United States Government Accountability Office

GAO Report to Congressional Requesters

AVIATION SECURITY

Federal Efforts to 

Secure U.S.-Bound Air 

Cargo Are in the Early 

Stages and Could Be 

Strengthened 

April 2007 

 

GAO-07-660
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

April 2007

AVIATION SECURITY

Federal Efforts to Secure U.S.-Bound Air 

Cargo Are in the Early Stages and Could 

Be Strengthened 

Highlights of GAO-07-660, a report to 

congressional requesters 

The Department of Homeland 

Security (DHS) has primary 

responsibility for securing air 

cargo transported into the United 

States from another country, 

referred to as inbound air cargo, 

and preventing implements of 

terrorism from entering the 

country. GAO examined (1) what 

actions DHS has taken to secure 

inbound air cargo, and how, if at 

all, these efforts could be 

strengthened; and (2) what 

practices the air cargo industry 

and foreign governments have 

adopted that could enhance 

DHS’s efforts to strengthen 

inbound air cargo security, and to 

what extent DHS has worked 

with foreign governments to 

enhance their air cargo security 

efforts. To conduct this study, 

GAO reviewed relevant DHS 

documents, interviewed DHS 

officials, and conducted site visits 

to seven countries in Europe and 

Asia. 

What GAO Recommends

GAO recommends that DHS 

develop a risk-based inbound air 

cargo security strategy; develop a 

systematic process to improve 

interagency communication; and 

analyze air cargo security

practices used by air cargo

industry stakeholders and foreign 

governments to determine their 

applicability to the United States. 

DHS generally concurred with 

GAO’s recommendations. 

However, we have concerns that 

DHS’s plans may not fully address 

our recommendations. 

Within DHS, the Transportation Security Administration (TSA) and U.S. 

Customs and Border Protection (CBP) have taken a number of actions 

designed to secure inbound air cargo, but these efforts are still largely in the 

early stages and could be strengthened. For instance, TSA completed a riskbased strategic plan to address domestic air cargo security, but has not 

developed a similar strategy for addressing inbound air cargo security, 

including how best to partner with CBP and international air cargo 

stakeholders. In addition, while TSA has identified the primary threats to 

inbound air cargo, it has not yet assessed inbound air cargo vulnerabilities 

and critical assets. Moreover, TSA’s air cargo security rule incorporated a 

number of provisions aimed at enhancing the security of inbound air cargo. 

This final rule also acknowledges that TSA amended its security directives 

and programs to triple the percentage of cargo inspected on domestic and 

foreign passenger aircraft. However, TSA continues to exempt certain types 

of inbound air cargo transported on passenger air carriers from inspection. 

Further, TSA inspects domestic and foreign passenger air carriers with 

service to the United States to assess whether they are complying with air 

cargo security requirements, but currently does not conduct compliance 

inspections of all air carriers transporting inbound air cargo. Moreover, TSA 

has not developed performance goals and measures to determine to what 

extent air carriers are complying with security requirements. In addition, 

CBP recently began targeting inbound air cargo transported on passenger 

and all-cargo aircraft that may pose a security risk and inspecting such cargo 

once it arrives in the United States. TSA and CBP, however, do not have a 

systematic process in place to share information that could be used to 

strengthen the department’s efforts in securing inbound air cargo, such as 

the results of TSA air carrier compliance inspections and foreign airport 

assessments.

The air cargo industry and foreign governments have implemented various 

security practices that could provide opportunities for strengthening DHS’s 

overall air cargo security program. TSA officials acknowledged that 

compiling and analyzing security practices implemented by foreign air cargo 

stakeholders and foreign governments may provide opportunities to enhance 

U.S. air cargo security, and have begun an initial review of practices in select

foreign countries. TSA has also begun working with foreign governments to 

coordinate security practices to enhance security and improve oversight, 

referred to as harmonization, but these efforts may be challenging to 

implement. For example, some foreign countries do not share the United 

States’ view regarding air cargo security threats and risks, which may make

the harmonization of air cargo security practices difficult to achieve. 

www.gao.gov/cgi-bin/getrpt?GAO-07-660. 

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 6 

Background 10

DHS Has Taken Initial Steps to Secure Inbound Air Cargo, and 

Opportunities Exist to Strengthen These Efforts 25 

Foreign Air Cargo Security Practices and International 

Harmonization Efforts Have Potential to Enhance Air Cargo 

Security, but May Be Challenging to Implement 48 

Conclusions 64

Recommendations for Executive Action 66 

Agency Comments and Our Evaluation 67 

Appendix I Objectives, Scope, and Methodology 73 

Appendix II TSA’s Efforts to Assess Air Carrier Compliance with 

Inbound Air Cargo Security Requirements 77 

Appendix III TSA’s Assessments of Foreign Airport Security 

Procedures 80 

Appendix IV Description of GAO’s Risk Management Framework 82 

Appendix V DHS and TSA Air Cargo Security Technology 

Pilot Tests 84 

Appendix VI Actions Taken by Select Domestic Air Carriers with 

Operations Overseas and Foreign Air Cargo Industry 

Stakeholders to Secure Air Cargo 89 

Page i GAO-07-660 Aviation Security
Appendix VII Actions We Identified That Select Foreign 

Governments Are Taking to Secure Air Cargo 92 

Appendix VIII Comments from the Department of Homeland 

Security 94 

Appendix IX GAO Contact and Staff Acknowledgments 101 

Table 

Table 1: Elements of a Typical Homeland Security Risk Assessment 83 

Figures 

Figure 1: Flow of Air Cargo Transported to the United States 11 

Figure 2: Type of X-ray Technology Used by Some Foreign Air 

Carriers to Inspect Air Cargo Bound for the United States 15 

Figure 3: CBP Officers Using Nonintrusive Technology to Inspect 

Inbound Air Cargo 19 

Figure 4: Inspections of Air Carrier Cargo Procedures Conducted 

from January 2004 to December 2005 78 

Figure 5: Air Cargo Security Violations Found during Inbound 

Passenger Air Carrier Inspections at Foreign Airports for 

the Period July 2003 to February 2006 79 

Figure 6: Risk Management Cycle 82 

Page ii GAO-07-660 Aviation Security
Abbreviations 

ACISP All-Cargo International Security Program 

AOSSP Aircraft Operator Standard Security Program 

ATS Automated Targeting System 

ATSA Aviation and Transportation Security Act 

CBP Customs and Border Protection 

CBSA Canadian Border Services Agency 

C-TPAT Customs-Trade Partnership Against Terrorism 

DHS Department of Homeland Security 

EDS explosive detection system 

ETD explosive trace detection 

FACAOSSP Full All-Cargo Aircraft Operator 

Standard Security Program 

GPRA Government Performance and Results Act 

HSPD Homeland Security Presidential Directive 

IAC indirect air carrier 

IATA International Air Transport Association 

ICAO International Civil Aviation Organization 

MSP Model Security Program 

NIPP National Infrastructure Protection Plan 

PARIS Performance and Results Information System 

PFNA pulsed fast neutron analysis 

RASCO Remote Air Sampling for Canine Olfaction 

RFID radio frequency identification 

S&T Directorate of Science and Technology 

SIDA secure identification display area

TSA Transportation Security Administration 

TSIS Transportation Security Intelligence Service 

VACIS vehicle and cargo inspection system 

WCO World Customs Organization 

WMD weapon of mass destruction 

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

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Page iii GAO-07-660 Aviation Security
United States Government Accountability Office

Washington, DC 20548 

April 30, 2007

Congressional Requesters

Recent instances of human stowaways hiding in cargo holds on 

international flights bound for the United States, and cargo smuggling and 

theft at foreign cargo facilities, have heightened concern over the security 

of air cargo by revealing vulnerabilities that could be exploited by 

terrorists. According to Department of Homeland Security (DHS) officials 

and air cargo industry stakeholders, terrorists could exploit such 

vulnerabilities to introduce an explosive device in cargo transported 

onboard a passenger aircraft, hijack an all-cargo aircraft and use it as a 

missile, or smuggle a weapon of mass destruction (WMD) in cargo 

transported on either type of aircraft.1

 While DHS reports that it has no 

specific intelligence indicating terrorist plans to exploit air cargo 

vulnerabilities, DHS’s National Strategy for Transportation Security 

identifies cargo aircraft operations and high-volume cargo facilities as 

aviation assets at significant risk of terrorist attack.2

In response to the terrorist attacks of September 11, 2001, the Aviation and 

Transportation Security Act was enacted in November 2001, which created 

the Transportation Security Administration (TSA) and required it to 

provide for the screening of all passengers and property, including cargo, 

U.S. mail, and carry-on and checked baggage that is transported onboard 

passenger aircraft.3 It also required that a system be put into place as soon 

as practicable to screen, inspect, or otherwise ensure the security of cargo

 1

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

devices. For the purposes of this report, the term “weapon of mass destruction” also

encompasses weapons of mass effect or scenarios that could result in a great loss of life 

and destruction. 

2

DHS and Department of Transportation, National Strategy for Transportation Security, 

2005. Other aviation assets identified as being at significant risk of terrorist attack include

passenger aircraft operations, major and midsized airport facilities, general aviation 

aircraft operations and airports/airfields near major urban areas, and critical national 

airspace system infrastructure. DHS is required to update its National Strategy for 

Transportation Security, and planned to update it for submission to Congress by the end of 

2006, and every 2 years thereafter. However as of February 2007 it had not been updated. 

3

Aviation and Transportation Security Act, Pub. L. No. 107-71, 115 Stat. 597 (2001). See 49

U.S.C. §§ 114(a), 44901(a). 

Page 1 GAO-07-660 Aviation Security
transported on all-cargo aircraft.4

 The act applies to air cargo transported 

into the United States from foreign countries onboard passenger and allcargo aircraft, as well as cargo transported domestically and out of the 

United States to a foreign location on these aircraft. 

Within DHS, two agencies have responsibilities related to the security of 

air cargo bound for the United States from a foreign country, referred to as 

inbound air cargo.5

 TSA has primary responsibility for securing U.S.-bound 

flights from destruction or hijacking, and as a result, is primarily 

concerned with preventing the illicit loading of explosives or stowaways 

onto aircraft prior to departure for the United States. TSA enforces 

statutory and regulatory requirements on passenger and all-cargo air 

carriers to secure air cargo bound for the United States. Both domestic air 

carriers and foreign air carriers with service to the United States are 

responsible for implementing security requirements, such as inspecting a 

portion of air cargo transported to the United States, in accordance with 

the applicable laws, TSA regulations, security directives, emergency 

amendments, and security programs. DHS’s U.S. Customs and Border 

Protection (CBP) has primary responsibility for preventing terrorists and 

implements of terrorism from entering the United States. Specifically, CBP

screens and inspects international air cargo upon its arrival in the United 

States to ensure that cargo entering the country complies with applicable

laws and does not pose a security risk.6

 CBP’s efforts include analyzing 

 4

The terms “inspecting” and “screening” have been used interchangeably by TSA to denote 

some level of examination of a person or good, which can entail a number of different 

actions, including manual physical inspections to ensure that cargo does not contain 

weapons, explosives, or stowaways, or inspections using nonintrusive technologies that do

not require the cargo to be opened in order to be inspected. For the purposes of this report,

the term “screening” is used when referring to TSA or CBP efforts to apply a filter to 

analyze cargo related information to identify cargo shipment characteristics or anomalies 

for security risks. Moreover, for the purposes of this report, we use the term “inspection” to 

refer only to air carrier, TSA, or CBP efforts to examine air cargo through physical searches 

and the use of nonintrusive technologies.

5

Cargo transported by air within the United States is referred to as domestic air cargo, and 

cargo transported by air from the United States to a foreign location is referred to as 

outbound air cargo. 

6

CBP aids in the enforcement of law and regulations of non-DHS agencies. For example,

CBP regulates the entry of sugar into the United States. (see 7 U.S.C. §§ 3601-04, pertaining

to the U.S. Department of Agriculture), assists in the enforcement of the Bank Secrecy Act 

(see 12 U.S.C. §§ 1951-59, pertaining to the U.S. Department of the Treasury), and aids in

the enforcement of regulations related to safety standards for the transportation of

hazardous materials (see 49 U.S.C. §§ 5101-28, pertaining to the U.S. Department of

Transportation). 

Page 2 GAO-07-660 Aviation Security
information on cargo shipments to identify high-risk air cargo arriving in 

the United States that may contain terrorists or weapons of mass 

destruction, commonly known as targeting, and physically inspecting this

cargo upon its arrival.7

 According to DHS and industry estimates, only a 

small percentage of the air cargo that is bound for the United States from a 

foreign country is inspected by passenger and all-cargo air carriers prior to 

an aircraft’s departure for the United States, and a very small percentage

of international air cargo is inspected by CBP officers upon its arrival in 

the United States.8

 Congress has allocated at least $255 million from fiscal 

years 2005 through 2007 for the purpose of enhancing the security of air 

cargo, through such actions as the development and testing of new and 

existing inspection technologies. Further, several laws have required TSA 

to take additional steps to secure domestic, outbound, and inbound air 

cargo. For example, the Department of Homeland Security Appropriations 

Act of 2005 required the Secretary to amend security directives and 

programs to, at a minimum, triple the percentage of cargo inspected on

passenger aircraft.9

 In addition, the Intelligence Reform and Terrorism 

Prevention Act of 2004 required, among other things, that TSA develop 

technology to better identify, track, and screen air cargo, and issue a final 

rule to enhance and improve the security of air cargo transported on both

passenger and all-cargo aircraft.10

In October 2005, we reported on TSA’s efforts to secure domestic air 

cargo, or cargo transported on passenger and all-cargo aircraft within the 

United States.

11 We reported that while TSA had taken a number of actions

intended to strengthen air cargo security, such as establishing a 

centralized database on people and businesses that routinely ship air 

cargo within the United States, and implementing requirements for the 

random inspection of air cargo, factors existed that potentially limited 

their effectiveness. For example, TSA exempted certain types of air cargo 

from inspection, potentially creating security weaknesses. We also 

 7

In this report, the term “targeting” refers to the use of information obtained from the

screening process to identify high-risk air cargo shipments for inspection.

8

DHS determined that the exact percentage of air cargo physically screened or inspected is 

Sensitive Security Information. 

9

See Pub. L. No. 108-334, § 513, 118 Stat. 1298, 1317 (2004). 

10See Pub. L. No. 108-458, §§ 4051-54, 118 Stat. 3638, 3728-29 (2004). 

11GAO, Aviation Security: Federal Action Needed to Strengthen Domestic Air Cargo 

Security, GAO-06-76 (Washington, D.C.: October 2005). 

Page 3 GAO-07-660 Aviation Security
reported that TSA’s plans for enhancing air cargo security posed financial,

operational and technological challenges to both the agency and to air 

cargo industry stakeholders. In addition, we reported that while TSA had 

taken initial steps toward applying a risk-based approach to address air 

cargo security, it had not yet established a methodology and schedule for 

completing assessments of air cargo vulnerabilities and critical assets. 

Moreover, we reported on the potential challenges the agency and air 

cargo industry stakeholders may face in implementing measures to 

strengthen air cargo security. We made several recommendations to assist 

TSA in developing a comprehensive risk-based approach for securing the

domestic air cargo transportation system. TSA agreed with our 

recommendations and informed us that it is taking steps to address some

of these recommendations. For example, in October 2006, TSA revised 

some of the inspection exemptions for domestic and outbound air cargo 

transported on passenger air carriers, consistent with our 

recommendation. TSA also issued an air cargo security rule in May 2006 

that included a number of provisions aimed at enhancing the security of

inbound air cargo. 

This report provides the results of our examination of the efforts of DHS, 

through TSA and CBP, to secure inbound air cargo, and represents the 

second phase of our congressionally requested work addressing air cargo 

security.12 To help Congress evaluate the status of DHS’s efforts to secure 

inbound air cargo, we answered the following questions: (1) Within DHS, 

what actions have TSA and CBP taken to secure inbound air cargo, and 

how, if at all, could these efforts be strengthened? (2) What practices have

the air cargo industry and select foreign governments adopted that could 

potentially be used to enhance TSA’s efforts to strengthen inbound air 

cargo security, and to what extent have TSA and CBP worked with foreign 

governments to enhance their air cargo security efforts? 

To determine what actions DHS, through TSA and CBP, has taken to 

secure inbound air cargo, and how, if at all, these efforts could be 

strengthened, we reviewed relevant documents such as TSA’s air cargo 

strategic plan, air carrier security programs, and related TSA guidance to

 12The security of cargo transported from the United States to other countries, referred to as 

outbound air cargo, is subject to similar security requirements and procedures that apply to

domestic air cargo. Because these security measures were addressed in our October 2005 

report (GAO-06-76), they are not included in this report except in our discussion of how

foreign air cargo security measures could be considered for strengthening domestic air 

cargo. 

Page 4 GAO-07-660 Aviation Security
determine the requirements placed on air carriers for ensuring inbound air 

cargo security.13 We interviewed officials from DHS, TSA, and CBP 

regarding their efforts to develop a strategy for securing inbound air cargo 

and conduct assessments of the vulnerabilities and critical assets 

associated with this area of aviation security and compared these efforts 

with GAO’s risk management framework. In addition, we interviewed TSA 

and CBP officials to obtain information on their current and planned 

efforts to secure inbound air cargo. We also reviewed the results of TSA’s 

compliance inspections to determine the agency’s progress in evaluating 

air carriers’ compliance with air cargo security requirements, and we 

reviewed the results of foreign airport assessments to identify any 

deficiencies found related to international air cargo standards. We 

discussed the reliability of TSA’s compliance inspection data for the 

period July 2003 to February 2006 with TSA officials and concluded that 

they were sufficiently reliable for the purposes of this review. We 

conducted site visits to three U.S. airports, which collectively receive 

about 50 percent of the total amount of air cargo transported into the 

United States, to observe inbound air cargo security operations and CBP 

efforts to inspect inbound air cargo. We selected these airports based on 

several factors, including airport size, the volume of air cargo transported 

to these airports from foreign locations, and geographical dispersion. 

Because we selected a nonprobability sample of airports, the results from 

these visits cannot be generalized to other U.S. airports. Further, we 

conducted site visits to seven countries in Europe and Asia to observe air 

cargo security processes and technologies, observe air cargo facilities, and 

obtain information on air cargo security practices implemented by foreign 

governments and industry stakeholders to identify those practices that 

could potentially enhance the department’s efforts to secure air cargo.14

We selected these countries based on several factors, including TSA threat

rankings, airports located within these countries that process high 

volumes of air cargo, and discussions with U.S. and foreign government 

officials and air cargo industry representatives regarding air cargo security

practices that may have application to TSA’s efforts to secure air cargo.

Moreover, we observed air cargo security practices at 8 foreign airports, 

4 of which rank among the world’s 10 busiest cargo airports in terms of 

 13“Air carriers” refers to both foreign and U.S.-based passenger air carriers whose aircraft

have been configured to accommodate both passengers and cargo, and all-cargo carriers 

whose aircraft transport only cargo. 

14For the purposes of this report, the term “air cargo security practices” collectively refers 

to requirements, standards, processes, and measures aimed at securing air cargo. 

Page 5 GAO-07-660 Aviation Security
volumes of cargo transported. We also obtained information on the air 

cargo security requirements implemented by 10 additional foreign 

countries from foreign government officials and publicly available 

documents. We selected these countries based on geographical dispersion 

as well as additional stakeholder input on countries implementing air 

cargo security practices that differ from those in the United States. To 

obtain information on air cargo industry and foreign government actions 

to secure air cargo, and TSA’s and CBP’s efforts to coordinate their 

security practices to enhance security and increase efficiency, referred to 

as harmonization, we interviewed foreign and domestic air carrier 

(passenger and all-cargo) officials from those air carriers that transport 

the largest volume of air cargo. Specifically, we spoke with officials 

representing 7 of the top 10 air cargo carriers based on volume of cargo

transported. We also interviewed representatives of foreign freight 

forwarders foreign and domestic airport authorities, air cargo industry 

associations, and U.S. and foreign governments.15 More detailed 

information on our scope and methodology is contained in appendix I. 

We conducted our work from October 2005 through February 2007 in 

accordance with generally accepted government auditing standards. 

The two DHS components with responsibilities related to air cargo 

security, TSA and CBP, have taken initial steps to enhance the security of 

inbound air cargo. However, the agencies are only beginning to implement 

inbound air cargo security programs,and opportunities exist to strengthen

these efforts. TSA and CBP have taken some preliminary steps to use risk 

management principles to guide their investment decisions related to 

inbound air cargo, as advocated by DHS, but most of these efforts are in 

the planning stages. For instance, TSA completed a risk-based strategic 

plan to address domestic air cargo security, but has not developed a 

similar strategy for addressing inbound air cargo security, including how 

best to partner with CBP and international air cargo stakeholders. Further, 

TSA has identified the primary threats associated with inbound air cargo,

but has not yet assessed which areas of inbound air cargo are most 

vulnerable to attack and which inbound air cargo assets are deemed most 

critical to protect. TSA plans to assess inbound air cargo vulnerabilities 

and critical assets—two crucial elements of a risk-based management 

Results in Brief 

 15A freight forwarder is an entity that consolidates air cargo shipments and delivers them to 

air carriers. 

Page 6 GAO-07-660 Aviation Security
approach—but has not yet established a methodology or time frame for 

how and when these assessments will be completed. Without such 

assessments, TSA may not be able to appropriately focus its resources on 

the most critical security needs. 

Another action TSA has taken is the issuance of its May 2006 air cargo 

security rule, which includes a number of provisions aimed at enhancing 

the security of inbound air cargo. For example, the final rule 

acknowledges that TSA amended its security directives and programs to 

triple the percentage of cargo inspected on domestic and foreign 

passenger aircraft. To implement the requirements contained in the air 

cargo security rule, TSA drafted revisions to its existing security programs 

for domestic and foreign passenger air carriers and created new security 

programs for domestic and foreign all-cargo carriers. However, TSA 

requirements continue to allow inspection exemptions for certain types of

inbound air cargo transported on passenger air carriers.16 This risk is 

further heightened because TSA has limited information on the 

background and security risk posed by foreign shippers whose cargo may 

fall within these exemptions. TSA officials stated that the agency is 

holding discussions with industry stakeholders to determine whether 

additional revisions to current air cargo inspection exemptions are 

needed. TSA also inspects domestic and foreign passenger air carriers 

with service to the United States to assess whether the air carriers are 

complying with air cargo security requirements, such as inspecting a 

certain percentage of air cargo. TSA, however, does not currently inspect 

all air carriers transporting cargo into the United States. While TSA’s 

compliance inspections provide useful information, the agency has not 

developed an inspection plan that includes performance goals and 

measures to determine to what extent air carriers are complying with 

security requirements. 

In addition, while CBP was previously targeting inbound air cargo on 

passenger and all-cargo aircraft for illicit items such as drugs and 

contraband, CBP has only recently begun targeting inbound air cargo 

transported on passenger and all-cargo aircraft that may pose a security 

risk and inspecting such cargo once it arrives in the United States. Further, 

TSA and CBP have taken steps to coordinate their efforts to safeguard air 

 16DHS determined that details on the types of inbound air cargo transported on passenger 

and all-cargo aircraft exempt from TSA inspection requirements are considered Sensitive 

Security Information. A description of these exemptions is provided in the restricted 

version of this report, GAO-07-337SU. 

Page 7 GAO-07-660 Aviation Security
cargo transported into the United States to include sharing information on 

TSA’s technology development programs, among other efforts. However, 

TSA and CBP do not have a systematic process in place to share 

information that could be used to strengthen their efforts, such as the 

results of TSA air carrier compliance inspections, assessments of foreign 

airports, and air carrier inspections of inbound air cargo. Without a 

systematic process to share relevant air cargo security information, TSA 

and CBP could be missing opportunities to more effectively secure 

inbound air cargo. 

Foreign governments that regulate airports with high volumes of cargo, 

and domestic and foreign air carriers that transport large volumes of 

cargo, employ various air cargo security practices that might have the 

potential to strengthen TSA’s efforts to secure inbound air cargo. Some of 

these practices may also help strengthen the security of domestic air 

cargo. We identified four categories of security practices required or 

employed by foreign governments and foreign air carriers, as well as 

domestic air carriers implementing practices required by host 

governments, that are currently not used in the United States. TSA officials 

acknowledged that the agency has not systematically analyzed these 

foreign practices to determine whether they would help strengthen the 

domestic and U.S.-bound air cargo supply chains or the costs associated 

with implementing such practices. For example, air carriers in some 

foreign counties inspect air cargo for potential WMDs prior to its loading 

on a U.S.-bound flight, which neither TSA nor CBP requires.17 TSA officials 

acknowledged that compiling and analyzing information on air cargo 

security practices implemented by foreign air carriers and foreign 

governments may provide opportunities to enhance the department’s air 

cargo security program, and they have begun an initial review of practices

in select countries. However, officials also cited challenges to applying 

these practices in the United States and the inbound air cargo supply 

chain. For example, TSA officials stated that increasing the percentage of

cargo inspections and utilizing various inspection technologies may not be 

applicable to the United States because the volume of air cargo processed 

in the United States is much larger than in most countries. While we 

recognize that differences in cargo volumes and inspection capabilities 

exist and could affect the feasibility and cost of implementing certain 

 17DHS determined that other examples of air carriers’ efforts to secure air cargo are 

Sensitive Security Information. Information on these examples is provided in the restricted

version of this report, GAO-07-337SU. 

