequent airport visits, TSA has taken steps to address some 

country-specific challenges that have limited TSA’s ability to conduct 

foreign airport visits. 

Various challenges have affected TSA’s ability to maintain its schedule of 

conducting foreign airport assessments and air carrier inspections. The 

ability to conduct these assessments and inspections as scheduled is 

important, according to TSA officials, because foreign airport and air 

carrier compliance with applicable security requirements may deteriorate 

significantly between assessments. As time between visits increases, the 

likelihood may also increase that security deficiencies at foreign airports 

and among air carriers may arise and go undetected and unaddressed. TSA 

officials also stated that conducting assessments and inspections on a 

consistent basis helps to ensure that foreign countries continue to comply 

TSA Is Taking Action 

to Address Some 

Challenges That Have 

Limited Its Ability to 

Conduct Foreign 

Airport Assessments 

and Air Carrier 

Inspections 

TSA Has Taken Steps to 

Enhance its Ability to 

Conduct Foreign Airport 

Assessments and Air 

Carrier Inspections on 

Schedule, but Staffing 

Challenges Remain 

Page 48 GAO-07-729 Aviation Security 
with ICAO standards and are operating with effective security measures. 

TSA data show that the agency deferred 90 of the 303 (about 30 percent) 

foreign airport visits that were scheduled for fiscal year 2005, which 

include both foreign airport assessments and air carrier inspections.57

According to TSA, these deferments resulted primarily from a lack of 

available inspectors to conduct the assessments and inspections. Our 

analysis identified that the reported shortage of available inspectors 

reflected the fact that (1) the inspector staff available to conduct the 

assessments and inspections was less than the number authorized at each 

of TSA’s five IFOs at some point during fiscal year 2005 and (2) TSA 

scheduled more foreign airport visits during the fiscal year than available 

inspectors could complete. 

TSA officials cited several reasons why the IFOs operated in fiscal year 

2005 with fewer inspectors than had been budgeted. First, TSA officials 

stated that due to State Department limitations on the number of 

inspectors that can be staffed at IFOs overseas, TSA did not have the 

budgeted number of inspectors on board to complete assessments and 

inspections scheduled for fiscal year 2005.58 Second, TSA officials stated 

that significant turnover among international inspectors and the 

subsequent lengthy process for filling vacant inspector positions also 

contributed to the lack of available inspectors. TSA officials attributed the 

turnover of international inspectors to various factors, including TSA’s 

policy that limits the term of international inspectors at overseas IFOs to 4 

years, the lack of opportunities for career advancement when stationed at 

an IFO, and unique difficulties inspectors experience when living and 

working overseas, such as disruptions to family life. As of January 2007, 

TSA officials did not have any specific efforts under way to help reduce 

turnover of international inspectors. Further, TSA officials stated that it

takes an average of about 6 months to fill a vacant inspector position, due 

to the lengthy process for vetting newly hired inspectors. Specifically, 

 57As discussed previously, TSA did not maintain accurate or complete data on the number 

of foreign airport assessments and air carrier inspections scheduled for a particular fiscal 

year. Therefore, our calculations may not include all of the assessments and inspections 

that were conducted, deferred, and canceled during fiscal year 2005. 

58The State Department bases the number of American positions overseas on the mission 

priorities of the embassy, the programmatic and administrative costs associated with 

increases in staffing, and security issues related to the number of Americans posted 

overseas. According to the State Department, the average cost of putting an American 

position overseas will be approximately $430,000. U.S. Office of Management and Budget, 

Department of State and International Assistance Programs, Budget of the United States 

Government, Fiscal Year 2006 (Washington, D.C.: February 2005). 

Page 49 GAO-07-729 Aviation Security 
once hired, international inspectors must be processed through the State 

Department, which entails applying for and receiving medical clearances, 

security clearances, a diplomatic passport, and visas. TSA officials stated 

that expediting the process of filling vacant positions is largely outside of 

TSA’s control. However, TSA assigned a headquarters official to oversee 

this process to identify opportunities for accelerating it. Table 3 shows the 

number of inspectors budgeted for and available at the IFOs each month

during fiscal year 2005. 

Table 3: Budgeted and Available International Inspectors by IFO, by Month for Fiscal Year 2005

Number of international inspectors 

Brussels/Frankfurt Dallas Los Angeles Miami Singapore

 Budgeted staffing for fiscal year 2005

16 5 4 10 4

Month Actual staffing levels for fiscal year 2005 

October 15 5 2 8 3

November 16 4 2 8 3

December 16 4 2 8 3

January 16 4 2 8 3

February 16 4 2 8 3

March 16 4 2 8 3

April 16 4 2 8 3

May 16 4 2 9 3

June 16 4 2 9 3

July 16 4 2 10 2

August 16 4 3 10 1

September 16 4 3 10 1

Source: GAO analysis of TSA data. 

Note: The bold numbers represent months when, according to TSA, IFOs operated below their 

budgeted number of inspectors. 

Even if TSA had been operating at its budgeted inspector staffing level, the

agency may still have deferred some of the foreign airport assessments 

and air carrier inspections scheduled for fiscal year 2005 because, 

according to TSA officials, internal policy required them to schedule more 

foreign airport visits than the budgeted number of inspectors could 

reasonably have conducted. According to TSA officials, this internal policy 

was developed by the Federal Aviation Administration, which was 

responsible for conducting foreign airport assessments and air carrier 

inspections prior to TSA. TSA officials also stated that the Federal 

Page 50 GAO-07-729 Aviation Security 
Aviation Administration had more available inspectors to conduct 

assessments and inspections than TSA. TSA officials stated that each 

international inspector should reasonably be able to conduct between 8 

and 12 foreign airport visits per year,59 depending on the amount of time 

inspectors remain on site to assist foreign officials and air carrier 

representatives in addressing security deficiencies that are identified 

during assessments and inspections. However, according to data provided

by TSA, each of the 5 IFOs scheduled more than 12 foreign airport visits 

per inspector for fiscal year 2005. Table 4 shows the average number of 

foreign airport visits scheduled per international inspector for fiscal year 

2005. 

Table 4: Budgeted Number of Inspectors, Total Scheduled Foreign Airport Visits, and Average Number of Scheduled Foreign

Airport Visits per Inspector, by IFO, for Fiscal Year 2005

IFO 

Budgeted

 number of inspectors

Total number of foreign

 airport visits scheduled

Average number

 of foreign airport visits

scheduled per inspector a

Brussels/ Frankfurt 16 110 13.8

Dallas 5 60 24.0

Los Angeles 3 19 12.7

Miami 10 84 16.8

Singapore 3 30 20.0

Total 37 303 16.4

Source: GAO analysis of TSA data. 

Note: TSA did not maintain accurate or complete data on the number of foreign airport assessments 

and air carrier inspections scheduled for a particular fiscal year. Therefore, our calculations may not 

include all of the assessments and inspections that were conducted, deferred, and canceled during 

fiscal year 2005.

a

The average number of foreign airport visits scheduled per inspector was calculated by multiplying 

the total number of foreign airport visits that were scheduled by 2 (assuming that 2 inspectors conduct

each visit), then dividing that number by the total number of budgeted inspectors. 

TSA officials acknowledged that for fiscal year 2005 they scheduled more 

foreign airport visits than the budgeted level of inspectors could have 

reasonably conducted. However, TSA has taken steps to compensate for 

the shortage of international inspectors by utilizing domestic inspectors to 

help complete the foreign airport assessments and air carrier inspections 

 59 Airport visits include visits to a foreign airport to conduct an airport assessment in 

conjunction with air carrier inspections or to conduct solely an airport assessment or air

carrier inspections. 

Page 51 GAO-07-729 Aviation Security 
that were scheduled for fiscal year 2005. Specifically, domestic inspectors 

were used to assist with about 34 percent of foreign airport assessments 

and about 35 percent of air carrier inspections.60 However, despite the use 

of domestic inspectors, TSA still had to defer foreign airport assessments 

and air carrier inspections. TSA headquarters officials and IFO staff 

further stated that the heavy reliance on domestic inspectors to conduct 

foreign airport assessments and air carrier inspections is not desirable 

because domestic inspectors lack experience conducting assessments 

using ICAO standards or inspecting foreign operations of air carriers, as 

well as working in the international environment. Additionally, using 

domestic inspectors sometimes presents challenges in planning and 

coordinating foreign airport visits. Specifically, it can be difficult to obtain

clearance from the State Department and host government to allow 

domestic inspectors to enter foreign countries because TSA may not 

always be able to provide sufficient notice that domestic inspectors will be 

participating in airport visits, particularly when the need for a domestic 

inspector is determined on short notice. Moreover, according to TSA 

officials, the availability of domestic inspectors may change unexpectedly

when they are needed to remain in the United States. TSA officials also 

said that domestic inspectors may not be available for the entire 4-week 

period that it takes to prepare for, conduct, and write reports for foreign 

airport assessments and air carrier inspections. Last, TSA officials stated 

that compared to international inspectors, some domestic inspectors are 

not effective at taking notes while conducting observations at foreign 

airports, nor are some domestic inspectors effective at preparing foreign 

airport reports—specifically, their word choices for describing security 

conditions at airports are not always sensitive to the concerns of foreign 

officials. According to TSA officials, if foreign officials take offense at the 

way in which TSA portrays the security deficiencies at their airports, 

foreign officials may no longer allow TSA to conduct airport assessments 

in their countries. TSA officials stated that they enhanced the notetaking 

module for the training provided to personnel conducting assessments and 

inspections overseas. However, for the reasons discussed above, TSA 

international officials plan to lessen their reliance on domestic inspectors. 

 60As of June 2006, there were 65 domestic inspectors stationed at 52 U.S. airports who were

eligible to conduct foreign airport assessments and inspections of air carriers operating out 

of foreign airports. There were approximately 700 domestic inspectors stationed at U.S.

airports at the beginning of fiscal year 2006. According to TSA, teams consisting only of

domestic inspectors were used to conduct about 2 percent of foreign airport assessments

and only 1 percent of air carrier inspections during fiscal year 2005. 

Page 52 GAO-07-729 Aviation Security 
Risk-Based Approach

A risk-based approach entails consideration 

of terrorist threats, vulnerability of potential 

terrorist targets to those threats, and the

consequences of those threats being carried 

out when deciding how to allocate resources 

to defend against these threats. Risk-based, 

priority-driven decisions can help inform 

decision makers in allocating finite resources 

to the areas of greatest need. 

During October 2006, TSA began implementing a risk-based approach to 

scheduling foreign airport assessments in order to focus its limited 

inspector resources on higher- risk airports. Another potential benefit to 

TSA’s new approach is that it may allow TSA to reduce its reliance on

domestic inspectors. The objectives of TSA’s risk-based scheduling 

approach are to (1) determine the appropriate frequency of foreign airport 

visits, and (2) identify the appropriate number of inspectors needed for 

each IFO based on the deployment availability of inspectors, the riskbased priority of each location, and the number of visits required each

year. 

Under the risk-based approach, when fully implemented, foreign airports 

are categorized based on risk level, and depending on the category in 

which they are placed, are scheduled to be assessed once a year, once 

every 2 years, or once every 3 years. According to information provided by

TSA, under this approach, the number of foreign airport assessments 

scheduled each year will decrease by about 38 percent (from 170 to 105 

assessments).

61 TSA officials stated that the reduction in the number of 

annual foreign airport assessments will help enable inspectors to complete 

foreign airport assessments according to schedule. Based on our analysis,

TSA’s risk-based approach for scheduling foreign airport assessments is 

consistent with generally accepted risk management principles. 

While it appears that this risk-based approach will reduce the number of 

foreign airport assessments international inspectors are expected to 

conduct in a year, it is too soon to determine the impact of this approach 

on TSA’s ability to complete scheduled foreign airport visits—including 

assessments and inspections—for two key reasons. First, TSA has not yet 

finalized its risk-based approach to scheduling air carrier inspections. In 

February 2007, TSA officials stated that the draft version of the risk-based 

approach to scheduling air carrier inspections was being vetted through 

the agency, but they do not expect the final version to be approved until 

spring 2007. TSA officials stated that in developing the risk-based 

approach for scheduling air carrier inspections, they determined that, 

 61Under the previous scheduling approach, foreign airports that exhibited no operational 

issues in the previous two assessments were assessed once every 3 years. Foreign airports

that had not been previously assessed, subjected to secretarial action within the last 5

years, or exhibited operational issues in either of the two previous assessments were 

assessed once a year. Operational issues are weaknesses in the security system at an 

airport that pose a direct threat to the safety and security of passengers, aircraft, and crew 

(i.e., screening and access control measures).

Page 53 GAO-07-729 Aviation Security 
unlike the situation with airports, using previous inspection results was 

not the best way to determine air carrier vulnerability. Rather, TSA 

officials expect to use foreign airport assessment results to determine the 

vulnerability of air carriers operating out of those airports, especially 

considering that the security status of foreign airports influences TSA’s 

decision to impose additional security requirements on air carriers 

operating out of foreign airports. 