Page 8 GAO-07-660 Aviation Security
practices to secure domestic and inbound air cargo, we believe that 

systematically identifying and evaluating the feasibility and costs 

associated with promising foreign air cargo security practices has the 

potential to benefit TSA’s efforts to secure domestic and inbound air 

cargo. TSA has also begun working with foreign governments to 

coordinate their security practices to enhance security and increase 

efficiency, referred to as harmonization. For example, TSA officials 

worked with foreign governments to develop internationally agreed upon 

standards for securing air cargo. However, challenges to harmonizing 

security practices may limit the effectiveness of these efforts. For 

instance, some countries may be hesitant to expend additional resources 

that may be necessary to implement common security standards that 

exceed their current security requirements. In addition, some foreign 

governments may have different views than TSA regarding the threats and 

risks associated with air cargo and where their resources should be 

directed. 

To better ensure the security of inbound air cargo, we are recommending 

that DHS direct TSA and CBP to take several actions. These include more 

fully developing a risk-based strategy to address inbound air cargo 

security, including establishing goals and objectives for securing inbound 

air cargo and establishing a methodology and time frames for completing 

assessments of inbound air cargo vulnerabilities and critical assets that 

can be used to help prioritize the actions necessary to enhance security; 

establishing a time frame for completing an assessment of whether 

existing inspection exemptions for inbound air cargo pose an 

unacceptable security vulnerability, and taking steps, if necessary, to 

address identified vulnerabilities; developing performance goals and 

measures to evaluate foreign and domestic air carrier compliance with 

inbound air cargo security requirements; developing a systematic process 

for ensuring communication between TSA and CBP regarding their efforts 

to secure inbound air cargo; and compiling and analyzing information on 

air cargo security practices implemented by domestic and foreign air cargo

industry stakeholders and foreign governments to identify those that could 

be used to strengthen DHS’s overall air cargo security program. 

We provided a draft of this report to DHS for review. DHS, in its written 

comments, generally concurred with the report and recommendations. 

However, we have concerns that the actions DHS intends to take may not 

fully address our recommendations. The full text of DHS’s comments is 

included in appendix VIII. 

Page 9 GAO-07-660 Aviation Security
The transportation of air cargo between global trading partners provides 

the world economy with critical goods and components. Air cargo valued

at almost $400 billion entered the United States in fiscal year 2004. 

According to TSA, approximately 200 U.S. and foreign air carriers 

currently transport cargo into the United States from foreign countries. 

During calendar year 2005, almost 9.4 billion pounds of cargo was shipped 

by air into the United States. About 40 percent of this amount, or 4 billion 

pounds, traveled onboard passenger aircraft. Typically, about one-half of 

the hulls of each passenger aircraft transporting cargo are filled with 

cargo. 

Background 

Air cargo includes freight and express packages that range in size from 

small to very large, and in type from perishables to machinery, and can 

include items such as electronic equipment, automobile parts, clothing,

medical supplies, other dry goods, fresh cut flowers, fresh seafood, fresh 

produce, tropical fish, and human remains. Cargo can be shipped in 

various forms, including large containers known as unit loading devices

that allow many packages to be consolidated into one container that can

be loaded on an aircraft, wooden crates, assembled pallets, or individually 

wrapped/boxed pieces, known as break bulk cargo. 

Participants in the international air cargo shipping process include 

shippers, such as individuals and manufacturers; freight forwarders or 

regulated agents, who consolidate shipments and deliver them to air 

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

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

store, load, and transport air cargo.18 International air cargo may have been

transported via ship, train, or truck prior to its loading onboard an aircraft. 

Shippers typically send cargo by air in one of two ways. Figure 1 depicts 

the two primary ways in which a shipper may send cargo by air to the 

United States. 

 18The International Civil Aviation Organization defines a regulated agent as an agent, freight

forwarder, or any other entity that conducts business with an aircraft operator and 

provides security controls that are accepted or required by the appropriate government

authority with respect to cargo or mail. 

Page 10 GAO-07-660 Aviation Security
Figure 1: Flow of Air Cargo Transported to the United States 

Source: GAO (analysis); MapArt (map); ArtExplosion and GAO (art). 

Consolidation facility

At a consolidation facility, 

air cargo is sorted and 

loaded onto trucks that 

take the cargo to an air 

carrier’s sorting center or, 

depending on its size, to 

the small-package receiving 

area at an air carrier’s 

ticket counter.

Shipper / manufacturer

A shipper may send 

air cargo by either of 

two ways.

Air carrier sorting center

At an air carrier's sorting

center, which is located at

the airport, either the air

carrier or cargo handling

agents sort and may inspect

cargo before it is loaded

onto aircraft. 

1 2

Cargo sent directly to airport 

sorting center

A shipper may directly 

package air cargo and 

deliver it to an air carrier’s 

sorting center. Cargo sent to freight 

forwarder or 

regulated agent

A shipper may bring air 

cargo to a freight forwarder 

or regulated agent, who, 

before delivering it to an air 

carrier's sorting center, may 

inspect the cargo and 

consolidate shipments from 

a number of shippers.

U.S.

EUROPE

ASIA

AFRICA

AUSTRALIA SOUTH AMERICA

NORTH AMERICA

Cargo Transported To U.S.

Cargo arrives in the U.S. and

gets unloaded from aircraft

and may be inspected before

it is permitted to be delivered

to its recipient.

A shipper may take its packages to a freight forwarder, or regulated agent,

which consolidates cargo from many shippers and delivers it to air 

Page 11 GAO-07-660 Aviation Security
carriers. The freight forwarder usually has cargo facilities at or near 

airports and uses trucks to deliver bulk freight to air carriers—either to a

cargo facility or to a small-package receiving area at the ticket counter. A 

shipper may also send freight by directly packaging and delivering it to an

air carrier’s ticket counter or sorting center where either the air carrier or 

a cargo handling agent will sort and load cargo onto the aircraft. The 

shipper may also have cargo picked up and delivered by an all-cargo 

carrier, or choose to take cargo directly to a carriers’ retail facility for 

delivery. As noted in figure 1, the inspections of air cargo can take place at 

several different points throughout the supply chain. For example, 

inspections can take place at freight forwarders or regulated agent’s 

consolidation facility, or at the air carrier’s sorting center. 

TSA and CBP 

Responsibilities for 

Ensuring the Security of 

Inbound Air Cargo 

The Aviation and Transportation Security Act (ATSA) charged TSA with 

the responsibility for ensuring the security of the nation’s transportation 

systems, including the transportation of cargo by air into the United 

States.19 In fulfilling this responsibility, TSA (1) enforces security 

requirements established by law and implemented through regulations, 

security directives, TSA-approved security programs, and emergency

amendments, covering domestic and foreign passenger and all-cargo 

carriers that transport cargo into the United States; (2) conducts 

inspections to assess air carriers’ compliance with established 

requirements and procedures; (3) conducts assessments at foreign airports 

to assess compliance with international aviation security standards, 

TSA’s Responsibilities Related 

to Securing Inbound Air Cargo 

 19Other federal entities involved in securing or safeguarding air cargo include the 

Department of Homeland Security–U.S. Customs and Border Protection, the United States

Postal Service, the Department of Commerce, the Department of Transportation, and the

Department of the Treasury. 

Page 12 GAO-07-660 Aviation Security
including those related to air cargo; and (4) conducts research and 

development of air cargo security technologies.20

Air carriers (passenger and all-cargo) are responsible for implementing 

TSA security requirements, predominantly through a TSA-approved 

security program that describes the security policies, procedures, and 

systems the air carrier will implement and maintain in order to comply 

with TSA security requirements.21 These requirements include measures 

related to the acceptance, handling, and inspection of cargo; training of 

employees in security and cargo inspection procedures; testing employee

proficiency in cargo inspection; and access to cargo areas and aircraft. If 

threat information or events indicate that additional security measures are 

needed to secure the aviation sector, TSA may issue revised or new 

security requirements in the form of security directives or emergency

amendments applicable to domestic or foreign air carriers. The air carriers 

must implement the requirements set forth in the security directives or 

emergency amendments in addition to those requirements already 

imposed and enforced by TSA. 

Under TSA regulations, the responsibility for inspecting air cargo is 

assigned to air carriers. TSA requirements, described in air carrier security 

programs, security directives, and emergency amendments, allow air 

carriers to use several methods and technologies to inspect domestic and 

inbound air cargo. These include manual physical searches and 

 20Foreign air carriers landing or taking off in the United States must adopt and use a 

TSA-approved security program that requires adherence to the identical security measures

required of U.S. air carriers serving the same airports. See 49 U.S.C. § 44906. TSA 

regulations provide that a foreign air carrier security program will only be deemed 

acceptable if it provides passengers a level of protection similar to the level of protection

provided by U.S. air carriers serving the same airports. See 49 C.F.R. § 1546.103(a)(1). For 

example, a foreign air carrier must prohibit cargo from being loaded on board its aircraft

unless handled in accordance with the foreign air carrier’s TSA-approved security program.

21As of January 2007, TSA security programs include the (1) Aircraft Operator Standard 

Security Program, which applies to domestic passenger air carriers; (2) Indirect Air Carrier 

Standard Security Program, which applies to domestic indirect air carriers; (3) Domestic 

Security Integration Program, a voluntary program that applies to domestic all-cargo 

carriers; (4) Twelve-Five Program, which applies to certain operators of aircraft weighing 

more than 12,500 pounds in scheduled or charter service that carry passengers, cargo, or

both; (5) Model Security Program, which applies to foreign passenger air carriers; and 

(6) All-Cargo International Security Procedures, which applies to each foreign air carrier 

engaged in the transportation of cargo to, from, within, or overflying the United States in

all-cargo aircraft with a maximum certified takeoff weight of more than 12,500 pounds. TSA 

drafted new security programs for foreign and U.S. all-cargo carriers with operations to, 

from, and within the United States. TSA expects to finalize these programs in early 2007. 

Page 13 GAO-07-660 Aviation Security
comparisons between airway bills and cargo contents to ensure that the 

contents of the cargo shipment matches the cargo identified in documents 

filed by the shipper, as well as using approved technology, such as X-ray 

systems, explosive trace detection systems, decompression chambers, 

explosive detection systems, and TSA explosives detection canine teams.22

(For an example of X-ray technology used by air carriers to inspect air 

cargo prior to its transportation to the United States, see fig. 2). TSA 

currently requires passenger air carriers to randomly inspect a specific 

percentage of non exempt air cargo pieces listed on each airway bill.23

Under TSA’s inbound air cargo inspection requirements, passenger air 

carriers can exempt certain cargo from inspection.24 TSA does not regulate 

foreign freight forwarders, or individuals or businesses that have their 

cargo shipped by air to the United States. 

 22Explosive trace detection (ETD) equipment requires human operators to collect samples

of items to be inspected with swabs, which are chemically analyzed to identify any traces 

of explosive material. Explosive detection systems use probing radiation to examine 

objects inside baggage and identify the characteristic signatures of threat explosives. 

Certified explosive detection canine teams have been evaluated by TSA and shown to

effectively detect explosive devices. Decompression chambers simulate the pressures 

acting on aircraft by simulating flight conditions, which cause explosives that are attached

to barometric fuses to detonate. 

23DHS determined that details on the percentage of air cargo required to be randomly 

inspected are considered Sensitive Security Information. Information on the percentage of

air cargo randomly inspected is provided in the restricted version of this report, 

GAO-07-337SU. 

24DHS determined that details on the types of inbound air cargo transported on passenger 

and all-cargo aircraft exempt from TSA inspection requirements are considered Sensitive 

Security Information. A description of these exemptions is provided in the restricted 

version of this report, GAO-07-337SU. 

Page 14 GAO-07-660 Aviation Security
Figure 2: Type of X-ray Technology Used by Some Foreign Air Carriers to Inspect 

Air Cargo Bound for the United States

Source: GAO.

To assess whether air carriers properly implement TSA inbound air cargo 

security regulations, the agency conducts regulatory compliance 

inspections of foreign and domestic air carriers at foreign airports. 

Currently, TSA conducts compliance inspections of domestic and foreign 

passenger carriers transporting cargo into the United States, but does not 

perform such inspections of all air carriers transporting inbound air cargo.

TSA inspects air cargo procedures as part of its broader international 

aviation security inspections program, which also includes reviews of 

regulations such as aircraft and passenger security. Compliance 

inspections can include reviews of documentation, interviews of air 

carrier personnel, and direct observations of air cargo operations.25 Air 

carriers are subject to inspection in several areas of cargo security, 

including accepting cargo from unknown shippers, access to cargo, and 

security training and testing. Appendix II contains a detailed description of 

 25Unlike its domestic air cargo inspection program, TSA’s inbound air cargo security 

program does not include a covert testing component to identify air cargo security 

weaknesses. TSA officials stated that foreign governments do not allow the agency to 

conduct such tests. 

Page 15 GAO-07-660 Aviation Security
TSA’s efforts to assess air carrier compliance with inbound air cargo 

security requirements. 

In addition, TSA assesses the effectiveness of the security measures 

maintained at foreign airports that serve U.S. air carriers, from which 

foreign air carriers serve the United States, or that pose a high risk of 

introducing danger to international air travel.26 To conduct its assessments, 

TSA must consult with appropriate foreign officials to establish a schedule 

to visit each of these foreign airports. TSA assessments evaluate the 

security policies and procedures in place at a foreign airport to ensure that 

the procedures meet baseline international aviation security standards, 

including air cargo security standards. For further information on TSA’s 

foreign airport assessments including the results of its assessment 

conducted during fiscal year 2005, see appendix III. 

CBP determines the admissibility of cargo entering the United States and 

is authorized to inspect inbound air cargo for security purposes. 

Specifically, CBP requires air carriers to submit cargo manifest 

information prior to the aircraft’s arrival in the United States.27 CBP also 

has authority to negotiate with foreign nations to place CBP officers 

abroad to inspect persons and merchandise prior to their arrival in, or 

subsequent to their exit from, the United States, but has not yet negotiated

arrangements with foreign host nations to station CBP officers overseas 

for the purpose of inspecting high-risk air cargo shipments.28 At U.S. 

airports, CBP officers may conduct searches of persons, vehicles, baggage, 

cargo, and merchandise entering or departing the United States.29 Since 

September 11, 2001, CBP’s priority mission has focused on keeping 

CBP’s Responsibilities Related 

to Inbound Air Cargo Security 

 2649 U.S.C. § 44907(a)(1). TSA assumed responsibility for conducting foreign airport 

assessments from the Secretary of Transportation (as delegated to the Federal Aviation 

Administration) in accordance with the Aviation and Transportation Security Act, enacted

in November 2001. See 49 U.S.C. § 114(d). TSA conducts these assessments utilizing a 

standard for analysis based, at least, on the standards and appropriate recommended 

practices of Annex 17 to the Convention on International Civil Aviation. § 44907(a)(2). The

Secretary of Homeland Security determines whether an airport maintains and carries out 

effective security measures using the results of TSA’s assessments. See § 44907(c). 

27See 19 C.F..R. § 122.48a (implementing a provision of the Trade Act of 2002, Pub. L. No.

107-210, § 343, 116 Stat. 933, 981-83, as amended, requiring the electronic submission of 

inbound cargo information prior to arrival in the United States). 

28See 19 U.S.C. § 1629. 

29See 19 U.S.C. §§ 482, 1467, 1499, 1581, and 1582. 

Page 16 GAO-07-660 Aviation Security
terrorists and their weapons from entering the United States.30 To carry out 

this responsibility, CBP employs several systems and programs. CBP’s 

Automated Targeting System (ATS) is a model that combines manifest and 

entry declaration information into shipment transactions and uses 

historical, specific enforcement, and other data to help target cargo 

shipments for inspection.31 ATS also has targeting rules that assign a risk 

score to each arriving shipment based in part on manifest information, as 

well as other shipment information, and potential threat or vulnerability 

information, which CBP staff use to make decisions on the extent of 

inspection to be conducted once the cargo enters the United States.32 To 

support its targeting system, CBP requires air carriers to submit cargo 

manifest information prior to the flight arriving in the United States.33 CBP

officers use the ATS risk scores to help them make decisions regarding the

extent of inspection to be conducted once the cargo arrives in the United

States.34 Shipments identified by CBP as high risk through its ATS targeting 

system are to undergo mandatory security inspections. CBP officers may 

 30Historically, CBP has been responsible for interdicting and seizing contraband and illegal 

drugs. CBP targets and inspects cargo on behalf of 16 other federal agencies, including the 

U.S. Dept. of Agriculture, the Food and Drug Administration, Bureau of Alcohol, Tobacco, 

Firearms and Explosives, and the Drug Enforcement Agency. 

31CBP defines an inspection as a physical examination and/or the imaging of cargo using 

non-intrusive inspection technology to identify contraband and terrorist-related items.

32DHS determined that details on the type of shipment information used by ATS to assign 

a risk score to air cargo shipments are considered Sensitive Security Information. A

description of the shipment information used by ATS is discussed in the restricted version

of this report, GAO-07-337SU.

33Pursuant to the Trade Act of 2002, as amended, CBP established time frames in which air

carriers are required to electronically submit air cargo manifest information. See 19 C.F.R.

§ 122.48a(b). Air carriers departing from any foreign location in the Americas, including

Mexico, Central America, and areas of South America north of the equator, must submit 

manifest information no later than the time of flight departure (the time at which wheels

are up on the aircraft and the aircraft is en route directly to the United States.). In the case 

of air carriers departing from any other foreign location, CBP requires that manifest

information be submitted 4 hours prior to the flight’s arrival in the United States. 

34Officers who are members of CBP’s Anti-terrorism Contraband Enforcement Teams

specialize in targeting and examining inbound air cargo shipments to identify potential 

contraband and terrorist-related items. 

Page 17 GAO-07-660 Aviation Security
also inspect air cargo if they determine that a particular shipment is 

suspicious or somehow poses a threat.35

CBP uses a variety of non intrusive technologies and methods to inspect 

some air cargo once it arrives in the United States. For example, CBP 

officers carry personal handheld radiation detectors, as well as handheld 

radioactive isotope identification devices which can distinguish between 

different types of radiological material, such as that used in medicine or 

industry from weapons-grade material. Other technologies and methods 

CBP uses to inspect inbound air cargo include mobile X-ray machines 

contained in vans, pallet X-ray systems, mobile vehicle and cargo 

inspection systems (VACIS), and canine teams.36 The results of the 

nonintrusive inspections determine the need for additional measures, 

which could include physical inspections conducted by CBP officers. 

Figure 3 shows an example of CBP officers using nonintrusive technology 

to inspect inbound air cargo upon its arrival in the United States. 

 35CBP also conducts inspections based on specific, usually classified, intelligence that

points to a specific threat and directs field officers in specific airports to take certain

actions. The results of field officer efforts may be analyzed and shared with the intelligence 

community. These inspections are not part of CBP’s routine efforts to address ongoing air 

cargo threats associated with the smuggling of contraband or WMD. 

36The pallet VACIS unit consists of a self-contained gamma ray imaging system designed to

quickly image pallets or pallet-sized containers. A mobile VACIS, similar to pallet VACIS 

unit consists of a truck-mounted, gamma ray imaging system that produces a radiographic

image used to evaluate the contents of trucks, containers, cargo, and passenger vehicles in 

order to determine the possible presence of contraband. 

Page 18 GAO-07-660 Aviation Security
Figure 3: CBP Officers Using Nonintrusive Technology to Inspect Inbound Air 

Cargo 

Mobile x-ray machines

Source: GAO.

To strengthen the security of the inbound cargo supply chain, the U.S. 

Customs Service (now CBP) initiated the voluntary Customs-Trade 

Partnership Against Terrorism (C-TPAT) program in November 2001. This 

program provides companies that implement CBP-defined security 

practices a reduced likelihood that their cargo will be inspected once it 

arrives in the United States.37 To become a member of C-TPAT, companies 

must first submit signed C-TPAT agreements affirming their desire to 

participate in the voluntary program. Companies must also provide CBP 

with security profiles that describe the current security procedures they 

have in place, such as pre-employment screening, periodic background 

reviews, and employee training on security awareness and procedures. 

 37The SAFE Port Act, enacted in October 2006, specifically authorized the Secretary of

Homeland Security, acting through the Commissioner of CBP, to establish the C-TPAT 

program in accordance with requirements set forth in the law. Security and Accountability

for Every (SAFE) Port Act of 2006, Pub. L. No. 109-347, §§ 211-223, 120 Stat. 1884, 

1909-15.

Page 19 GAO-07-660 Aviation Security
CBP reviews a company’s application to identify any weaknesses in the 

company’s security procedures and work with the company to resolve 

these weaknesses. Once any weaknesses are addressed, CBP signs an 

agreement stating that the company is considered to be a certified C-TPAT 

member, eligible for program benefits.

38

After certification, CBP has a process for validating that C-TPAT members 

have implemented security measures. During the validation process, CBP 

staff meet with company representatives to verify supply chain security 

measures. The validation process includes visits to the company’s U.S. and 

foreign sites, if any. Upon completion of the validation process, CBP 

reports back to the company on any identified areas that need

improvement and suggested corrective actions, as well as a determination 

of whether program benefits are still warranted for the company. 

According to CBP officials, they use a risk-based approach for identifying 

the priority in which C-TPAT participants should be validated.39 

International Air Cargo 

Security Standards and 

Recommended Practices 

The International Civil Aviation Organization (ICAO) is a specialized 

agency of the United Nations in charge of coordinating and regulating

international air transportation. ICAO was established by the Convention 

on International Civil Aviation (also known as the Chicago Convention) in

1944 and is composed of over 180 member nations with aviation service 

capabilities. In 1974, ICAO established aviation security standards and 

recommended practices to ensure a baseline level of security. These 

standards are aimed at preventing suspicious objects, weapons, 

explosives, or other dangerous devices from being placed on board 

passenger aircraft either through concealment, in otherwise legitimate 

shipments, or through gaining access to air cargo shipments via cargohandling areas. The standards call for member nations to implement 

measures to ensure the protection of air cargo being moved within an 

airport and intended for transport on an aircraft, and to ensure that 

aircraft operators do not accept cargo on passenger flights unless 

 38In May 2005, CBP began using a three-tiered approach in providing C-TPAT participants 

with benefits. Under this approach, air carriers’ benefits, including a reduction in their risk

score, increase based on (1) whether the carriers are certified,(2) whether they are

validated, and (3) whether they are implementing security requirements that exceed 

minimum guidelines. 

39DHS determined that details on the information CBP uses to prioritize which C-TPAT 

participants should be validated are Sensitive Security Information. A description of this

information is included in the restricted version of this report, GAO-07-337SU. 

Page 20 GAO-07-660 Aviation Security
application of security controls has been confirmed and accounted for by

a regulated agent or that such cargo has been subjected to appropriate 

security controls. ICAO standards also provide that except for reasons of 

aviation security, member states should not require the physical inspection 

of all air cargo that is imported or exported. In general, member states 

should apply risk management principles (such as targeting higher-risk 

cargo) to determine which goods should be examined and the extent of 

that examination. While compliance with these standards is voluntary, all 

180 ICAO members, including the United States, have committed to 

incorporating these standards into their national air cargo security 

programs.40 

The International Air Transport Association (IATA) represents about 

260 air carriers constituting 94 percent of international scheduled air 

traffic. Building upon ICAO’s standards, IATA issued voluntary 

recommended practices and guidelines to help ensure that global air cargo

security measures are uniform and operationally manageable. For 

example, IATA published a manual that, among other things, encourages 

air carriers to implement measures and procedures to prevent explosives 

or other dangerous devices from being accepted for transport by air, 

conduct pre-employment checks on individuals involved in the handling or 

inspection of air cargo, and ensure the security of all shipments accepted 

from persons other than known shippers41 or regulated agents through 

physical inspection or some type of screening process. IATA also 

developed guidelines to assist air carriers in developing security policies 

by providing detailed suggestions for accepting, handling, inspecting, 

storing, and transporting air cargo. 

The World Customs Organization (WCO) consists of 166 member nations, 

representing 99 percent of global trade, including cargo transported by air. 

 40Although adopting these standards is voluntary, in the sense that each contracting state 

signs onto the convention of its own accord, a state may face consequences for not

adopting and following the ICAO standards. For example, if a state does not amend its own 

regulations or practices in light of amendments to the ICAO standards, all other states will

be notified of the difference existing between the international standards and the 

corresponding national practice of the state. Similarly, TSA is authorized under U.S. law to

conduct foreign airport assessments using, at least, the ICAO standards and appropriate 

recommended practices to determine if the airport maintains and carries out effective 

security measures, and to take appropriate actions in the event the airport does not

maintain effective security measures. See 49 U.S.C. § 44907.

41A known shipper is an individual or business with an established history of shipping cargo

on passenger carriers. 

Page 21 GAO-07-660 Aviation Security
In June 2005, WCO established its Framework of Standards to Secure and 

Facilitate Global Trade that, among other things, sets forth principles and 

voluntary minimum security standards to be adopted by its members. The 

framework provides guidance for developing methods to target and 

inspect high-risk cargo, establishes time frames for the submission of 

information on cargo shipments, and identifies inspection technology that 

could be used to inspect high-risk cargo. 

Applying a Risk-Managed 

Approach for Securing 

Inbound Air Cargo 

Risk management is a tool for informing policy makers’ decisions about 

assessing risks, allocating resources, and taking actions under conditions 

of uncertainty. In recent years, the President, through Homeland Security 

Presidential Directives (HSPD), and Congress, more recently through the 

Intelligence Reform and Terrorism Prevention Act of 2004, required 

federal agencies with homeland security responsibilities to apply riskbased principles to inform their decision making regarding allocating 

limited resources and prioritizing security activities. The National 

Commission on Terrorist Attacks Upon the United States (also known as 

the 9/11 Commission), recommended that the U.S. government identify 

and evaluate the transportation assets that need to be protected, set riskbased priorities for defending them, select the most practical and costeffective ways of doing so, and then develop a plan, budget, and funding to

implement the effort.42 In addition, DHS issued the National Strategy for 

Transportation Security in 2005 that describes the policies DHS will apply 

when managing risks to the security of the U.S. transportation system.43

We have previously reported that a risk management approach can help to

prioritize and focus the programs designed to combat terrorism. As 

applied in the homeland security context, risk management can help 

officials make decisions about resource allocations and associated tradeoffs in preparing defenses against acts of terrorism and other threats. We 

 42National Commission on Terrorist Attacks upon the United States, The 9/11 Commission 

Report: Final Report of the National Commission on Terrorist Attacks upon the United

States (Washington, D.C.: 2004). The 9/11 Commission was an independent, bipartisan 

commission established in late 2002, to prepare a complete account of the circumstances

surrounding the September 11 terrorist attacks, including preparedness for and the 

immediate response to the attacks. The commission was also mandated to provide 

recommendations designed to guard against future attacks. 

43The Intelligence Reform and Terrorism Prevention Act of 2004 requires the Secretary of 

Homeland Security to develop, prepare, implement, and update, as needed a National 

Strategy for Transportation Security and transportation modal security plans. See Pub. L. 

No. 108-458, § 4001, 118 Stat. 3638, 3710-12 (codified at 49 U.S.C. §§ 114(t), 44904(c)-(d)). 

Page 22 GAO-07-660 Aviation Security
have recommended that TSA apply a comprehensive risk-based approach

for securing the domestic air cargo transportation system.44

The Homeland Security Act of 2002 also directed the department’s 

Directorate of Information Analysis and Infrastructure Protection to use 

risk management principles in coordinating the nation’s critical 

infrastructure protection efforts.45 This includes integrating relevant 

information, and analysis and vulnerability assessments to identify 

priorities for protective and support measures by the department, other 

federal agencies, state and local government agencies and authorities, the 

private sector, and other entities. Homeland Security Presidential 

Directive 7 and the Intelligence Reform and Terrorism Prevention Act of 

2004 further define and establish critical infrastructure protection 

responsibilities for DHS and those federal agencies given responsibility for 

particular industry sectors, such as transportation. In June 2006, DHS 

issued the National Infrastructure Protection Plan (NIPP), which named 

TSA as the primary federal agency responsible for coordinating critical

infrastructure protection efforts within the transportation sector, which 

includes all modes of transportation.46 The NIPP requires federal agencies 

to work with the private sector to develop plans that, among other things,

identify and prioritize critical assets for their respective sectors. In 

accordance with the NIPP, TSA must conduct and facilitate risk 

assessments in order to identify, prioritize, and coordinate the protection 

of critical transportation systems infrastructure, as well as develop riskbased priorities for the transportation sector. TSA officials reported that 

work is now under way on specific plans for each mode of transportation, 

but as of January 2007, they were not completed.

To provide guidance to agency decision makers, we have created a risk 

management framework, which is intended to be a starting point for 

applying risk-based principles. Our risk management framework entails a 

continuous process of managing risk through a series of actions, including 

setting strategic goals and objectives, assessing risk, evaluating 

 44GAO-06-76. 

45In 2006, DHS reorganized the Information Analysis and Infrastructure Protection 

Directorate and moved its functions to the Office of Intelligence and Analysis and Office of

Infrastructure Protection. 

46DHS designated TSA as the lead agency for addressing HSPD-7 as it relates to securing 

the nation’s transportation sector. The Department of Transportation also has a 

collaborative role for addressing HSPD-7. 

Page 23 GAO-07-660 Aviation Security
alternatives, selecting initiatives to undertake, and implementing and 

monitoring those initiatives. DHS’s NIPP describes a risk management 

process that closely mirrors our risk management framework. 

Setting strategic goals, objectives, and constraints is a key first step in 

applying risk management principles and helps to ensure that management 

decisions are focused on achieving a purpose. These decisions should take 

place in the context of an agency’s strategic plan that includes goals and 

objectives that are clear and concise. These goals and objectives should 

identify resource issues and other factors to achieving the goals. Further, 

the goals and objectives of an agency should link to a department’s overall 

strategic plan. The ability to achieve strategic goals depends, in part, on 

how well an agency manages risk. The agency’s strategic plan should 

address risk-related issues that are central to the agency’s overall mission. 

Risk assessment, an important element of a risk-based approach, helps

decision makers identify and evaluate potential risks so that 

countermeasures can be designed and implemented to prevent or mitigate 

the effects of the risks. Risk assessment is a qualitative and/or quantitative

determination of the likelihood of an adverse event occurring and the 

severity, or impact, of its consequences. Risk assessment in a homeland 

security application often involves assessing three key elements—threat, 

vulnerability, and criticality or consequence. A threat assessment identifies 

and evaluates potential threats on the basis of factors such as capabilities, 

intentions, and past activities. A vulnerability assessment identifies 

weaknesses that may be exploited by identified threats and suggests 

options to address those weaknesses. A criticality or consequence 

assessment evaluates and prioritizes assets and functions in terms of 

specific criteria, such as their importance to public safety and the 

economy, as a basis for identifying which structures or processes are 

relatively more important to protect from attack. Information from these 

three assessments contributes to an overall risk assessment that may 

characterize risks on a scale such as high, medium, or low and provides 

input for evaluating alternatives and management prioritization of security

initiatives. The risk assessment element in the overall risk management 

cycle may be the largest change from standard management steps and can

be important to informing the remaining steps of the cycle. For further 

details on our risk management framework, see appendix IV.

Page 24 GAO-07-660 Aviation Security
The two components within DHS responsible for air cargo security, TSA

and CBP, have initiated efforts to better secure inbound air cargo, but 

these efforts are in the early stages and could be enhanced. While TSA and 

CBP have taken some preliminary steps to use risk management principles

to guide their decisions related to inbound air cargo security, most of 

TSA’s and CBP’s efforts to enhance inbound air cargo security are still 

largely in the planning stages. For instance, TSA has completed a strategic

plan to address domestic air cargo security and has identified the primary 

threats associated with inbound air cargo. However, the agency has not 

identified goals and objectives for addressing inbound air cargo security, 

such as how it will coordinate with CBP to ensure that all relevant areas of 

inbound air cargo security are addressed. Further, TSA has not assessed 

which areas of inbound air cargo are most vulnerable to attack and which

assets are deemed most critical to protect. Another action TSA has taken 

is the publication of its final air cargo security rule in May 2006 that 

included a number of provisions aimed at enhancing the security of 

inbound air cargo. However, TSA’s inbound air cargo inspection 

requirements continue to allow for a number of exemptions for cargo 

transported on passenger air carriers, which could be exploited to 

transport an explosive device. In addition, TSA conducts compliance 

inspections of domestic and foreign passenger air carriers transporting 

cargo into the United States, but the agency has not developed an 

inspection plan that would establish goals and measures for its inspection 

program to evaluate air carriers’ performance against expected results. 

Also within DHS, CBP has recently initiated efforts to mitigate the threat

of a WMD entering the United States by targeting inbound air cargo 

transported on passenger and all-cargo aircraft that may pose a security 

risk and inspecting such cargo once it arrives in the United States. CBP 

also manages the C-TPAT program, which encourages those businesses 

involved in the transportation of cargo into the United States to enhance 

their security practices. However, CBP is still in the early stages of 

developing specific security criteria for air carriers participating in the 

program. In addition, DHS is in the early stages of researching, developing, 

and testing technologies to enhance the security of air cargo, but has not 

yet assessed the results or determined whether these technologies will be 

deployed abroad. Finally, TSA and CBP have taken steps to coordinate 

their responsibilities to safeguard air cargo transported into the United 

States, but the two agencies do not have a systematic process in place to

share information that could be used to strengthen their efforts to secure 

inbound air cargo. 

DHS Has Taken Initial 

Steps to Secure 

Inbound Air Cargo, 

and Opportunities 

Exist to Strengthen 

These Efforts 

Page 25 GAO-07-660 Aviation Security
TSA and CBP Have Taken 

Preliminary Steps to 

Incorporate Risk 

Management Principles 

into Their Decision Making 

to Secure Inbound Air 

Cargo, but Most Efforts 

Are in the Planning Stages 

Within DHS, TSA and CBP have begun incorporating risk management 

principles into their inbound air cargo security programs, but these efforts 

are in the early stages and more work remains to be done. Applying a risk 

management framework to decision making is one tool to help provide 

assurance that programs designed to combat terrorism are properly 

prioritized and focused. Thus, risk management, as applied in the 

homeland security context, can help decision makers to more effectively 

and efficiently prepare defenses against acts of terrorism and other 

threats. Risk management principles can be incorporated on a number of 

different levels within an agency’s operations. For example, CBP’s ATS 

system uses information from various sources to assign risk scores to 

cargo, as part of its risk-managed approach to cargo security. Another 

example of a risk management activity is considering risk when allocating

resources. TSA has underscored the importance of implementing a riskbased approach that protects against known threats, but that is also 

sufficiently flexible to direct resources to mitigate new and emerging 

threats. According to TSA, the ideal risk model would be one that could be

used throughout the transportation sector and applicable to different 

threat scenarios. 

As part of TSA’s risk-based approach, the agency issued an Air Cargo 

Strategic Plan in November 2003 that focused on securing the domestic air 

cargo supply chain and transportation system. However, this plan does not 

describe how the agency plans to secure inbound air cargo.47 TSA’s Air 

Cargo Strategic Plan describes an approach for screening or reviewing 

information on all domestic air cargo shipments to determine their level of

relative risk, ensuring that 100 percent of cargo identified as posing an 

elevated risk is physically inspected, and pursuing technological solutions 

to physically inspect air cargo. This approach to target elevated risk 

domestic air cargo for inspection, however, is not yet in place. In 

developing its Air Cargo Strategic Plan, TSA coordinated with air cargo 

industry stakeholders representing passenger and all-cargo carriers, as 

well as with CBP to assist in developing a system for targeting domestic 

air cargo.48 TSA’s Air Cargo Strategic Plan, however, does not include goals 

 47U.S. Department of Homeland Security, TSA’s Air Cargo Strategic Plan, November 2003.

48According to CBP officials, CBP provided TSA with information on CBP’s targeting efforts 

and systems to assist TSA in the development of a system to target domestic air cargo for 

inspection. However, according to CBP officials, TSA has not sought further assistance 

from CBP on developing a targeting system for domestic air cargo. 

Page 26 GAO-07-660 Aviation Security
and objectives for addressing inbound air cargo security, which presents 

different security challenges than domestic air cargo.49 

According to CBP, the agency has begun a comprehensive review of its 

current air cargo security strategy, including how C-TPAT as well as 

relevant TSA programs can be incorporated into this strategy. As part of 

its risk management efforts, CBP developed a strategic plan covering fiscal 

years 2007-2011 focusing on securing the nation’s borders at ports of entry, 

including airports. This plan includes a discussion on how CBP will use 

risk-based principles to guide decisions related to securing inbound air 

cargo. For example, to achieve CBP’s strategic objective of screening all 

goods entering the United States by air, CBP plans to develop an approach

to increase the percentage of goods for which it receives advance 

information. By increasing the amount of information available, CBP can 

better identify low-risk goods and move them quickly through the port of

entry, while focusing its resources on inspecting cargo that represents 

higher risks. 

As TSA develops a strategy for inbound air cargo, it will be important to 

work with CBP to ensure that the two agencies coordinate their respective 

responsibilities for securing inbound air cargo and leverage available 

information to ensure vulnerabilities are addressed. For example, during 

discussions with TSA and CBP officials, we determined that, due in part to

a lack of coordination between the two agencies, neither agency was 

addressing an area that both considered a potential threat to air cargo 

security. Although TSA and CBP have not stated whether this issue results 

in a vulnerability to the cargo’s transport to the United States, some air 

cargo industry stakeholders with whom we spoke told us it represents a 

security vulnerability.50

 49DHS determined that examples of the specific challenges TSA may face in addressing 

inbound air cargo security are considered Sensitive Security Information. A description of 

the specific challenges TSA may face is included in the restricted version of this report, 

GAO-07-337SU. In July 2006, DHS issued its goals and priorities to be achieved prior to 

January 2009. The department identified protecting air cargo transported on passenger 

aircraft as one of its top priorities, and called for the implementation of a system to protect

against hidden explosives devices in air cargo transported on passenger aircraft by the end 

of 2007. Although the goals and priorities do not specify whether they apply to domestic, 

inbound, or outbound air cargo, TSA officials stated that they apply only to domestic air 

cargo. 

50DHS determined that details on the potential vulnerability are considered sensitive 

security information. Information on the potential vulnerabilities is discussed in the 

restricted version of this report, GAO-07-337SU. 

Page 27 GAO-07-660 Aviation Security
TSA officials acknowledged that it is important to partner with CBP, 

foreign governments, and international air cargo stakeholders in 

developing a strategy for securing inbound air cargo. TSA officials stated 

that they plan to revise their existing domestic air cargo strategic plan and 

will consider incorporating a strategy for addressing inbound air cargo 

security at that time. However, as of January 2007, agency officials had not 

set a time frame for when TSA will complete this revision, and the extent 

to which this plan will address inbound air cargo is unclear. CBP officials 

stated that their input could contribute to any strategy developed by TSA, 

and that CBP is in the initial stages of developing its own air cargo 

strategic plan, scheduled for completion by the end of 2007. 

In addition to developing a strategic plan, a risk management framework 

in the homeland security context should include risk assessments, which 

typically involve three key elements—threats, vulnerabilities, and 

criticality or consequence (for more information on our risk management 

framework, see app. IV). Information from these three assessments 

provides input for setting priorities, evaluating alternatives, allocating 

resources, and monitoring security initiatives. TSA has completed an

assessment of air cargo threats, but has not assessed air cargo

vulnerabilities or critical assets. 

In September 2005, TSA’s Transportation Security Intelligence Service 

(TSIS) completed an overall threat assessment for air cargo, which 

identified general and specific threats related to both domestic and 

inbound air cargo.51 According to TSA, the primary threats to inbound air 

cargo focus on the introduction of an explosive device in cargo loaded on

a passenger aircraft, and the hijacking of an all-cargo aircraft resulting in 

its use as a weapon to inflict mass destruction.52 As stated previously, TSA, 

CBP, and industry stakeholders have also identified the introduction and 

 51TSA’s Office of Intelligence, formerly known as TSIS, does not independently gather 

intelligence information but rather produces threat assessments using available intelligence 

from sources such as DHS’s Directorate of Intelligence and Analysis, the Federal Bureau of 

Investigation, and the Central Intelligence Agency. The details of TSA’s threat assessment 

are classified. 

52DHS defines “threat” as the capabilities (demonstrated and theoretically feasible) of 

terrorist organizations/affiliates to attack/damage/destroy critical infrastructure such as 

transportation assets, coupled with the intentions (both demonstrated and articulated 

publicly) to actually perpetrate these attacks. 

Page 28 GAO-07-660 Aviation Security
transport of a WMD or its component parts as a potential threat.53 TSA has 

characterized the threats to inbound air cargo as high and has identified 

air cargo as a primary aviation target for terrorists in the short term. 

However, TSA has not evaluated the relative security risk presented by 

inbound air cargo compared to other areas of aviation security, such as 

passengers and checked baggage.54

While TSA has acknowledged that the vulnerabilities to inbound air cargo 

would likely be similar to those of domestic air cargo, TSA has not 

conducted a vulnerability assessment, nor has it identified vulnerabilities 

specific to inbound air cargo.55 TSA officials stated that the agency is first 

planning to conduct an assessment of domestic air cargo vulnerabilities 

before initiating an assessment of inbound air cargo vulnerabilities. TSA 

does not plan to complete its assessment of domestic air cargo 

vulnerabilities until late in 2007, thus potentially delaying the start of an 

assessment of the inbound air cargo vulnerabilities until 2008. According 

to TSA officials, limited resources and competing priorities have delayed

agency efforts to conduct an assessment of inbound air cargo security 

vulnerabilities. Nevertheless, TSA officials acknowledge that 

vulnerabilities to inbound air cargo exist and that these vulnerabilities are 

in some cases similar to those facing the domestic air cargo supply chain.56 

 53According to CBP, mitigating the threat of a WMD entering the United States via any 

transportation mode is its priority mission. According to CBP officials, CBP will not 

conduct its own air cargo specific threat assessment, but rather rely on TSA’s air cargo 

threat assessments and information obtained from the Central Intelligence Agency. 

54In April 2005, TSA briefed a congressional committee on the threats to the nation’s entire 

transportation sector, including aviation. The briefing included a threat matrix that ranked 

the risk associated with the different transportation modes and showed threats to air cargo 

that were consistent with previous TSA threat assessments. 

55At a departmental level, DHS does not have any efforts under way specifically aimed at 

assessing the vulnerabilities of inbound air cargo. However, agency officials stated that the 

Office of Infrastructure Protection, an office within DHS charged with coordinating 

national critical infrastructure protection efforts, is coordinating with TSA on conducting 

risk assessments associated with U.S. airports. 

56DHS determined that examples of inbound air cargo security vulnerabilities are Sensitive 

Security Information. Examples of inbound air cargo security vulnerabilities are discussed 

in the restricted version of this report, GAO-07-337SU. In our October 2005 report on

domestic air cargo security, we cited air cargo system vulnerabilities related to the

adequacy of background investigations for persons handling cargo, the possible tampering 

with cargo during land transport to the airport or at the cargo handling facilities of air 

carriers and freight forwarders, and the illegal shipments of hazardous materials. See 

GAO-06-76. 

Page 29 GAO-07-660 Aviation Security
TSA officials stated that conducting vulnerability assessments for inbound 

air cargo will be difficult because these assessments require an

understanding of the inbound air cargo supply chain, and while the agency 

has some information on the supply chains of several foreign countries, it 

does not have access to that information for many others. Although agency

officials reported that they have taken initial steps toward developing a 

methodology for assessing inbound air cargo security vulnerabilities, they 

have not established a time frame for completing the methodology or 

determined when the vulnerability assessments will be conducted. TSA 

officials acknowledged that conducting assessments to identify 

vulnerabilities associated with inbound air cargo, and analyzing the results 

of such assessments, could help to strengthen the agency’s efforts to 

secure inbound air cargo by providing information that could be used to 

develop measures to address identified vulnerabilities. Air cargo industry 

stakeholders we spoke with, including those representing domestic and 

foreign air carriers, agreed that TSA-led vulnerability assessments could 

help to identify air cargo security weaknesses and develop measures to 

mitigate these weaknesses. 

TSA also has not developed a methodology or schedule for completing an

assessment to identify those inbound air cargo assets deemed most critical 

to protect, or whose destruction would cause the most severe damage to 

the United States. TSA officials stated that inbound air cargo assets mirror 

domestic air cargo assets, and could include workers, facilities, and 

aircraft. According to TSA, factors that could be used to define critical

inbound air cargo assets include the number of fatalities resulting from a 

terrorist attack on a domestic or foreign cargo facility or aircraft; the 

economic or political importance of the asset; and consequences that an

attack would have on the public’s confidence in the U.S. government’s 

ability to maintain order, among other things. According to TSA officials, 

the agency will conduct an assessment of critical inbound air cargo assets

once it has completed its vulnerability and criticality assessments for 

domestic air cargo expected in 2007. 

The need for an assessment of critical transportation infrastructure, which 

could include inbound air cargo assets, has been identified by various 

sources, including DHS’s NIPP and National Strategy for Transportation 

Security, and a number of Presidential Directives. The 9/11 Commission 

also recommended that the U.S. government identify and evaluate the 

transportation assets that need to be protected, set risk-based priorities 

for defending them, select the most practical and cost-effective ways of 

doing so, and develop a plan, budget, and funding to implement the effort. 

TSA officials we spoke with acknowledged that such assessments could 

Page 30 GAO-07-660 Aviation Security
better enable the agency to prioritize its efforts by focusing on highpriority or high-value inbound air cargo assets, and by targeting resources 

to address the most critical inbound air cargo security risks. Moreover, 

TSA officials agreed that analyzing the results of a criticality assessment 

could provide the basis for taking immediate protective actions depending

on the threat environment, and guiding future agency decisions related to

securing the inbound air cargo transportation system. 

TSA Revised its Security 

Programs to Require Air 

Carriers Transporting 

Cargo into the United 

States to Implement 

Additional Air Cargo 

Security Measures, but the 

Programs Do Not Address 

Some Areas of Inbound Air 

Cargo Security 

In May 2006, TSA issued a final rule that revised some of the requirements 

air carriers need to follow to ensure air cargo security. While TSA’s air 

cargo security rule is focused primarily on domestic air cargo, it also 

includes more stringent security requirements for passenger and all-cargo 

carriers transporting cargo into the United States.

57 For example, TSA 

created a new mandatory security regime for domestic and foreign allcargo air carrier operations. The final rule also acknowledges that TSA 

amended its security directives and programs to triple the percentage of 

cargo inspected on domestic and foreign passenger aircraft.58 TSA 

currently requires foreign and domestic all-cargo carriers to inspect a 

different percentage of nonexempt items prior to the cargo’s loading.59

While the air cargo security rule establishes general requirements air 

carriers must follow to secure inbound air cargo, TSA is currently drafting

and revising security programs to incorporate applicable elements of the 

rule and with which air carriers will need to comply. These security 

programs will address inbound, outbound, and domestic air cargo 

operations. TSA regulations require that each air carrier, foreign or 

domestic, adopt a security program that incorporates applicable security 

requirements and that is approved by TSA. Once TSA finalizes revisions to 

the security programs—which for domestic passenger air carriers is 

TSA develops security programs that 

describe the measures air carriers

are required to implement to ensure 

compliance with TSA security 

requirements, including air cargo. To 

demonstrate how they will implement 

these requirements, each air carrier 

adopts a TSA-approved security 

program.

TSA develops security programs that

describe the measures air carriers

are required to implement to ensure 

compliance with TSA security

requirements, including air cargo. To

demonstrate how they will implement 

these requirements, each air carrier 

adopts a TSA-approved security

program.

 57TSA’s rule sets forth domestic air cargo security requirements, such as requiring airports 

to expand the secure identification display area (SIDA)at airports to include areas where 

cargo is loaded and unloaded, and conduct security threat assessments on individuals with 

access to air cargo to assess any terrorist threats from those individuals. 

58TSA amended this requirement in response to the DHS Appropriations Act, 2005, in July 

2005. Pub. L. No. 108-334, § 513, 118 Stat. 1298, 1317 (2004). 

59DHS determined that details on the percentage of inbound air cargo transported on 

passenger and all-cargo aircraft required to be inspected is Sensitive Security Information. 

Information on the percentage of inbound air cargo required to be inspected is included in 

the restricted version of this report, GAO-07-337SU. 

Page 31 GAO-07-660 Aviation Security
known as the Aircraft Operator Standard Security Program (AOSSP) and 

for foreign passenger air carriers is known as the Model Security 

Program (MSP)—TSA will require air carriers to amend their security 

programs to reflect TSA’s new requirements.60 TSA also drafted new 

security programs for domestic all-cargo carriers, referred to as the Full 

All-Cargo Aircraft Operator Standard Security Program (FACAOSSP), and 

for foreign all-cargo carriers, referred to as the All-Cargo International 

Security Program (ACISP).61 As of January 2007, TSA had yet to issue the 

final security programs. Air carriers will be required to be in full 

compliance with the revised and new security programs on a date to be 

established by the agency. However, TSA officials could not provide a time 

frame for when these programs would be finalized, nor has the date that 

air carriers will be required to be in compliance with the new and revised 

security programs been announced.

62 

After TSA issued its final air cargo security rule and released its draft 

security programs for comment, the agency held eight listening sessions in 

five cities to provide industry an opportunity to share its views on the 

proposed requirements before the final security programs are issued. At 

these listening sessions, some air carriers were pleased that TSA had taken 

action to strengthen air cargo security. Other air carriers, however, 

expressed concerns regarding the cost and feasibility of implementing 

TSA’s air cargo security requirements contained in the agency’s draft 

security programs.63 Air carriers present at these listening sessions also 

stated that given the operational changes they would need to make to 

implement TSA’s new air cargo security requirements, TSA should provide 

 60The AOSSP and MSP also contain new security requirements for carriers transporting

cargo within the United States and from the United States to a foreign location. 

61Previously, distinct security programs did not exist for domestic and foreign all-cargo 

carriers. All-cargo carriers, however, were required to implement security measures 

contained in TSA security directives and emergency amendments. Some of the proposed 

requirements in the proposed all-cargo security programs are already implemented by 

all-cargo carriers. 

62DHS determined that details on the draft requirements contained in security programs for

passenger and all-cargo carriers that relate to inbound air cargo security are Sensitive 

Security Information. The draft requirements are discussed in the restricted version of this

report, GAO-07-337SU. 

63According to TSA, the increased cost estimates contained in the final rule were largely 

due to tripling the percentage of cargo passenger air carriers are required to inspect, which 

was required by the DHS Appropriations Act of 2005. 