In addition, it is uncertain how TSA’s upcoming audits of foreign repair 

stations will affect the workload of international inspectors. In December 

2003, Congress passed the Vision 100—Century of Aviation 

Reauthorization Act (Vision 100), which mandated that TSA issue 

regulations to ensure the security of foreign and domestic repair stations 

and, in coordination with the Federal Aviation Administration (FAA), 

complete a security review and audit of foreign repair stations certified by

FAA within 18 months of issuing the regulations.62 Currently, there are 

approximately 665 FAA-certified repair stations in foreign countries that 

TSA is required to audit.63 Of these, 93 are deemed substantial with regard 

to safety and security in that they perform work on the airframe, flight 

controls, or propulsion systems. In addition, another 38 are located in 

countries that, pursuant to Vision 100, TSA and FAA must give priority to 

because they have been identified as posing the most significant security 

risks. TSA plans to initiate security audits of the repair stations during 

fiscal year 2007. Specifically, TSA expects to conduct 127 audits of foreign 

repair stations during the initial year, focusing on those located in highthreat areas. According to TSA, the majority of repair stations deemed 

substantial (65 of 93)—are located on or near foreign airports already 

subject to assessment by TSA. TSA expects that it will take inspectors 3 

days to complete initial audits if the foreign repair stations are collocated 

with foreign airports being assessed, and 5 days to complete for stations 

which are not collocated. According to TSA, the agency’s fiscal year 2006 

funding levels were sufficient to allow for an additional 13 international 

inspector positions, including a program manager position, to supplement 

its current international inspector staff and help meet the requirement to 

conduct foreign repair station security audits. As of January 2007, all 13 

 62See Pub. L. No. 108-176, § 611(b)(1), 117 Stat. 2490, 2571-72 (2003) (codified at 49 U.S.C. §

44924). As of March 2007, TSA had not issued final regulations to satisfy this requirement.

63FAA-approved repair stations in foreign countries are facilities located overseas that 

perform maintenance and repairs on aircraft operated by U.S. air carriers or aircraft 

registered in the United States. 

Page 54 GAO-07-729 Aviation Security 
positions were filled, but TSA had not yet begun to conduct these audits. 

Therefore, it is not yet known how these audits and additional inspector 

positions will actually affect overall inspector workload or TSA’s ability to 

complete its foreign assessments and inspections as scheduled. 

Harmonization of Security 

Standards and Assessment 

and Inspection Processes 

Would Help TSA Address 

Host Government 

Concerns Regarding 

Resource Burdens 

Harmonization of TSA, host government, and third party (e.g., European 

Commission) security standards and the processes used to assess foreign 

airports and air carriers would address concerns regarding the resource 

burden placed on host governments as a result of frequent airport visits 

conducted by TSA and others. Officials from 3 of the 7 foreign countries 

we visited in March 2006, as well as officials representing the European 

Commission—the executive arm of the European Union (which is 

composed of 27 countries64), stated that the frequency of airport 

assessments and air carrier inspections conducted by TSA and others had

placed a significant resource burden on the host government. In addition, 

a representative of the Association of European Airlines and IATA stated 

that frequent security inspections by TSA, the host government, and other 

countries, as well as safety inspections, including inspections conducted 

by FAA, burdened the limited personnel resources available to air carriers. 

Specifically, for each inspection, the air carrier must assign one of its 

employees to escort the inspection team around the airport. (In general, 

TSA officials must be accompanied by host government officials when 

conducting foreign airport assessments and air carrier inspections because

TSA officials are not allowed to enter restricted areas of the airport 

unescorted.) Belgian officials, for example, proposed to shorten TSA’s 

fiscal year 2006 assessment of the airport in Brussels, stating that being 

assessed by TSA, as well as ICAO, the European Commission, and the 

European Civil Aviation Conference65 within a short span of time would 

pose a significant resource burden on the Belgian aviation security 

department. Host government officials in Germany raised concerns 

 64The 27 member states of the European Union are Belgium, Bulgaria, Czech Republic, 

Denmark, Germany, Estonia, Greece, Spain, France, Ireland, Italy, Cyprus, Latvia, 

Lithuania, Luxembourg, Hungary, Malta, the Netherlands, Austria, Poland, Portugal, 

Romania, Slovenia, Slovakia, Finland, Sweden and the United Kingdom. 

65Founded in 1955 as an intergovernmental organization, ECAC aims to promote the

continued development of a safe, efficient, and sustainable European air transport system. 

In so doing, ECAC conducts assessments of airports within member states, at the request 

of officials from its member states. ECAC derived the standards by which airports are 

assessed from ICAO Annex 17 civil aviation security standards. However, ECAC officials 

stated that their standards are more prescriptive than those of ICAO. 

Page 55 GAO-07-729 Aviation Security 
regarding the resource burden placed on their aviation security 

department due to the frequency of TSA visits. German officials said that 

TSA scheduled 10 airport visits between January 2006 and September 

2006, which German officials viewed as excessive. In addition to individual 

European countries, the Director of Security for the Protection of Persons, 

Goods, and Installations for the European Commission’s Directorate 

General of Transport and Energy wrote a letter to the TSA Assistant 

Secretary dated March 9, 2006, expressing concern about the frequency of 

TSA airport assessments and air carrier inspections in Europe. The 

Director suggested that TSA consider the high level of quality control 

exercised within the European Union by the European Commission as 

well as the European Union member states when determining the 

frequency of airport assessment visits and that TSA and the European 

Commission embark upon a joint effort to improve coordination of airport 

visits to alleviate the resource burden placed on member states. TSA’s 

risk-based approach for scheduling foreign airport assessments could help 

address some host governments’ concerns regarding the resource burden 

placed on them in part due to the frequency of airport assessments 

conducted by TSA. 

In addition to implementing a risk-based approach to scheduling, there are 

other potential opportunities for TSA to address host country concerns 

regarding the resource burden experienced as a result of frequent airport 

visits. Industry representatives and some host government officials stated

that if TSA and other inspecting entities either conducted joint airport 

assessments and air carrier inspections or used the results of each other’s 

assessments and inspections in lieu of conducting their own, the frequency 

of airport visits could be reduced, in turn reducing the resource burden 

placed on host governments and air carriers. Airports Council 

International officials we interviewed, who represent airport operators 

worldwide, stated that if TSA and other inspecting entities were to 

conduct joint assessments, the resource burden experienced by airport 

operators would also be reduced. Moreover, officials from 2 of the 7 

countries we visited suggested that TSA review the results of airport 

assessments conducted by the host government or by third parties either 

in lieu of conducting its own airport assessments or to target its 

assessments on specific security standards. These officials said that by 

doing this, TSA could reduce the length of the assessment period, thereby 

reducing the resource burden placed on host government officials. 

According to TSA, the agency must physically observe security operations 

at foreign airports to determine whether airports are maintaining and 

carrying out effective security measures in order to satisfy its statutory 

Page 56 GAO-07-729 Aviation Security 
mandate to conduct assessments of foreign airports. This interpretation 

precludes TSA from relying solely on third party or host government 

assessments to make this determination.66 However, TSA officials stated 

that they may be able to use host government or third party assessments—

provided that foreign officials make these assessments available to TSA—

to help refine the agency’s risk-based approach to scheduling foreign 

airport assessments, such that TSA would be able to focus its limited 

inspection resources on foreign airports that pose the greatest security 

risk to the United States. For example, instead of visiting a foreign airport 

that TSA considers low risk once every 3 years, TSA, hypothetically, could 

visit such airports once every 5 years, and review third party or host 

government assessments between visits to help determine whether the 

airport is maintaining and carrying out effective security measures. This 

would enable TSA to reduce the number of visits to foreign airports, thus 

addressing host government officials’ concerns regarding the resource 

burden they experience as a result of frequent airport assessments. 

However, three of the five IFO managers we interviewed said that the 

option of using host government assessments is not currently available to 

them because host governments in their areas of responsibility generally

do not have airport assessment programs in place. These IFO managers 

said that even if host governments had assessment programs in place, they 

would be cautious about using the assessment reports and conducting 

joint assessments for one of two reasons: (1) TSA has not independently

evaluated the quality of the assessments conducted by host governments 

and third parties or the quality of the inspectors conducting these 

assessments, and (2) host governments and third party inspectors base 

their assessments on different aviation security standards than TSA. 

Similarly, foreign government officials and industry representatives have 

cited differences in security standards as an impediment to conducting 

joint assessments and using host government or third party assessments. 

 66According to TSA officials, TSA conducts its foreign airport assessments in a manner 

consistent with how the Federal Aviation Administration conducted its assessments before

this responsibility transferred to TSA pursuant to the Aviation and Transportation Security 

Act (ATSA). See International Security and Development Cooperation Act of 1985, Pub. L.

No. 99-83, § 551, 99 Stat. 190, 222-25 (authorizing the Secretary of Transportation to

conduct assessments of the effectiveness of the security measures maintained at foreign 

airports); see also H.R. Conf. Rep. No. 99-237, pp. 124-29 (1985). 

Page 57 GAO-07-729 Aviation Security 
TSA headquarters officials stated that harmonization of airport and air 

carrier security standards and airport assessment and air carrier 

inspection processes would make them less cautious about using other 

assessment reports and conducting joint assessments. To this end, TSA 

has taken steps toward harmonizing airport assessment processes and 

some airport and air carrier security standards with the European 

Commission. In May 2006, in responding to the European Commission’s 

concerns regarding the frequency of TSA airport assessments and air 

carrier inspections in Europe, the TSA Assistant Secretary suggested that 

TSA and the European Commission develop working groups to address 

these concerns. Further, in June 2006, TSA initiated efforts with the 

European Commission that will enable each party to learn more about the 

other party’s quality control programs. As part of these efforts, TSA and 

the European Commission established six working groups. TSA and the 

European Commission have not established firm time frames for when the 

working groups are to complete their efforts. The objectives and the status 

of the working groups are described in table 5. 

Harmonization

In the homeland security context,

“harmonization” is a broad term used to 

describe countries’ efforts to coordinate their 

security practices to enhance security and

increase efficiency by avoiding duplication of 

effort. Harmonization efforts can include 

countries’ mutually recognizing and 

accepting each other’s existing practices—

which could represent somewhat different 

approaches to achieve the same outcome, as

well as working to develop uniform 

standards.

Page 58 GAO-07-729 Aviation Security 
Table 5: Description and Status of TSA-European Commission Aviation Security Working Groups

Title of working group Purpose of working group 

Status of working group 

efforts as of January 2007 

SSI Agreement Facilitate sharing of Sensitive Security 

Information (SSI) between TSA and the 

European Commission. 

• TSA and the European Commission agreed

upon the verbiage of the information-sharing

agreement. The agreement is in the final 

formal approval stages at TSA, the European

Commission, and the Department of State. 

Observer Participation on

Inspections 

Facilitate TSA observation of European 

Union airport assessments and European 

Commission observation of TSA 

assessments of U.S. airports. 

• TSA and the European Commission are 

currently in the process of identifying mutually 

agreeable dates for a European Commission 

observer to join a TSA inspection of a U.S. 

airport. 

• Final dates and location for TSA participation

in European Commission audit are to be 

determined. 

• European Commission representatives 

expressed an interest in viewing the PARIS 

database, which is a compilation of U.S. 

inspection findings. 

• The European Commission is in the process 

of developing a database for its inspection 

findings. 

Risk Based Assessment 

Methodology

Establish a risk-based methodology for 

scheduling U.S. airport assessment visits 

to European member states. 

• TSA developed a risk-based methodology for 

scheduling foreign airport assessments. 

• TSA and the European Commission will 

determine next steps. 

Audit Schedules Determine how TSA and the European 

Commission will provide advance notice 

of the dates for planned airport 

assessment visits. 

• TSA and the European Commission agreed to 

share audit schedule information on a 

quarterly basis.

• The level of detail on audit schedules that will 

be shared is to be determined. 

Data Interoperability Facilitate the exchange of information 

regarding supply chain data monitoring 

between the United States and the 

European Commission.a

• TSA and the European Commission 

developed a data interoperability template 

outlining the purpose, key objectives, and 

challenges of data interoperability. 

• This working group may be restructured to 

focus on cargo harmonization.

Compare and Contrast 

U.S./European Commission Aviation 

Security Requirements 

Assess which of TSA’s and the European 

Commission’s aviation security measures 

are comparable (not identical) and 

determine where significant differences 

exist. 

• To accomplish a meaningful comparison, TSA 

and the European Commission have 

developed a matrix to reflect major aviation

security categories and measures. Once the

SSI agreement is finalized, TSA and the 

European Commission will complete the 

comparison matrix. 

Source: TSA. 

a

A supply chain involves the flow of information, product, and funds between different parties involved 

in the development and provision of goods. These parties include manufacturers, suppliers, 

transporters, warehouses, retailers, and customers. 

Page 59 GAO-07-729 Aviation Security 
In December 2006, the TSA Assistant Secretary stated that the agency had 

primarily coordinated with the European Commission on harmonizing 

aviation security standards because airports in the European Union 

generally have a high level of security. The Assistant Secretary further 

stated that TSA should not focus its inspector resources on foreign 

airports that are known to have a high level of security, such as several 

European airports; rather, TSA should focus its limited resources on 

foreign airports that are known to be less secure. The Assistant Secretary 

added that a number of options for better leveraging inspector resources 

are being considered by one of the European Commission-TSA working 

groups, including scheduling European Commission and TSA assessments 

to overlap for 1 or 2 days to enable both parties to share their assessment 

results, which could enable TSA to shorten the length of its assessments. 

The Assistant Secretary also stated that TSA could eventually recognize 

European Commission airport assessments as equivalent to those 

conducted by TSA and have TSA inspectors shadow European 

Commission assessment teams to periodically validate the results. 

However, in January 2007, European Union member states reached 

consensus that they would not share the results of European Commission 

assessments of their airports with TSA until the following occur: (1) TSA 

and the European Commission agree upon protocols for sharing sensitive 

security information; (2) TSA inspectors shadow European Commission 

inspectors on an assessment of a European airport, and European 

Commission inspectors shadow TSA inspectors on an assessment of a U.S. 

airport; and (3) TSA agrees to provide the European Commission with the 

results of U.S. airport assessments. TSA and European Commission 

officials stated that they expect information-sharing protocols to be 

established and shadowing of airport assessments to take place during 

spring 2007. TSA officials also stated that once the information-sharing 

protocols are finalized, they would be willing to provide European Union 

member states with the results of U.S. airport assessments. 

Aviation industry representatives stated that in addition to facilitating joint 

assessments and use of third party assessments, harmonization of aviation

security standards between countries would enhance the efficiency and 

effectiveness of international aviation security efforts. For example, IATA 

representatives we interviewed stated that they have met with TSA 

officials about harmonizing the list of items prohibited onboard aircraft 

with the European Commission. IATA officials stated that having different

security requirements to follow for different countries leads to confusion, 

and perhaps noncompliance with security requirements, among air 

carriers. The Chairman of the Security Committee for the Association of 

European Airlines stated that there are numerous redundancies in the 

Page 60 GAO-07-729 Aviation Security 
international aviation security system that could be reduced through 

harmonization, particularly with regard to screening transfer passengers—

passengers who have a layover en route from their originating airport to 

their destination airport. For example, for a passenger traveling from 

Frankfurt to Chicago who has to change planes in New York, upon landing

in New York, the passenger must be rescreened and have his or her 

checked baggage rescreened before boarding the flight for Chicago. 

According to officials from various air carrier and airport operator 

associations, the rescreening of transfer passengers is costly and is only 

required because individual countries do not formally recognize each 

other’s aviation security measures as providing an equivalent level of 

security. Air carrier representatives also stated that because air carriers 

must use their limited resources to implement redundant security 

measures, they are not able to focus their resources on implementing 

other security measures that may be more effective at preventing a 

terrorist from carrying out an attack.67 The TSA Assistant Secretary agreed 

that rescreening transfer passengers that originate from airports that have

a high level of security may be unnecessarily redundant. The Assistant 

Secretary said that TSA plans to assess the effectiveness of the checked 

baggage screening system commonly used at European airports to 

determine if that system provides at least the same level of security as 

TSA’s baggage screening system. However, TSA officials said that even if 

the agency determines that the baggage screening system in place at 

European airports provides an equivalent level of security, TSA would still 

have to rescreen checked baggage for transfer passengers arriving from 

Europe because the Aviation and Transportation Security Act requires 

passengers and baggage on flights originating in the United States to be 

screened by U.S. government employees.68 According to an attorney in 

TSA’s Office of Chief Counsel, Congress would have to change the law in 

order for TSA to discontinue the screening of transfer passengers. 

TSA also made efforts to harmonize some aviation security measures with 

other countries outside of the European Union. For example, TSA officials 

worked with Canadian officials to develop a common set of security 

 67These officials, at the time of the interview, were not able to offer specific examples of 

other security measures that would be more effective at preventing a terrorist attack. 

68Pursuant to 49 U.S.C. § 44901(a), the screening of all passengers and property that will be 

carried aboard a passenger aircraft with a flight or flight segment originating in the United 

States shall take place before boarding and shall be carried out by a federal government 

employee (or by private screeners under contract to TSA as part of the Screener 

Partnership Program in accordance with § 44920). 

Page 61 GAO-07-729 Aviation Security 
requirements for air carriers that have flights between the United States 

and Canada. Additionally, in response to the alleged August 2006 liquid 

explosives terrorist plot, TSA initially banned all liquids, gels, and aerosols 

from being carried through the checkpoint and, in September 2006, began 

allowing passengers to carry on small, travel-size liquids and gels (3 fluid 

ounces or less) using a single quart-size, clear plastic, zip-top bag. In an 

effort to harmonize its liquid screening procedures with other countries, in 

November 2006, TSA revised its procedures to allow 3.4 fluid ounces of 

liquids, gels, and aerosols onboard aircraft, which is equivalent to 100 

milliliters—the amount permitted by the 27 countries in the European 

Union, as well as Canada, Australia, Norway, Switzerland, and Iceland.

According to the Assistant Secretary of TSA, this means that 

approximately half of the world’s air travelers will be governed by similar 

measures with regard to this area of security. ICAO also adopted the 

liquid, gels, and aerosol screening procedures implemented by TSA and 

others as a recommended practice. As we reported in March 2007, DHS 

has also taken steps toward harmonizing international air cargo security 

practices.69 As part of this effort, TSA has worked through ICAO to develop

uniform international air cargo security standards. 

TSA Is Taking Steps to 

Address Sovereignty 

Concerns Raised by 

Foreign Officials on a 

Case-by-Case Basis 

In addition to concerns regarding the resource burden placed on host 

governments as a result of frequent airport visits by TSA and others, TSA, 

on a case-by-case basis, has also had to address host government concerns 

regarding sovereignty—more specifically, concerns that TSA assessments 

and inspections infringe upon a host government’s authority to regulate 

airports and air carriers within its borders. According to TSA officials and

representatives of the European Commission, several foreign governments 

have stated that they consider TSA’s foreign airport assessments as an 

infringement on their sovereignty. For example, government officials in 

one country have prevented TSA from assessing the security at their 

airports and from inspecting non-U.S. air carriers because they do not 

believe TSA has the authority to assess airports outside of the United 

States and that the host government is the sole regulator of air carriers 

 69GAO, Aviation Security: Federal Efforts to Secure U.S. Bound Air Cargo Are in the

Early Stages and Could Be Strengthened, GAO-07-337SU (Washington, D.C.: March 2007). 

Page 62 GAO-07-729 Aviation Security 
that are based out of their country.70 Based on the results of air carrier 

inspections provided to us by TSA, we found that during fiscal year 2005, 

TSA conducted only one inspection of an air carrier that was based out of

this particular country. According to TSA, officials from this country 

allowed TSA to conduct this particular inspection to accommodate TSA’s 

request to inspect the security of air carriers that had flights originating in

Europe and arriving in Washington, D.C., during the January 2005 U.S. 

presidential inauguration activities. We also found that TSA conducted 

assessments of four airports in this particular country during fiscal year 

2005. TSA officials said that they were able to conduct these assessments 

under the guise of a TSA “visit” to—versus an “assessment” of—the 

airport. TSA officials, however, stated that because officials from this 

country do not believe TSA has the authority to assess the security at their 

airports, these officials would not accept—neither orally nor in writing—

the results of TSA airport assessments. TSA officials also stated that 

officials from this country prohibited TSA inspectors from assessing 

airport perimeter security as well as the contents of the country’s 

individual airport security programs. 

TSA officials identified that there are at least 3 additional countries that 

raised concerns regarding sovereignty. According to TSA, officials from 

one of these countries stated that they did not know of any international 

requirements compelling them to allow TSA to assess their airport and 

that TSA had too many internal flaws to assess airports in other countries. 

In response to this country’s concerns, TSA sent a representative to meet 

with the country’s Minister of Transportation. At the meeting, the Minister 

granted TSA future access to the country’s airports for assessments after 

being offered the opportunity to visit U.S. airports to observe security 

measures. Additional countries, according to TSA, were concerned about

their sovereignty being violated and TSA gathering intelligence 

information for the U.S. government through the airport assessment 

program. TSA officials stated that when unique concerns arise in the 

future, they will continue to work with countries on a case-by-case basis to

try to address their concerns. 

 70 TSA is authorized under U.S. law to conduct assessments of foreign airports. See 49

U.S.C. § 44907. Although TSA does not have any authority to compel a foreign airport or

government to submit to a TSA assessment, the agency does have authority (in conjunction 

with other appropriate U.S. government entities such as FAA and the Department of State)

to impose restrictions on air travel between that airport and the United States in the event 

it is not permitted to conduct an assessment. See id. 

Page 63 GAO-07-729 Aviation Security 
The alleged August 2006 terrorist plot to detonate liquid explosives on 

U.S.-bound flights from the United Kingdom illustrates the continuing 

threat of international terrorism to commercial aviation and the 

importance of TSA’s foreign airport assessment and air carrier inspection 

programs. As part of these programs, TSA has provided on-site 

consultation and made recommendations to foreign officials on how to 

resolve security deficiencies. In rare cases, DHS and TSA have taken more 

aggressive action by notifying the traveling public that an airport does not 

meet minimum international standards or issuing warning letters and 

letters of correction to air carriers. While foreign government officials and 

air carrier representatives acknowledged that TSA’s efforts have helped to

strengthen the security of U.S.-bound flights, there are several 

opportunities for TSA to strengthen oversight of its foreign airport 

assessment and air carrier inspection programs. First, although TSA has 

made some efforts to improve its tracking of foreign airport assessments 

and air carrier inspections, until additional controls are in place to track 

the status of foreign airport assessments and air carrier inspections, such 

as whether scheduled assessments and inspections were actually 

conducted, TSA has limited assurance that all assessments and inspections

are accounted for and that appropriate action was taken for airports and 

air carriers that did not comply with security standards. Second, while 

TSA has helped to strengthen security at foreign airports by providing 

assistance to foreign officials, because TSA does not consistently track 

and document foreign officials’ progress in addressing security 

deficiencies, it may be difficult for TSA to assess the impact of its efforts 

on meeting program goals—to ensure that foreign airports and air carriers 

servicing the United States are meeting, at a minimum, applicable ICAO 

standards and TSA’s security requirements, respectively. Third, although

TSA has established some output performance measures and targets 

related to the assessment and inspection programs, the current measures 

do not enable TSA to draw particularly meaningful conclusions about the 

impact of its foreign airport assessment and air carrier inspection 

programs on the security of U.S.-bound flights and how to most effectively 

direct its improvement efforts. 

Conclusions 

TSA has faced several challenges in meeting the goals of its assessment 

and inspection programs, including a lack of available staff and concerns 

regarding the resource burden placed on host governments as a result of 

frequent airport visits conducted by TSA and others. TSA’s development of 

a risk-based approach to scheduling airport assessments and air carrier 

inspections is a step in the right direction to address host government 

concerns and better leverage limited inspector resources. However, it is 

too soon to determine the extent to which the risk-based approach will 

Page 64 GAO-07-729 Aviation Security 
help to improve TSA’s ability to complete scheduled foreign airport 

assessments and air carrier inspections, and the extent to which the 

approach will alleviate host government concerns regarding the frequency

of airport visits. The collaboration between TSA and the European 

Commission regarding opportunities for conducting joint airport 

assessments and sharing assessment results, as well as efforts to 

harmonize aviation security standards—including those related to the 

screening of liquids, gels, and aerosols—with the European Commission 

and others, are key steps toward addressing host government concerns 

regarding the resource burden that results from frequent assessments by 

TSA and others. It will be important for TSA to continue working with 

foreign officials to address their concerns, such as sovereignty issues, in 

order to continue assessing the security at foreign airports that service the

United States. 

To help strengthen oversight of TSA’s foreign airport assessment and air

carrier inspection programs, in our April 2007 report that contained 

sensitive security information, we recommended that the Secretary of the

Department of Homeland Security direct the Assistant Secretary for the 

Transportation Security Administration to take the following five actions: 

Recommendations for 

Executive Action 

• develop controls to track the status of scheduled foreign airport 

assessments from initiation through completion, including the reasons 

why assessments were deferred or canceled; 

• develop controls to track the status of scheduled air carrier inspections 

from initiation through completion, including the reasons why 

inspections were deferred or canceled, as well as the final disposition 

of any investigations that result from air carrier inspections; 

• develop a standard process for tracking and documenting host 

governments’ progress in addressing security deficiencies identified 

during TSA airport assessments; 

• develop outcome-oriented performance measures to evaluate the 

impact TSA assistance has on improving foreign airport compliance 

with ICAO standards; and 

• develop outcome-oriented performance measures to evaluate the 

impact TSA assistance and enforcement actions have on improving air 

carrier compliance with TSA security requirements. 