Page 32 GAO-07-660 Aviation Security
air carriers sufficient time to fully comply with the new and revised 

security programs. Although passenger air carriers expressed concern 

regarding the implementation of measures contained in the final rule and

draft security programs, most of their comments relate to domestic air 

cargo security. Domestic and foreign all-cargo carriers cited several 

challenges related to TSA’s draft security programs for all-cargo carriers. 

These included 

• new requirements for inspecting 100 percent of certain nonexempt 

inbound air cargo viewed as unnecessary, burdensome to 

implement, and costly; 

• proposed revisions to existing inspection exemptions based on

weight and packaging viewed as negatively affecting delivery of 

specific cargo shipments;

• application of new inspection and other requirements viewed as not 

consistent with identified threats to the air cargo industry; 

• difficultly determining which TSA requirements apply to all-cargo 

carriers versus which apply to cargo transferred from an all-cargo 

aircraft to a passenger aircraft; and 

• a proposed requirement to train carrier personnel to screen 

individuals and their property transported on an all-cargo flight 

viewed as unwarranted because very few individuals other than 

crew members fly on these aircraft.

Among other things, the draft security programs for foreign and domestic 

passenger carriers would require the physical inspection of air cargo 

shipments, including manual searches and the use of technology, in 

addition to other methods currently in use. The primary concern 

expressed by all-cargo carriers about the draft security programs focus on 

air cargo inspection requirements. Specifically, some all-cargo carriers did 

not understand TSA’s rationale for requiring them to inspect 100 percent 

of certain types of nonexempt cargo and noted that this would require 

them to inspect three times more cargo than passenger carriers are 

required to inspect. According to some all-cargo carriers, TSA has not 

adequately explained any additional risk to all-cargo carriers that would 

justify the new inspection requirements. TSA officials stated that the 

agency will review the comments submitted by industry stakeholders 

regarding the new and revised security programs prior to issuing the final 

security programs. 

Page 33 GAO-07-660 Aviation Security
In our October 2005 report, we noted that TSA’s inspection requirements 

allowed carriers to exempt certain types of air cargo from inspection.64

These exemptions may leave the air cargo transportation system 

vulnerable to terrorist attack. We reported that a terrorist could place an 

explosive device in an exempt piece of cargo, which would not be 

detected prior to its loading onto aircraft because such cargo is not 

subject to inspection. We recommended that TSA assess the rationale for

the exemptions, determine whether these exemptions pose vulnerabilities, 

and determine whether adjustments were needed.65 According to TSA 

officials, the agency originally chose to exempt certain cargo from the 

inspection requirements because it did not view the exempted cargo as 

posing a significant security risk and because the time required to inspect 

certain cargo could adversely affect the flow of commerce. 

Inspection Exemptions 

Pose a Potential 

Vulnerability for Air Cargo 

Transported into the 

United States 

TSA recognized, however, that some of the inspection exemptions could 

pose a potential vulnerability, and convened an internal cargo policy 

working group in February 2006 to examine air cargo policies and 

regulations that apply to inbound, outbound, and domestic air cargo, 

including inspection exemptions, to identify requirements that may allow 

for unacceptable security gaps. In March 2006, the working group made 

several recommendations to TSA related to the inspection exemptions for 

cargo transported on passenger aircraft. The working group’s

recommendations included more stringent inspection requirements for 

passenger carriers. In October 2006, TSA issued a security directive and 

emergency amendment to domestic and foreign passenger air carriers 

operating within and from the United States that implemented elements of 

the recommendations of the internal working group. However, these new 

requirements do not cover all air carriers.66 

In addition to the actions TSA took to address the working group’s 

recommendations, the agency is also considering limiting some of the 

inspection exemptions for all-cargo carriers, and has drafted security 

programs for foreign and domestic all-cargo carriers aimed at 

strengthening the security of inbound, outbound, and domestic air cargo. 

 64The inspection exemptions apply to inbound, outbound, and domestic air cargo. See 

GAO-06-76. 

65GAO-06-76. 

66DHS determined that details on the specific policy changes TSA made as a result of the

working group are considered Sensitive Security Information. A description of these policy 

changes is provided in the restricted version of this report, GAO-07-337SU.

Page 34 GAO-07-660 Aviation Security
The draft programs for all-cargo carriers would require all-cargo carriers 

to inspect 100 percent of certain nonexempt air cargo.67 TSA officials 

stated that prior to issuing the final security programs, the agency will 

consider comments by all-cargo carriers on this proposed requirement. 

Under TSA’s revisions to the inspection exemptions for passenger air 

carriers transporting cargo from and within the United States, and TSA’s 

proposed changes to the inspection exemptions contained in the draft 

security programs for all-cargo carriers, certain types of air cargo will 

remain exempt from inspection. 68 These remaining exemptions for both 

all-cargo and passenger air carriers transporting cargo into the United 

States continue to represent potential vulnerabilities to the air cargo 

transportation system.69 According to TSA officials, the agency has not 

established a time frame for completing its assessment of whether existing 

inspection exemptions pose an unacceptable security vulnerability. 

Some all-cargo carriers expressed concern over TSA’s proposal to 

eliminate the inspection exemption for certain types of cargo, and 

recommended that this proposal be reconsidered.70 TSA officials stated 

that the proposed revisions to the inspection requirements are aimed at 

increasing the overall security of air cargo transported on all-cargo 

aircraft. According to TSA officials, the agency is still evaluating industry’s 

comments to the proposed security programs, including those related to

removing the inspection exemption for certain types of cargo transported 

on all-cargo carriers. TSA officials noted that the agency is also holding 

discussions with the air cargo industry to determine whether or not the 

current inspection exemptions leave the air cargo transportation system 

vulnerable to attack and what impact further revisions to the inspection 

 67DHS determined that details on the requirements contained in the draft security programs 

for all-cargo carriers are Sensitive Security Information. A description of these 

requirements is provided in the restricted version of this report, GAO-07-337SU. 

68DHS determined that the specific types of cargo exempted are considered Sensitive 

Security Information. A description of these policy changes is provided in the restricted

version of this report, GAO-07-337SU. 

69DHS determined that details on specific vulnerabilities associated with inbound air cargo 

inspection exemptions are Sensitive Security Information. A description of the 

vulnerabilities is provided in the restricted version of this report, GAO-07-337SU. 

70DHS determined that details on the specific concerns expressed by all-cargo air carriers 

are Sensitive Security Information. A description of these concerns is included in the

restricted version of this report, GAO-07-337SU. 

Page 35 GAO-07-660 Aviation Security
exemptions would have on air carriers’ operations.71 According to TSA 

officials, while ongoing discussions with industry are focused on the 

domestic air cargo transportation system, any decisions made as a result 

of these discussions could affect inbound air cargo. TSA officials added 

that while industry stakeholder concerns are considered, decisions 

regarding what requirements will be issued will be based on the agency’s

assessment of air cargo risks and security needs.

TSA Developed a Program 

to Assess Passenger Air 

Carrier Compliance with 

Inbound Air Cargo 

Security Requirements, but 

This Program Could Be 

Strengthened by 

Developing an Inspection 

Plan That Includes 

Performance Goals and 

Measures 

TSA currently inspects domestic and foreign passenger air carriers 

transporting cargo into the United States to assess their compliance with 

TSA inbound air cargo security requirements. The agency, however, does 

not perform compliance inspections of all air carriers transporting cargo 

into the United States.72

Between July 2003 and February 2006, TSA conducted about 1,000 

inspections of domestic and foreign passenger air carriers that included a 

review of air cargo security procedures.73 TSA’s inbound air cargo security 

inspections differ from its domestic air cargo security inspections in that 

the agency does not have an inspection plan that focuses solely on air 

cargo security regulations. Instead, TSA inspectors evaluate inbound cargo 

security procedures as a part of its international aviation security 

inspection program, which also includes reviews of areas such as aircraft,

passenger, and baggage security. TSA’s five international field offices are

responsible for scheduling and conducting the international air carrier 

inspections.74 TSA inspections may include areas of cargo security, such as 

cargo acceptance procedures, security testing and training, and ensuring

 71In an October 20, 2005, meeting with a wide range of industry stakeholders, TSA 

announced its intent to review current policies and processes. During a follow-on meeting

held November 9, 2005, with corporate security representatives from most of the major 

passenger air carriers, TSA continued that dialogue and specifically addressed the need to

reevaluate the rationale for existing inspection exemptions. 

72DHS determined that the specific actions TSA is taking to address this issue are 

considered Sensitive Security Information. These actions are discussed in the restricted 

version of this report, GAO-07-337SU. 

73TSA compliance inspections are fundamentally different from air carriers’ inspections of

air cargo. TSA inspections are designed to ensure air carrier compliance with air cargo 

security requirements, while air carrier inspections focus on ensuring that air cargo does

not contain an improvised explosive device or human stowaway. 

74International field office officials stated that these inspections may occur in conjunction 

with a foreign airport assessment. 

Page 36 GAO-07-660 Aviation Security
that foreign air carriers implement a cargo security plan that is consistent 

with TSA standards. 

According to TSA records, inspectors have found instances where 

passenger air carriers were not complying with inbound air cargo security 

procedures. For example, TSA found that some passenger air carriers 

were accepting cargo from unknown shippers, not physically screening 

cargo in accordance with TSA regulations, and failing to search empty 

cargo holds on an aircraft to prevent unauthorized access prior to loading

and unloading. If not corrected, these problems could create 

vulnerabilities in the security of inbound air cargo. For information on 

TSA’s inspections conducted, including inspection results from July 2003 

to February 2006, see appendix II. 

TSA has a domestic aviation security inspection plan that, among other 

things, describes how the agency will ensure that air carriers that use 

domestic airports are complying with TSA security requirements, 

including those that apply to passengers, baggage, and air cargo. However, 

TSA has not developed a similar inspection plan for international aviation 

security. As a result, there is no inspection plan that would establish 

performance goals and measures that provide a clear picture of the 

intended objectives and performance of its inspections of passenger and 

all-cargo carriers that transport cargo into the United States. The 

Government Performance and Results Act of 1993 (GPRA), among other 

things, requires agencies to prepare an annual performance plan for their 

programs and directs executive agencies to articulate goals and strategies

for achieving those goals.75 These plans should include performance goals

and measures to determine the extent to which agencies are achieving 

their intended results. TSA’s annual domestic inspection plan describes 

how the agency will ensure air carrier compliance with federal aviation 

security requirements, including those related to air cargo security. The 

domestic inspection plan includes goals, such as the number of air cargo 

inspections of air carriers each inspector is to conduct for the year. TSA 

officials stated that the agency applied risk management principles that 

considered threat factors, local security issues, and input from law 

enforcement to target key vulnerabilities and critical assets to develop its 

A performance goal is a target level 

of performance expressed as a

measurable objective, against which 

actual achievement can be 

compared. A performance measure 

is an indicator used to gauge 

achievement of an established goal 

and is meant to address key aspects

of program performance and help 

decision makers assess program 

achievements and improve program 

performance.

A performance goal is a target level 

of performance expressed as a

measurable objective, against which

actual achievement can be 

compared. A performance measure 

is an indicator used to gauge 

achievement of an established goal 

and is meant to address key aspects

of program performance and help

decision makers assess program 

achievements and improve program 

performance.

 75The Government Performance and Results Act of 1993, Pub. L. No. 103-62, 107 Stat. 285, 

as amended, focuses the federal government on providing objective, results-oriented 

information to improve the efficiency and effectiveness of federal programs, among other

things. Under GPRA, developing performance goals and measures is a component of

results-oriented management. See 31 U.S.C. § 1115. 

Page 37 GAO-07-660 Aviation Security
domestic inspection plan goals. According to TSA, its plan for conducting 

domestic cargo inspections also takes into account how to use the 

agency’s limited inspection resources most effectively. 

Within the context of TSA’s international inspections program, an 

inspection plan should describe the agency’s approach for conducting 

compliance inspections of air carriers that transport cargo into the United

States. This plan should include performance goals and measures to gauge 

air carriers’ compliance with inbound air cargo security requirements. 

Developing such indicators is also recommended by our standards for 

internal control in order for agencies to compare and analyze actual 

performance data against established goals.76 For example, we reported 

that successful organizations try to link performance goals and measures 

to the organization’s strategic goals and, to the extent possible, have

performance goals that will show annual progress toward achieving their 

long-term strategic goals.

77 With regard to TSA’s inspection plan, a goal 

could be to ensure that passenger and all-cargo air carriers transporting 

cargo to the United States are meeting an acceptable level of compliance 

with air cargo security requirements. Another goal could be to assess allcargo carriers transporting inbound air cargo within a specified time frame 

based on the identified risk posed by these carriers to the United States. In

addition, we reported that a successful agency focuses its goals on the 

results it expects the program to achieve. For example, TSA could 

measure the achievement of a compliance inspection goal by establishing 

the number and type of inspections the agency wants to conduct, and 

determining appropriate measures to gauge air carrier compliance with air 

cargo security requirements. 

TSA officials stated that the agency uses its foreign airport assessment 

schedule as its plan for determining where it will conduct compliance 

inspections of passenger air carriers during each fiscal year. Officials 

added that they select passenger air carriers for inspection based on 

factors such as the results of previous inspections, when the air carrier 

was last inspected, and the availability of inspection resources. While 

TSA’s schedule for completing airport assessment is an important step in 

focusing TSA’s international compliance inspection efforts, this schedule 

 76GAO, Internal Control Management and Evaluation Tool, GAO-01-1008G (Washington,

D.C.: August 2001). 

77GAO, The Results Act: An Evaluator’s Guide to Assessing Agency Annual Performance 

Plans, GAO/GGD-10.1.20 (Washington, D.C.: April 1998). 

Page 38 GAO-07-660 Aviation Security
does not include goals or measures for evaluating passenger carrier 

compliance with TSA’s inbound air cargo security requirements. Further, 

the schedule does not include inspections of all-cargo carriers. Without an 

inspection plan, TSA may not be able to clearly show the relationship 

between its inspections efforts and its longer-term goals to secure inbound 

air cargo. Moreover, without establishing performance goals and 

measures, TSA is limited in its ability to assess the agency’s performance 

and the performance of the air carriers it regulates against expected 

outcomes. While we understand that TSA has competing demands and 

must address numerous areas of aviation security with limited resources, 

developing a risk-based plan would help the agency better plan for and 

articulate how it intends to address inbound air cargo security inspections

using its limited resources. Further, developing goals and measures to 

benchmark its performance would demonstrate the effectiveness of its 

inbound air cargo security efforts and help TSA determine the extent to

which the inspections are contributing to the agency’s overall aviation

security goals and objectives. 

TSA Implemented a RiskBased Scheduling System 

to Assess Certain Foreign 

Airports’ Security 

Measures, but Not All 

Foreign Airports Have 

Been Assessed 

TSA is authorized by U.S. law to assess the effectiveness of security 

measures maintained at foreign airports that serve U.S. air carriers or from 

which foreign air carriers serve the United States, or that pose a high risk

of introducing danger to international air travel.

78 TSA staff located at five

international field offices conduct these assessments. During an 

assessment, TSA inspectors are to evaluate the security policies and 

procedures in place at a foreign airport to determine whether procedures 

meet ICAO aviation security standards and recommended practices. TSA

consults with foreign government officials to schedule these assessments. 

According to TSA officials, however, some foreign governments are 

sensitive to permitting the United States to come into their country and 

assess their airport security and may put conditions on the assessments, 

such as limiting the number of days that TSA has to conduct its 

assessments. TSA supplements its limited international inspection 

resources by using inspectors that are assigned to conduct aviation 

security inspections inside the United States to help international aviation 

security inspectors conduct foreign airport assessments. In October 2006,

TSA implemented a risk-based methodology to prioritize which foreign 

 78See 49 U.S.C. § 44907(a)(1). TSA may conduct assessments at intervals it considers 

necessary to ensure that airports maintain and carry out effective security measures 

based, at least, on the standards and recommended practices of ICAO Annex 17. See 

§ 44907(a)(2). 

Page 39 GAO-07-660 Aviation Security
airports to assess based on an analysis of the risk of an attack at an airport 

as determined by credible threat information, the vulnerability of the 

airport’s security based on previous airport assessments, and the number 

of flights coming to the United States from a foreign airport.79 TSA officials 

stated that this approach will allow the agency to focus its limited 

resources on airports that pose the most significant risk to the United 

States and aviation security.80

TSA officials stated that the agency has not performed assessments of all 

foreign airports with service to the United States, in part because of 

political sensitivities associated with foreign airport assessments and 

because limited international oversight resources may affect whether TSA 

assesses additional airports. Therefore, TSA cannot determine whether 

cargo transported from foreign airports at which it has not performed an 

airport assessment poses a security risk. 

CBP Has Begun Efforts to 

Address the Security of 

Inbound Air Cargo, but 

These Efforts Can Be 

Expanded 

To prevent WMD and other elements of terrorism from unlawfully entering 

the United States, CBP uses its automated targeting system, referred to as

ATS, and other information to identify cargo that may pose a relatively

high security risk, so it can undergo inspection once the cargo arrives in 

the United States. In July 2006, CBP began using ATS to target inbound air 

cargo on passenger and all-cargo aircraft that may pose a security risk.81 As 

discussed previously, ATS uses weighted rules or criteria that assign a risk 

score to each arriving shipment based on a variety of factors. This includes 

the submission of cargo manifest information required by CBP either at an 

aircraft’s time of departure for the United States or no later than 4 hours 

prior to arrival, as specified in regulation.82 Inbound air cargo transported 

 79Prior to October 2006, TSA scheduled assessments by categorizing airports into two

groups. Airports that historically had met or exceeded international security standards

were assessed once every 3 years, while airports that did not regularly meet international 

standards or had not been previously assessed were visited annually. 

80We are currently conducting an evaluation of TSA’s foreign airport assessment program

and air carrier compliance inspection program, and are scheduled to publish a Sensitive 

Security Information report in April 2007. 

81In addition to cargo identified through ATS, CBP also performs random inspections of

cargo through its compliance measurement program. According to CBP officials, these 

inspections are conducted on a stratified sample, using data contained in ATS. CBP 

officials noted that the results of the random inspections are compared with the results of 

ATS inspections to improve future targeting efforts.

82See 19 C.F.R. § 122.48a. 

Page 40 GAO-07-660 Aviation Security
by passenger and all-cargo air carriers that is targeted for security reasons 

by ATS is inspected by CBP personnel stationed at airports in the United 

States.83 CBP officials stated that the extent to which a cargo shipment is 

inspected depends on the risk score it receives, as well as the type of 

commodity that is shipped.84

CBP’s targeting policy describes the roles and responsibilities of CBP 

personnel involved in targeting air cargo transported on passenger and allcargo air carriers that may pose a security risk and inspecting such cargo 

once it enters the United States.85 CBP’s targeting policy also includes 

details on the risk scores given to shipments that require inspection by

CBP personnel.86 The policy also describes what an inspection of high-risk 

air cargo should include, such as the use of X-rays; inspection with 

radiation detection technology, such as personal handheld radiation 

detectors; and physical inspection. CBP has also established performance 

goals related to its efforts to target and inspect air cargo transported into 

the United States on passenger and all-cargo aircraft. Specifically, these

performance goals relate to (1) targeting, controlling, inspecting, and 

interdicting high-risk air cargo shipments that may pose a threat to the

national security of the United States, including instruments of terror or 

 83CBP is currently not using ATS, but rather the proprietary systems of express

consignment couriers, such as UPS and Fed Ex, to target inbound air cargo these carriers

transport. According to CBP officials, CBP officers are provided access to the proprietary

systems and inspect high-risk shipments identified through these systems. CBP is in the 

process of developing policies and procedures to screen information on cargo transported

on express consignment couriers through ATS. 

84CBP officials added that the knowledge and experience of the CBP officer conducting the

inspection factors in on the extent to which a cargo shipment is inspected. Specifically, the 

extent to which a cargo shipment is inspected depends on what the officer needs to see to

feel comfortable that the cargo shipment does not pose a threat. 

85According to CBP officials, its targeting policy does not apply to express consignment 

couriers that sometimes make a stop at an intermediate airport in the United States, prior

to its final arrival at an all-cargo carrier’s hub facility, such as Memphis for FedEx or 

Louisville for UPS. According to CBP, air carrier hubs are adequately staffed to conduct air 

cargo inspections, while intermediate airports have limited inspection resources. CBP

officials acknowledge the importance of developing a targeting policy that specifically 

applies to express consignment couriers and plans to issue such a policy sometime during 

2007. 

86CBP’s policy also states that any shipment determined to be related to terrorism or 

terrorist activities, regardless of score, should be examined at the first airport of arrival. 

Factors that may contribute to this determination include, but are not limited to, national 

intelligence, a validated exact terrorism match, FBI terrorist information, and alerts from a

foreign country intelligence service or similar factors. 

Page 41 GAO-07-660 Aviation Security
any commodity with a link to terrorism, narcotics, and other contraband, 

and agriculture risks, and (2) the accountability and reconciliation of all 

identified high-risk air cargo shipments. To gauge its effectiveness of 

meeting these goals, CBP recently drafted performance measures in 

conjunction with its targeting policy. According to CBP, many of the 

measures are new and will first be tested at selected airports to assess 

their feasibility, utility, and relevancy. These performance measures 

include the number of shipments identified by CBP as having direct ties to 

terrorism, the number of shipments that have been identified for further 

examination based on an anomaly in a nonintrusive inspection, the 

number of shipments that CBP holds, and the type of inspection findings. 

CBP did not provide us with a time frame for when these performance 

measures would be fully implemented. 

Our previous reports identified challenges that CBP faced when targeting 

oceangoing cargo shipped in containers for inspection.87 Specifically, we 

reported that CBP did not have a comprehensive, integrated process for 

analyzing inspection results of oceangoing cargo and incorporating these 

results into its targeting system. We also identified limitations with the 

information CBP used to target oceangoing cargo, such as vague or 

incomplete cargo manifests. We concluded that without complete and

accurate information on shipments, it was difficult for CBP’s targeting 

system to accurately assess the risk of shipments and to conduct thorough 

targeting. We also found that CBP did not yet have a system in place to 

report sufficient details of the results of security inspections nationwide 

that could allow management to analyze those inspections and 

systematically adjust its targeting system. We noted that without a more 

comprehensive feedback system, the effectiveness of CBP’s targeting 

system could be limited. CBP officials acknowledged that the problems 

identified with ATS’s effectiveness in targeting oceangoing cargo would 

also apply to CBP’s efforts to target inbound air cargo. For example, CBP 

uses cargo manifests as a data source to identify high-risk cargo 

shipments, but according to some air carrier representatives, the 

information contained in these manifests is not always complete or 

 87GAO, Cargo Container Inspections: Further Improvements to the Automated Targeting 

System Are Needed, GAO-06-809SU (Washington, D.C.: August 2006), Cargo Container 

Inspections: Preliminary Observations on the Status of Efforts to Improve the Automated

Targeting System, GAO-06-591T (Washington, D.C.: March, 30, 2006), Homeland Security: 

Challenges Remain in the Targeting of Oceangoing Cargo Containers for Inspection,

GAO-04-352NI (Washington, D.C.: Feb. 20, 2004), and Container Security: A Flexible

Staffing Model and Minimum Equipment Requirements Would Improve Overseas 

Targeting and Inspection Efforts, GAO-05-557 (Washington, D.C.: April 2005). 

Page 42 GAO-07-660 Aviation Security
accurate. CBP’s new effort to target and inspect inbound air cargo 

transported on passenger carriers that may pose a security risk provides 

CBP an opportunity to strengthen its targeting activities by addressing the 

issues with its targeting system that we previously identified.

DHS’s strategy for addressing the threat of nuclear and radiological 

terrorism includes deploying radiation detection equipment at U.S. ports 

of entry, including airports. CBP plans to deploy radiation portal monitors 

at international airports by September 2009 in order to inspect 100 percent 

of inbound cargo for radiation.88 We have previously reported that 

currently deployed radiation portal monitors have limitations and that 

CBP is behind schedule in deploying radiation portal monitors at U.S. 

ports of entry, including airports.89 Specifically, we reported that the portal 

monitors are limited by the type of radioactive materials they are able to

detect and they cannot differentiate naturally occurring radiological 

material from radiological threat material. We also reported that meeting 

DHS’s goal to deploy over 3,000 radiation portal monitors at U.S. ports of 

entry, including U.S. airports, by September 2009 was unlikely. As of 

December 2005, CBP had deployed 57 radiation portal monitors at U.S. 

facilities that receive international mail and express consignment courier 

facilities in the United States, but had not yet deployed monitors at U.S. 

airports that receive inbound air cargo.90 CBP officials cited a lack of 

resources as the primary reason for not being able to purchase and deploy 

more monitors, including those at U.S. international airports. Until CBP 

fully deploys radiation portal monitors at international airports that 

receive inbound air cargo, CBP’s efforts to effectively inspect air cargo 

once it enters into the United States for radiological weapons or the 

materials to build such a weapon may be limited. 

Another effort CBP has under way to secure the security of inbound air 

cargo is the voluntary C-TPAT program. This program is aimed at 

strengthening the international supply chain and U.S. border security. In 

 88The first four phases of CBP deployment of radiation portal monitors include 

(1) international mail and express courier facilities, (2) major northern border crossings, 

(3) major seaports, and (4) southwestern border crossings.

89GAO, Combating Nuclear Smuggling: DHS Has Made Progress Deploying Radiation

Detection Equipment at U.S. Ports of Entry, but Concerns Remain, GAO-06-389

(Washington, D.C.: March 2006). 