Page 65 GAO-07-729 Aviation Security 
On April 13, 2007, we received written comments on the draft report, 

which are reproduced in full in appendix V. DHS generally concurred with 

the findings and recommendations in the report and stated that the 

recommendations will help strengthen TSA’s oversight of foreign airport 

assessments and air carrier inspections. 

Agency Comments 

and Our Evaluation 

With regard to our recommendations that TSA develop controls to track 

the status of scheduled airport assessments and air carrier inspections 

from initiation through completion, including the reasons for any 

deferments or cancellations, and the final disposition of investigations 

related to air carrier inspections, DHS stated that TSA plans to enhance its 

tracking system to include the reason for any deferment or cancellation of 

an airport assessment or an air carrier inspection. The tracking system 

also incorporates the risk-based methodology and criteria for scheduling 

foreign airport assessments that TSA adopted in October 2006. Enhancing 

the tracking system should provide TSA greater assurance that airport 

assessments and air carrier inspections are conducted within applicable 

time frames. If properly implemented and monitored, this tracking system 

should address the intent of our recommendation. Regarding the 

disposition of investigations related to air carrier inspections, DHS stated 

that TSA’s Office of Chief Counsel currently documents the final 

disposition of investigations in PARIS, but TSA will enhance PARIS to 

ensure that inspection activities are linked to investigations so that 

comprehensive enforcement information is readily available. A clear link 

between violations identified as a result of an inspection and the final 

disposition of those violations is important for maintaining comprehensive 

inspection and enforcement information. As we reported, TSA often 

pursued one enforcement action in response to multiple violations, and 

inspectors were not required to identify which violations were included in

the enforcement action. Without being able to readily identify what 

enforcement action was taken in response to specific security violations, 

TSA cannot readily ensure that air carriers receive appropriate penalties, 

and that security violations are resolved. 

Concerning our recommendation that TSA develop a standard process for 

tracking and documenting host governments’ progress in addressing 

security deficiencies identified during assessments, TSA stated that it is 

currently developing a system whereby outstanding deficiencies identified

during an assessment will be tracked along with deficiency-specific 

information, deadlines, and current status. TSA plans to archive this 

information for future trend analysis and to provide a historical 

understanding of each airport’s security posture. This effort, if properly 

Page 66 GAO-07-729 Aviation Security 
implemented, will provide additional relevant, useful information to TSA

in performing its oversight responsibilities. 

TSA concurred with our recommendation that it develop outcomeoriented performance measures to evaluate the impact TSA assistance has 

on improving foreign airport compliance with international security 

standards, and on improving air carrier compliance with TSA security 

requirements. TSA is considering several elements to include in the 

performance measures, such as the number of assessments conducted,

corrective actions recommended, TSA assistance provided, and corrective 

actions achieved. TSA indicated that its outcome-based performance 

measures would be structured to recognize the collaborative nature of the 

process, particularly where corrective action by a foreign government is 

concerned. Such outcome-based performance measures, if properly 

developed and utilized, will enable TSA to determine the impact of its 

airport assessment program and assistance provided for improving 

security at foreign airports. Likewise, these types of measures can be 

applied to air carrier inspections at foreign airports to determine he 

impact that such inspections have on compliance, and to identify which 

approaches to for improving air carrier compliance with security 

requirements work well and which could be improved upon. 

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

at (202) 512-3404 or berrickc@gao.gov. Contact points for our Offices of 

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

of this report. GAO staff that made major contributions to this report are 

listed in appendix VI. This report will also be available at no charge on the 

GAO Web site at http://www.gao.gov. 

Cathleen A. Berrick 

Director, Homeland Security and Justice 

Page 67 GAO-07-729 Aviation Security 
Appendix I: 

Methodology 

Objectives, Scope, and 

Page 68 GAO-07-729

Appendix I: Objectives, Scope, and 

Methodology 

To examine efforts by the Transportation Security Administration (TSA) to 

ensure the security of international aviation, and in particular flights 

bound for the United States from other countries, we addressed the 

following questions: (1) What were the results of TSA’s fiscal year 2005 

foreign airport assessments and air carrier inspections, and what actions

were taken, if any, when TSA identified that foreign airports and air 

carriers were not complying with security standards? (2) How, if at all, did 

TSA assist foreign countries and air carriers in addressing any deficiencies 

identified during foreign airport assessments and air carrier inspections, 

and to what extent did TSA provide oversight of its assessment and 

inspection efforts? (3) What challenges, if any, affected TSA’s ability to 

conduct foreign airport assessments and air carrier inspections, and what 

actions have TSA and others taken to address these challenges? 

To determine the results of TSA’s foreign airport assessments we reviewed 

128 fiscal year 2005 assessment reports, the most recent year for which 

complete foreign airport assessment reports were available.

1

 To determine 

the extent to which foreign airports complied with International Civil 

Aviation Organization (ICAO) standards and recommended practices, we 

looked at the following information contained in the reports: 

Results of Fiscal Year 

2005 Foreign Airport 

Assessments and Air 

Carrier Inspections 

and Actions Taken by 

TSA in Response to 

Noncompliance 

Foreign Airport 

Assessment Results 

(1) ICAO standards or recommended practices with which the airport did 

not comply;

 1

Based on the assessment reports TSA provided us, we determined that TSA conducted 128

foreign airport assessments at 126 unique airports during fiscal year 2005; that is, 2 foreign 

airports were assessed twice during fiscal year 2005. 

Aviation Security
Appendix I: Objectives, Scope, and 

Methodology 

(2) whether issues of noncompliance were “old” (identified during the 

previous assessment) or “new” (identified during the current 

assessment);

(3) explanation of the problems that existed that caused the airport not to 

comply with ICAO standards or recommended practices, and, if 

provided, any actions taken by the host government to address the 

problems; 

(4) TSA’s recommendations for how the airport could correct security 

deficiencies in order to meet ICAO standards or recommended 

practices; and 

(5) whether issues of noncompliance remained “open” (unresolved) or 

“closed” (resolved) prior to the completion of the assessment. 

We developed an electronic data collection instrument to capture 

information from copies of the assessment reports. All data collection 

instrument entries, with the exception of the problem descriptions and 

recommendations, were verified to ensure they had been copied correctly

from the assessment reports. Considering that we only intended to discuss 

the problem descriptions and the recommendations anecdotally, and given

the resources available to verify this information, we verified that the 

problem descriptions and recommendations had been copied correctly for

a random sample of 20 assessment reports from fiscal year 2005. 

We analyzed the data to determine the frequency with which foreign 

airports complied with particular categories of ICAO standards and 

recommended practices, such as passenger screening, checked baggage

screening, access controls, etc., and the number of airports that resolved 

deficiencies upon completion of the assessment. 

Air Carrier Inspection 

Results 

To determine the results of TSA’s air carrier inspections, we obtained 

inspection data from TSA’s Performance and Results Information System 

(PARIS).2

 For the purposes of our review, we analyzed the results of 

 2

 The PARIS database, established in July 2003, provides TSA a Web-based method for

entering, storing, and retrieving performance activities and information on TSA-regulated 

entities, including air carriers. PARIS includes profiles for each entity, inspections 

conducted by TSA, and investigations that are prompted by incidents or inspection 

findings.

Page 69 GAO-07-729 Aviation Security
Appendix I: Objectives, Scope, and 

Methodology 

inspections conducted in fiscal year 2005 to be consistent with the analysis 

performed on the results of foreign airport assessments for fiscal year 

2005. 

TSA’s inspections database contained information on 529 air carrier 

inspections at 145 foreign airports in 71 countries conducted by TSA 

during fiscal year 2005. Specifically, the inspections database included the

date and location of the inspection, the inspected air carrier, the security 

requirements being inspected, as well as the inspector’s determination as 

to whether the air carrier was or was not in compliance with security 

requirements. Prior to conducting any analysis, we assessed the reliability 

of the inspection data by performing electronic testing for obvious errors 

in accuracy and completeness. Our testing revealed a few errors, such as 

inconsistencies in the names of individual air carriers or incorrectly 

identifying the airport as the assessed entity rather than the air carrier. We 

also found instances of inspections conducted at domestic airports that 

were included in the data; those inspection records were removed. We

also interviewed agency officials familiar with the data, and worked with 

them to resolve the data problems we identified. Based on our electronic 

testing and discussions with agency officials, we found the data to be 

sufficiently reliable for the purposes of our report. For our analysis, we 

also added additional information to the inspection records to include the 

country where the inspection occurred, and whether the air carrier being 

inspected was a U.S.-based air carrier or a foreign air carrier. Finally, to

facilitate our analysis, we grouped the security requirements being 

inspected into several categories, such as aircraft security, cargo, checked 

baggage, passenger and carry-on screening and special procedures. 

Actions Taken by TSA 

when Foreign Airports and 

Air Carriers Did Not 

Comply with Security 

Requirements 

To determine the actions taken by TSA when foreign airports did not 

comply with ICAO standards and recommended practices, we reviewed 

TSA’s Foreign Airport Assessment Program Standard Operating 

Procedures (SOP). We also reviewed relevant statutory provisions that 

identify specific actions to be taken by the Secretary of Homeland Security 

when the Secretary determines that a foreign airport does not maintain 

and carry-out effective security measures. 3

To determine the actions taken by TSA when air carriers did not comply 

with TSA security requirements, we reviewed fiscal year 2005 information 

 3

See 49 U.S.C. § 44907. 

Page 70 GAO-07-729 Aviation Security
Appendix I: Objectives, Scope, and 

Methodology 

from the findings and investigations databases in PARIS. As with the 

inspection data, to facilitate our analysis, we included additional 

information in the findings database, such as the country where the 

inspection occurred, and whether the air carrier being inspected was a 

U.S.-based air carrier or a foreign air carrier. Further, we grouped the 

security requirements being inspected into several categories, such as 

aircraft security, cargo, checked baggage, passenger and carry-on 

screening, and special procedures. 

To assess the reliability of the findings data, we performed electronic 

testing for obvious errors and completeness and interviewed agency

officials knowledgeable about the data. We identified two issues of 

concern during our reliability assessment. First, we found that the findings 

database is not linked to the inspections database to allow for ready 

determination of the actions taken by TSA in response to specific 

deficiencies. Second, the findings database did not consistently include 

accurate information on actions taken in response to findings. According 

to TSA officials knowledgeable about the data, the findings database 

should contain information on actions taken by TSA for each response of 

“not in compliance” in the inspections database. However, we found that 

in half of the inspections where deficiencies were identified, such 

information was not properly recorded in the findings database. 

Considering the amount of information excluded from the findings 

database and that this information could not be readily provided by TSA, 

we determined that the findings data were not sufficiently reliable for 

conducting evaluative analysis of the actions taken by TSA when security 

violations were identified during air carrier inspections. However, we 

determined that the findings data were sufficiently reliable for conducting

descriptive analysis of TSA’s actions, while including appropriate 

statements as to its reliability, and for anecdotal purposes. 

To assess the reliability of the investigations data included in PARIS, we 

conducted electronic testing and interviewed agency officials 

knowledgeable about the data. We found that information in the 

investigations database is not recorded in such a way that one can readily

determine which air carrier inspection, and in particular which specific 

security violations identified, were the impetus behind a particular 

investigation. TSA officials explained that inspectors are not required to 

link an investigation to the inspection which it stemmed from. When we 

performed our analysis, TSA officials were, however, able to provide links

to inspections for some of the investigations. For the remainder of the 

investigations data, we attempted to make the link between inspections 

and investigations by using information from the inspections database 

Page 71 GAO-07-729 Aviation Security
Appendix I: Objectives, Scope, and 

Methodology 

such as the date when the investigation record was created and the 

narrative fields, which in some cases identified whether the investigation 

was a result of an inspection or some other offense, such as an air carrier 

allowing a passenger on the No-Fly list to board a U.S.-bound flight.4

 Our 

analysis of actions taken by TSA when air carriers did not comply with 

security requirements is, therefore, based on those investigations that we 

were able to link to fiscal year 2005 inspection activity. We found these 

data to be sufficiently reliable for purposes of this report. 

For additional information on actions taken by TSA when foreign airports 

and air carriers did not comply with security requirements, we interviewed 

TSA headquarters and field officials in the Office of Security Operations—

the division responsible for conducting foreign airport assessments and air 

carrier inspections and making recommendations for corrective action—

and the Transportation Security Network Management division—the unit 

responsible for working with foreign officials to coordinate TSA foreign 

airport visits and monitoring host government and air carrier progress in 

addressing security deficiencies. 

To identify actions taken by TSA to help foreign officials address security 

deficiencies identified at foreign airports during the fiscal year 2005 

airport assessments, we obtained and analyzed information from the fiscal 

year 2005 foreign airport assessment reports. To obtain information on 

TSA’s efforts to assist air carrier representatives in addressing identified

security deficiencies, we reviewed information in the findings and 

Assistance Provided 

by TSA to Address 

Security Deficiencies 

and Oversight of 

Airport Assessment 

and Air Carrier 

Inspection Efforts 

Assistance Provided by 

TSA to Address Security 

Deficiencies 

 4

The No-Fly list contains the names of individuals that pose, or are suspected of posing, a 

threat to civil aviation for national security and are precluded from boarding an aircraft. 

Page 72 GAO-07-729 Aviation Security
Appendix I: Objectives, Scope, and 

Methodology 

investigations databases from TSA’s PARIS. As previously discussed, we 

assessed the reliability of the findings and investigations data by 

performing electronic testing for obvious errors in accuracy and 

completeness, and interviewed agency officials knowledgeable about the 

data. While we identified errors during our reliability assessment, many of

which remained unresolved, we determined that the findings and 

investigations data were sufficiently reliable for anecdotal descriptions of 

the assistance TSA provided air carriers to help them address security 

deficiencies.

To obtain additional information on actions taken by TSA to address 

security deficiencies identified during foreign airport assessments and air 

carrier inspections, we interviewed TSA headquarters officials from the 

Office of Security Operations and the Transportation Sector Network 

Management division. We also made site visits to TSA’s five international 

field offices (IFO) located in Los Angeles, Dallas, Miami, Frankfurt, and 

Singapore, where we met with the IFO managers; international aviation 

security inspectors, who conduct foreign airport assessments and air 

carrier inspections; 10 of the 20 TSA Representatives (TSAR), who 

schedule TSA airport visits and follow up on host governments’ progress 

in addressing security deficiencies; and 4 of the 6 International Principal 

Security Inspectors (IPSI), who are responsible for assisting foreign air 

carriers in understanding and complying with TSA security requirements. 

We also met with 3 of the 15 Principal Security Inspectors (PSI) located at 

TSA headquarters that are responsible for helping U.S. air carriers 

understand and comply with TSA security requirements. During each of 

these interviews, we discussed these officials’ responsibilities related to 

the foreign airport assessment and air carrier inspection programs, 

including their role in assisting foreign officials and air carrier

representatives in correcting security deficiencies identified during 

assessments and inspections. Information from our interviews with 

government officials, members of the aviation industry, and TSA officials 

and inspectors cannot be generalized beyond those that we spoke with 

because we did not use statistical sampling techniques in selecting 

individuals to interview. To obtain a greater understanding of the foreign 

airport assessment and air carrier inspection processes, as well as the 

assistance TSA provides, we accompanied a team of TSA inspectors and a

TSAR during the assessment of E.T. Joshua International Airport in 

Kingstown, St. Vincent and the Grenadines, and the inspection of 

Caribbean Sun Airlines at that location. Moreover, we identified and met 

with officials from other U.S. government agencies that assist foreign 

officials in enhancing security at foreign airports. Specifically, we met with 

Page 73 GAO-07-729 Aviation Security
Appendix I: Objectives, Scope, and 

Methodology 

officials from the Department of Justice, Department of State, Department 

of Transportation, and the U.S. Trade and Development Administration. 

Oversight of the Foreign 

Airport Assessment and 

Air Carrier Inspection 

Programs 

To obtain information on the extent to which TSA provided oversight of its 

assessment and inspection efforts, we reviewed the agency guidance for 

each program. We also reviewed sections of the fiscal year 2005 foreign

airport assessment reports for completeness and general consistency with 

TSA guidance for preparing assessment reports. In addition, we reviewed 

the inspections, findings, and investigations databases in PARIS for 

completeness and the ability to track air carrier inspection activity from 

initiation through completion, including actions taken against air carriers 

who did not comply with security requirements. We compared TSA’s 

guidance and reporting mechanisms for the assessment and inspection 

programs with federal standards for internal controls and associated 

guidance.

5

 We also met with TSA headquarters officials, IFO managers, 

TSARs, and aviation security inspectors to discuss the extent to which 

they documented assessment and inspection activity from initiation 

through completion and follow-up activity for unresolved security 

deficiencies.

We obtained additional information on TSA’s oversight of the foreign 

airport assessment and air carrier inspection programs, particularly with 

regard to assessing the impact of these programs, by reviewing TSA’s 

fiscal year 2006 Performance Assessment Rating Tool (PART) 

submissions. The Office of Management and Budget describes PART as a 

diagnostic tool meant to provide a consistent approach to evaluating 

federal programs as part of the executive budget formulation process. 

PART includes information on an agency’s program goals and 

performance measures used to assess whether program goals are being 

met. We compared the program goals identified in TSA’s PART submission 

with the Government Performance and Results Act of 1993 (GPRA), which 

identifies requirements for the types of measures federal agencies should 

use to assess the performance of their programs. We also interviewed TSA 

headquarters and field officials to obtain their perspectives on appropriate

ways to assess the performance of the foreign airport assessment and air

carrier inspection programs. 

 5

GAO, Internal Control: Standards for Internal Control in the Federal Government, 

GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999), and GAO, Internal Control:

Internal Control Management and Evaluation Tool, GAO-01-1008G (Washington, D.C.: 

August 2001). 

Page 74 GAO-07-729 Aviation Security
Appendix I: Objectives, Scope, and 

Methodology 

To identify challenges that affected TSA’s ability to conduct foreign airport 

assessments and air carrier inspections at foreign airports, we met with 

TSA headquarters and field officials in the Office of Security Operations 

and the Transport Sector Network Management division regarding their 

efforts to obtain access to foreign airports to conduct assessments and 

inspections. We also visited the embassies of 16 nations and the 

Delegation of the European Commission in Washington, D.C., to obtain 

perspectives of foreign transportation security officials on TSA’s airport 

assessment and air carrier inspection program.6

 In addition, we conducted 

site visits to meet with aviation security officials in Belgium, Canada, 

Germany, the Philippines, St. Vincent and the Grenadines, Thailand, and 

the United Kingdom to discuss their perspectives on TSA’s foreign airport 

assessment and air carrier inspection activity. We selected these locations

because they met one or more of the following criteria: a relatively high 

volume of passengers fly to the United States each year, TSA assigned a 

relatively high threat ranking to the country, the country received aviation

security training or technical assistance from a U.S. government agency, or 

a TSA international field office was located in the country. We also met 

with individuals representing 11 air carriers, including both U.S. and 

foreign airlines,7

 to obtain their perspectives on TSA’s foreign airport 

assessment and air carrier inspections programs. Additionally, we met 

with officials from the European Commission, the European Civil Aviation 

Commission, and ICAO to discuss similar efforts these organizations have

in place to ensure compliance with international aviation security 

standards. Information from our interviews with foreign government 

officials and members of the aviation industry cannot be generalized 

beyond those that we spoke with because we did not use statistical 

sampling techniques in selecting individuals to interview. We also 

reviewed documentation associated with TSA’s risk-based methodology 

for scheduling foreign airport assessments and air carrier inspections, 

which TSA intended to address some of the challenges in conducting 

assessments and inspections, and compared the methodology to our risk 

management guidance. 

Challenges That 

Affected TSA’s Ability 

to Conduct Foreign 

Airport Assessments 

and Air Carrier 

Inspections and 

Actions Taken to 

Address those 

Challenges 

 6

 We visited the embassies of Australia, Belgium, Canada, the Dominican Republic, 

Ecuador, France, Germany, Indonesia, Israel, Japan, Mexico, the Netherlands, the 

Philippines, Singapore, Thailand, and the United Kingdom. 

7

 We met with officials from American Airlines, British Airways, Caribbean Sun Airlines,

Continental Micronesia, Delta Air Lines, Lufthansa, Northwest Airlines, Philippine Airlines, 

Singapore Airlines, Thai Airways International, and Virgin Atlantic. 

Page 75 GAO-07-729 Aviation Security
Appendix I: Objectives, Scope, and 

Methodology 

In addition, we interviewed 4 Federal Security Directors8 and 7 aviation 

security inspectors stationed in the United States to discuss their support 

of the foreign airport assessment and air carrier inspection programs as 

well as the impact, if any, that their involvement in these programs has had 

on their operations at U.S. airports. 

We conducted our work from October 2005 through March 2007 in 

accordance with generally accepted government auditing standards. 

 8

The Federal Security Director is the ranking TSA authority responsible for the leadership

and coordination of TSA security activities at the nation’s commercial airports.

Page 76 GAO-07-729 Aviation Security
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Appendix II: International Civil Aviation Organization 

Standards and Recommended Practices Used by TSA to 

Conduct Fiscal Year 2005 Foreign Airport Assessments 

Page 77 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 78 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 79 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 80 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 81 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 82 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 83 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 84 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 85 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 86 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 87 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 88 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 89 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 90 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 91 GAO-07-729 Aviation Security 
Appendix II: International Civil Aviation

Organization Standards and Recommended 

Practices Used by TSA to Conduct Fiscal Year 

2005 Foreign Airport Assessments 

Page 92 GAO-07-729 Aviation Security 
Appendix III: TSA Sec

U.S.-Based

Out of Fore

urity Requirements for 

 and Foreign Carriers Operating 

ign Airports 

Page 93 GAO-07-729

The aircraft operator standard security program (AOSSP) is designed to 

provide for the safety of persons and property traveling on flights against 

acts of criminal violence and air piracy, and the introduction of explosives,

incendiaries, weapons, and other prohibited items on board an aircraft. 

TSA requires that each air carrier adopt and implement a security program 

approved by TSA for scheduled passenger and public charter operations at 

locations within the United States, from the United States to a non-U.S. 

location, or from a non-U.S. location to the United States, and from a nonU.S. location to a non-U.S. location (for example, an intermediate stop 

such as Singapore to Tokyo to the United States). The AOSSP developed 

by TSA and used by U.S.-based carriers is divided into chapters and lays 

out security requirements for operations. Table 6 summarizes 

requirements applicable to flights operating from a non-U.S. location to 

the United States. 

Table 6: Elements of the Aircraft Operator Standard Security Program Applicable to International Operations

Chapter Types of requirements 

Introduction and definitions Defines roles and responsibilities for the positions of Ground Security Coordinator, In-flight 

Security Coordinator, and the Federal Flight Deck Officer. 

Incidents, suspicious activities, and threat 

information

Requires procedures for notification of the Transportation Security Operations Center and 

law enforcement agencies to report incidents and suspicious activities as well as 

procedures to ensure the security of aircraft upon receipt of specific or credible threats. 

Prescreening procedures and passenger 

identification checks 

Requires air carriers to implement passenger prescreening on flights to match passenger 

names against the No-Fly and Selectee screening lists, check of all passenger 

identification, and control of entry into the sterile area. 

Passengers designated as selectee 

passengers 

In addition to the above requirements, defines requirements for screening the checked 

baggage of selectee passengers. 

International flights Requires measures specific to checked baggage acceptance, protective escorts, jump 

seat access, prohibited items, flights departing to a non-U.S. location, flights departing a 

non-U.S. location, and crew member vetting. 

Cargo security measures Requires measures specific to the acceptance of cargo for shipment, cargo screening 

procedures, accompanied courier consignments, cargo for subsequent transfer to another 

carrier, control of access to cargo, notification procedures, and cargo security measures at

non-U.S. locations. 

Catering security measures Requires procedures to ensure security of catering loaded onto a flight, or security at 

catering facilities. 

Additional requirements at extraordinary 

locations 

Some locations outside of the United States have been designated by TSA as requiring 

extraordinary security measures. These measures include items such as aircraft security, 

passenger prescreening, screening selectee passengers, and the questioning of 

enplaning passengers. 

Aircraft and area security Requires measures to prevent unauthorized access to aircraft, search departing aircraft 

prior to passengers enplaning, sealing procedures for vehicles transporting checked 

baggage, access controls to areas such as baggage rooms and other nonpublic areas, 

and criminal history records check of air carrier employees. 

Aircraft Operator Standard 

Security Program: U.S.-

based Carriers 

Appendix III: TSA Security Requirements for 

U.S.-Based and Foreign Carriers Operating 

Out of Foreign Airports 

Aviation Security 
Appendix III: TSA Security Requirements for 

U.S.-Based and Foreign Carriers Operating 

Out of Foreign Airports 

Chapter Types of requirements 

Training Outlines security training requirements for Ground Security Coordinators, In-flight Security

Coordinator, crew members, air carrier employees, and authorized representatives. 

Screening Outlines requirements for air carriers to conduct additional screening at locations outside

of the United States where screening does not meet requirements. 

Source: TSA. 

When TSA determines that additional security measures are necessary to 

respond to a threat assessment or to a specific threat against civil aviation, 

TSA may issue a Security Directive setting forth mandatory measures. 