90The 57 radiation portal monitors do not include those monitors deployed at Fed Ex and 

UPS, both of whom inspect air cargo at their overseas facilities as agreed in a 

memorandum of understanding with CBP. 

Page 43 GAO-07-660 Aviation Security
exchange for implementing security policies and procedures, such as preemployment screening, periodic background reviews, and employee 

training on security awareness and procedures, CBP provides C-TPAT 

participants, including foreign and domestic air carriers, with a reduced

likelihood that their cargo will be inspected once it arrives in the United 

States. According to CBP, while there are more than 6,000 participants in 

the C-TPAT program, as of June 2006, only 31 of the approximately 

200 foreign and domestic air carriers that transport cargo into the United 

States, and only 52 of the potentially thousands of freight forwarders that 

consolidate cargo departing by air for the United States, are participating 

in the program. 

Some foreign air carriers and foreign freight forwarders we spoke with 

stated that although CBP has made them aware of C-TPAT benefits, they 

have not applied for program membership because they do not see the 

value of participating in C-TPAT. Specifically, these air carriers and freight

forwarders noted that participation in C-TPAT does not ensure quicker 

delivery times of their shipments and therefore does not benefit them. 

According to CBP officials, while C-TPAT offers participants a wide range

of benefits, such as a reduced number of inspections and priority 

processing for inspections, CBP cannot compel air carriers to participate 

in the program because the C-TPAT program is voluntary. CBP has, 

however, identified expanding the number C-TPAT participants, including

air carriers, as one of its objectives in CBP’s fiscal years 2007-2011

Strategic Plan for Securing America’s Borders at Ports of Entry. 

At present, the requirements to become a member of C-TPAT are more 

broadly written for air carriers and freight forwarders than they are for 

importers, sea carriers, and highway carriers because CBP has not yet 

finalized specific security criteria for air carriers and freight forwarders 

participating in the program. According to CBP officials, they have drafted

specific security criteria for air carriers. However, the finalization of the 

air carrier criteria has been placed on hold, as CBP is in the process of 

conducting a comprehensive review of its current air cargo strategy, 

including how CBP will incorporate C-TPAT. 

DHS Is in the Early Stages 

of Testing Technologies to 

Strengthen Air Cargo 

Security 

DHS has taken some steps to incorporate new technologies into 

strengthening the security of air cargo, which will affect both domestic 

and inbound air cargo. However, TSA and DHS’s Science and Technology 

(S&T) Directorate are in the early stages of evaluating available aviation 

security technologies to determine their applicability to the domestic air 

cargo environment. TSA and S&T are seeking to identify and develop 

Page 44 GAO-07-660 Aviation Security
technologies that can effectively inspect and secure air cargo with minimal 

impact on the flow of commerce. DHS officials added that once the 

department has determined which technologies it will approve for use on 

domestic air cargo, they will consider the use of these technologies for 

enhancing the security of inbound air cargo shipments. According to TSA 

officials, there is no single technology capable of efficiently and effectively 

inspecting all types of air cargo for the full range of potential terrorist 

threats, including explosives and WMDs. As such, TSA, together with S&T, 

is conducting a number of pilot programs that are testing a variety of 

different technologies that may be used separately or in combination to 

inspect and secure air cargo. These pilot programs seek to enhance the 

security of air cargo by improving the effectiveness of air cargo

inspections through increased detection rates and reduced false alarm 

rates, while addressing the two primary threats to air cargo identified by

TSA—hijackers on an all-cargo aircraft and explosives on passenger 

aircraft.91

DHS’s pilot programs are testing a number of currently employed 

technologies used in other areas of aviation and transportation security, as 

well as new technologies. These pilot programs include 

• an air cargo explosives detection pilot program implemented at 

three airports, testing the use of explosive detection systems, 

explosive trace detectors, standard X-ray machines, canine teams, 

technologies that can locate a stowaway through detection of a 

heartbeat or increased carbon dioxide levels in cargo, and manual 

inspections of air cargo;92

• an explosive detection system (EDS) pilot program, which is testing 

the use of computer-aided tomography to compare the densities of 

objects to locate explosives in air cargo and to determine the longterm feasibility of using EDS equipment as a total screening process 

for break bulk air cargo;93

 91The current technology pilots do not include tests to identify chemical or biological 

weapons. 

92The Conference Report accompanying the Department of Homeland Security 

Appropriations Act, 2006, Pub. L. No. 109-90, 119 Stat. 2064 (2005), directed $30 million to 

the Science and Technology Directorate to conduct three cargo screening pilot programs

testing different concepts of operations. See H.R. Conf. Rep. No. 109-241, at 53 (2005). 

93Computer-aided tomography is a method of producing a three-dimensional image of the 

internal structures of an object from a large series of two-dimensional X-ray images taken 

around a single axis of rotation. 

Page 45 GAO-07-660 Aviation Security
• an air cargo security seals pilot, which is exploring the viability of 

potential security countermeasures, such as tamper-evident security 

seals, for use with certain classifications of exempt cargo; 

• the use of hardened unit loading devices, which are containers

made of blast-resistant materials that could withstand an explosion 

on board the aircraft; and 

• the use of pulsed fast neutron analysis (PFNA) which allows for the 

identification of the chemical signatures of contraband, explosives, 

and other threat objects (see appendix V for more detailed 

information on DHS’s and TSA’s air cargo security pilot tests). 

TSA anticipates completing its pilot tests by 2008, but has not yet 

established time frames for when it might implement these methods or 

technologies for the inbound air cargo system. As noted, some of the 

technologies being pilot-tested are currently employed or certified for use 

in other areas of aviation security, to include air cargo. According to DHS 

and TSA officials, further testing and analysis will be necessary to make 

determinations about the capabilities and costs of these technologies 

when employed for inspecting inbound air cargo at foreign locations. 

TSA and CBP Have Taken 

Some Steps to Coordinate 

Efforts Related to Inbound 

Air Cargo Security, but Do 

Not Have Processes in 

Place to Communicate 

Important Information 

Pursuant to Homeland Security Presidential Directive 7, TSA is 

responsible for coordinating with relevant federal agencies, such as CBP, 

to secure the nation’s transportation sector, including the air cargo 

system.94 TSA and CBP have taken a number of steps to coordinate their 

respective efforts to safeguard air cargo transported into the United 

States. For example, CBP shared its experience in targeting international

cargo shipments with TSA to help the agency develop a system to target 

elevated-risk domestic air cargo shipments for inspection.95 Moreover, in 

2003, interagency working groups were established to share information 

on TSA’s technology development programs and CBP’s air cargo targeting 

activities, among other things. In addition, TSA and CBP officials at the 

three U.S. airports we visited told us that both agencies discuss aviation 

 94Homeland Security Presidential Directive 7 (HSPD-7), issued in December 2003, defines

critical infrastructure protection responsibilities for DHS, sector-specific agencies (those 

federal agencies given responsibility for transportation, energy, telecommunications, and 

so forth), and other departments and agencies. HSPD-7 specifically directed the 

Department of Transportation and DHS to collaborate on all matters relating to 

transportation security and transportation infrastructure protection. DHS subsequently 

designated TSA as the lead agency for addressing HSPD-7 as it relates to securing the 

nation’s transportation sector. 

95According to CBP officials, CBP is not currently assisting TSA with the development of a

system to target domestic air cargo for inspection. 

Page 46 GAO-07-660 Aviation Security
security issues, including inbound air cargo, during weekly or monthly 

meetings with airport representatives and other aviation industry 

stakeholders. These officials also stated that TSA and CBP staff located at

U.S. airports participate in operational planning and compliance 

inspection activities, and that these task forces and inspection activities 

may include inbound air cargo security issues. 

While these collaborative efforts are important, the two agencies do not 

have a systematic process in place to ensure that they are communicating 

information on air cargo security programs and requirements, such as the

results of compliance oversight and targeting activities that could be used

to enhance the security of inbound air cargo. Both collect information that 

each other could use. For example, if TSA’s compliance inspection results 

indicated that certain air carriers were in violation of TSA air cargo 

inspection requirements, CBP could use this information to assess the risk 

of inbound air cargo shipments from these particular air carriers. 

Moreover, if air carrier inspections revealed routine problems with certain 

types of shipments or certain shippers, CBP could use this information to 

apply greater scrutiny to those types of shipments or shippers. Likewise, if 

TSA’s foreign airport assessments identify airports that are not meeting 

international security standards, CBP could use this information to 

improve its inbound air cargo targeting efforts. TSA also requires air 

carriers transporting cargo into the United States to randomly inspect a 

certain percentage of inbound cargo and compile information on these 

inspections. These inspection results could indicate which shipments were 

inspected, the outcome of those inspections, and the location at which the 

inspections took place. Similarly, CBP collects information that could be

useful to TSA’s efforts to secure inbound air cargo. For example, 

information gathered from CBP’s inbound air cargo targeting and 

inspection activities could be used by TSA to help focus its compliance 

oversight efforts on those air carriers whose shipments have been 

identified by CBP as posing an elevated security risk. In addition, the 

results of CBP officers’ inspection of inbound air cargo could be used by 

TSA to make risk-based decisions regarding the types of cargo air carriers 

should be required to inspect, based on its contents and points of origin, 

prior to its departure to the United States. 

Without a systematic process to communicate relevant air cargo security 

information, TSA and CBP are limited in their ability to most effectively 

secure inbound air cargo. TSA and CBP officials agreed that a process to 

improve information sharing could provide opportunities for enhancing 

their respective efforts to secure inbound air cargo. Specifically, CBP 

officials stated that information on the results of TSA’s compliance 

Page 47 GAO-07-660 Aviation Security
inspections of air carriers and assessments of foreign airport security, as 

well as the results of air carrier inspections of air cargo prior to its 

transport to the United States, could potentially help CBP in targeting 

high-risk inbound air cargo shipments for inspection upon its arrival in the 

United States. TSA officials also stated that having access to the results of 

CBP’s inbound air cargo targeting and inspection activities could be used 

to potentially strengthen existing TSA air cargo security requirements. 

Although both agencies agree that sharing relevant air cargo information 

could help to more effectively secure inbound air cargo, neither TSA or 

CBP has plans to establish a process to share information on the other’s 

air cargo security programs and requirements and the results of 

compliance oversight and targeting activities that could be used to 

enhance the security of inbound air cargo. 

While some of the security practices employed by foreign governments 

that regulate airports with high volumes of cargo and domestic and foreign 

air carriers that transport large volumes of cargo are similar to those 

required by TSA, we identified some security practices that are currently 

not used by TSA that could have potential for strengthening the security of 

inbound and domestic air cargo supply chains.96 Although TSA has 

initiated a review of select countries’ air cargo security practices, the 

agency has not systematically compiled and analyzed information on 

actions taken by foreign countries and foreign and domestic air carriers to 

determine whether the benefits that these practices could potentially have

in strengthening the security of the U.S. and inbound air cargo supply 

chain are worth the cost. In addition, DHS has begun working with foreign 

governments to develop uniform air cargo security standards and to 

mutually recognize each other’s security standards, referred to as 

harmonization. However, challenges to harmonizing security practices 

may limit the overall impact of TSA’s efforts. 

Foreign Air Cargo 

Security Practices and 

International 

Harmonization Efforts 

Have Potential to 

Enhance Air Cargo 

Security, but May Be 

Challenging to 

Implement 

 96Specifically, these include security practices at 8 foreign airports, 4 of which rank among

the world’s 10 busiest cargo airports, and security practices implemented by 7 of the

world’s 10 largest air cargo carriers.

Page 48 GAO-07-660 Aviation Security
TSA, foreign governments, and foreign and domestic industry stakeholders

employ some similar air cargo security practices, such as inspecting a 

specific percentage of air cargo or the use of specific technologies to 

inspect air cargo. However, 18 of the 22 industry stakeholders and 9 of the 

11 countries we compiled information on reported that they have 

implemented security practices that differ in some way from those 

required by TSA to ensure the security of air cargo they transport both 

within their own countries and into the United States. Some of these 

practices could potentially be used to mitigate terrorist threats and 

strengthen TSA efforts to secure inbound air cargo when employed in 

conjunction with current TSA security practices. While we observed a 

range of security practices used by foreign countries, we identified four 

categories of security practices implemented by foreign governments and 

foreign and domestic air carriers that could potentially enhance the 

agencies’ efforts to secure air cargo. These practices include (1) the use of

air cargo inspection technologies and methods, (2) the percentage of air 

cargo inspected, (3) physical security and access control methods for air 

cargo facilities, and (4) procedures for validating known shippers.97 We 

focused on these practices based on input from air cargo industry 

stakeholders. We did not compare the effectiveness or cost of foreign 

practices with current TSA requirements and practices. Rather, we 

determined whether the use of these security practices differed from 

existing TSA efforts to secure domestic and inbound air cargo and could 

have the potential to augment the department’s current efforts to secure 

domestic and inbound air cargo. For additional information on actions 

taken by domestic and foreign air carriers with operations overseas and 

air cargo industry stakeholders to secure air cargo, see the table in 

appendix VI. Additional information about the actions taken by foreign 

governments to secure air cargo is included in the table in appendix VII. 

Three of the 17 air carriers and 1 of the 7 countries we visited require the

use of large X-ray machines to inspect entire pallets of cargo transported 

on passenger aircraft.98 These machines allow for cargo on pallets to 

undergo X-ray inspection without requiring the pallet to be broken down 

Foreign Governments and 

Air Cargo Industry 

Stakeholders Have Taken 

Some Actions That Might 

Provide Opportunities to 

Strengthen U.S. Domestic 

and Inbound Air Cargo 

Security, but TSA Has Not 

Systematically Compiled 

and Analyzed This 

Information 

Air Cargo Inspection 

Technologies and Methods 

 97TSA uses the term “known shipper” to refer to shippers of cargo that have met certain 

criteria established by the agency and have an established shipping history with an air 

carrier or indirect air carrier. These entities are also referred to as known consignors in

other countries. 

98These figures may be higher than reported because some countries we visited and air 

carriers we met with were not specific about the type of X-ray technology they employ. 

Page 49 GAO-07-660 Aviation Security
and reconfigured. Government officials from the country that uses large 

X-ray machines stated that this technology allows for the expedited 

inspection of high volumes of large cargo items, without impeding the flow

of commerce. CBP also uses this technology to inspect inbound air cargo 

once it enters the United States. While DHS’s S&T and TSA have recently 

begun to research large X-ray technology, TSA officials stated that the 

agency has not established time frames for developing and testing X-ray

technology capable of inspecting large pallets of cargo transported 

domestically or at a foreign location prior to its transport to the United 

States. Without further consideration of the use of large X-ray technology,

which may have been enhanced over the past 8 years, TSA may be limited

in its ability to make such determinations regarding its effectiveness in the 

post-September 11 air cargo environment. 

In addition, three domestic all-cargo carriers with operations overseas 

have independently chosen to employ radiation detection technologies to

inspect air cargo for potential WMD and other radiological items prior to

the cargo being transported on an all-cargo aircraft. Specifically, one allcargo air carrier determined that the introduction of a WMD onto aircraft 

poses a significant threat. As a result, this carrier inspects cargo shipments 

using radiation detection portals and handheld radiation detectors. 

According to TSA officials, the agency does not currently require air 

carriers to conduct inspections of air cargo to detect WMD prior to its 

transport into the United States because the agency considers mitigating 

the threat of WMD to be the responsibility of CBP. 

Further, two European countries are currently using canines in a different

manner than TSA to inspect air cargo for explosives. Specifically, these 

countries are using the Remote Air Sampling for Canine Olfaction 

(RASCO) technique, which involves the use of highly trained dogs to sniff 

air samples collected from air cargo or trucks through a specially designed

filter. The dogs sniff a series of air samples to determine whether or not 

there is a trace of explosives and indicate a positive detection by sitting 

beside the sample. According to foreign government officials representing

two of the countries that use this technique, tests to determine the 

effectiveness of this practice have shown that RASCO has a very high rate

of effectiveness in detecting traces of explosives in cargo. According to 

foreign government officials, this inspection method can be used on cargo 

that is difficult to inspect using other methods, due to size, density, or 

clutter, and does not require the breakdown of large cargo pallets. Further, 

Page 50 GAO-07-660 Aviation Security
officials stated that the dogs used in RASCO do not tire as easily as dogs 

involved in searching cargo warehouses, and can therefore be used for a 

longer period of time.99 Both TSA and CBP have certified canine teams for 

use in detecting explosives in baggage and currently use dogs for air cargo

inspection. These canine teams are currently used to search narrow and 

wide-body aircraft, vehicles, terminals, warehouses, and luggage in the 

airport environment. According to TSA officials, while the results of 

previous agency tests of RASCO raised questions about its effectiveness, 

they continue to work with their international counterparts to obtain 

information on the feasibility of using RASCO to inspect air cargo. TSA 

officials stated that the agency has not yet determined whether RASCO is 

sufficiently effective at finding explosive in quantities that could cause 

catastrophic damage to an aircraft and whether this technique will be 

approved for use in the United States. 

The majority of the countries we visited and the majority of air carriers we 

spoke with have taken several actions to increase the percentage of air 

cargo that is inspected as well as using threat information to target certain

cargo for inspection prior to transport. For example, 6 of the 17 foreign

and domestic air carriers we met with are either required by their host 

government or have independently chosen to inspect a higher percentage

of air cargo shipments, with X-ray technology or other inspection 

methods, than is currently required by TSA.100 Air carrier officials stated 

that the decision to inspect a higher percentage of air cargo is based on 

several considerations, including concerns about the terrorist threat to 

passenger aircraft, as well as concerns regarding the security of the air 

cargo supply chain in their host country. In addition, in 4 of the 7 countries 

we visited, air cargo inspections are conducted earlier in the supply chain 

prior to the cargo’s consolidation and delivery to airports. Specifically, the 

governments in these 4 countries permit inspections to be conducted by 

regulated agents who meet certain government requirements, such as 

Percentage of Air Cargo 

Inspected 

 99Unlike for RASCO, canines used to physically search cargo storage facilities and aircraft 

can typically work for about 30-minute intervals at a time before needing to rest. 

100Officials from one foreign passenger air carrier stated that, because of unique security 

concerns, their personnel are required to inspect 100 percent of air cargo transported on

their aircraft. These officials also acknowledged that they are able to inspect 100 percent of 

air cargo because of the small volume of cargo transported in this country and the small 

amount of passenger flights.

Page 51 GAO-07-660 Aviation Security
maintaining an approved security program.101 Foreign government officials 

we spoke with stated that this practice contributed to the security of air 

cargo because it increased the total amount of cargo inspected and 

facilitated the inspection of cargo earlier in the supply chain. Finally, the 

majority of air carriers we spoke with have independently chosen to use 

available threat information to determine how much scrutiny and what 

methods to apply to certain cargo prior to its transport on aircraft. 

Specifically, 9 of the 17 passenger and all-cargo air carriers we interviewed 

target their air cargo inspection efforts based on analyses of available 

threat information, among other factors that could affect air cargo 

security. 

TSA recently increased the amount of cargo air carriers are required to 

inspect and initiated efforts to require freight forwarders to inspect 

domestic air cargo earlier in the supply chain. The agency, however, has 

not evaluated the procedures foreign countries and air carriers use to 

inspect a higher percentage of air cargo without affecting the flow of 

commerce to determine whether the cost of using these procedures would 

be worth the potential benefits of enhanced security. Moreover, unlike the

majority of foreign and domestic air carriers we interviewed, TSA does not 

adjust the percentage of air cargo air carriers are required to inspect based 

on threat information related to specific locations. While TSA requires 

passenger air carriers to implement additional security requirements for 

inspecting checked baggage and passengers for flights departing from 

high-risk locations, the agency has not implemented additional 

requirements for air cargo departing from these same locations. Agency 

officials stated that new air cargo security requirements, contained in the 

agency’s air cargo security rule, are adequate to safeguard all air cargo 

transported into the United States, including cargo transported from highrisk locations. TSA officials added that the agency would consider 

implementing additional air cargo security requirements for high-risk 

locations if intelligence information became available that identified air 

cargo transported from these locations as posing a high risk to the United

States. CBP, however, currently considers information on high-risk 

locations to identify cargo that should undergo inspection upon its arrival

in the United States. In October 2006, TSA issued an emergency 

 101According to European Union Regulation 2320, a regulated agent is an agent, freight

forwarder, or other entity that conducts business with an air carrier and provides security 

controls that are accepted or required by the appropriate authority in respect of cargo,

courier, and express parcels or mail. In the United States, “indirect air carrier” (IAC) is the 

term used to refer to freight forwarders validated by TSA. 

Page 52 GAO-07-660 Aviation Security
amendment requiring indirect air carriers, under certain conditions, to 

inspect a certain percentage of air cargo prior to its consolidation. While 

TSA’s efforts to require freight forwarders to inspect domestic air cargo 

earlier in the supply chain have the potential for enhancing domestic air 

cargo security, we have previously identified problems with TSA’s 

oversight of freight forwarders to ensure they are complying with air cargo

security regulations.102

In addition to inspecting air cargo prior to its transport on aircraft, we 

identified additional security practices implemented by air carriers and 

foreign governments to physically secure air cargo and air cargo facilities. 

For example, two foreign governments require that all air cargo be stored 

in a secured terminal facility located within a restricted area of the airport 

to prohibit tampering to the cargo prior to its loading onto an aircraft. At 

some airports with restricted areas, individuals accessing these areas must 

first undergo physical screening through the use of walk-through metal 

detectors or biometric identification systems. For instance, one all-cargo 

air carrier uses a biometric hand-scanning identification system to grant 

employees access to air cargo storage facilities. In addition, 10 of the 17 air 

carriers we interviewed are subject to audits of the access controls at air 

cargo facilities to assess security vulnerabilities at such a facility. If the 

test results in a breach of security, all cargo contained within the breached 

facility must be inspected before it is permitted to be loaded onto a 

passenger or all-cargo aircraft. TSA acknowledged the importance of 

enhancing the security of air cargo and air cargo facilities, and included 

provisions in the agency’s air cargo security rule for applying or expanding

the secure identification display area (SIDA) requirements at U.S. airports 

to include areas where cargo is loaded and unloaded.103 However, TSA has 

no plans to require additional air cargo access control measures. 

Physical Security and Access 

Controls for Air Cargo 

Facilities 

Two of the 7 countries we visited employ stringent programs for validating 

known shippers that differ from the program used in the United States. 

For example, 1 country we visited requires its known shippers or those 

Procedures for Validating 

Known Shippers 

 102GAO-06-76. 

103An airport’s SIDA is not to be accessed by passengers and typically encompasses areas

near terminal buildings, baggage loading areas, and other areas that are close to parked 

aircraft and airports facilities, including air traffic control towers and runways used for 

landing, take off, or surface maneuvering. SIDA security requirements include security 

awareness training for all workers with access to area, measures to detect and respond to

unauthorized presence in the SIDA area, and access controls that meet performance

standards (for example, proximity cards and personal identification number). 

Page 53 GAO-07-660 Aviation Security
shippers that have met certain criteria and have an established shipping 

history, referred to as known consignors in the country, to be validated by 

government-approved contractors. Prior to implementing this 

requirement, the country’s consignor program allowed regulated agents 

and airlines to assess and validate their own consignors with whom they 

did business. However, according to government officials, the previous 

program was ineffective because it allowed for breaches in the security of

the air cargo supply chain, such as the implementation of weak security 

programs by shippers and conflicts of interest among air carriers and their

customers.104 We previously reported on the limitations of TSA’s current 

known shipper program, such as the relative ease of TSA’s requirements 

for becoming a known shipper.105 Under this foreign country’s new 

program, validations of known consignors are conducted by independent 

third parties that have been selected, trained, and accredited by the 

government. The government maintains the authority to remove a 

validator from an approved list, accompany a validator on a site visit, or 

conduct unscheduled spot visits to known consignor sites. 

To become known in this particular country, the consignor can choose 

from a list of over 100 validators to schedule a validation inspection. The 

validation process is conducted using a checklist of security requirements 

that includes the physical security measures in place at the site, staff 

recruitment, personnel background checking and security checks, access 

control to the site, air cargo packing procedures, and storage of secure 

cargo, among other things.

106 After the initial validation inspection, 

consignors must be reassessed every 12 months to retain their known 

status. During the first round of assessments conducted, 70 percent of 

existing known customers failed to become known consignors because of

the stricter security requirements in place under the new scheme. Since 

the new validation program requires program participants to implement 

stricter security practices for securing air cargo before it is delivered to 

 104Under this foreign country’s previous validation program, shippers could become known

if they were validated by a certified regulated agent and underwent site and operations 

inspections at least once a year. The cargo from these customers was then considered 

“secure” or “known.” In 2003, the country’s government introduced a new program that 

removed the responsibility for assessing consignors from regulated agents and airlines. 

Validations have since been carried out by independent, government-appointed validators. 

105GAO-06-76. 

106Recruitment procedures must include a reference check of at least 5 years, or until the

end of full-time education, without gaps. 

Page 54 GAO-07-660 Aviation Security
the air carrier, it helps to ensure that cargo coming from known 

consignors has been adequately safeguarded. 

While TSA’s air cargo security rule contains provisions for enhancing the 

agency’s known shipper program, such as making air carrier and indirect 

air carrier participation in the agency’s centralized database mandatory, it

did not modify TSA’s current process for validating known shippers, which 

remains the responsibility of indirect air carriers and air carriers.107

Accordingly, passenger, all-cargo, and indirect air carriers will continue to

be responsible for entering shipper information into TSA’s central known 

shipper database, which may allow for potential conflicts of interest 

because air carriers who conduct business with shippers will also 

continue to have the authority to validate these same shipping customers. 

TSA officials stated that the agency will continue to rely on its mandatory 

centralized known shipper database that allows air carriers and indirect 

air carriers to validate shippers as known until it develops a system that 

would enable TSA to validate known shippers. According to TSA officials, 

however, the agency is not considering implementing a program that relies 

on an independent third party to validate shippers because high 

administrative costs, combined with the large number of shippers located

within the United States, may make it difficult to implement a third-party 

validation program. Foreign government officials stated that using third 

parties to validate shippers has enhanced the countries’ air cargo security

by reducing the number of shippers that are considered known and by 

introducing more security controls at an earlier point in the supply chain.

Although the implementation of a third-party validation program may be 

challenging in the United States, without further analysis of such a 

program, TSA may be missing an opportunity to determine the extent to 

which all or parts of a similar scheme could be incorporated into the 

agency’s current air cargo security practices. 

 107Additional information on TSA’s Known Shipper program and database is contained in 

our report on domestic air cargo security (GAO-06-76). 

Page 55 GAO-07-660 Aviation Security
We previously reported that in order to identify innovative security 

practices that could help further mitigate terrorism-related risk to 

transportation sector assets—especially as part of a broader risk 

management approach discussed earlier—it is important to assess the 

feasibility as well as the costs and benefits of implementing security 

practices currently used by foreign countries.108 However, DHS has not 

taken systematic steps to compile or analyze information that could 

contribute to the security of both domestic and inbound air cargo. In 

response to a recommendation made by DHS’s Science and Technology 

Directorate, TSA has taken initial steps to learn more about foreign air 

cargo security technologies and practices that could be applied in the 

United States.

109 For example, according to TSA officials, the agency

collects information on the security measures implemented by countries 

from which air carriers transport air cargo into the United States. In 

addition, the United States has agreements with several countries that 

allow TSA to visit and compile information on their aviation security 

efforts, including those related to air cargo. Likewise, officials from these

countries are allowed to visit the United States to learn about DHS’s 

aviation security measures. 

TSA Is Exploring the 

Applicability of Some 

Foreign Air Cargo Security 

Practices to the United 

States, but the Agency Has 

Not Systematically

Compiled and Analyzed 

These Practices to Assess 

Their Viability 

TSA officials acknowledge that further examination of how foreign air 

cargo security practices may be applied in the United States could yield 

opportunities to strengthen the department’s overall air cargo security 

program. While TSA has obtained some information on foreign air cargo 

security efforts, TSA officials acknowledged that the agency has not 

systematically compiled and analyzed information on foreign air cargo 

security practices to determine those, if any, that could be used to 

strengthen the agency’s efforts to secure air cargo. TSA officials stated 

that while some foreign air cargo security practices may hold promise for 

use in the United States, the agency and the air cargo industry face 

challenges in implementing some of these practices because the U.S. air 

cargo transportation system involves multiple stakeholders and is 

responsible for transporting large amounts of cargo on both passenger and 

all-cargo aircraft. While large amounts of air cargo are transported to and

 108GAO, Passenger Rail Security: Enhanced Federal Leadership Needed to Prioritize and 

Guide Security Efforts, GAO-05-851 (Washington, D.C.: September 2005), and GAO,

Aviation Security: Further Steps Needed to Strengthen the Security of Commercial

Airport Perimeters and Access Controls, GAO-04-728 (Washington, D.C.: June 2004).

109DHS, Science and Technology Directorate, “Systems Engineering Study of Civil Aviation 

Security-Phase I,” April 7, 2005. 

Page 56 GAO-07-660 Aviation Security
from U.S. airports on a daily basis, we identified air cargo security 

practices implemented at foreign airports that also process large volumes 

of air cargo shipments that may have application to securing domestic and 

inbound air cargo operations. For example, we observed the security 

practices at 8 foreign airports, 4 of which rank among the world’s 

10 busiest cargo airports. In addition, some of the security practices we

identified are being implemented by air carriers that transport large 

volumes of air cargo. Specifically, we spoke with air carrier officials 

representing 7 of the world’s 10 largest air cargo carriers. 

DHS Is Working with 

Foreign Governments and 

Air Cargo Stakeholders to 

Harmonize Air Cargo 

Security Efforts, but 

Inherent Challenges May 

Affect Their Progress 

In addition to taking initial steps to collect information on foreign air 

cargo security practices, DHS has also begun efforts to work with foreign 

governments to develop uniform air cargo security standards and to 

mutually recognize each other’s air cargo security practices—referred to 

as harmonization. Harmonization has security as well as efficiency 

benefits, including better use of resources and more effective information 

sharing. However, working with foreign governments to achieve 

harmonization may be challenging because these efforts are voluntary. 

Additionally, many countries around the world may lack the resources or 

infrastructure needed to develop an air cargo security program as 

developed as that of the United States. 

One way TSA is working with foreign governments is by collaborating on 

the drafting of international air cargo security standards. For example, 

according to TSA officials, agency representatives worked with foreign 

counterparts to develop Amendment 11 to ICAO’s Annex 17, issued in 

June 2006, which sets forth new standards and recommended practices 

related to air cargo security. In addition, TSA is working with the 

European Union to develop a database containing information on shippers 

and freight forwarders that will be shared between the United States and 

European Union member states. As of January 2007, TSA was negotiating 

with the European Union on (1) how information in the databases will be 

shared, (2) what information will be shared, and (3) how the shared 

information will be used by each entity. Currently, the European Union 

database can transmit data to the TSA system as part of the development 

and testing of the European Union system. However, TSA’s system will not 

be able to transmit data to the European Union’s database until TSA’s new 

known shipper and indirect air carrier databases are online, which TSA 

expects to occur sometime in late 2007. 

TSA and CBP Are Working with 

Foreign Governments to 

Develop Uniform Standards 

The term harmonization is defined 

differently by various international 

aviation security stakeholders. In the 

context of this report, the term 

harmonization is 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 mutually 

acceptable uniform standards.

The term harmonization is defined 

differently by various international 

aviation security stakeholders. In the 

context of this report, the term

harmonization is 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 mutually 

acceptable uniform standards.

CBP has also engaged in efforts to develop uniform air cargo security 

standards with select foreign countries. Specifically, CBP undertook a 

Page 57 GAO-07-660 Aviation Security
study with the Canadian Border Services Agency (CBSA) to identify 

similar air cargo security practices being carried out by CBP and CBSA 

and areas in need of improvement. The study made recommendations to 

enhance both agencies’ efforts to secure air cargo that included specific 

steps the agencies can take to harmonize security measures. For example, 

the study recommended that CBP and CBSA explore harmonizing air 

cargo targeting and inspection protocols, including the use of detection 

technology. The study also recommended that the two agencies share 

knowledge of emerging technologies. CBP’s fiscal years 2007-2011 

Strategic Plan for Securing the Nation’s Borders at Ports of Entry 

recognizes the need to partner with foreign governments to share relevant

information in an effort to improve cargo security, including cargo 

transported by air. 

According to foreign government and international air cargo industry 

representatives, the development of uniform air cargo security 

requirements and measures could provide security benefits by eliminating 

ineffective requirements and practices and focusing on automated or 

nonintrusive inspection technologies that could be universally employed 

to reduce the potential for human error. The cargo security mission of the 

International Air Transport Association, according to the association’s 

cargo security strategy 2006/2007, is to simplify cargo security by 

developing an integrated approach that involves all key supply chain 

stakeholder groups, and which is proportionate to the threat, effective, 

harmonized, and sustainable. The World Customs Organization’s 

Framework of Standards to Secure and Facilitate Global Trade has also 

called for aviation and customs security requirements to be harmonized 

into one integrated solution, to the extent possible. 

Foreign air carrier officials we spoke with also stated that developing 

uniform air cargo security standards related to performing background 

checks on air cargo workers, training air cargo workers, and controlling 

access to air cargo facilities would increase security levels in these areas. 

These officials added that uniform air cargo security requirements could 

facilitate industry compliance with security requirements. Further, foreign 

air carrier representatives and foreign government officials discussed the 

need to harmonize the terms used in the air cargo environment. For 

example, TSA uses the term “indirect air carriers” when referring to 

certified freight forwarders, whereas most other countries refer to these 

entities as “regulated agents.” In addition, TSA uses the term “known 

shipper” to refer to certified shippers, while most other nations use the 

term “known consignor” when referring to these same entities. 

Page 58 GAO-07-660 Aviation Security
Harmonized terminology would provide air cargo industry stakeholders 

clarification on which security requirements apply to them. 

Foreign and U.S. air cargo industry representatives and foreign 

government officials added that there is currently too much variation 

among countries regarding what type of air cargo must be inspected, what 

types of cargo are exempt from inspection, which entities should conduct 

the inspections, and what methods or technologies should be used to 

inspect air cargo. These representatives and officials stated that a 

harmonized inspection process would reduce duplicative efforts to inspect 

cargo shipments in order to meet different countries’ security 

requirements. According to industry officials, having to implement 

duplicative security requirements, particularly those related to air cargo 

inspections, can impede the flow of commerce, expose air cargo 

shipments to theft, and damage high-value items. For example, 

representatives from a U.S. air carrier stated that in one Asian country, 

government employees inspect 100 percent of outbound air cargo 

transported on a passenger air carrier. However, to meet U.S.

requirements, TSA requires passenger air carriers transporting air cargo

into the United States to inspect a certain percentage of nonexempt cargo

shipments, which would have already been inspected by the foreign 

government. Air carrier representatives stated that meeting TSA 

inspection requirements is problematic in certain foreign countries 

because air carriers are not permitted to re-inspect air cargo shipments 

that have already been inspected by foreign government employees and

deemed secure. These conflicts and duplication of effort could be avoided 

through mutually acceptable uniform air cargo security standards 

developed jointly between the United States and foreign countries. 

However, we recognize that because foreign countries’ requirements are 

so varied, and the threats to certain foreign airports are less than to others, 

TSA would have to consider accepting other countries’ inspection 

requirements on a case-by-case basis to determine the viability of such an

option. According to TSA officials, developing stronger uniform

international standards would improve the security of inbound air cargo 

and assist TSA in performing its mission. For example, TSA officials stated 

that the harmonization of air cargo security standards would provide a 

level of security to those entities not currently regulated by the agency, 

such as foreign freight forwarders and shippers. 

Page 59 GAO-07-660 Aviation Security
TSA has taken additional steps to begin mutual recognition of foreign air 

cargo security requirements in an effort to enhance the security of 

inbound air cargo. For example, TSA officials stated that the agency 

approved amendments to air carriers’ security programs in November 2001 

permitting those carriers operating out of the United Kingdom, France, 

Switzerland, Israel, and Australia to implement the air cargo security 

requirements of these foreign countries, in lieu of TSA’s. TSA officials 

stated that these five countries were selected based on agency officials’ 

recommendations and a review of the countries’ security programs to 

determine if country requirements and practices met or exceeded TSA 

requirements.110 In contrast, those air carriers operating out of a foreign 

country other than the five previously identified must implement their host 

government’s requirements in addition to TSA’s. Officials added that in 

order for these countries’ air cargo security programs to remain 

recognized by TSA, they must have met or exceeded TSA’s air cargo 

security requirements, including new requirements set forth in the air 

cargo security rule. TSA officials further stated that they do not currently 

have plans to review other countries’ air cargo security measures and that 

such reviews would be predicated on a host countries’ request. 

TSA and CBP Are Partnering 

with Foreign Governments to 

Begin Mutual Recognition of 

Air Cargo Security 

Requirements 

In addition, air carriers may seek TSA’s approval of amendments to their 

security programs that would enable the air carrier to implement 

alternative air cargo security measures that satisfy TSA’s minimum 

security requirements while maintaining compliance with the security 

requirements of the host government. According to TSA officials, the 

agency will approve these alternative measures as long as TSA deems that 

they meet ICAO’s standards and TSA’s minimum requirements. For 

example, officials noted that some foreign governments allow cargo from 

unknown shippers to be transported on passenger aircraft after that cargo

is inspected. Although this measure differs from the requirements in place 

in the United States that do not permit cargo from unknown shippers to be 

transported on passenger aircraft, TSA officials stated that the ICAO 

standards are being met and air carriers operating out of such countries 

are permitted to transport cargo into the United States. 

Foreign government officials, embassy officials, and foreign industry 

members with whom we met also stated that to lessen the burden on 

 110TSA officials stated that as of October 2006, the agency had completed its reexamination 

of the air cargo security requirements of these five countries and confirmed that security 

procedures were in place to meet the requirements. 

Page 60 GAO-07-660 Aviation Security
airports and air carriers, TSA should consider accepting the results of 

ICAO or European assessments of airports with passenger air carrier 

service to the United States, and air carrier compliance inspections 

conducted by the European Union in lieu of conducting their own 

assessments and inspections. According to foreign government officials, in 

addition to TSA air carrier inspections and foreign airport assessments, air 

carriers located at foreign locations and airports around the world are 

subject to inspections by ICAO, as well as their host country. The 

European Union has also recently begun to conduct its own assessments 

of the security of airports located within its member states. Officials from 

one country told us that TSA should consider accepting the results of 

European Union assessments in light of the progress the European Union 

has made in developing its oversight program. 

Foreign government officials also expressed concern over TSA’s 

inspections of foreign air carriers, saying that TSA lacks the authority 

under host government or international laws to assess foreign air carriers’ 

compliance with TSA’s security requirements that exceed ICAO’s 

standards. Notwithstanding this view, TSA is authorized under U.S. law to 

ensure that all air carriers, foreign and domestic, operating to, from, or 

within the United States maintain the security measures included in their 

TSA-approved security programs and any applicable security directives or 

emergency amendments issued by TSA.111 Although TSA security 

requirements support the ICAO standards and recommended practices, 

TSA may subject air carriers operating to, from, or within the United 

States to any requirements necessary and assess compliance with such 

requirements, as the interests of aviation and national security dictate.112

TSA officials acknowledged that they have discussed the possibility of 

using European Union airport assessment results to either prioritize the 

frequency of TSA’s assessments or to conduct more focused TSA 

assessments at European Union airports. According to TSA officials, the 

agency may also be able to use host government or third-party 

assessments to determine the aviation security measures to focus on 

during TSA’s own airport assessments in foreign countries. TSA is also 

considering reducing the number of assessments conducted at airports 

that are known to have effective security measures in place and focus 

inspector resources on airports that are known to have less effective 

 111See 49 U.S.C. §§ 44903, 44906; see also 49 C.F.R. §§ 1544.3, 1546.3. 

112See 49 U.S.C. § 44906. 

Page 61 GAO-07-660 Aviation Security
security measures in place. In addition, TSA is considering having a TSA 

inspector shadow a European Union inspection team for 1 or 2 days to 

validate the results of European Union assessments. Another option would 

be for TSA and the European Union to leverage their resources by 

conducting joint airport assessments. According to a European Union 

official, however, member states recently met to discuss sharing European

Union assessment results with TSA. Specifically, member states 

determined that until the European Union and TSA agree on how they will 

share sensitive security information with each other and how they will 

conduct joint assessments of each other’s airports, that at this time they 

will not share the results of European Union airport assessments with 

TSA. The European Union official further stated that member states will 

not share their European Union airport assessment results with TSA 

unless TSA reciprocates. The official added that member states may share 

the results of airport assessments conducted by their own internal auditing

entities with TSA, but it would be illegal for member states to share their 

European Union assessment results with TSA. 

TSA is also working closely with the European Union to develop mutually 

acceptable air cargo security measures. For example, in March 2005 a

bilateral meeting on air cargo security was held between the European 

Union and the United States. An objective of this meeting was to share 

information on the air cargo security policies being developed by both, 

which, in turn, may encourage mutual acceptance. The development of the 

European Union/United States joint air cargo database was a focus of this 

meeting. The meeting also provided the European Union an opportunity to 

comment on TSA’s notice of proposed rule making on air cargo security 

before the rule was finalized. 

Despite DHS’s efforts to harmonize international air cargo security 

practices, a number of key obstacles, many of which are outside of DHS’s 

control, may impede their progress. For example, because international 

aviation organizations, such as ICAO, have limited enforcement authority,

they can only encourage, but generally not require, countries to implement 

air cargo security standards or mutually accept other countries’ security 

measures. In addition, the implementation of uniform air cargo security 

standards may require the expenditure of limited resources. For example, 

according to European Union and air cargo industry officials, those 

countries with air cargo security programs that are less advanced than

those of the European Union and the United States may not have the 

resources or infrastructure necessary to enhance their air cargo security 

programs. 

Challenges to DHS’s 

Harmonization Efforts May 

Affect Progress 

Page 62 GAO-07-660 Aviation Security
In addition, some foreign governments do not share DHS’s view regarding 

the threats and risk associated with air cargo. For example, CBP has 

identified the introduction of terrorist weapons, including a WMD, as the 

primary threat to cargo entering the United States. Government officials 

from one country we met with, however, stated that they do not view the 

introduction of a WMD as a significant threat to air cargo security. 

Officials from another country stated that, unlike DHS, they do not 

consider stowaways as a primary threat to air cargo, while an official from 

a third country noted that it does not differentiate between the threats to

passenger air carriers and those to all-cargo carriers. In addition, while 

TSA prohibits cargo from unknown shippers from being transported on 

passenger aircraft, the European Union and one Asian country we 

obtained information from allows cargo from unknown shippers to be 

transported on passenger aircraft after the cargo is inspected. These 

countries also inspect 100 percent of cargo from unknown shippers that is 

transported on all-cargo aircraft, while TSA requires all-cargo air carriers 

to randomly inspect a portion of the air cargo they transport. These 

differing approaches to air cargo security may make the harmonization of 

inspection requirements difficult to achieve. 

Further, TSA faces legal challenges in mutually accepting the results of 

other entities’ airport assessments. According to TSA officials, the agency 

interprets its statutory mandate to conduct assessments of foreign airports 

to mean that TSA must physically observe security operations at a foreign 

airport. This interpretation, according to TSA, precludes TSA from relying 

solely on third-party or host government assessments. If the Secretary of 

DHS, on the basis of the results of a TSA assessment, determines that a 

foreign airport does not maintain and carry out effective security 

measures, the Secretary must take further action. Such actions include, 

among others, notifying appropriate authorities of the foreign government

of deficiencies identified, providing public notice that the airport does not 

maintain and carry out effective security measures, or suspending service

between the United States and the airport if it is determined a condition 

exists that threatens the safety or security of the passengers, aircraft, or 

crew, and such action is in the public interest.113 TSA officials noted that 

unlike DHS, ICAO has limited enforcement capabilities. However, TSA 

officials stated that the agency is taking steps to further emphasize 

reciprocity with other governments by encouraging them to assess 

 113See 49 U.S.C. § 44907(c)-(e). 

Page 63 GAO-07-660 Aviation Security
airports within the United States.114 Such an effort could help facilitate the 

agency’s foreign airport assessments and air carrier inspections. 

TSA officials also stated that although they are working with the European

Union to develop a process to share airport assessment and inspection 

results, the agency currently does not have an agreement with either the 

European Union or ICAO to share assessment results. TSA officials added 

that even if they obtain access to these results, TSA is still legally required 

to conduct its own assessments of airports at which air carriers have 

operations into the United States and will continue with inspections of air 

carriers that transport cargo into the United States. Information on the 

results of other governments’ airport assessments and air carrier 

inspections could help TSA focus its oversight resources on those 

countries and carriers that may pose a greater risk to the United States. In

addition, foreign government and embassy officials noted that it will be 

difficult to harmonize air cargo security standards and requirements until 

the international community develops an approach for sharing sensitive 

information, such as security requirements. Developing a process for 

sharing sensitive information could help the United States and other 

countries improve their understanding of each others’ security measures 

and identify overlapping or contradicting security requirements. 

While DHS has made significant strides in strengthening aviation security, 

it is still in the early stages of developing a comprehensive approach to 

ensuring inbound air cargo security. Until TSA and CBP take additional 

actions to assess the risks posed by inbound air cargo and implement 

appropriate risk-based security measures, U.S.-bound aircraft transporting 

cargo will continue to be vulnerable to terrorist attack. In October 2005, 

we recommended that TSA take a number of actions designed to 

strengthen the security of the nation’s domestic air cargo transportation 

system. Similar actions, if effectively implemented, could also strengthen 

the department’s overall efforts to enhance the security of inbound air 

cargo, both before the cargo has departed a foreign nation and once it has 

arrived in the United States. We are encouraged by TSA’s initial efforts to 

use a risk-based approach to guide its investment decisions related to 

inbound air cargo security while at the same time addressing other 

pressing aviation and transportation security priorities. However, risk 

Conclusions 

 114According to TSA officials, the concept of reciprocity has been a part of TSA’s airport 

assessment program since its inception. 

Page 64 GAO-07-660 Aviation Security
management efforts should begin with a strategy that includes specific 

goals and objectives, which TSA has not yet identified. Likewise, TSA’s 

efforts to prioritize inbound air cargo assets and guide decisions about 

protecting them could be strengthened by establishing a methodology and

time frames for completing risk assessments of inbound air cargo and 

determining how to use the results to target security programs and 

investments. Further, while TSA has drafted new requirements for 

securing inbound air cargo, without reexamining the rationale for existing

inspection exemptions specific to air cargo transported into the United 

States on passenger aircraft and making any needed adjustments to these 

exemptions, there will continue to be a vulnerability that could be 

exploited by terrorists. Moreover, without developing an inspection plan

that includes performance goals and measures to gauge air carrier 

compliance with air cargo security requirements, TSA cannot readily 

identify those air carriers that are achieving an acceptable level of 

compliance and focus the agency’s inspection resources on those air 

carriers with higher levels of noncompliance that may pose a greater risk. 

Coordination and communication between TSA and CBP is also important

to ensuring that gaps do not exist in the security of inbound air cargo. 

Without effectively sharing information, TSA’s and CBP’s inbound air 

cargo security activities may be less efficient and effective. While TSA and

CBP have separate missions within DHS, their responsibilities for the 

security of air cargo are complementary. A strategy that clearly defines 

TSA’s and CBP’s roles and responsibilities with regard to securing inbound 

air cargo could help ensure that all areas of inbound air cargo security are 

being addressed. TSA and CBP also lack a systematic process to share 

relevant air cargo security information, such as the results of air carrier 

compliance inspections and foreign airport assessments that could 

enhance both agencies’ efforts to secure air cargo. Such a process could 

provide opportunities for enhancing TSA’s and CBP’s respective efforts to

secure inbound air cargo. 

TSA’s efforts to coordinate with foreign governments and air cargo 

stakeholders are an important step toward developing enhanced and

mutually agreeable international air cargo security standards. While TSA 

has taken steps to obtain information on foreign air cargo security 

practices, further examination of how these practices may be applied in

the United States could yield opportunities to strengthen the department’s 

overall air cargo security program. Doing so could also enable the United 

States to leverage the experiences and knowledge of foreign governments 

and international air cargo industry stakeholders and help identify 

Page 65 GAO-07-660 Aviation Security
additional innovative practices to secure air cargo against a terrorist 

attack in this country. 

To help ensure that the Transportation Security Administration and 

Customs and Border Protection take a comprehensive approach to 

securing air cargo transported into the United States, in the restricted 

version of this report we recommended that the Secretary of Homeland 

Security direct the Assistant Secretary for the Transportation Security 

Administration and the Commissioner of U.S. Customs and Border 

Protection to take the following two actions: 

Recommendations for 

Executive Action 

(1) Develop a risk-based strategy, either as part of the existing air cargo

strategic plan or as a separate plan, to address inbound air cargo security,

including specific goals and objectives for securing this area of aviation

security. This strategy should clearly define TSA’s and CBP’s 

responsibilities for securing inbound air cargo, as well as how the agencies

should coordinate their efforts to ensure that all relevant areas of inbound 

air cargo security are being addressed, particularly as they relate to 

mitigating the threat posed by weapons of mass destruction. 

(2) Develop a systematic process for sharing information between TSA 

and CBP that could be used to strengthen the department’s efforts to 

enhance the overall security of inbound air cargo, including, but not 

limited to, information on the results of TSA inspections of air carrier 

compliance with TSA inbound air cargo security requirements and TSA 

assessments of foreign airports’ compliance with international air cargo

security standards. 

To help strengthen the Transportation Security Administration’s inbound 

air cargo security efforts, we recommend that the Secretary of Homeland 

Security direct the Assistant Secretary for the Transportation Security 

Administration to take the following four actions:

(3) establish a methodology and time frame for completing assessments of 

inbound air cargo vulnerabilities and critical assets, and use these 

assessments as a basis for prioritizing the actions necessary to enhance 

the security of inbound air cargo; 

(4) establish a time frame for completing the assessment of whether 

existing inspection exemptions for inbound air cargo pose an 

unacceptable vulnerability to the security of air cargo, and take steps, if 

necessary, to address identified vulnerabilities; 

Page 66 GAO-07-660 Aviation Security
(5) develop and implement an inspection plan that includes performance 

goals and measures to evaluate foreign and domestic air carrier 

compliance with inbound air cargo security requirements; and 

(6) in collaboration with foreign governments and the U.S. air cargo 

industry, systematically compile and analyze information on air cargo 

security practices used abroad to identify those that may strengthen the 

department’s overall air cargo security program, including assessing 

whether the benefits that these practices could provide in strengthening 

the security of the U.S. and inbound air cargo supply chain are costeffective, without impeding the flow of commerce. 

We provided a draft of this report to DHS for review and comments. On 

are reproduced in full in appendix VIII. DHS generally concurred with the 

report and recommendations. 

Agency Comments 

and Our Evaluation 

With regard to our recommendation to develop a risk-based strategy to 

address inbound air cargo security which clearly defines TSA’s and CBP’s 

responsibilities for securing inbound air cargo, particularly as they relate

to mitigating the threat posed by weapons of mass destruction, DHS stated 

that CBP is in the preliminary stages of developing its Air Cargo Security

Strategic Plan. According to DHS, the draft plan includes goals and 

objectives, such as capturing accurate advance information to effectively 

screen air cargo shipments; accounting for and reconciling all high-risk air 

cargo shipments arriving from foreign destinations; developing and 

enhancing partnerships to strengthen air cargo security while continuing 

to facilitate the movement of legitimate trade; and controlling, inspecting 

and interdicting all air cargo that may pose a threat to national security of

the United States. DHS also stated that CBP is coordinating with TSA in 

the refinement of CBP’s Air Cargo Security Strategic Plan. Current efforts 

include discussions with TSA management and the review of relevant 

information in the classified TSA air cargo threat assessment. DHS further 

stated that CBP plans to collaborate with TSA during the vetting stage of

CBP’s Air Cargo Strategic Plan to ensure coordination of efforts and 

seamless implementation. Further, DHS stated that TSA plans to revise its 

existing Air Cargo Strategic Plan in fiscal year 2007, and will consider 

including a strategy for addressing inbound air cargo transported on 

passenger and all-cargo aircraft. DHS stated that TSA will identify and 

include specific goals and objectives for securing this area of aviation 

security and will work with CBP to share best practices in mitigating 

threats posed by weapons of mass destruction. While DHS has recognized

Page 67 GAO-07-660 Aviation Security

April 19, 2007, we received written comments on the draft report, which 
the need for CBP and TSA to work together to address inbound air cargo 

security threats, DHS has not indicated whether the Air Cargo Strategic 

Plan CBP is developing or TSA’s revised Air Cargo Strategic Plan will 

provide a risk-based strategy for how the agencies will coordinate their 

respective efforts to ensure the security of air cargo transported into the 

United States, particularly as they relate to mitigating the threat posed by 

weapons of mass destruction. Taking such action would be necessary to

fully address our recommendation. 

Concerning our recommendation to develop a systematic process for 

sharing information between TSA and CBP that could be used to 

strengthen the department’s efforts to enhance the overall security of 

inbound air cargo, DHS stated that CBP and TSA plan to meet monthly to 

continue working on ensuring air cargo security and to determine whether 

they can work more collaboratively to ensure air cargo security. DHS 

stated that these meetings will also focus on its air cargo security strategy, 

including proposed DHS definitions for the terms “screen,” “scan” and 

“inspection.” DHS also noted that TSA and CBP have previously 

collaborated on air cargo security initiatives and efforts through their 

ongoing participation in the Aviation Security Advisory Committee Air 

Cargo Working Group, and CBP has shared information on its Automated 

Targeting System with TSA staff who are developing a Freight Assessment 

System to target elevated risk domestic cargo. DHS further stated that TSA 

recognizes that CBP’s Customs-Trade Partnership Against Terrorism

program may include some information that could help TSA in its efforts 

to strengthen the security requirements for individuals and businesses that 

ship air cargo domestically. While CBP’s and TSA’s efforts to collaborate 

on their air cargo security activities are worthwhile, it is also important 

that TSA and CBP develop a system to share information—such as the 

results of TSA inspections of air carrier compliance with TSA inbound air 

cargo security requirements and TSA assessments of foreign airports’ 

compliance with international air cargo security standards—that could be

used to strengthen the department’s efforts to secure inbound air cargo.

Ensuring that TSA and CBP incorporate systematic information sharing 

into their ongoing coordination efforts would more fully address our 

recommendation. 

Regarding our recommendation to establish a methodology and time 

frame for completing assessments of inbound air cargo vulnerabilities and 

critical assets, and use these assessments as a basis for prioritizing the 

actions necessary to enhance the security of inbound air cargo, TSA 

acknowledged that assessments of inbound air cargo vulnerabilities and 

critical assets can assist in the prioritization of programs and initiatives 

Page 68 GAO-07-660 Aviation Security
developed to enhance air cargo security. While TSA stated that it has taken 

steps to develop a methodology and a framework to complete

vulnerability assessments of the domestic air cargo supply chain, TSA 

does not plan to begin work on assessments of vulnerabilities of the 

inbound air cargo supply chain until after the domestic assessments are 

completed. TSA stated that it will pursue partnerships with foreign 

countries to assess the security vulnerabilities associated with U.S.-bound 

air cargo. TSA’s efforts to complete a vulnerability assessment for 

domestic air cargo are an important step in applying a risk management 

approach to securing air cargo. However, TSA did not provide a time 

frame for completing the domestic vulnerability assessments and therefore 

could not provide a schedule for when it will conduct an assessment of 

inbound air cargo security vulnerabilities. Moreover, TSA has not 

determined whether it will conduct a criticality assessment of inbound air 

cargo assets or indicated how it plans to use information resulting from 

these assessments of inbound air cargo to prioritize the agency’s efforts to 

enhance the security of inbound air cargo. Taking these steps would be 

necessary to fully address our recommendation. 

With regard to our recommendation to establish a time frame for 

completing the assessment of whether existing inspection exemptions for 

inbound air cargo pose an unacceptable security vulnerability, and taking 

steps, if necessary, to address identified vulnerabilities, TSA 

acknowledged that air cargo inspection exemptions represent a security 

risk and described several actions it had taken to revise the air cargo 

inspection exemptions. For example, TSA stated that in October 2006, the 

agency issued a series of security enhancements in the form of a security 

directive, removing air cargo inspection exemptions. While TSA’s actions 

are an important step in addressing a recommendation we made in our 

October 2005 report on domestic air cargo security, TSA’s recent security

directive does not remove all inspection exemptions for air cargo. 

Specifically, TSA’s action only applies to air cargo transported from and 

within the United States and not to air cargo transported into the United 

States from a foreign country, and only applies to air cargo transported on 

passenger air carriers, not all-cargo carriers. Until TSA assesses whether 

existing inspection exemptions for cargo transported on passenger and allcargo aircraft into the United States pose an unacceptable vulnerability, 

and takes any necessary steps to address the identified vulnerabilities, 

TSA cannot be assured that the agency’s inbound air cargo inspection 

requirements for air carriers provide a reasonable level of security. Taking

this important step is necessary to fully address our recommendation. 

Page 69 GAO-07-660 Aviation Security
Concerning our recommendation to develop and implement an inspection

plan that includes performance goals and measures to evaluate foreign 

and domestic air carrier compliance with inbound air cargo security 

requirements, TSA stated that it recognizes the importance of evaluating 

air carrier compliance using performance measures and goals. TSA also 

stated that its international and domestic field offices establish

comprehensive inspection schedules for field staff to visit air carriers 

based on risk factors, inspection histories, and security determinations. In 

addition, TSA noted that it is hiring 10 dedicated international air cargo 

inspectors, who will be deployed to four international field offices to 

inspect all-cargo operations at last points of departure to the United States 

on an annual basis to ensure that they are in compliance with relevant allcargo security programs and applicable security directives or emergency 

amendments. TSA stated that it will also track the progress on these 

inspections utilizing the tracking system developed for its Foreign Airport 

Assessment Program. Hiring additional inspectors to conduct compliance 

inspections of all-cargo carriers that transport cargo into the United States

is an important step for enhancing the agency’s oversight of such carriers. 

However, TSA has not indicated whether it will develop an inspection plan 

that includes performance goals and measures to evaluate foreign and

domestic air carrier compliance with inbound air cargo security 

requirements. Developing such a plan will be important to fulfilling the 

agency’s oversight responsibilities and is a necessary action in addressing 

our recommendation. 

Regarding our recommendation to collaborate with foreign governments 

and the U.S. air cargo industry and compile and analyze information on air 

cargo security practices used abroad to identify those that may strengthen

the department’s overall air cargo security program, TSA stated that it 

recognizes the importance of collaborating with foreign governments and 

U.S. industry to identify best practices and lessons learned for enhancing 

air cargo security. Specifically, TSA stated that it has taken numerous 

steps to increase collaboration with foreign governments and industry, 

including developing relations with United Kingdom and Irish officials to

better understand their air cargo security practices and programs. TSA 

also noted that it actively coordinates with Canadian transportation 

security officials to share lessons learned and improve air cargo security 

between the two countries. Moreover, TSA stated that it is continuing to 

build relationships with foreign governments, including European Union 

members and southeast Asian nations. TSA also stated that it is

collaborating with U.S. industry through the Aviation Security Advisory 

Committee Air Cargo Working Group to partner with air cargo supply 

chain stakeholders on new initiatives and existing programs and pilot 

Page 70 GAO-07-660 Aviation Security
programs. TSA’s efforts to collaborate with foreign governments and 

industry are important steps toward improving inbound air cargo security.

However, TSA has not indicated whether it plans to compile or analyze 

information on air cargo security practices used abroad to identify those 

that may strengthen the department’s overall air cargo security program, 

including assessing whether the benefits that these practices could 

provide in strengthening the security of the U.S. and inbound air cargo 

supply chain are cost-effective, without impeding the flow of commerce. 

Taking such actions would be necessary to fully address the intent of this 

recommendation. 

DHS also offered technical comments and clarifications, which we have 

considered and incorporated where appropriate.

As agreed with your offices, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days after its

issue date. At that time, we will provide copies of this report to the 

Secretary of Homeland Security, the Assistant Secretary of the 

Transportation Security Administration, the Commissioner of U.S. 

Customs and Border Protection, and interested congressional committees. 

If you have any further questions about this report, please contact me at 

(202) 512-3404 or berrickc@gao.gov. Key contributors to this report are 

listed in appendix IX. 

Cathleen A. Berrick 

Director 

Homeland Security and Justice Issues 

Page 71 GAO-07-660 Aviation Security
Congressional Requesters

The Honorable Bennie G. Thompson

Chairman 

The Honorable Peter T. King 

Ranking Minority Member 

Committee on Homeland Security 

House of Representatives 

The Honorable Loretta Sanchez 

Chairwoman

Subcommittee on Border, Maritime and Global Counterterrorism 

Committee on Homeland Security 

House of Representatives 

The Honorable Tom Davis 

Ranking Minority Member 

Committee on Oversight and Government Reform 

House of Representatives 

The Honorable Daniel E. Lungren 

Ranking Minority Member 

Subcommittee on Transportation Security and Infrastructure Protection 

Committee on Homeland Security 

House of Representatives 

The Honorable Christopher Shays 

Ranking Minority Member 

Subcommittee on National Security and Foreign Affairs 

Committee on Oversight and Government Reform 

House of Representatives 

The Honorable Edward J. Markey 

House of Representatives 

Page 72 GAO-07-660 Aviation Security
Appendix I: Objectives, Scope, and 

Methodology 

Page 73 GAO-07-660 Aviation Security

Appendix I: Objectives, Scope, and 

Methodology 

This report addresses the following questions: (1) What actions has the 

Department of Homeland Security (DHS) taken to secure inbound air 

cargo, and how, if at all, could these efforts be strengthened? (2) What 

practices have the air cargo industry and select foreign countries adopted 

that could potentially be used to enhance DHS’s efforts to strengthen air 

cargo security, and to what extent have the Transportation Security 

Administration (TSA) and the U.S. Customs and Border Protection (CBP) 

worked with foreign government stakeholders to enhance its air cargo 

security efforts? 

To determine what actions DHS has taken to secure inbound air cargo, 

and how, if at all, these efforts could be strengthened, we reviewed TSA’s 

domestic air cargo strategic plan, proposed and final air cargo security 

rules, air cargo-related security directives and emergency amendments, 

aircraft operator security programs, and related guidance to determine the 

requirements placed on air carriers for ensuring inbound air cargo 

security.1

 We also interviewed TSA and CBP officials to obtain information 

on their current and planned efforts to secure inbound air cargo. Further, 

we reviewed CBP’s programs and performance measures related to 

targeting and inspecting air cargo once it reaches the United States. 

Specifically, we reviewed CBP’s Customs and Trade Partnership Against 

Terrorism (C-TPAT) program and its Automated Targeting System (ATS) 

related to air cargo to obtain information on CBP’s efforts to secure, 

target, and inspect inbound air cargo. We analyzed TSA foreign airport 

assessment reports conducted during fiscal year 2005, compliance 

inspection data from July 2003 to February 2006, and performance 

measures to determine the agency’s progress in evaluating air carriers’ 

compliance with existing air cargo security requirements. We also 

discussed the reliability of TSA’s compliance inspection data for the 

period July 2003 to February 2006 with TSA officials. Although our initial 

reliability testing indicated that there were some inconsistencies in the 

data provided by TSA, we were able to resolve most of the discrepancies 

and concluded that the data were sufficiently reliable for the purposes of 

this review. For example, we found spelling variations in the inspections 

for the same air carrier, which we identified and made uniform in the 

dataset. We found that some records contained duplicate information. We 

removed these records based on a comparison of information such as the 

 1

“Air carriers” refers to both foreign and U.S.-based passenger air carriers whose aircraft

have been configured to accommodate both passengers and cargo and all-cargo carriers 

whose aircraft transport only cargo. 
Appendix I: Objectives, Scope, and 

Methodology 

inspection record number, the date of the inspection, the specific 

requirement the TSA inspector assessed, and the determination of the air 

carriers’ compliance with the requirement. We also found some 

inspections in the dataset that had occurred at U.S. airports. We identified 

these by the airport name and removed them from the data. To identify 

DHS’s plans for enhancing inbound air cargo security, we reviewed DHS 

Science and Technology Directorate, TSA, and CBP documents to identify 

pilot programs for inspection technology, including program funding 

levels, time frames, results, and implementation plans. We discussed how, 

if at all, DHS efforts could be strengthened to secure inbound air cargo 

with TSA and CBP officials and air cargo industry stakeholders. 

To identify any challenges DHS and its components may face in

strengthening inbound air cargo security, we interviewed TSA and CBP 

officials about how they coordinate and share information on their 

respective inbound air cargo security efforts. We obtained information on 

DHS’s, TSA’s, and CBP’s efforts to apply risk management principles to 

inform their decisions related to securing inbound air cargo and compared 

these actions against our risk management framework. Our complete risk 

management framework includes a specific set of risk management 

activities: setting strategic goals and objectives, assessing risk (threat, 

vulnerabilities, and criticality), evaluating alternatives, selecting initiatives 

to undertake, and implementing and monitoring those initiatives. This 

report examines the two risk management efforts TSA has focused on thus 

far related to inbound air cargo security—setting strategic goals and 

objectives and assessing risk. With regard to establishing strategic goals 

and objectives, we reviewed DHS’s Strategic Plan, National Infrastructure 

Protection Plan, and National Strategy for Transportation Security. We 

also reviewed TSA’s strategic plan and TSA’s air cargo strategic plan to 

determine DHS’s strategy for addressing the security of inbound air cargo. 

Regarding risk assessments, we interviewed DHS officials to discuss the 

department’s plans to conduct assessments of the vulnerabilities and 

critical assets associated with inbound air cargo. In addition, we 

interviewed TSA and CBP officials, foreign government officials, and air 

cargo industry stakeholders to identify efforts to develop international air 

cargo security standards, and DHS’s efforts to work with foreign 

governments to develop uniform air cargo security standards that would 

apply to participant countries, including a structure for mutually 

recognizing and accepting other countries’ air cargo security practices. 

To identify actions the air cargo industry and select foreign countries have

taken to secure air cargo and whether such actions have the potential to 

be used to strengthen air cargo security in the United States, we

Page 74 GAO-07-660 Aviation Security
Appendix I: Objectives, Scope, and 

Methodology 

interviewed foreign and domestic air carrier (passenger and all-cargo) 

officials, foreign freight forwarder representatives, airport authorities, air 

cargo industry associations, and DHS and foreign government officials. We 

also conducted site visits to 3 U.S. airports to observe inbound air cargo 

security operations and industry and CBP efforts to inspect inbound air 

cargo using nonintrusive inspection technologies, including radiation 

detection systems.2

 We selected these airports based on several factors, 

including airport size, the volume of air cargo transported to these airports 

from foreign locations, geographical dispersion, the presence of CBP 

officers, and TSA international field office officials.3

 Because we selected a 

nonprobability sample of airports, the results from these visits cannot be 

generalized to other U.S. airports. Further, we conducted site visits to 

7 countries in Europe and Asia to observe air cargo facilities on and off 

airport grounds, observe air cargo security processes and technologies, 

and obtain information on air cargo security measures implemented by 

foreign governments and industry stakeholders.4

 During our international 

site visits, we also met with officials from the European Union and TSA’s 

international field offices. We selected these countries based on several 

factors, including geographical dispersion; TSA threat rankings; and 

discussions with DHS, State Department, and foreign government officials 

and air cargo industry representatives and experts regarding air cargo 

security practices that may have application to DHS’s efforts to secure air 

cargo. We also considered information on 4 additional countries whose air 

cargo security practices differ from those used in the United States.5

According to TSA and air cargo industry stakeholders, these countries 

have implemented stringent air cargo security programs. Specifically, we 

observed security practices at 8 foreign airports, 4 of which rank among 

the world’s 10 busiest cargo airports. We also obtained information on the 

air cargo security requirements implemented by 4 additional foreign 

 2

TSA classifies over 400 commercial airports in the United States into one of five categories

(X, I, II, III, and IV) based on various factors, such as the total number of takeoffs and 

landings annually and other special security considerations. 

3

DHS determined that information on the specific domestic airports we visited is Sensitive 

Security Information. The domestic airports we visited are listed in the restricted version of 

this report, GAO-07-337SU. 

4

DHS determined that information on the specific international airports we visited is 

sensitive security information. The international airports we visited are listed in the

restricted version of this report, GAO-07-337SU. 

5

DHS determined that the names of specific countries on whose air cargo security practices 

and requirements we collected information are Sensitive Security Information. These 

countries are identified in the restricted version of this report, GAO-07-337SU. 

Page 75 GAO-07-660 Aviation Security
Appendix I: Objectives, Scope, and 

Methodology 

countries. In addition, some of the security practices we identified are 

being implemented by air carriers that transport large volumes of air 

cargo. Specifically, we spoke with air carrier officials representing 7of the 

world’s 10 largest air cargo carriers. We also discussed the feasibility of 

applying foreign air cargo security measures in the United States with TSA 

officials. We did not, however, evaluate the effectiveness of the foreign 

measures we identified during this review. We also discussed efforts to 

develop, harmonize, and mutually recognize international air cargo 

security standards with TSA, foreign government, and air cargo industry 

officials. 

TSA’s and CBP’s roles and responsibilities for securing air cargo 

transported from the United States to a foreign location were not included

in the scope of this review. TSA’s requirements for outbound air cargo are 

similar to those governing the security of air cargo transported within the 

United States. For a review of TSA’s practices related to securing domestic 

air cargo, GAO-05-446SU. 

We conducted our work from October 2005 through February 2007 in 

accordance with generally accepted government auditing standards. 

Page 76 GAO-07-660 Aviation Security
Appendix II: TSA’s Efforts to Assess Air 

Carrier Compliance with Inbound Air Cargo 

Security Requirements 

Page 77 GAO-07-660 Aviation Security

Appendix II: TSA’s Efforts to Assess Air 

Carrier Compliance with Inbound Air Cargo 

Security Requirements 

TSA’s inspections at foreign airports are conducted by aviation inspectors 

who are responsible for reviewing aviation security measures of foreign 

and domestic passenger air carriers to determine their compliance with a 

variety of TSA aviation security requirements, including those related to 

inbound air cargo. These inspectors are responsible for conducting foreign

airport assessments as well as domestic and foreign air carrier inspections 

at foreign airports. According to international field office officials, the 

agency usually conducts inspections and foreign airport assessments 

during the same visit to an airport. The agency also trains and utilizes 

domestic aviation security inspectors to conduct inspections under the 

supervision of the international field offices to supplement its 

international inspection resources. 

TSA uses its automated Performance and Results Information System 

(PARIS) to compile the results of its aviation inspections and the actions

taken when violations are identified. As shown in figure 4, our analysis of 

PARIS inspection records determined that between July 2003 and 

February 2006, TSA conducted 1,020 international compliance inspections 

of domestic and foreign carriers that included a review of one or more 

areas of cargo security. TSA data also show that inspectors conducted 

747 inspections at 452 separate domestic air carrier stations and 

273 inspections at 177 separate foreign air carrier stations.1

 

 1

“Air carrier station” refers to those locations at an airport where an air carrier conducts its 

operations.
Appendix II: TSA’s Efforts to Assess Air 

Carrier Compliance with Inbound Air Cargo 

Security Requirements 

Figure 4: Inspections of Air Carrier Cargo Procedures Conducted from January 2004 to December 2005 

Number of inspections

Source: GAO analysis of TSA’s data.

Date

0

20

40

60

80

100

120

Jan. Feb. Mar. Apr. May June July Aug. Sept. Oct. Nov. Dec. Jan. Feb. Mar. Apr. May June July Aug. Sept. Oct. Nov. Dec.

2004 2005

Note: TSA provided us information on the number of inspections conducted from July 2003 to 

February 2006. DHS determined that details on the number of inspections conducted on air carrier 

cargo procedures are Sensitive Security Information. Details on the number of inspections are 

provided in the restricted version of this report, GAO-07-337SU. 

TSA has taken initial steps to compile information on the violations found 

during its inspections of inbound air carrier cargo security requirements. 

For example, from July 2003 to February 2006, TSA inspectors identified 

57 air cargo security violations committed by foreign and domestic 

passenger air carriers at foreign airports in several areas of air cargo 

security responsibility. Specifically, as shown in figure 5, these violations

covered areas such as cargo acceptance procedures, cargo screening 

procedures, and air carrier cargo hold search procedures. 

Page 78 GAO-07-660 Aviation Security
Appendix II: TSA’s Efforts to Assess Air 

Carrier Compliance with Inbound Air Cargo 

Security Requirements 

Figure 5: Air Cargo Security Violations Found during Inbound Passenger Air Carrier Inspections at Foreign Airports for the

Period July 2003 to February 2006 

Number of violations

0

2

4

6

8

10

12

Cargo program

documentation

Cargo hold searches

Non-IATA agent

acceptance procedures

Cargo security

controls

Access to cargo

IATA agent acceptance

procedures

Acceptance of cargo at

last point of departure

Courier acceptance

procedures

Known shipper

acceptance procedures

Unknown shipper

acceptance procedures

Cargo inspection

procedures

General acceptance

procedures

Source: GAO analysis of TSA’s PARIS database.

Violation area

Note: TSA provided us information on the number of violations found during inspections 

conducted from July 2003 to February 2006. DHS determined that details on the number of each 

type of violation found are Sensitive Security Information. Details on the number of each type of 

violation are provided in the restricted version of this report, GAO-07-337SU. 

Page 79 GAO-07-660 Aviation Security
Appendix III: TSA’s Assessments of Foreign 

Airport Security Procedures 

Page 80 GAO-07-660 Aviation Security

Appendix III: TSA’s Assessments of Foreign 

Airport Security Procedures 

During fiscal year 2005, TSA conducted 128 foreign airport assessments at 

the approximately 260 airports that service passenger air carriers 

departing for the United States.1

 As part of the foreign airport assessment 

process, TSA develops a report that identifies recommendations for the 

airport to improve its airport security to meet ICAO standards, which 

include air cargo security standards. Of the 128 assessments TSA 

conducted during fiscal year 2005, the agency made 28 recommendations 

to improve air cargo security. As of October 2005, 2 cargo security 

recommendations were adopted by the airports and 26 recommendations 

remained to be addressed. Examples of TSA recommendations include 

developing a national cargo security program to establish government 

authorities and air cargo industry responsibilities for securing air cargo,

among other things. 

When TSA inspectors identify a deficiency that requires immediate action, 

they work with the airport and government officials to resolve the 

deficiency. If TSA inspectors determine that effective security is still not 

being maintained, the law prescribes steps and actions available for 

encouraging compliance with the standards used in TSA’s assessment.2

Such actions include, among other things, notifying appropriate 

authorities of the foreign government of deficiencies identified, providing 

public notice that the airport does not maintain and carry out effective 

security measures, or suspending service between the United States and 

the airport if it is determined a condition exists that threatens the safety or

security of the passengers, aircraft, or crew, and such action is in the 

public interest.3

 The agency has not issued a travel advisory or suspended 

 1

See 49 U.S.C. § 44907 (authorizing TSA to conduct foreign airport assessments). 

2

TSA conducts assessments to determine the extent to which a foreign airport effectively 

maintains and carries out security measures using a standard of analysis based at least on 

the standards and appropriate recommended practices contained in ICAO Annex 17. 

49 U.S.C. § 44907(a)(2). 

3

See 49 U.S.C. § 44907(c)-(f). 
Appendix III: TSA’s Assessments of Foreign 

Airport Security Procedures 

service solely for air cargo security deficiencies at an airport since its 

inception. 

Page 81 GAO-07-660 Aviation Security
Appendix IV: D

M

escription of GAO’s Risk

anagement Framework 

Page 82 GAO-07-660 Aviation Security

Appendix IV: Description of GAO’s Risk 

Management Framework 

GAO’s risk management framework is intended to be a starting point for 

risk management activities and will likely evolve as processes mature and 

lessons are learned. A risk management approach entails a continuous 

process of managing risk through a series of actions, including setting 

strategic goals and objectives, assessing risk, evaluating alternatives, 

selecting initiatives to undertake, and implementing and monitoring those 

initiatives. Figure 6 depicts a risk management cycle. 

Figure 6: Risk Management Cycle 

Source: GAO. 

Strategic goals, 

objectives and constraints

Risk assessment

Alternatives evaluation

Management 

selection

Implementation and

monitoring

Risk assessment, a critical element of a risk management approach, helps 

decision makers identify and evaluate potential risks so that 

countermeasures can be designed and implemented to prevent or mitigate 

the effects of the risks. The risk assessment element in the overall risk 

management cycle may be the largest change from standard management 

steps and is central to informing the remaining steps of the cycle. Table 1 

describes the elements of a risk assessment. 
Appendix IV: Description of GAO’s Risk

Management Framework 

Table 1: Elements of a Typical Homeland Security Risk Assessment

Threat assessment: “Threat” is defined as a potential intent to cause harm or damage 

to an asset (e.g., natural environment, people, man-made infrastructures, and activities 

and operations). Threat assessments consist of the identification of adverse events that 

can potentially affect an entity. Threats might be present at the global, national, or local 

level and their sources include terrorists and criminal enterprises. Specific threat 

information may indicate vulnerabilities that are subject to attack or following the 

completion of a risk management process, may, for instance, indicate that resources 

should be temporarily deployed to protect cargo in a particular region of the country or a 

specific airport. Even if updated frequently, a threat assessment might not adequately 

capture some emerging threats. 

Vulnerability assessment: “Vulnerability” is defined as the inherent state (either 

physical, technical, or operational) of an asset that can be exploited by an adversary to 

cause harm or damage. Vulnerability assessments identify these inherent states and the 

extent of their susceptibility to exploitation, relative to the existence of any 

countermeasures. A vulnerability assessment is generally conducted by a team of 

experts skilled in such areas as engineering, intelligence, security, information systems, 

finance, and other disciplines.

Criticality/Consequence assessment: “Criticality” is defined as an asset’s relative 

importance given that an event occurs. Criticality or similar consequence assessments 

identify and evaluate an entity’s assets based on a variety of factors, including the 

importance of its mission or function, the extent to which people are at risk, or the 

significance of a structure or system in terms of, for example, national security, economic 

activity, or public safety. Criticality or consequence assessments are important because

they provide, in combination with threat and vulnerability assessments, information for 

later stages of the risk management process.

Source: GAO.

Another element of our risk management approach—alternatives 

evaluation—considers what actions may be needed to address identified 

risks, the associated costs of taking these actions, and any resulting 

benefits. This information can be provided to agency management to assist 

in the selection of alternative actions best suited to the unique needs of the 

organization. An additional step in the risk management approach is the 

implementation and monitoring of actions taken to address the risks, 

including evaluating the extent to which risk was mitigated by these 

actions. Once the agency has implemented the actions to address risks, it 

should develop criteria for and continually monitor the performance of 

these actions to ensure that they are effective and also reflect evolving 

risk. 

Page 83 GAO-07-660 Aviation Security
Appen

Tech

dix V: DHS and TSA Air Cargo Security 

nology Pilot Tests 

Page 84 GAO-07-660 Aviation Security

Appendix V: DHS and TSA Air Cargo Security 

Technology Pilot Tests 

According to DHS officials, the department’s ongoing pilot programs seek 

to enhance the physical security of air cargo and improve the effectiveness 

of air cargo inspections by increasing detection rates and reducing false 

alarm rates. DHS officials stated that its air cargo technology pilot 

programs focus on securing domestic air cargo, and while these pilot 

methods have yet to be implemented, the results of these tests could be 

applied to securing inbound air cargo against similar threats. These 

technology pilots focus on addressing the two primary threats to air cargo 

identified by TSA—hijackers on an all-cargo aircraft and explosives on 

passenger aircraft—but do not include tests to identify weapons of mass 

destruction. DHS’s pilot programs are described below. 

Air Cargo Explosives 

Detection Pilot Program 

Of the amounts appropriated to DHS in fiscal year 2006, $30 million was 

allocated to the Science and Technology (S&T) Directorate to conduct 

three cargo screening pilot programs.1

 DHS’s S&T, working in conjunction

with TSA, selected San Francisco International Airport, Seattle-Tacoma 

International Airport, and Cincinnati/Northern Kentucky International 

Airport as the sites for the pilot and commenced cargo inspection 

operations at all three airports in September 2006. The pilots will test 

different concepts of operation at each of the airports. At San Francisco 

International Airport, the program will test the use of approved inspection 

technologies, including explosive detection systems, such as CTX 9000, 

explosive trace detectors, standard X-ray machines, canine teams, and 

manual inspections of air cargo, in attempts to determine the 

technological and operational issues involved in explosives detection. The 

pilot at San Francisco International Airport will further examine how the 

use of these existing checked baggage inspection technologies at a higher 

rate than is currently required by TSA will affect air cargo personnel and 

operations on, for example, throughput.2

 The pilot at Seattle-Tacoma 

International Airport will use canines and stowaway detection

technologies, for example, technologies that can locate a stowaway 

through detection of increased carbon dioxide levels in cargo, to detect 

 1

H.R. Conf. Rep. No. 109-241, at 53 (2005) (accompanying H.R. 5441, enacted as the 

Department of Homeland Security Appropriations Act, 2006, Pub. L. No. 109-90, 110 Stat. 

2064 (2005)). 

2

“Throughput” means the amount of cargo screened during a given period of time, for

example, per hour. 
Appendix V: DHS and TSA Air Cargo Security 

Technology Pilot Tests 

threats in freighter air cargo,3 while the Cincinnati/Northern Kentucky 

International Airport pilot program will test existing passenger 

infrastructure for inspecting air cargo, including explosive detection 

systems (EDS) technology. The projected benefits of these pilots include 

the following: increases in the amount of cargo inspected, increases in 

detection reliability without adversely affecting commerce, and a better 

understanding of the necessary procedures and costs associated with 

greater cargo security. 

Pilot Program Evaluating 

Explosives Detection 

System Technology 

EDS is a form of X-ray technology that can be highly automated to screen 

several hundred bags an hour. EDS machines, in contrast to explosive 

trace detection technology, are much larger, up to the size of a minivan 

and cost in excess of $1 million. EDS technology uses computer 

tomography to scan objects and compare their density to the density of 

known objects in order to locate explosives.4

 According to TSA, EDS 

provides an equivalent level of security as explosive trace detection (ETD) 

technology. However EDS provides a higher level of efficiency. 

TSA’s EDS Cargo Pilot Program is currently in the third phase of a threephased program testing the use and effectiveness of explosive detection 

systems at 12 participating sites.5

 While the Air Cargo Explosives 

Detection Pilot Program will test a range of explosives detection 

technologies, the EDS pilot focuses specifically on EDS technology for its 

use in the air cargo environment. Phase I, referred to as Developmental 

Test and Evaluation, was conducted using live explosives to test the 

detection capability and technical performance of the systems screening 

simulated break bulk air cargo. Phase II, referred to as Operational Utility 

Evaluation, was conducted in cargo facilities to test the system’s 

effectiveness in the air cargo environment, in addition to determining the 

operational alarm and false alarm rates of the technology. Phase III of 

TSA’s testing is referred to as the Extended Field Test and is designed as a

longer-term evaluation of available EDS technologies in the air cargo 

environment. According to TSA officials, the extended time frame of Phase 

 3

The Seattle-Tacoma International Airport pilot requires technology for stowaway 

detection that has not been operationally tested and evaluated in that environment.

According to DHS officials, this technology was being acquired as of May 2006. 

4

Computer tomography generates a three-dimensional image of the internals of an object 

from a large series of two-dimensional X-ray images taken around a single axis of rotation. 

5

Five air carriers have agreed to participate in TSA’s EDS Cargo Pilot Program. 

Page 85 GAO-07-660 Aviation Security
Appendix V: DHS and TSA Air Cargo Security 

Technology Pilot Tests 

III (a minimum of 1 year) will allow TSA to evaluate the reliability, 

maintainability, and availability of the EDS technology, in addition to 

establishing operational parameters and procedures within a realistic 

operational environment. 

Air Cargo Security Seals 

Pilot Program 

TSA officials stated that the agency is exploring the viability of potential 

security countermeasures, such as tamper-evident security seals, for use 

with certain classifications of exempt cargo. Traditionally used in the 

maritime environment, container seals include a number of tamper-evident 

technologies that range from tamper-evident tape to more advanced 

technologies used to secure air cargo on aircraft. Tamper-evident tape can

identify cargo that requires further screening and inspection to safeguard 

against the introduction of explosives and incendiary devices. Indicative 

seals are made of plastic and show signs of tampering. Ranging in price 

from 5 to 20 cents, they provide the cheapest solution to air cargo security.

Barrier seals, which cost between 50 cents and $2 or more, are stronger 

seals that are generally used on more sensitive cargo because they require

bolt cutters to remove. The most advanced seal technology allows 

shipping companies to track a container through the entire shipping 

process through a radio frequency identification (RFID) tag that is 

embedded in the seal. Average RFID seals can range in cost from $1 to $10, 

with the most sophisticated models costing upward of $100. Security seals

could be used in combination with known shipper protocols to insure that 

known shippers provide security in their packaging facilities and deter 

tampering during shipping and handling. 

In 2003, the Congressional Research Service reported that the utility of 

electronic seals in air cargo operations has been questioned by some 

experts because currently available electronic seals have a limited 

transmission range that may make detecting and identifying seals difficult. 

In 2006, GAO reported that container seals provide limited value in 

detecting tampering with cargo containers.6

 However, according to TSA 

officials, such countermeasures could provide an additional layer of 

security and warrant further examination. In January 2006, the agency 

issued a public request for information regarding security seals. Although 

the agency has since acquired information on seals from five vendors, 

officials stated that efforts to begin the pilot program have been delayed 

 6

GAO, Technology Assessment: Securing the Transport of Cargo Containers, 

GAO-06-68SU, (Washington: DC: January 2006). 

Page 86 GAO-07-660 Aviation Security
Appendix V: DHS and TSA Air Cargo Security 

Technology Pilot Tests 

due to funding issues, among other things. TSA officials stated that the 

agency plans to implement the pilot at four airports by the first quarter of 

2007. These airports include Portland International Airport, John F. 

Kennedy International Airport, Chicago O’Hare International Airport, and 

Ronald Reagan Washington National Airport. 

Hardened Unit Load 

Devices/Hardened Cargo 

Containers 

While the Federal Aviation Administration, TSA, and DHS have been 

involved in testing hardened unit load devices since the mid-1990s, testing 

of these devices has increased since the 9/11 Commission recommended 

that all U.S. airliners deploy at least one hardened cargo container in the 

hold of every passenger aircraft to carry suspect passenger baggage or air 

cargo.7

 Hardened unit load devices are blast-resistant containers capable 

of transporting passenger baggage or air cargo within the lower deck 

cargo holds of wide-body aircraft. These containers are required to 

withstand an explosive blast up to a certain magnitude while maintaining 

the integrity of the container and aircraft structure. The container must 

also be capable of extinguishing any fire that results from the detonation 

of an incendiary device.

In accordance with the Intelligence Reform and Terrorism Prevention Act 

of 2004, TSA began a pilot program in June 2005 to conduct airline 

operational testing of the ability of hardened or blast-resistant containers 

to minimize the potential effects, including explosion or fire, of a 

detonation caused by an explosive device smuggled into the belly of an 

aircraft.8

 TSA officials stated that the start up of the pilot program was 

slow because one of the two participating vendors dropped out of the 

program and because there were few available domestic wide-body flights 

in which to conduct the tests. TSA officials added that the agency has 

since made progress in conducting the pilot and is collecting test data. 

TSA officials stated that the agency expects to conclude the data 

collection phase of the program by summer 2007 and make policy 

decisions regarding the possible implementation of hardened unit loading 

devices by December 2007. In addition, TSA has been working with 

 7

Previous research and development efforts examining blast-resistant containers were 

conducted by the Federal Aviation Administration. For more than 10 years the agency

examined the airworthiness, ground handling, and blast resistance of hardened containers.

8

See Pub. L. No 108-458, § 4051, 118 Stat. 3638, 3728 (2004), authorizing $2 million for the

Assistant Secretary of Homeland Security (Transportation Security Administration) to

carry out this pilot program. 

Page 87 GAO-07-660 Aviation Security
Appendix V: DHS and TSA Air Cargo Security 

Technology Pilot Tests 

vendors and airlines to develop and test a hardened unit load device that 

would satisfy industry’s request for a lighter, less cost-prohibitive model 

while still providing the necessary level of security to the aircraft. 

Pulsed Fast Neutron 

Analysis Testing 

TSA officials reported that the agency’s efforts to test pulsed fast neutron 

analysis (PFNA) are currently in the proof-of-concept design stage, which

is focusing on the development of the technology. PFNA technology 

allows for bulk inspection of containerized air cargo by measuring the 

reaction to injected neutrons and identifying elemental chemical 

signatures of contraband, explosives, and other threat objects. The agency 

plans to complete the proof-of-concept phase of testing by March 2007, at

which point TSA and DHS will evaluate the technology on its technical, 

environmental, operational, and performance specifications. Testing of 

this technology will then proceed to the Development Testing and 

Evaluation phase. Agency officials project that the next two phases, 

Development Testing and Evaluation and Operational Testing and 

Evaluation, will take another 2 to 3 years (after the completion of the 

proof-of-concept design phase) to fully determine the operational 

readiness and maturity of the technology. Agency officials were unable to 

provide us with a time frame for when PFNA would be operational at the 

George Bush Intercontinental Airport. 

Page 88 GAO-07-660 Aviation Security
Appendix VI: Actions Taken by Select 

Domestic Air Carriers with Operations 

Overseas and Foreign Air Cargo Industry 

Stakeholders to Secure Air Cargo 

Page 89 GAO-07-660 Aviation Security

Area of Action Passenger Air Carriers All-Cargo Air Carriers Freight Forwarders 

Cargo Inspection: 

Methods and Focus 

• Inspect a higher 

percentage of cargo 

placed on passenger 

aircraft than is required by 

TSA or host government. 

• 100 percent of air cargo 

loaded onto passenger 

aircraft bound for the 

United States required to 

undergo inspection. 

• Large palletized cargo is 

broken down in order to 

pass cargo through X-ray 

machines. 

• Canines used to sniff air 

samples taken from cargo 

shipments. 

• Limited or no air cargo 

inspection exemptions. 

• Large X-ray machines 

used to inspect entire 

pallets of cargo bound for 

passenger craft. 

• Additional targeted 

inspections are conducted 

based on analysis of 

available threat

information, among other 

things. 

• 100 percent inspection

performed on: 

• express cargo on 

passenger aircraft bound for 

the United States. 

• air cargo from unknown 

(cash paying) customers. 

• air cargo shipped in or out 

of locations deemed high-risk

by the air carrier is inspected 

via X-ray. 

• air cargo bound for 

passenger flights to the 

United States are inspected 

via X-ray. 

• Color-coded threat 

assessment system 

indicates when air cargo 

should be inspected and 

when other procedures 

should apply. The color 

assigned (red, amber, or 

green) is based on the 

cargo’s point of origin, 

destination, and other 

relevant intelligence 

information. 

• Radiation detection 

technology is used to 

inspect cargo transported 

to the United States and 

differentiate between 

legitimate and illegitimate 

sources of radiation. 

• Canines used to sniff air 

samples from cargo 

shipments. 

• Freight forwarders, also 

known as regulated 

agents, are validated by 

the government and are 

responsible for conducting 

inspections. 

• Canines and 

decompression chambers 

are used to inspect cargo 

that cannot be X-rayed. 

• Customers are charged a 

fee when use of

decompression chamber 

is required. 

Identification of

Known Shippers/ 

Cosigners 

• Work with known 

cosigners to prepare for 

annual audits; new 

identification numbers are 

given post-audit to ensure 

security of cosigner 

identity. 

Appendix VI: Actions Taken by Select 

Domestic Air Carriers with Operations 

Overseas and Foreign Air Cargo Industry 

Stakeholders to Secure Air Cargo 
Appendix VI: Actions Taken by Select 

Domestic Air Carriers with Operations 

Overseas and Foreign Air Cargo Industry 

Stakeholders to Secure Air Cargo 

Area of Action Passenger Air Carriers All-Cargo Air Carriers Freight Forwarders 

Employee Security • Air cargo workers undergo 

additional and stringent 

background checks, 

including criminal and 

employment history 

checks. 

• Program provides 

monetary incentives to 

employees in order to 

increase employee 

awareness of access 

controls, including 

rewards for reporting 

suspicious individuals. 

• All personnel are trained 

to identify and handle 

security risks; quarterly 

training is provided to 

security personnel on a 

range of issues, including 

security updates and the 

use of new technology. 

• Database tracks training 

completed by employees; 

employees are not 

permitted to enter facility if 

training lapses or 

requirements are not met. 

• Managers are required to 

remain knowledgeable on 

security policies and 

regulations in destination 

countries. 

Compiling and 

Disseminating Air 

Cargo Data 

• Threat information is 

derived from public/private 

intelligence. This 

information includes data 

on the 

sociopolitical/economic 

conditions of countries. 

• Independent risk 

assessments are 

conducted based on 

internal testing to identify 

cargo security 

weaknesses. 

• Representatives from the 

air carrier industry meet to 

identify best practices in 

aviation security. 

• Annual audits of carrier 

facilities are conducted 

using an online

questionnaire; facilities 

undergo a certification 

process that is linked to 

the audits. 

• Security incident database 

tracks worldwide security 

issues. 

• Manifest information is 

provided to CBP earlier 

than is required by CBP. 

Page 90 GAO-07-660 Aviation Security
Appendix VI: Actions Taken by Select 

Domestic Air Carriers with Operations 

Overseas and Foreign Air Cargo Industry 

Stakeholders to Secure Air Cargo 

Area of Action Passenger Air Carriers All-Cargo Air Carriers Freight Forwarders 

Physical Security and 

Access Controls 

• Truck drivers entering 

carrier facilities to deliver 

air cargo are escorted by 

an airline representative at 

all times. 

• Security guards control 

access to freighters at 

every stop made by the 

aircraft. 

• Secured cart system 

transports cargo within 

cargo storage facility. 

• Pallets are locked and 

sealed in a completely 

enclosed chain-like 

container after they are 

built to prevent the 

possibility of tampering. 

• Biometric badge required 

to gain access to secured 

areas. 

• All employees/visitors are 

required to pass through a 

metal detector before 

entering/exiting cargo 

facility. 

• Assessments are 

conducted of security 

conditions in foreign 

destinations where staff 

are located; armed 

security personnel are 

assigned to those 

locations deemed high 

risk. 

• High-tech camera and 

surveillance system 

monitor all-cargo areas 24 

hours a day. 

• Biometric identification 

system that scans the 

hand to grant access air 

carrier facilities and cargo 

areas. 

• Strategic placement of air 

cargo in the aircraft to 

secure the cockpit and 

minimize the potential for 

a hijacking by a 

stowaway. 

• Monthly internal audits of 

cargo facilities, including 

testing of access controls 

to identify security 

weaknesses. 

• Seals and plastic straps 

are applied to all cargo 

crates, containers, and 

boxes to prevent 

tampering. 

• Cargo is consolidated

whenever possible into 

larger units and sealed 

with steel banding to limit 

the possibility of 

tampering. 

• Only authorized company 

employees are permitted 

to pick up, pack, and 

transport cargo to cargo 

facilities and the airport. 

• Fingerprints and 

photographs of all truck 

drivers that transport 

cargo are taken, kept on 

file, and used to authorize 

access. 

Cargo Acceptance • Refusal of all express 

cargo brought directly to 

the ticketing or check-in 

counter by an unknown 

shipper. 

• Palletized cargo is refused 

unless airline security 

personnel are present 

when pallet is built. 

• Thorough security review 

is conducted of potential 

customers prior to 

acceptance of their 

business or cargo. 

• Refusal of improperly 

documented that could 

pose a potential security 

threat. 

• Refusal of express cargo 

brought directly to the 

counter. 

• Refuse all inbound and 

outbound cargo from 

unknown shippers. 

Air Cargo Technology 

Testing 

• Examining use of 

inspection technology 

capable of detecting 

traces of explosives. 

• Pilot testing the use of 

bees to detect explosive 

traces in air cargo 

shipments. 

Source: GAO analysis of industry efforts to secure air cargo that differ from those implemented in the United States. 

Page 91 GAO-07-660 Aviation Security
Appendix VII: Actions We Identified That 

Select Foreign Governments Are Taking to 

Secure Air Cargo 

Page 92 GAO-07-660 Aviation Security

Actions Taken by Select Foreign Governments to Secure Air Cargo

Cargo Inspection Methods and Technology 

• Twenty-four hour holding period 

used as form of inspection. 

• Random selection of inspection

methods to avoid detection of 

inspection patterns. 

• Canines used to sniff air samples 

from air cargo shipments–Remote 

Air Sampling for Canine Olfaction 

(RASCO). 

Performing Entity 

• Government, airport, or 

freight forwarder 

representatives are 

responsible for

inspecting air cargo. 

• Military police conduct 

air cargo inspections. 

Inspection Focus 

• One hundred percent of 

unknown cargo loaded 

on either passenger or 

all-cargo aircraft is 

physically inspected. 

• No differentiation 

between cargo placed

on passenger aircraft 

versus all-cargo aircraft 

in regards to type or 

degree of inspection. 

• Unknown cargo that 

undergoes inspection

becomes known and is 

permitted on passenger 

aircraft. 

• No, or limited number 

of, air cargo inspections 

exemptions. 

• Palletized cargo from 

unknown shippers, 

broken up, inspected, 

and re-palletized before 

being loaded unto 

aircraft. 

Regulated Agents 

and Shippers 

• Process to become a regulated agent is strict and costly; decertification for unsatisfactory performance. 

• Third-party validation required to become a known shipper/consignor; annual third-party compliance 

inspections conducted of known shippers/cosigners. 

Regulated agents are validated by aviation authority prior to regulating and auditing shippers and conducting 

inspections of air cargo.

Employee Security • Air cargo handlers and workers attend government-certified schools to receive mandatory training in air 

cargo security awareness and quality control.

• Air cargo workers undergo background checks that include a criminal history records check before being 

granted access to cargo facilities. 

Air cargo workers must be of native descent to be hired.

Screening Air 

Cargo Data 

• Developing multicountry database containing information on all known consignors and regulated agents 

to facilitate the exchange of information among countries. 

Appendix VII: Actions We Identified That 

Select Foreign Governments Are Taking to 

Secure Air Cargo 
Appendix VII: Actions We Identified That 

Select Foreign Governments Are Taking to 

Secure Air Cargo 

Actions Taken by Select Foreign Governments to Secure Air Cargo

Physical Security 

and Access 

Controls 

To Aircraft and Cargo 

• Security personnel accompany and surround

aircraft upon landing to guard aircraft and its 

contents, including cargo. 

• Cargo is stored in secured terminal facility, 

located within a “restricted” area of the airport. 

• All individuals accessing cargo facilities are 

required to pass through a walk-through metal 

detector. 

To Cargo Facilities 

• Biometric technologies used to control access

to cargo facilities. 

• Government personnel conduct testing and 

attempt to gain access to cargo 

warehouses/facilities; if successful, all cargo in 

the breached facility is considered unknown 

and must be inspected before being loaded 

unto aircraft. 

Technology 

Certification and 

Funding 

• Government and airport authority subsidize the costs of purchasing X-ray equipment to inspect air cargo.

Source: GAO analysis of foreign government efforts to secure air cargo that differ from those implemented in the United States.

Page 93 GAO-07-660 Aviation Security
Appendix VIII: Comments from the 

Department of Homeland Security 

Page 94 GAO-07-660 Aviation Security

Appendix VIII: Comments from the 

Department of Homeland Security 
Appendix VIII: Comments from the 

Department of Homeland Security 

Page 95 GAO-07-660 Aviation Security
Appendix VIII: Comments from the 

Department of Homeland Security 

Page 96 GAO-07-660 Aviation Security
Appendix VIII: Comments from the 

Department of Homeland Security 

Page 97 GAO-07-660 Aviation Security
Appendix VIII: Comments from the 

Department of Homeland Security 

Page 98 GAO-07-660 Aviation Security
Appendix VIII: Comments from the 

Department of Homeland Security 

Page 99 GAO-07-660 Aviation Security
Appendix VIII: Comments from the 

Department of Homeland Security 

Page 100 GAO-07-660 Aviation Security
Appendix IX: 

A

GAO Contact and Staff 

cknowledgments 

Page 101 GAO-07-660 Aviation Security

Appendix IX: GAO Contact and Staff 

Acknowledgments 

Cathleen A. Berrick, (202) 512-3404 

In addition to the contact named above, John C. Hansen, Assistant 

Director; Susan Baker; Charles W. Bausell; Katherine Davis; 

Jennifer Harman; Richard Hung; Cathy Hurley; Tom Lombardi; 

Jeremy Manion; Linda Miller; Steve D. Morris; and Meg Ullengren made 

key contributions to this report. 

GAO Contact 

Acknowledgments 

(440604) 
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