Each air carrier required to have a TSA-approved security program must 

comply with each Security Directive issued to it by TSA, within the time 

frame prescribed in the Security Directive for compliance.1

 

TSA requires that the security program of a foreign air carrier provide 

passengers a level of protection similar to the level of protection provided

by U.S. air carriers serving the same airports.2

 The security program must 

be designed to prevent or deter the carriage onboard airplanes of any 

prohibited item, prohibit unauthorized access to airplanes, ensure that 

checked baggage is accepted only by an authorized agent of the air carrier, 

and ensure the proper handling of cargo and checked baggage to be 

loaded onto passenger flights. In addition, carriers are requested to 

provide an acceptable level of security for passengers by developing and 

implementing procedures to prevent acts of unlawful interference. 

Security Directives 

Model Security Program 

TSA’s foreign air carrier model security program was prepared to assist 

foreign airlines in complying with security requirements for operations 

into and out of the United States. Table 7 summarizes requirements 

applicable to foreign carriers’ flights operating from a non-U.S. location to

the United States. 

 1

 The specific Security Directives are sensitive security information and, therefore, are not 

identified in this report. 

2

See 49 C.F.R. § 1546.103(a)(3). 49 U.S.C. § 44906, however, provides that TSA shall not

approve the security program of a foreign air carrier unless it requires the foreign carrier in 

its operations to and from airports in the United States to adhere to the identical security 

measures required of air carriers serving the same airports. 

Page 94 GAO-07-729 Aviation Security 
Appendix III: TSA Security Requirements for 

U.S.-Based and Foreign Carriers Operating 

Out of Foreign Airports 

Table 7: Elements of the Foreign Air Carrier Model Security Program Applicable to International Operations

Area of requirement Description

Screening of passengers and carry-on 

baggage 

Sets forth requirements for screening of passengers and their property as well as the 

transport of armed individuals and weapons. 

Checked baggage Sets forth requirements for accepting, handling, and screening of checked luggage, 

including restricting access to baggage areas, conducting passenger baggage matches, 

and the transport of misdirected baggage. 

Cargo Requires procedures be in place to ensure no unauthorized explosives, incendiaries, or 

dangerous articles or persons are included in cargo. In addition, sets forth requirements 

to ensure that once cargo is accepted, it is safeguarded to prevent unauthorized access 

or tampering. 

Security of aircraft and facilities Sets forth requirements for preventing access to aircraft while it is unattended and 

conducting a search of the aircraft interior prior to boarding. This also includes 

requirements for authorized personnel to possess and display proper identification. 

Addressing and reporting acts of unlawful 

interference 

Requires air carriers to implement procedures to respond to threats of hijacking and bomb 

threats. In addition it requires that the carrier establish a procedure for reporting threats 

when they are received. 

Contingency planning Requires air carriers to establish procedures to implement additional security measures 

(regarding checked baggage, passenger, and carry-on baggage screening, aircraft 

security, and cargo handling) when conditions warrant. 

Training Sets forth requirements for air carriers to ensure that employees (screeners, crew 

members, or other air carrier employees) receive adequate training in those security 

areas for which they have responsibilities. 

Source: TSA. 

Emergency Amendments When TSA determines that additional security measures are necessary to 

respond to an emergency requiring immediate action with respect to safety

in air transportation, it may issue an emergency amendment. An 

emergency amendment mandates additional actions beyond those in the 

air carrier’s security program. When TSA issues an emergency

amendment, it also issues a notice indicating the reasons for the 

amendment to be adopted. Air carriers are required to comply with 

emergency amendments immediately.3

 

 3

The specific emergency amendments are sensitive security information and, therefore, are 

not identified in this report. 

Page 95 GAO-07-729 Aviation Security 
A

Securit

Prog

ppendix IV: U.S. Government Aviation

y Training and Technical Assistance

rams for Foreign Entities 

Page 96 GAO-07-729

Appendix IV: U.S. Government Aviation 

Security Training and Technical Assistance 

Programs for Foreign Entities 

The State Department’s Anti-Terrorism Assistance (ATA) program seeks to 

provide partner countries the training, equipment, and technology they 

need to combat terrorism and prosecute terrorists and terrorist 

supporters. The Anti-Terrorism Assistance program was established in 

1983. 

Countries must meet at least one of the four following criteria to 

participate in the ATA program: 

• The country or region must be categorized as having a critical or high 

threat of terrorism and unable to protect U.S. facilities and personnel 

within the country 

• There are important U.S. policy interests with the prospective country, 

which may be supported through the provision of antiterrorism 

assistance. For example, officials in one country received assistance 

through the ATA program because they allowed the United States to 

establish air bases in their country. 

• The prospective country must be served by a U.S. air carrier, or is the 

last point of departure for flights to the United States. 

• The prospective country cannot be engaged in gross human rights 

violations. 

The State Department determines whether and what training and 

assistance to provide countries based on needs assessments done by State 

Department personnel along with a team of interagency subject matter 

experts. The assessment team evaluates prospective program participants 

using 25 Antiterrorism Critical Capabilities. Program officials stated that 

the assessment is a snapshot of the country’s antiterrorism capabilities, 

including equipment, personnel, and available training. ATA program 

officials stated that the assessment includes a review at several levels, 

including tactical capabilities (people and resources), operational 

management capabilities (overall management and ability), and strategic 

capabilities. 

Department of State: 

Anti-Terrorism 

Assistance Program 

Program Background 

Program Selection 

Selection of Countries 

Determination of Type of 

Training 

Antiterrorism Critical Capabilities 

1. Land Border Security 

2. Land Port of Entry Security 

3. Maritime Border Security

4. Maritime Port of Entry Security

5. Air Space Security 

6. Airport of Entry Security

7. Critical Infrastructure Protection 

8. National Leadership Security 

9. Diplomatic Community Security 

10. Preventative Intelligence 

11. National Level Major Incident 

Command and Control 

12. Police Special Operations 

13. Explosive Incidents Countermeasures 

14. Mass Casualty Incident Management 

15. Kidnapping/Hostage Incident 

Management 

16. Police Investigative Capability

17. Post Blast Investigations 

18. Mass Casualty Incident Management 

19. Crime Science and Evidence 

Management 

20. Forensic Examination and Analysis 

21. Financial Investigations 

22. Prosecutorial Capability

23. Critical Digital Infrastructure Security 

24. Cyber Crime Investigations 

25. Institutionalization of Anti/Counter 

Terrorism Training

Aviation Security 
Appendix IV: U.S. Government Aviation

Security Training and Technical Assistance

Programs for Foreign Entities 

Two of the 25 capabilities reviewed during the needs assessments are 

related to aviation security. Those are Airspace Security and Air Port of 

Entry Security. The first is an assessment of how a country controls what 

goes through its airspace. The second is an assessment of security at the 

country’s main airport. According to program officials, when doing an

assessment, the ATA team will usually visit the busiest airport within the 

country to examine the operational security of the airport and assesses 

training provided to airport security management. 

The results of the needs assessments determine what type of assistance 

the State Department will offer to countries participating in the ATA 

program. The various types of training and assistance offered through the 

program include crisis management and response, cyber-terrorism, 

dignitary protection, bomb detection, border control, kidnap intervention 

and hostage negotiation and rescue, response to incidents involving 

weapons of mass destruction, counter terrorist finance, interdiction of 

terrorist organizations, and airport security. During fiscal year 2005, 146 

countries received antiterrorism training through the ATA program; 7 

countries received training for aviation security.

The ATA program offers one course in aviation security, “Airport Security 

Management.” This is a 1-week seminar that is generally taught in-country. 

According to State Department officials, TSA employees teach the course. 

State Department officials stated that this course helps countries to meet 

internationally recognized aviation security standards established by 

ICAO. State Department officials stated that while most countries’ officials 

know about ICAO, and can obtain ICAO manuals and standards, many of 

the countries do not have the resources or equipment to operationalize 

ICAO standards. State Department officials stated that the ATA program 

offers countries the resources to implement ICAO standards. 

For fiscal year 2005, aviation security training was provided to 7 countries 

through the ATA program, Philippines ($94,723), Kazakhstan ($98,200), 

Bahamas ($95,000), Barbados ($45,900), Dominican Republic ($45,900), 

Qatar ($98,046), and United Arab Emirates ($95,000). 

TSA employees teach in-country aviation security training to foreign 

officials through the ATA program. In addition, ATA uses TSA staff as 

subject matter experts when performing needs assessments. 

Program Assistance 

Recipient Countries 

Relationship to TSA 

Page 97 GAO-07-729 Aviation Security 
Appendix IV: U.S. Government Aviation

Security Training and Technical Assistance

Programs for Foreign Entities 

The U.S. Trade and Development Agency (USTDA) works to advance

economic development and U.S. commercial interests in developing and 

middle-income countries. The agency funds various forms of technical 

assistance, training, and business workshops to support the development 

of a modem infrastructure and a fair and open trading environment. 

USTDA’s use of foreign assistance funds to support sound investment 

policy and decision making in host countries is intended to create an 

enabling environment for trade, investment, and sustainable economic 

development. In carrying out its mission, USTDA gives emphasis to 

economic sectors that may benefit from U.S. exports of goods and 

services. For example, according to USTDA, the agency obligated 

approximately 24 percent of its program funding in support of 

transportation sector projects. More specifically, according to USTDA, 5.6 

percent of the agency’s budget is obligated toward projects in the aviation 

security sector. The general goals of USTDA’s work in the aviation security

field are to help foreign airports achieve “Category I” status (the FAA 

classification for an airport that meets minimum safety standards, which 

allows foreign air carriers to fly from their country of origin directly to the 

United States), to help countries prepare to pass and adhere to ICAO 

standards, and to offer training to increase aviation security.

According to USTDA, assistance projects and recipients are selected

within the framework of USTDA’s development and commercial mandate.

Generally, projects are not selected based strictly on security (i.e., not 

selected based on threat) but on the likelihood of a country implementing 

the recommended actions to obtain greater aviation safety and security. 

USTDA projects are developed through consultations by USTDA staff and 

U.S. and foreign embassies, foreign officials (public or private) that have 

decision-making authority to implement the assistance project, or U.S. 

industry officials that identify a need for assistance. According to USTDA, 

when developing the project, the agency evaluates a number of factors, 

including the priority the government places on the project and if the 

entity has the technical capability to implement the project. According to 

USTDA, this evaluation is conducted in order to ensure that U.S. 

taxpayers’ dollars are wisely used on projects that will help strengthen a 

foreign countries’ ability to transport passengers and goods to the United 

States. 

U.S. Trade and 

Development Agency 

Program Background 

Selection of Projects 

Page 98 GAO-07-729 Aviation Security 
Appendix IV: U.S. Government Aviation

Security Training and Technical Assistance

Programs for Foreign Entities 

After an initial evaluation by USTDA staff, USTDA employs a technical 

expert to conduct an independent evaluation of the proposed assistance 

project. That technical evaluation can take two forms: a Desk Study or a 

Definitional Mission. The Desk Study is completed for proposals where 

sufficient information is provided that allows for a technical expert to 

make an informed decision as to whether or not USTDA should fund the 

project. If the project proposal does not contain sufficient detail to 

evaluate without conducting a field site visit, USTDA then employs a small 

business contractor—or consultant—to conduct a Definitional Mission, 

which, according to USTDA, costs between $25,000 and $40,000. The

consultant undertaking the Definitional Mission takes 1 to 2 weeks to meet 

with the stakeholders in the foreign country, including the potential grant 

recipients, in order to review project ideas and generate additional project 

opportunities. Upon return from the site visits, the consultant prepares a 

report for USTDA on the findings of the Definitional Mission. According to

USTDA, consultants typically assess more than one proposed assistance 

project at a time when in the field. To avoid conflicts of interest, the 

consultant that undertakes the Definitional Mission is prohibited from 

participating in any of the follow-on work, including the early investment 

analysis or training recommended in the report. 

Program Assistance 

Early investment analysis is the main form of USTDA assistance. 

According to USTDA, the cost of such assistance typically ranges from 

$100,000 to $500,000. These technical assistance programs may take from 

6 to 18 months to complete. The studies are undertaken by U.S. consulting 

firms under a grant program and are intended to evaluate the technical, 

financial, environmental, legal, and other critical aspects of infrastructure 

development projects that are of interest to potential lenders and 

investors. Host country project sponsors select the U.S. companies, 

normally through open competitions. 

Early Investment Analysis 

USTDA organizes Annex 17 workshops to help bring developing countries

into compliance with lCAO Annex 17. These workshops are designed to 

give countries assistance before lCAO inspections so that they meet 

minimum standards and pass inspections. According to USTDA, the 

workshops suggest ways that relatively poor countries can meet ICAO 

standards with a low level of technological sophistication. According to 

USTDA, the workshops focus on enhancing training and improving human 

resources related to aviation security. 

Annex 17 Workshops 

Page 99 GAO-07-729 Aviation Security 
Appendix IV: U.S. Government Aviation

Security Training and Technical Assistance

Programs for Foreign Entities 

According to USTDA, for fiscal year 2005, the agency awarded Chile 

($359,000), Haiti ($150,000), Iraq ($243,000), Malaysia ($100,000), Tanzania 

($371,000), Ukraine ($625,000), West Africa Regional Training ($353,000) 

and Worldwide Aviation Security training ($596,000) grant assistance in 

the aviation security sector. 

USTDA consults with TSA on an ongoing basis. USTDA used TSA 

personnel as instructors for the Annex 17 workshops. 

The Department of Transportation (DOT) manages the Safe Skies for 

Africa presidential initiative (Safe Skies), which started in 1998. Safe Skies

is a technical program that assists participating countries in meeting 

international aviation safety and security standards. According to DOT 

officials, Safe Skies is a small program with an annual budget— including

operating and administrative costs—between $1 million and $3 million. 

According to DOT officials, approximately one-fourth of the Safe Skies 

budget goes toward aviation security. Funding for Safe Skies is provided 

by the State Department and the U.S. Agency for International

Development (USAID). 

The original Safe Skies participants were selected in 1998 by an 

interagency committee made up of Department of Defense, Department of 

Transportation, State Department, and the U.S. Trade and Development 

Agency. The committee held a series of meetings to consider priority lists 

created by each agency, cables exchanged with U.S. embassies across subSaharan Africa, and responses to questionnaires sent to various states. The 

committee selected countries that it believed had the highest likelihood of

successfully complying with international aviation safety and security 

standards set by ICAO and requirements set by the Federal Aviation 

Administration (FAA) and TSA. The committee also considered U.S. trade 

interests and regional diversity issues. In the end, countries from across 

sub-Saharan Africa were selected to participate in the program. Since 1998

only two countries have been added to the list of Safe Skies participants. 

Recipients 

Participation by TSA 

Department of 

Transportation—Safe 

Skies for Africa 

Program 

Background 

Selection of Participants 

Page 100 GAO-07-729 Aviation Security 
Appendix IV: U.S. Government Aviation

Security Training and Technical Assistance

Programs for Foreign Entities 

Both Uganda and Djibouti became Safe Skies countries after President 

Bush announced the East Africa Counterterrorism Initiative in 2003.1

Program Assistance 

All Safe Skies countries receive some degree of aid, with priority going to 

those countries that demonstrate political will. DOT gauges political will 

based on consultations with embassies and TSA and whether a country 

implements recommended safety and security practices. The 

Administration’s priorities are communicated through the State 

Department. According to DOT, all participants except Zimbabwe have 

had aviation security, safety, and air navigation surveys of their civil 

aviation systems performed at their airports by U.S. government subject -

matter experts. 

General 

Since September 11, 2001, the State Department has provided $5 million in 

additional resources for DOT to provide security equipment to Safe Skies 

countries. DOT officials stated that they worked with their TSA (formerly 

FAA security) colleagues to perform site visits to help agency officials 

determine country-specific security equipment needs for the screening of

passengers and baggage.

Equipment 

According to DOT, Safe Skies has an East Africa aviation security advisor 

stationed in Nairobi, Kenya to provide direct advice and technical 

assistance to Djibouti, Kenya, Tanzania, and Uganda in meeting ICAO 

standards and to assist these states in addressing potential threats to civil

aviation. 

Security Advisor

 1

 East Africa Counterterrorism Initiative (EACTI) includes military training for border and

coastal security, programs to strengthen control of the movement of people and goods

across borders, aviation security capacity building, assistance for regional efforts against 

terrorist financing, and police training. EACTI also includes an education program to 

counter extremist influence and a robust outreach program. According to DOT, with the 

exception of Djibouti, which has a separate funding course, the Economic Support Funds 

used to support the remainder of the Safe Skies countries can only be used to support

those aviation security technical assistance and capacity-building activities performed by 

nonmilitary and nonpolice personnel. 

Page 101 GAO-07-729 Aviation Security 
Appendix IV: U.S. Government Aviation

Security Training and Technical Assistance

Programs for Foreign Entities 

According to DOT, fiscal year 2005 recipients of Safe Skies assistance 

were Angola, Cameroon, Cape Verde,3

 Djibouti, Kenya, Mali, Namibia, 

Tanzania, and Uganda. 

TSA and DOT responsibilities are laid out in a 2004 TSA-DOT 

memorandum of agreement. Under this agreement, TSA provides advice, 

technical assistance, and training through the TSA Enforcement Academy, 

in addition to providing an aviation security advisor to Safe Skies. These 

activities are funded by DOT, with funds that were appropriated to USAID 

and transferred to DOT for the purposes of implementing Safe Skies. TSA

also works in partnership with DOT to prioritize recipient countries based 

on need. 

The Bureau of International Narcotics and Law Enforcement Affairs (INL) 

of the Department of State has a program under way aimed at combating 

alien smuggling and improving border security. The part of the program 

Recipients2

Collaboration with TSA 

Department of 

State—Bureau of 

International 

Narcotics and Law 

Enforcement 

Affairs—Organization 

of American States 

Inter-American 

Committee against 

Terrorism

Background 

 2

According to DOT, Safe Skies offers technical assistance and training for both aviation 

safety and security and does not track funding levels by activity. 

3

According to DOT, Cape Verde is the only Safe Skies country that has successfully 

achieved FAA Category 1 status for safety oversight in accordance with ICAO aviation 

security standards. Cape Verde also met ICAO standards for security oversight and TSA

security requirements for providing direct service to the United States. As such, DOT

provides limited assistance to Cape Verde to sustain its safety and security status. 

Page 102 GAO-07-729 Aviation Security 
Appendix IV: U.S. Government Aviation

Security Training and Technical Assistance

Programs for Foreign Entities 

relating to border security contains elements relating to maritime security 

and airport security. These efforts are undertaken in cooperation with the 

Organization of American States’ (OAS) Inter-American Committee against 

Terrorism (CICTE). The INL-OAS efforts began with maritime security and 

were broadened to include aviation security in 2003. 

INL officials worked with CICTE officials to select the appropriate OAS 

member countries to receive training. As of August 2006, the aviation 

security effort under way was focused on Caribbean nations, and fiscal 

year 2006 funding was also intended to provide funding for some Central 

and South American nations. Roughly $264,000 was spent in 2004, $187,110 

in 2005, and $236,610 in 2006 on aviation security. 

INL funds pay for aviation security training courses, and the courses are 

taught by TSA officials. These training courses are aimed at helping 

countries to develop national civil aviation security programs and other 

essential plans based on the ICAO standards as well as crisis management. 

INL funds were used to pay for national development workshops for 

Caribbean countries. These workshops were taught by TSA staff who 

spent 1 week in each Caribbean country. While in country, TSA 

representatives reviewed the country’s security program, looked for 

deficiencies within the security program, and attempted to build a 

program that would resolve the deficiencies they identified. According to 

OAS, participants in these workshops identified recommendations to 

improve aviation security and combat terrorism and submitted the 

recommendations to their respective governments. The workshops 

addressed enhancements to the national security program, national 

legislation, oversight, national security committees, and program approval

processes. According to OAS, in 2006, these workshops took place in

Antigua and Barbuda, Bahamas, Belize, Dominican Republic, Grenada, 

Guyana, Jamaica, St. Kitts and Nevis, and St. Vincent and the Grenadines. 

According to OAS, starting in September 2006, this program began 

functioning in Central America, where national development workshops 

were planned to take place in Costa Rica, El Salvador, Guatemala, 

Honduras, Nicaragua, and Panama. 

Selection of Participants 

Program Assistance 

According to OAS, in addition to the national development workshops, 

this program also offers a 5-day crisis management workshop for midlevel 

to senior-level aviation management and other government officials. INL, 

through CICTE, also funds aviation security courses that are taught by 

ICAO instructors. 

Page 103 GAO-07-729 Aviation Security 
Appendix IV: U.S. Government Aviation

Security Training and Technical Assistance

Programs for Foreign Entities 

According to OAS, the recipient countries of CICTE-sponsored aviation

security training for calendar year 2006 were Antigua and Barbuda, 

Bahamas, Barbados, Belize, Bolivia, Columbia, Costa Rica, Dominican 

Republic, El Salvador, Grenada, Guatemala, Guyana, Honduras, Jamaica, 

Nicaragua, Panama, Paraguay, Peru, St. Kitts and Nevis, St. Lucia, St. 

Vincent and the Grenadines, Trinidad andTobago, and Uruguay. 4

TSA officials are the instructors for the on-site workshops. CICTE 

established an memorandum of agreement with TSA, and discussed the 

best approach for helping OAS members develop a long-term international 

aviation security program. CICTE and TSA decided that in-country, on-theground visits would be the best approach, since these allow CICTE and 

TSA to see which problems are present. 

According to OAS, during the fourth quarter of 2006, CICTE received grant 

funding to provide aviation security training courses for the nine countries 

that will host the 2007 Cricket World Cup. 

According to OAS, grant funding was used to support two aviation security

training courses—the Basic Security Training Course and the Aviation 

Security Training Course. The Basic Security Training Course is a 7-day 

Recipient Countries 

TSA Participation 

Department of 

State—Western 

Hemisphere Affairs—

Organization of 

American States—

Inter-American 

Committee against 

Terrorism

Background 

Program Assistance 

 4

The Department of State did not fund workshops directly, but rather through a grant to 

OAS/CICTE; thus the specific cost information is not available. Further, many countries

received assistance at workshops held for multiple countries at the same time and it is 

difficult to disaggregate cost information. 

Page 104 GAO-07-729 Aviation Security 
Appendix IV: U.S. Government Aviation

Security Training and Technical Assistance

Programs for Foreign Entities 

course focused on improving aviation security screeners’ ability to detect 

threat items using X-ray machines, metal detection portals, physical search 

techniques, and explosive trace detection technologies. 

According to OAS, the Aviation Security Training Course is a 9-day course 

that addresses concepts and principles of managing aviation security 

operations within the unique environment of an international airport. 

Course content is also based on ICAO standards and recommended 

practices and focused on the protection of passengers, crew, ground 

personnel, the general public, the aircraft, and airport facilities. According 

to OAS, practical exercises are used to reinforce classroom learning. This 

course provided training to midlevel managers and supervisors who are 

responsible for aviation security program planning, oversight, and 

operations. According to OAS, TSA instructors train these officials in 

identifying vulnerabilities at their airports, developing preventive 

measures, and allocating resources to handle the flow of passengers while 

maintaining adequate security. 

The recipient countries for calendar year 2006 and the first half of 2007 are 

Antigua and Barbuda, Grenada, Guyana, Jamaica, St. Kitts and Nevis, and 

St. Lucia. 

The Department of Justice’s (DOJ) International Criminal Investigative 

Training Assistance Program (ICITAP) aims to develop law enforcement 

agencies and systems. Training is only one component of ICITAP’s holistic 

approach to this mission. ICITAP has an ongoing relationship with the 

Department of State to offer various types of training. Since 2000, ICITAP 

facilitated Department of State-initiated aviation security training in Ghana 

and the Dominican Republic, and conducted an assessment in Benin. 

Recipient Countries 

Department of 

Justice-International 

Criminal Investigative 

Training and 

Assistance Program 

Background 

Page 105 GAO-07-729 Aviation Security 
Appendix IV: U.S. Government Aviation

Security Training and Technical Assistance

Programs for Foreign Entities 

The Department of Justice’s involvement can begin when a foreign 

government makes a request to the U.S. embassy for training to rectify 

perceived weaknesses in aviation security. The embassy then collaborates

with DOJ to put together a proposal for action, which is then sent to the 

Department of State’s Bureau of International Narcotics and Law 

Enforcement. INL attempts to obtain a country-specific appropriation for 

the project, and alerts DOJ as to whether funding is available. According 

to DOJ, INL sometimes targets certain countries for assistance and then 

asks ICITAP to prepare proposals and budgets to support training 

activities and technical assistance to improve law enforcement capacity in

the host countries. 

ICITAP assistance included on-site aviation security needs assessments, 

with ICITAP serving as facilitator and current and former TSA (previously 

FAA) employees performing the aviation security needs assessments. The 

assessment was based on standards laid out in ICAO Annex 17. The 

assessment attempted to broadly gauge the adequacy of the available 

security systems and each country’s ability to manage the systems. 

As of February 2007, the most recent recipients are Benin ($79,500 in 

2002),5

 Ghana ($79,500 in 2002), and the Dominican Republic ($32,000 in

2003). 

In 2003, as a result of information gathered from TSA’s foreign airport 

assessment report, ICITAP provided drug interdiction training to customs 

officials in Ghana stationed at the airport. According to DOJ, INL granted 

$79,500 each to Ghana and Benin for the purpose of providing airport 

security training. 

Former and current TSA officials have conducted needs assessments and 

provided training to foreign officials through ICITAP. 

Selection of Participants 

Program Assistance 

Recipients 

TSA Participation 

 5

Not all money was used due to inability to place an aviation security expert on site. 

Page 106 GAO-07-729 Aviation Security 
Appendix V: Comments from the Department Appendix V of Homeland Security : Comments from the Department 

of Homeland Security 

Page 107 GAO-07-729 Aviation Security 
Appendix V: Comments from the Department 

of Homeland Security

Page 108 GAO-07-729 Aviation Security 
Appendix V: Comments from the Department 

of Homeland Security

Page 109 GAO-07-729 Aviation Security 
Appendix V: Comments from the Department 

of Homeland Security

Page 110 GAO-07-729 Aviation Security 
Appendix VI: 

A

GAO Contacts and Staff 

cknowledgments 

Page 111 GAO-07-729

Appendix VI: GAO Contacts and Staff 

Acknowledgments 

Cathleen A. Berrick, (202) 512-3404 or berrickc@gao.gov 

In addition to the person named above, Maria Strudwick, Assistant 

Director; Amy Bernstein; Kristy Brown; Alisha Chugh; Emily Hanawalt; 

Christopher Jones; Stanley Kostyla; Kyle Lamborn; Thomas Lombardi; 

Jeremy Manion; and Linda Miller made key contributions to this report. 

GAO Contacts 

Acknowledgments 

Aviation Security 
Related Products

Page 112 GAO-07-729

Related Products 

Aviation Security: Federal Efforts to Secure U.S.-Bound Air Cargo Are 

in the Early Stages and Could Be Strengthened. GAO-07-660. Washington, 

D.C.: April 30, 2007. 

Aviation Security: TSA's Change to its Prohibited Items List Has Not 

Resulted in Any Reported Public Safety Incidents, but the Impact of the 

Change on Screening Operations is Uncertain. GAO-07-623R.

Washington, D.C.: April 25, 2007. 

Aviation Security: Risk, Experience, and Customer Service Drive 

Changes to Airline Passenger Screening Procedures, but Evaluation and 

Documentation of Proposed Changes Could Be Improved. GAO-07-634. 

Washington, D.C.: April 16, 2007.

Aviation Security: TSA’s Staffing Allocation Model Is Useful for 

Allocating Staff among Airports, but Its Assumptions Should Be 

Systematically Reassessed. GAO-07-299. Washington, D.C.: Feb. 28, 2007.

Aviation Security: Progress Made in Systematic Planning to Guide Key

Investment Decisions, but More Work Remains. GAO-07-448T. 

Washington, D.C.: Feb. 13, 2007. 

Aviation Security: TSA Oversight of Checked Baggage Screening 

Procedures Could Be Strengthened. GAO-06-869. Washington, D.C.: 

Jul. 28, 2006.

Aviation Security: TSA Has Strengthened Efforts to Plan for the Optimal 

Deployment of Checked Baggage Screening Systems but Funding 

Uncertainties Remain. GAO-06-875T. Washington, D.C.: June 29, 2006. 

Aviation Security: Management Challenges Remain for the 

Transportation Security Administration’s Secure Flight Program. 

GAO-06-864T. Washington, D.C.: June 14, 2006. 

Aviation Security: Further Study of Safety and Effectiveness and Better

Management Controls Needed if Air Carriers Resume Interest in 

Deploying Less than Lethal Weapons. GAO-06-475. Washington, D.C.: 

May 26, 2006. 

Aviation Security: Enhancements Made in Passenger and Checked 

Baggage Screening, but Challenges Remain. GAO-06-371T. Washington,

D.C.: Apr. 4, 2006. 

Aviation Security 
Related Products 

Aviation Security: Transportation Security Administration Has Made

Progress in Managing a Federal Security Workforce and Ensuring 

Security at U.S. Airports, but Challenges Remain. GAO-06-597T. 

Washington, D.C.: Apr. 4, 2006. 

Aviation Security: Progress Made to Set Up Program Using PrivateSector Airport Screeners, but More Work Remains. GAO-06-166. 

Washington, D.C.: Mar. 31, 2006. 

Aviation Security: Significant Management Challenges May Adversely 

Affect Implementation of the Transportation Security Administration’s 

Secure Flight Program. GAO-06-374T. Washington, D.C.: Feb. 9, 2006. 

Aviation Security: Federal Air Marshal Service Could Benefit from 

Improved Planning and Controls. GAO-06-203. Washington, D.C.: 

Nov. 28, 2005. 

Aviation Security: Federal Action Needed to Strengthen Domestic Air 

Cargo Security. GAO-06-76. Washington, D.C.: Oct. 17, 2005. 

Transportation Security Administration: More Clarity on the Authority 

of Federal Security Directors Is Needed. GAO-05-935. Washington, D.C.: 

Sept. 23, 2005. 

Aviation Security: Flight and Cabin Crew Member Security Training 

Strengthened, but Better Planning and Internal Controls Needed. 

GAO-05-781. Washington, D.C.: Sept. 6, 2005. 

Aviation Security: Transportation Security Administration Did Not 

Fully Disclose Uses of Personal Information During Secure Flight 

Program Testing in Initial Privacy Notes, but Has Recently Taken Steps

to More Fully Inform the Public. GAO-05-864R. Washington, D.C.: 

July 22, 2005.

Aviation Security: Better Planning Needed to Optimize Deployment of 

Checked Baggage Screening Systems. GAO-05-896T. Washington, D.C.: 

July 13, 2005.

Aviation Security: Screener Training and Performance Measurement 

Strengthened, but More Work Remains. GAO-05-457. Washington, D.C.: 

May 2, 2005.

Page 113 GAO-07-729 Aviation Security 
Related Products 

Aviation Security: Secure Flight Development and Testing Under Way, 

but Risks Should Be Managed as System Is Further Developed. 

GAO-05-356. Washington, D.C.: Mar. 28, 2005. 

Aviation Security: Systematic Planning Needed to Optimize the 

Deployment of Checked Baggage Screening Systems. GAO-05-365. 

Washington, D.C.: Mar. 15, 2005. 

Aviation Security: Measures for Testing the Effect of Using Commercial

Data for the Secure Flight Program. GAO-05-324. Washington, D.C.: 

Feb.23, 2005. 

Transportation Security: Systematic Planning Needed to Optimize 

Resources. GAO-05-357T. Washington, D.C.: Feb.15, 2005. 

Aviation Security: Preliminary Observations on TSA’s Progress to Allow 

Airports to Use Private Passenger and Baggage Screening Services. 

GAO-05-126. Washington, D.C.: Nov.19, 2004. 

General Aviation Security: Increased Federal Oversight Is Needed, but 

Continued Partnership with the Private Sector Is Critical to Long-Term 

Success. GAO-05-144. Washington, D.C.: Nov. 10, 2004. 

Aviation Security: Further Steps Needed to Strengthen the Security of 

Commercial Airport Perimeters and Access Controls. GAO-04-728. 

Washington, D.C.: Jun. 4, 2004. 

Transportation Security Administration: High-Level Attention Needed 

to Strengthen Acquisition Function. GAO-04-544. Washington, D.C.: May 

28, 2004. 

Aviation Security: Challenges in Using Biometric Technologies. 

GAO-04-785T. Washington, D.C.: May 19, 2004. 

Nonproliferation: Further Improvements Needed in U.S. Efforts to 

Counter Threats from Man-Portable Air Defense Systems. GAO-04-519. 

Washington, D.C.: May 13, 2004. 

Aviation Security: Private Screening Contractors Have Little Flexibility 

to Implement Innovative Approaches. GAO-04-505T. Washington, D.C.: 

Apr. 22, 2004. 

Page 114 GAO-07-729 Aviation Security 
Related Products 

Aviation Security: Improvement Still Needed in Federal Aviation 

Security Efforts. GAO-04-592T. Washington, D.C.: Mar. 30, 2004. 

Aviation Security: Challenges Delay Implementation of ComputerAssisted Passenger Prescreening System. GAO-04-504T. Washington, D.C.: 

Mar. 17, 2004. 

Aviation Security: Factors Could Limit the Effectiveness of the 

Transportation Security Administration’s Efforts to Secure Aerial 

Advertising Operations. GAO-04-499R. Washington, D.C.: Mar. 5, 2004. 

Aviation Security: Computer-Assisted Passenger Prescreening System 

Faces Significant Implementation Challenges. GAO-04-385. Washington, 

D.C.: Feb. 13, 2004. 

Aviation Security: Challenges Exist in Stabilizing and Enhancing 

Passenger and Baggage Screening Operations. GAO-04-440T. Washington,

D.C.: Feb. 12, 2004. 

The Department of Homeland Security Needs to Fully Adopt a 

Knowledge-based Approach to Its Counter-MANPADS Development 

Program. GAO-04-341R. Washington, D.C.: Jan. 30, 2004. 

Aviation Security: Efforts to Measure Effectiveness and Strengthen 

Security Programs. GAO-04-285T. Washington, D.C.: Nov. 20, 2003. 

Aviation Security: Federal Air Marshal Service Is Addressing Challenges 

of Its Expanded Mission and Workforce, but Additional Actions Needed. 

GAO-04-242. Washington, D.C.: Nov. 19, 2003. 

Aviation Security: Efforts to Measure Effectiveness and Address 

Challenges. GAO-04-232T. Washington, D.C.: Nov. 5, 2003. 

Airport Passenger Screening: Preliminary Observations on Progress 

Made and Challenges Remaining. GAO-03-1173. Washington, D.C.: Sept. 

24, 2003. 

Aviation Security: Progress since September 11, 2001, and the 

Challenges Ahead. GAO-03-1150T. Washington, D.C.: Sept. 9, 2003. 

Transportation Security: Federal Action Needed to Enhance Security 

Efforts. GAO-03-1154T. Washington, D.C.: Sept. 9, 2003. 

Page 115 GAO-07-729 Aviation Security 
Related Products 

Transportation Security: Federal Action Needed to Help Address 

Security Challenges. GAO-03-843. Washington, D.C.: Jun. 30, 2003. 

Federal Aviation Administration: Reauthorization Provides 

Opportunities to Address Key Agency Challenges. GAO-03-653T. 

Washington, D.C.: Apr. 10, 2003. 

Transportation Security: Post-September 11th Initiatives and LongTerm Challenges. GAO-03-616T. Washington, D.C.: Apr. 1, 2003. 

Airport Finance: Past Funding Levels May Not Be Sufficient to Cover 

Airports’ Planned Capital Development. GAO-03-497T. Washington, D.C.: 

Feb. 25, 2003. 

Transportation Security Administration: Actions and Plans to Build a 

Results-Oriented Culture. GAO-03-190. Washington, D.C.: Jan. 17, 2003. 

Aviation Safety: Undeclared Air Shipments of Dangerous Goods and 

DOT’s Enforcement Approach. GAO-03-22. Washington, D.C.: Jan. 10, 

2003. 

Aviation Security: Vulnerabilities and Potential Improvements for the 

Air Cargo System. GAO-03-344. Washington, D.C.: Dec. 20, 2002. 

Aviation Security: Registered Traveler Program Policy and 

Implementation Issues. GAO-03-253. Washington, D.C.: Nov. 22, 2002. 

Airport Finance: Using Airport Grant Funds for Security Projects Has 

Affected Some Development Projects. GAO-03-27. Washington, D.C.: Oct. 

15, 2002. 

Commercial Aviation: Financial Condition and Industry Responses 

Affect Competition. GAO-03-171T. Washington, D.C.: Oct. 2, 2002. 

Aviation Security: Transportation Security Administration Faces 

Immediate and Long-Term Challenges. GAO-02-971T. Washington, D.C.: 

Jul. 25, 2002.

Aviation Security: Information Concerning the Arming of Commercial

Pilots. GAO-02-822R. Washington, D.C.: Jun. 28, 2002. 

Page 116 GAO-07-729 Aviation Security 
Related Products 

Aviation Security: Vulnerabilities in, and Alternatives for, Preboard 

Screening Security Operations. GAO-01-1171T. Washington, D.C.: Sept. 

25, 2001. 

Aviation Security: Weaknesses in Airport Security and Options for 

Assigning Screening Responsibilities. GAO-01-1165T. Washington, D.C.: 

Sept. 21, 2001. 

Homeland Security: A Framework for Addressing the Nation’s 

Efforts. GAO-01-1158T. Washington, D.C.: Sept. 21, 2001. 

Aviation Security: Terrorist Acts Demonstrate Urgent Need to Improve 

Security at the Nation’s Airports. GAO-01-1162T. Washington, D.C.: Sept. 

20, 2001. 

Aviation Security: Terrorist Acts Illustrate Severe Weaknesses in 

Aviation Security. GAO-01-1166T. Washington, D.C.: Sept. 20, 2001. 

(440454) Page 117 GAO-07-729 Aviation Security 
GAO’s Mission The Government Accountability Office, the audit, evaluation and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “Subscribe to Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, D.C. 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Gloria Jarmon, Managing Director, JarmonG@gao.gov (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, D.C. 20548 

Paul Anderson, Managing Director, AndersonP1@gao.gov (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Mail or Phone 

To Report Fraud,

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER