Department of Homeland Security
 

Transportation Security Administration’s 


Use of Backscatter Units 


OIG-12-38 February 2012
 
Office a/Inspector General 

U.S. Deparhuent of Homeland Security 

Washington, DC 20528 

Homeland 

Security 

February 14, 2012 

Preface 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was established 

by the Homeland Security Act of 2002 (Public Law 107-296) by amendment to the Inspector 

General Act of 1978. This is one of a series of audit, inspection, and special reports prepared as 

part of our oversight responsibilities to promote economy, efficiency, and effectiveness within 

the Department. 

This report addresses the strengths and weaknesses of the Transportation Security Administration's 

use of backscatter units. It is based on interviews with employees and officials of relevant 

agencies and institutions, direct observations, and a review of applicable documents. 

Thc recommendations herein have been developed to the best knowledge available to our office, 

and have been discussed in draft with those responsible for implenlentation. We trust this report 

will result in more effective, efficient, and economical operations. We express our appreciation 

to all of those who contributed to the preparation of this report. 

C~~(-~ Carlton I. Mann 

Assistant Inspector General for Inspections 
Table of Contents/Abbreviations 


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

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

Results of Review ............................................................................................................................5
 

Independent Surveys Conducted Prior to Deployment Conclude That 


Backscatter Radiation Levels Are Below Established Limits ...................................................5 


TSA Complied With ANSI Radiation Safety Survey Requirements .........................................8 


Recommendation .....................................................................................................................11
 

Management Comments and OIG Analysis ............................................................................12 


Radiation Surveys and Studies Conducted After Deployment Conclude That
 

Levels Are Within Established Limits .....................................................................................12 


Backscatter Calibrations Have Not Been Performed Consistently..........................................14 


Recommendation .....................................................................................................................14
 

Management Comments and OIG Analysis ............................................................................15 


Not All Transportation Security Officers Have Completed Required 


Radiation Safety Training ........................................................................................................15
 

Recommendations ...................................................................................................................16
 

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


Additional On-the-Job Training for Transportation Security Officers 


Should Be Considered..............................................................................................................17
 

Recommendation .....................................................................................................................18
 

Management Comments and OIG Analysis ............................................................................18 


Accidental Radiation Overdoses Have Not Occurred .............................................................19 


Recommendation .....................................................................................................................19
 

Management Comments and OIG Analysis ............................................................................20 


Appendices 

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


Appendix B: Management Comments to the Draft Report ...................................................22 


Appendix C: Major Contributors to this Report....................................................................26 


Appendix D: Report Distribution ..........................................................................................27 

 

Abbreviations 

AIT 

ANSI 

APL 

CDRH 

DHS 

FDA 

HPS 

JHU 

mrem 

NIST 

OIG 

OJT 

OLC 

OSHE 

RSO 

S&T 

SAT 

TSA 

TSO 

μrem 

USAPHC 

Advanced Imaging Technology 

American National Standards Institute 

Applied Physics Laboratory 

Center for Devices and Radiological Health 

Department of Homeland Security 

Food and Drug Administration 

Health Physics Society 

Johns Hopkins University 

millirem 

National Institute of Standards and Technology 

Office of Inspector General 

on-the-job training 

Online Learning Center 

Office of Occupational Safety, Health and Environment 

Radiation Safety Office 

Science and Technology 

Site Acceptance Test 

Transportation Security Administration 

Transportation Security Officer 

microrem 

U.S. Army Public Health Command 
OIG
 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The Transportation Security Administration is responsible for screening 

passengers at commercial airports. One method of securing the traveling 

public is through the use of Advanced Imaging Technology to detect a 

wide range of metallic and nonmetallic threats, including weapons and 

explosives. The general-use backscatter unit is a type of imaging 

technology that delivers an extremely low dose of ionizing radiation to the 

person being screened. These units create an image from very small 

amounts of x-ray that reflect off the person being screened. 

The Transportation Security Administration began deploying general-use 

backscatter units in March 2010, with 247 units currently operating in 39 

commercial airports around the country. Advanced Imaging Technology 

equipment used by the agency must conform to requirements established 

by the Health Physics Society and accredited by the American National 

Standards Institute, an entity responsible for facilitating the development 

of national radiation safety standards. 

Professional organizations conducted independent radiation studies that 

concluded that radiation levels emitted from backscatter units were below 

the acceptable limits. Specifically, to reach annual radiation dose limits, a 

passenger would have to receive more than approximately 17,000 

screenings in a 12-month period, which is equivalent to approximately 47 

screenings per day, 365 days per year. The Transportation Security 

Administration entered into interagency agreements for additional 

radiation safety surveys and dosimetry monitoring studies to document 

radiation dose to agency personnel and individuals undergoing screening. 

The results of each study concluded that the level of radiation emitted was 

below acceptable limits. 

We are making recommendations for the Transportation Security 

Administration to (1) ensure that radiation surveys are conducted on 

backscatter units for any incidents of unintended radiation emissions, 

(2) ensure that backscatter calibrations are consistently conducted and 

documented, (3) ensure that Transportation Security Officers complete 

annual radiation safety training, (4) verify that training requirements are 

completed, (5) determine the appropriate amount of on-the-job training for 

Transportation Security Officers who operate backscatter units, and 

(6) develop procedures to ensure appropriate notifications of unintended 

radiation emissions or overdoses. 

Transportation Security Administration’s Use of Backscatter Units 

Page 1 
Background 

The Transportation Security Administration (TSA), the primary agency 

responsible for securing the Nation’s civil aviation enterprise, is 

responsible for screening passengers at commercial airports throughout the 

United States and its territories. Passenger screening is carried out by 

Transportation Security Officers (TSOs) trained to perform screening 

duties. In addition to TSOs at federal airports, nonfederal airports use 

private contract screeners for passenger screening with TSA oversight. 

Guidance from TSA’s screening policies and training requirements for 

TSOs also applies to contract screeners at nonfederal airports. 

TSA’s Passenger Screening Program manages security technology 

processes for passenger screening at airport security checkpoints to 

prevent the entry of dangerous and prohibited items on commercial 

aircraft. Advanced Imaging Technology (AIT) equipment is used to 

screen passengers for metallic and nonmetallic threats that include 

weapons, explosives, and other prohibited objects concealed on 

individuals entering secure areas of the airport. The general-use 

backscatter unit shown in figure 1 is one type of AIT equipment used for 

passenger screening.1 

Figure 1. Backscatter Unit 

Source: TSA. 

Backscatter units are categorized as general-use systems—systems that 

ensure a high degree of radiation safety based on the emission of 

negligible doses of radiation and built-in engineering controls. 

Unlike a traditional x-ray machine, which relies on the transmission of 

1

 Millimeter wave technology is the other AIT used by TSA. It consists of non-ionizing electromagnetic waves that 

generate images based on energy reflected from the body. 

Transportation Security Administration’s Use of Backscatter Units 

Page 2 
 

x-rays through the object, general-use backscatter units detect the radiation 

that reflects off the object and forms an image. The backscatter pattern is 

dependent on the material property, which makes it suitable for imaging 

organic material. General-use backscatter units rapidly scan an x-ray 

beam over an individual’s body, electronically creating an image from 

x-rays that scatter from the skin’s surface. The technology displays the 

front and back images of the scanned individual, which a TSA image 

operator analyzes to identify potential threats. 

General-use backscatter technology using x-ray exposes the person being 

scanned to negligible doses of ionizing radiation. When a person is 

exposed to radiation, energy is deposited in the tissues of the body. The 

amount of energy deposited per unit mass of human tissue is called the 

absorbed dose. The effective dose of radiation is a measure of the 

combined effects of radiation on various body tissues and organs. 

A person’s biological risk—the risk of suffering health effects from 

exposure to radiation—is measured in rems. A rem is a unit used to 

describe how much radiation energy an individual receives. When the 

amount of radiation being measured is less than 1 rem, prefixes are 

attached to the unit of measure. Smaller radiation doses can be measured 

in millirems (mrem), which is one thousandth (1/1,000) of a rem, and 

microrem (μrem), which is one millionth (1/1,000,000) of a rem. 

In the United States, an x-ray system is considered compliant with 

requirements for general-purpose security screening of humans if it 

complies with standards of the American National Standards Institute 

(ANSI). ANSI facilitates the development of national standards by 

accrediting the procedures of organizations that collaborate in developing 

national consensus standards. ANSI and the Health Physics Society 

(HPS), a scientific organization specializing in promoting excellence in 

radiation safety, collaborated on the radiation safety standard ANSI/HPS 

N43.17-2002, Radiation Safety for Personnel Security Screening Systems 

Using X-Rays. This standard included requirements intended for selfenclosed, full-body x-ray scanners that operated by scanning a person who 

was standing still. 

Several new x-ray scanning system designs and new use requirements 

were developed after the publication of ANSI/HPS N43.17-2002, such as 

systems that scan occupied vehicles and those that inspect casts and 

prosthetic devices. As a result of these new designs, a revised standard 

was published in November 2009, ANSI/HPS N43.17-2009, Radiation 

Safety for Personnel Security Screening Systems Using X-Ray or Gamma 

Radiation. 

Transportation Security Administration’s Use of Backscatter Units 

Page 3 
 

TSA requires that general-use backscatter units approved for deployment 

conform to ANSI/HPS N43.17-2009, which provides guidelines specific 

to radiation safety in the design, performance, and operation of these 

systems, and covers dose to subject, operational procedures, training for 

operators, and other information. The standard includes requirements for 

(1) general-use full-body scanning systems, such as backscatter units, that 

scan individuals standing in a fixed position, and (2) the maximum amount 

of radiation a passenger receives within a 12-month period. 

The ANSI/HPS N43.17-2009 committee changed the way the dose limit is 

stated from 10 microrem for one front scan to 25 microrem for a full 

screening. ANSI/HPS N43.17-2009 retained the annual effective dose 

limit of 25 mrem in a 12-month period for scanned individuals. By 

comparison, 25 mrem is equal to the amount of background radiation 

exposure from the air and soil at sea level every 1.5 hours. Table 1 lists 

examples of radiation exposures and the associated doses: 

Table 1. Examples of Radiation Exposure 

Source of Exposure Dose in mrem 

Exposure to cosmic rays during a 

roundtrip airplane flight from 

New York to Los Angeles 

3 mrem 

One dental x ray 4–15 mrem 

One chest x ray 10 mrem 

One mammogram 70 mrem 

One year of exposure to natural radiation 

(from soil, cosmic rays, etc.) 300 mrem 

Source: Centers for Disease Control and Prevention 

According to Rapiscan, the manufacturer, the effective dose for one 

screening from a backscatter unit is 5 microrem (0.005 mrem) or less. 

Radiation surveys required by ANSI standards are conducted to determine 

the x-ray emissions from general-use backscatter units. Independent, or 

third-party, surveys of the general-use backscatter units are also performed 

to measure these emissions and determine whether they comply with 

ANSI standards and federal regulations. Third-party surveys are in 

addition to the annual radiation surveys that maintenance providers perform. 

Transportation Security Administration’s Use of Backscatter Units 

Page 4 
Results of Review 


Independent Surveys Conducted Prior to Deployment Conclude That 

Backscatter Radiation Levels Are Below Established Limits 

Prior to the deployment of general-use backscatter units in March 2010, TSA 

entered into agreements with federal agencies and partnered with accredited 

organizations to determine whether the level of radiation emitted by backscatter 

units was within ANSI’s acceptable limits. Four radiation safety assessments 

were performed on backscatter units prior to their deployment and use for 

passenger scanning. The results of each study concluded that the level of 

radiation emitted was below ANSI’s acceptable limits.2 

The following sections provide the results of radiation assessments conducted on 

the backscatter units. 

Food and Drug Administration Radiation Safety Assessments 

The Food and Drug Administration’s (FDA’s) Center for Devices and 

Radiological Health (CDRH) is responsible for the oversight of radiationproducing equipment. CDRH entered into an interagency agreement with 

TSA in April 2006 to evaluate x-ray emissions from airport screening 

equipment and estimate the effective dose of radiation to individuals being 

scanned, AIT operators, and bystanders.3 

In July 2006, CDRH determined the effective dose of radiation for 

individuals scanned by Rapiscan’s Secure 1000 backscatter unit. Based 

on the results of CDRH’s study, an adult would receive an effective dose 

of about 2.4 microrem per scan, a child would receive an effective dose of 

about 4 microrem per scan, and an infant would receive an effective dose 

of about 5 microrem per scan. All test results concluded that the effective 

dose of radiation for individuals scanned was below the ANSI standard of 

10 microrem per scan.4 

Rapiscan’s Third-Party Radiation Testing 

TSA developed a Qualification Test and Evaluation of Whole Body 

Imagers to support its procurement decisions prior to awarding the 

backscatter contract. As the manufacturer of the backscatter unit, 

Rapiscan submitted a Qualification Data Package, which included a 

requirement that certification to the ANSI safety radiation levels be 

performed by a third party, not the manufacturer. 

2

 ANSI/HPS N43.17, Section 2.0.
 

3

 Task Order 001 of Interagency Agreement HSTS04-06-X-CTO003.
 

4

 Radiation Safety for Personnel Security Screening Systems Using X-rays (N43.17-2002), July 2002. 


Transportation Security Administration’s Use of Backscatter Units 

Page 5 
Rapiscan redesigned backscatter units from a dual-pose to a single-pose 

configuration, allowing an individual’s front and back to be scanned in 

succession. This modification required that the backscatter unit be 

assessed for compliance with ANSI standards by a third-party tester. 

Therefore, a radiation safety assessment of its newly configured 

backscatter unit was included as part of the third-party testing. 

In a June 2008 report, the third-party tester assessed radiation levels for 

scanned individuals and backscatter operators. The report concluded that 

the redesigned backscatter unit met ANSI standards of less than 10 

microrem per scan. For the backscatter unit, the effective dose of 

radiation for individuals per scan was 1.81 microrem, and the effective 

dose for operators was approximately 0.68 microrem. Although the units 

met ANSI safety standards, the third-party tester recommended that wing 

shields be installed to further reduce radiation exposure levels for 

backscatter operators. 

National Institute of Standards and Technology 

The National Institute of Standards and Technology’s (NIST) Office of 

Law Enforcement Standards maintains expertise in developing electronic 

instruments that detect contraband on an individual’s body or under 

clothing. To support the research efforts of DHS’ Science and Technology 

(S&T) Directorate, DHS has an interagency agreement with NIST to 

provide reviews, audits, and technical support for TSA and S&T’s 

Transportation Security Laboratory’s testing of enhanced metal detectors, 

which includes backscatter units. 

In July 2008, NIST assessed the backscatter unit’s radiation safety level 

and its compliance with ANSI N43.17-2002. Based on a review of 

Rapiscan’s third-party tester’s compliance reports, backscatter unit 

specifications, and results from the FDA CDRH assessment of the original 

backscatter configuration, NIST concluded that radiation levels for 

scanned individuals were below ANSI limits. NIST also agreed with 

Rapiscan’s third-party tester’s June 2008 recommendation to add wing 

shields to further reduce backscatter operators’ exposure to radiation. 

Rapiscan’s Third-Party Supplemental Report 

Based on recommendations from the third-party tester and NIST, Rapiscan 

modified the backscatter unit in August 2008 by attaching wing shields on 

each side to minimize operators’ exposure to radiation. Because of the 

ANSI requirement to test units after any update or modification, Rapiscan’s 

third-party tester retested the modified backscatter unit to determine 

Transportation Security Administration’s Use of Backscatter Units 

Page 6 
whether radiation exposures to operators were in compliance with ANSI 

dose limitations after the addition of wing shields. 

In October 2008, Rapiscan’s third-party tester provided a supplement to 

the June 2008 report, which concluded that the operator dose was 

approximately 0.02 microrem per scan, which is less than the 10 microrem 

per scan limit established by ANSI/HPS N43-17-2002. 

Johns Hopkins University Independent Assessment 

The Johns Hopkins University Applied Physics Laboratory (JHU/APL) 

provides technical support to TSA by evaluating x-ray systems used for 

scanning vehicles and personnel. TSA requested that JHU/APL conduct 

an independent radiation safety engineering assessment of the backscatter 

unit to determine compliance with ANSI.5 

JHU/APL conducted its assessment from July 27 through 29, 2009. 

ANSI/HPS N43.17-2002 was in effect during this period. Under this 

standard, the limit of the effective dose per scan was 10 microrem. 

However, a revised standard, ANSI/HPS N43.17-2009, was pending 

publication during the time of that assessment. This new ANSI/HPS 

standard changed the effective dose from 10 microrem for one front scan 

to 25 microrem for a full screening. JHU/APL applied both ANSI 

standards as part of its assessment methodology. 

In October 2009, JHU/APL released the results of both assessments. 

When applying the requirements of the 2002 ANSI standard, the 

assessment determined an individual effective dose per scan of 

1.58 microrem. Therefore, an individual who receives fewer than 15,822 

screenings in a 12-month period, which is equivalent to 43 screenings per 

day, 365 days per year, will not reach the annual effective dose of 

25 mrem. Using the 2009 standard, the assessment determined an 

individual effective dose of 1.48 microrem per screening. An individual 

effective dose is below the 25 mrem annual limit for individuals with 

fewer than 16,891 screenings in a 12-month period, which is equivalent to 

46 screenings per day, 365 days per year. 

The background exposure reading was revised in an August 2010 

JHU/APL report that changed the average effective dose per screening 

from 1.48 microrem to 1.46 microrem, and the individual effective dose 

from 16,901 to 17,123 screenings in a 12-month period. The 2009 and 

2010 calculations were both below the annual limit. 

5

 ANSI N43.17-2002 and ANSI/HPS N43.17-2009, Radiation Safety for Personnel Security Screening Systems 

Using X-Ray or Gamma Radiation. 

Transportation Security Administration’s Use of Backscatter Units 

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TSA Complied With ANSI Radiation Safety Survey Requirements 

In addition to establishing radiation levels, the ANSI standard requires that 

radiation safety surveys be conducted to verify the effective dose, radiation 

leakage, inspection zone, and any other parameters specified by the manufacturer.6 

To accomplish these objectives, radiation surveys are required (1) upon installation 

of backscatter units; (2) every 12 months; (3) after any maintenance that affects 

the radiation shielding, shutter mechanism, or x-ray production components; and 

(4) after any incident that may have damaged the unit in such a way that 

unintended radiation emission occurs. TSA has established procedures to ensure 

that radiation safety surveys are conducted during specific intervals and when 

circumstances dictate. 

Radiation Safety Surveys at Installation 

ANSI N43.17- 2009 requires that radiation safety surveys be performed 

upon installation of backscatter units. These surveys, referred to as Site 

Acceptance Tests (SATs), verify that backscatter units are installed and 

configured properly and that radiation levels are compliant with ANSI 

standards. The SAT Plans and Procedures lists each specification to be 

verified and includes the reporting requirements for survey results. 

Rapiscan field technicians conducted independent SATs on each 

backscatter unit deployed to airports. As units were installed, the field 

technicians recorded SAT results on Form R-0646-1, Secure 1000 

Radiation Emission Measurement Survey, which was reviewed by 

Rapiscan’s Radiation Safety Office (RSO) and provided to TSA 

personnel. 

In November 2010, TSA received a request from a news organization for 

the results of radiation safety surveys conducted during the initial 

installation of backscatter units that began in March 2010. In December 

2010, TSA also received a congressional request to release the radiation 

test results of its backscatter units in response to public concern over 

possible increases in radiation levels. However, TSA asked Rapiscan to 

review the survey results prior to any public release. 

Rapiscan’s RSO reviewed the initial surveys for each backscatter unit and 

identified miscalculations in determining radiation levels. Although all 

backscatter units were in compliance with ANSI standards, Rapiscan 

technicians conducting the initial surveys improperly calculated radiation 

levels and documented results that exceeded the 25 microrem ANSI limit. 

Other errors included excluding background radiation levels and using 

incorrect scan times. 

6

 The inspection zone is the entire area between the backscatter’s two scanning units, including the rubber mat. 

Transportation Security Administration’s Use of Backscatter Units 

Page 8 
RSO employees concluded that the survey reporting form needed 

clarification, and Rapiscan technicians required additional training on how 

to complete the forms. Therefore, RSO personnel recommended revising 

the survey form and providing refresher training for service technicians by 

January 31, 2011. 

In January 2011, TSA collaborated with Rapiscan to revise the survey 

form and automate the mathematical formulas in order to electronically 

calculate radiation levels. Rapiscan training records indicated that 

technicians attended refresher training in February and March 2011. 

In March 2011, Rapiscan resurveyed all 247 backscatter units deployed at 

39 commercial airports to verify that radiation levels were within the 

ANSI limit of 25 microrem per screening. The resurveys showed that 

radiation levels for all backscatter units were below ANSI standards. 

Even though the resurveys provided assurances that the radiation levels of 

all backscatter units were below ANSI limits, TSA did not have a process 

in place to consistently review and verify the accuracy of radiation safety 

results. However, effective August 2011, TSA amended its Rapiscan 

contract to include a process for reviewing the results of all radiation 

safety surveys at multiple levels to ensure accuracy, completeness, and 

compliance with ANSI standards. 

The revised contract also requires updates on the status of radiation safety 

surveys, including (1) radiation surveys performed to date, (2) corrected 

radiation surveys to date, (3) number of radiation resurveys to date, 

(4) status of trained and certified technicians for radiation surveys, and 

(5) upcoming radiation surveys and resurveys. 

Radiation Safety Surveys Every 12 Months 

ANSI N43.17-2009 requires that radiation safety surveys be conducted at 

least once every 12 months on x-ray personnel security screening systems. 

The general-use backscatter units were deployed beginning March 2010, 

with radiation safety surveys due each year after their respective 

deployment date. Rapiscan’s resurvey of all backscatter units in March 

2011 satisfied the ANSI requirement through March 2012. 

TSA’s August 2011 amended contract with Rapiscan required biannual 

radiation safety surveys on backscatter units for the first 2 years of 

warranty coverage. Rapiscan created a database that maintains and tracks 

its preventive maintenance and survey schedule. The database 

automatically creates work orders for field technicians assigned to airports 

to complete required annual and semi-annual surveys. Once a radiation 

survey is completed, the database automatically generates a new work 

Transportation Security Administration’s Use of Backscatter Units 

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order, dated 6 months in advance, for the next required survey. The 

amended contract also requires Rapiscan to conduct a final radiation 

survey for each backscatter unit a month before the warranty expires. 

The biannual radiation safety survey schedule established by TSA and 

Rapiscan provides a mechanism for deployed backscatter units to be 

surveyed twice within 12-month intervals. This schedule exceeds the 

ANSI requirement for performing radiation surveys at least once every 12 

months. 

Radiation Safety Surveys After Maintenance 

ANSI requires that radiation safety surveys be conducted on backscatter 

units after any maintenance that affects the radiation shielding, shutter 

mechanism, or x-ray production components. Since all backscatter units 

are under warranty, Rapiscan, as the manufacturer, is responsible for 

conducting the surveys. 

In collaboration with TSA, Rapiscan developed a Maintenance Manual to 

ensure that backscatter units comply with ANSI standards. The manual 

contains instructions for performing corrective maintenance, and indicates 

the type and frequency of preventive maintenance activities. Although the 

manual is primarily used by Rapiscan’s contract technicians, it also directs 

TSA personnel to periodically perform inspections of the backscatter’s 

exterior to determine whether parts may be damaged, missing, or worn. 

The maintenance manual describes the corrective and preventive 

maintenance to be performed on backscatter units. Corrective maintenance 

is an unscheduled activity performed to restore backscatter units to an 

operating condition after a system failure. Preventive maintenance 

consists of periodic scheduled checks to ensure that backscatter units 

remain reliable and operate as intended. These maintenance activities are 

conducted by qualified service providers at predetermined intervals. 

A database is used to schedule preventive maintenance on backscatter 

units every 6 months. After preventive maintenance is completed, the 

database generates another work order for the next 6-month period. 

TSA’s backscatter maintenance log showed that, from May 2010 to May 

2011, 3,778 service calls were made in response to mechanical problems 

with backscatter units. Of that number, 84, or 2%, resulted in radiation 

safety surveys. The three most prevalent corrective actions taken to 

resolve mechanical problems were replacing parts where no adjustments 

to the units were required (680), rebooting or resetting the unit (566), and 

replacing parts where adjustments or calibrations were required (528). We 

Transportation Security Administration’s Use of Backscatter Units 

Page 10 
did not identify any instances where a radiation survey should have been 

performed but was not. 

Radiation Safety Surveys After Unintended Emissions 

ANSI standards require that radiation safety surveys be conducted on 

backscatter units after any incident that may have damaged the system and 

caused unintended radiation emission. We did not identify any instances 

of unintended radiation emissions. 

According to TSA’s Occupational Safety and Health Manual, safety 

measures to ensure that unintended radiation emission does not occur 

include system controls such as interlocking doors, emergency on/off 

switches, warning labels, and standard operating procedure for the safe use 

of radiation screening systems. 

TSA’s Maintenance Manual directs all personnel responsible for 

maintaining backscatter units to provide TSA with a detailed written 

report of any actions by backscatter users or operators that could cause a 

radiation accident or unsafe event as soon as such an action is identified. 

Maintenance personnel are also required to respond to and investigate all 

reports of system malfunctions or failures and resolve problems before 

units are back in service. 

Rapiscan personnel stated that no contingency plans existed for unintended 

radiation emissions because safety features were built into backscatter 

units. Specifically, the failure of any subsystem results in non-operation 

of the x-ray generator to prevent accidental exposures. TSA personnel 

also said that a process to handle unintended radiation emissions has not 

been established since backscatter units were designed not to exceed the 

ANSI dose limit. 

During our fieldwork, we were not informed of any unintended radiation 

emissions, and we did not identify any reports or other documents that 

included information related to unintended radiation emissions. However, 

even with safety requirements that include fail-safe controls, TSA needs to 

ensure that radiation surveys are conducted after any incident that may 

damage the system and cause unintended radiation emissions. 

Recommendation 

We recommend that the Assistant Administrator for Security and 

Technology, Transportation Security Administration: 

Transportation Security Administration’s Use of Backscatter Units 

Page 11 
Recommendation #1: Develop a process to ensure that radiation surveys 

are conducted on general-use backscatter units after any incident that may 

have damaged the system and caused unintended radiation emissions. 

Management Comments and OIG Analysis 

We evaluated TSA’s written comments and made changes to the report 

where we deemed appropriate. A summary of TSA’s written responses to 

our recommendations and our analysis of the responses follow each 

recommendation. A copy of TSA’s response, in its entirety, appears in 

appendix B. 

TSA Response: TSA concurred with Recommendation 1. 

TSA’s current safety protocols require all equipment manufacturers to 

comply with nationally recognized safety standards to ensure both 

passenger and operator safety. Each backscatter unit undergoes a system 

inspection and radiation survey before leaving the manufacturer and after 

installation in the airport. Radiation surveys are also performed once 

every 6 months; whenever a unit is moved; after any maintenance action 

that affects radiation shielding, shutter mechanism, or x-ray production 

components; and after any incident that may have damaged the system. 

TSA partnered with Certified Health Physicists at the U.S. Army Public 

Health Command (Provisional) to conduct independent radiation surveys 

and inspections to confirm the regular testing performed by the equipment 

manufacturer. 

OIG Analysis: TSA’s response describes Rapiscan’s responsibility for 

compliance with federal safety standards relating to damaged backscatter 

units that may cause unintended radiation emission, and when radiation 

safety surveys should be conducted. Although there have been no 

instances of unintended radiation emissions, TSA’s oversight 

responsibilities should include a process to verify that protocols in place 

are followed in the event of such occurrences. Therefore, this 

recommendation is unresolved and open, pending our receipt and review 

of such a process. 

Radiation Surveys and Studies Conducted After Deployment Conclude 

That Levels Are Within Established Limits 

In 2010, TSA’s Office of Occupational Safety, Health and Environment (OSHE) 

and U.S. Army Public Health Command (USAPHC) extended an established 

interagency agreement to include USAPHC conducting radiation safety surveys 

of deployed backscatter units. The agreement also required USAPHC to provide 

Transportation Security Administration’s Use of Backscatter Units 

Page 12 
radiation dosimetry monitoring studies to document the radiation exposure levels 

of TSA personnel.7 

USAPHC’s radiation safety surveys of backscatter units are not an ANSI 

requirement, but supplement surveys conducted before and at the time of 

installation. As part of OSHE’s radiation safety program, the surveys are 

conducted to ensure that backscatter units are in compliance with the 25 microrem 

per screening limit required by ANSI/HPS N43.17-2009. Radiation safety 

surveys and dosimetry studies completed by USAPHC concluded that backscatter 

units were in compliance with the ANSI limit. 

USAPHC Radiation Safety Surveys 

In April 2010, USAPHC began conducting radiation safety surveys on 

backscatter units to determine the radiation dose to individuals being 

screened, system operators, and bystanders. According to test results, all 

machines surveyed emitted levels of radiation less than the 25 microrem 

limit per screening. Specifically, the test results concluded that an 

individual would have to be screened more than 5,000 times in a year to 

exceed the annual effective dose limit. For system operators and 

bystanders, the radiation level at the inspection zone would require an 

individual to be present during 1,000,000 screenings in a year to reach the 

annual effective dose limit. 

USAPHC Dosimetry Studies 

From January to Feburary 2011, USAPHC worked with OSHE to conduct 

an area dosimetry study at TSA’s Transportation Systems Integration 

Facility. This facility assesses various screening systems before and after 

deployment at airports.8 

A TSA official explained that USAPHC includes area dosimetry studies 

during some of the radiation safety surveys. The official said that area 

dosimetry studies are currently underway at five airports in which 

dosimeters are mounted on various backscatter units. Data are analyzed 

by USAPHC and OSHE and incorporated into a final report to OSHE. 

During the study, dosimeters were placed in and around a backscatter unit 

to determine potential radiation doses to TSOs conducting passenger 

screenings and individuals in close proximity to backscatter units. 

Preliminary study results showed that the potential radiation dose to 

backscatter unit operators and individuals in close proximity to the units 

7

 Dosimetry studies measure the potential radiation dose to individuals operating backscatter units as well as to 


personnel in the vicinity of the units during screening operations. 


8

 Area dosimetry studies measure radiation levels within the immediate area of backscatter units. 


Transportation Security Administration’s Use of Backscatter Units 

Page 13 
was within the ANSI limit. As of August 2011, USAPHC had not 

submitted a final report to TSA on the dosimetry study. 

From April 2010 to August 2011, 145 of the 247 backscatter units 

deployed nationwide were surveyed. OSHE established a radiation survey 

schedule through August 2011 that included dates, locations, and 

durations of each survey. An OSHE official said that plans were 

underway to survey the remaining backscatter units during fiscal year 

2012; however, no specific timeframe for completion has been set. 

ANSI standards include a requirement for performing radiation surveys at 

least every 12 months. Studies performed by USAPHC could provide 

increased assurance that backscatter units are in compliance with ANSI 

limits if the interagency agreement included timeframes to survey all 

backscatter units within a 12-month period. 

Backscatter Calibrations Have Not Been Performed Consistently 

Backscatter units must be calibrated to ensure appropriate image quality and 

operational safety. According to TSA’s March 2011 Screening Management 

Standard Operating Procedures, calibrations of backscatter units should be 

performed at defined intervals and under specified circumstances. The procedures 

provide detailed instructions for recording and maintaining the results of each 

calibration. However, there were inconsistencies in how TSA personnel adhered 

to policy requirements. 

During our fieldwork, TSA personnel at different airport locations described 

(1) various frequencies for conducting calibrations at their assigned checkpoint, 

(2) different scenarios that would require the results to be recorded, and (3) a 

range of methods for recording calibration results. We did not identify any 

improperly calibrated backscatter units that compromised operational safety. 

However, consistency in conducting calibrations and recording the results would 

provide additional assurance that appropriate safety measures are being enforced. 

Recommendation 

We recommend that the Assistant Administrator for Security and 

Technology, Transportation Security Administration: 

Recommendation #2: Develop controls to ensure that backscatter unit 

calibrations are conducted consistently and documented as required by 

established standard operating procedures. 

Transportation Security Administration’s Use of Backscatter Units 

Page 14 
Management Comments and OIG Analysis 

TSA Response: TSA concurred with Recommendation 2. 

The Screening Management Standard Operating Procedure, Section 3.2., 

contains the requirements for the operation, testing, and maintenance of all 

backscatter and millimeter wave AIT screening equipment. This section 

also requires that a Supervisory Transportation Security Officer record the 

results of the daily calibration and image quality verification and that the 

test records must be maintained for at least 30 days at the checkpoint. 

After the 30 days, the records must be labeled and maintained for 1 year 

under the control of the Federal Security Director. 

OIG Analysis: TSA’s Screening Management Standard Operating 

Procedures describe how backscatter units should be calibrated and the 

results recorded. However, we found inconsistencies in the enforcement 

of these procedures. This recommendation is unresolved and open, 

pending our receipt and review of TSA’s measures to ensure uniform 

compliance with established procedures. 

Not All Transportation Security Officers Have Completed Required 

Radiation Safety Training 

ANSI standards require that personnel operating backscatter units receive 

adequate radiation safety training, followed by refresher training at least once 

every 12 months. To facilitate completion of this training, TSA has established a 

centralized online training system for use by TSOs. However, the online system 

has not been an efficient or effective means of providing radiation safety training 

or refresher training. As a result, not all TSOs have satisfied the online training 

requirement for radiation safety. 

ANSI standards require that personnel be trained in specific areas that include 

(1) defining radiation, (2) identifying exposure limits, radiation safety measures, 

and other safety hazards, (3) procedures to prevent unauthorized use or access to 

the system, and (4) emergency procedures. 

To satisfy ANSI standards, OSHE developed a radiation safety course as part of 

its Radiation Safety Program. All employees who could be exposed to radiation 

must complete the most current version of the radiation safety course within 6 

months of their initial employment date. In addition, TSOs must retake the most 

recent version of the radiation safety course every year to satisfy the annual 

refresher training requirement. 

TSA’s Online Learning Center (OLC) is a centralized system to support the 

delivery and management of all TSA learning and development programs. TSA 

Transportation Security Administration’s Use of Backscatter Units 

Page 15 
policy requires TSOs to complete 2 hours of OLC training each week, including 

the radiation safety course, to satisfy training requirements. In addition to the 

online radiation safety training, OSHE officials said TSA promotes radiation 

safety awareness through bulletins posted on its Intranet site and through the 

OLC. TSA officials also described other activities, such as Safety Week, in 

which radiation safety has been a topic of interest during training workshops. 

During our fieldwork, several TSOs told us that they were unable to access and 

complete OLC training because of time constraints associated with performing 

their duties, or computer delays. They also said that this is why other information 

concerning radiation safety is not read. 

Providing TSOs with an appropriate level of training regarding radiation exposure 

limits, hazards, and emergency procedures is essential to promote safety. Although 

TSA provides various resources to inform its employees, it needs to ensure that 

training resources are effective in satisfying TSO training requirements. 

Recommendations 

We recommend that the Assistant Administrator for Security and 

Technology, Transportation Security Administration: 

Recommendation #3: Develop a process to ensure that TSOs satisfy 

ANSI requirements for radiation safety training. 

Recommendation #4: Develop a process to verify the completion of 

annual refresher training by TSOs operating backscatter units. 

Management Comments and OIG Analysis 

TSA Response: TSA concurred with Recommendation 3. 

TSA has developed its training to meet ANSI safety requirements for 

radiation. All security officers are required to complete radiation safety 

awareness training on an annual basis. TSA records show that 98% of the 

security officers at airports with backscatter technology completed the 

training in fiscal year 2011; the other 2% are not actively screening. 

Employees’ training records are tracked through the TSA OLC. 

OIG Analysis: ANSI standards require that operators of backscatter units 

receive radiation safety training, followed by refresher training at least 

once every 12 months. TSA established its OLC to manage all TSA 

learning and development programs. TSA’s internal policy requires TSOs 

to complete 2 hours of OLC training weekly, including the radiation safety 

course, to satisfy training requirements. However, several actively 

Transportation Security Administration’s Use of Backscatter Units 

Page 16 
screening TSOs informed us that they were unable to access and complete 

OLC training due to time constraints associated with performing their 

duties or computer delays. The TSOs’ statements were supported by 

reconciling their names to a list of radiation-safety trained TSOs. This 

recommendation is unresolved and open, pending our receipt and review 

of TSA records showing completion of fiscal year 2011 radiation safety 

training by employees operating backscatter units. 

TSA Response: TSA concurred with Recommendation 4. 

At the local level, each individual’s learning plan contains the required 

trainings he or she must complete to remain a certified officer. Airport 

management routinely monitors the training plans of officers to ensure that 

training is completed by the required completion date. At the headquarters 

level, training requirements are incorporated into TSA’s Management 

Control Objective Plan. Although this reporting process does not break 

down completion compliance by individual courses, it alerts executive 

leadership when an airport’s staff is not completing required training. 

This can prompt leadership to generate reports showing which officers are 

delinquent and ensure that training is completed. Using both systems to 

validate completion of training is the process developed to verify 

completion of training for officers operating all equipment, including 

backscatter units. 

OIG Analysis: TSOs operating AIT equipment must take the most recent 

version of the radiation safety course each year to satisfy ANSI’s annual 

refresher training requirement. TSA’s response addresses all training 

requirements for TSOs; however, a process to verify whether TSOs 

operating backscatter units complete the annual radiation safety refresher 

training is not included. Without such a mechanism in place, TSA has no 

assurance that radiation safety training will be completed in a timely 

manner. Therefore, this recommendation is unresolved and open. 

Additional On-the-Job Training for Transportation Security Officers 

Should Be Considered 

To provide TSOs with the skills necessary to operate backscatter units, TSA 

developed an AIT training curriculum that includes classroom training and 8 

hours of on-the-job training (OJT). Based on information obtained during our 

field visits, the classroom portion of the AIT training is presented as outlined in 

the curriculum at all locations. However, there were variances among airports in 

the OJT provided to prepare TSOs to operate backscatter units without 

supervisory assistance. 

Transportation Security Administration’s Use of Backscatter Units 

Page 17 
Four of the six airports we visited developed an OJT curriculum that included 

more than the 8 hours of OJT required in the AIT curriculum. OJT at these 

airports ranged from 20 to 38 hours. TSOs explained that the AIT classroom 

curriculum requires understanding a vast amount of knowledge before operating 

backscatter units, and additional OJT can improve TSOs’ competency. 

Several TSOs working in airports that required additional OJT hours informed us 

that they were more comfortable operating backscatter units without supervision 

as a result of the extra training. Some TSOs who worked in airports that required 

only the standard 8 hours of OJT said that additional hours would be beneficial 

before they independently operated backscatter units. A number of TSOs who 

worked in airports said that the 8 hours of required OJT were sufficient for them 

to perform their duties effectively. 

During our fieldwork, we did not identify TSOs who were not competent to 

operate backscatter units. However, additional OJT requirements could provide 

better assurance that TSOs receive training that fully prepares them to operate 

backscatter units independently. 

Recommendation 

We recommend that the Assistant Administrator for Security and 

Technology, Transportation Security Administration: 

Recommendation #5: Conduct an assessment to determine the 

appropriate amount of OJT training for TSOs operating general-use 

backscatter units. 

Management Comments and OIG Analysis 

TSA Response: TSA concurred with Recommendation 5. 

TSA determined the minimum number of OJT hours required for 

backscatter units by considering input from subject matter experts, 

feedback from operational tests and evaluation, and the backscatter course 

content. This process is used to establish the minimum number of hours to 

become proficient. The OJT Monitor assesses each officer throughout the 

OJT process to ensure proficiency in operating the equipment prior to 

certifying the officer and releasing him or her from OJT. Officers who are 

not proficient after 8 hours continue with additional OJT until they 

achieve proficiency. 

OIG Analysis: TSA describes the initial process used to establish the 

minimum number of OJT hours TSOs require to become proficient in the 

operation of backscatter units. During our fieldwork, some TSOs 

explained that the 8 hours of OJT was adequate to become proficient in 

Transportation Security Administration’s Use of Backscatter Units 

Page 18 
operating backscatter units, while other TSOs said they would have been 

more comfortable if additional OJT hours were available. Most TSOs said 

the AIT classroom instructions covered an enormous amount of 

information and additional OJT could be beneficial. 

Although we did not find any TSOs who were not competent in the 

operation of backscatter units, the intent of this recommendation is for 

TSA to reassess the 8-hour minimum OJT to determine whether additional 

training should be required. This recommendation will remain 

unresolved and open, pending our receipt of the results of TSA’s updated 

assessment. 

Accidental Radiation Overdoses Have Not Occurred 

FDA requires immediate notification from manufacturers upon discovery of any 

accidental radiation occurrence or an equipment safety defect. TSA’s amended 

contract with Rapiscan, dated August 2011, requires immediate notification to 

TSA and FDA of any accidental radiation emission. Specifically, the amended 

contract states that radiation safety surveys will be conducted according to the 

Federal Food, Drug and Cosmetic Act and related regulations requiring 

manufacturers to investigate and report any accidental radiation occurrence to 

TSA and FDA. However, TSA does not have procedures in place to verify such 

notifications from Rapiscan to FDA in the event of these occurrences. 

According to TSA and Rapiscan personnel, no accidental radiation overdoses of 

backscatter units have ever occurred. They explained that safety features in 

backscatter units make it impossible for scanned passengers or TSA employees to 

receive radiation doses that exceed ANSI standards, because the units immediately 

default to a shutdown mode when not operating properly. 

Our fieldwork did not identify any incidents or reports of accidental radiation 

emissions or overdoses. However, Rapiscan is required to notify FDA and TSA 

of any accidental radiation emissions. Therefore, a process to provide such 

notifications needs to be in place. 

Recommendation 

We recommend that the Assistant Administrator for Security and 

Technology, Transportation Security Administration: 

Recommendation #6: Develop procedures to ensure FDA is notified of 

any instances of accidental radiation emissions or overdoses. 

Transportation Security Administration’s Use of Backscatter Units 

Page 19 
Management Comments and OIG Analysis 

TSA Response: TSA concurred with Recommendation 6. 

Under the provisions of the Federal Food, Drug, and Cosmetic Act, the 

manufacturer is required to investigate and report any accidental radiation 

occurrence to the FDA and immediately notify the FDA in the event that 

the manufacturer becomes aware of a defect. In addition, ANSI/HPS 

N43.17-2009 requires the manufacturer to establish and maintain records 

of any incidents involving unplanned exposures as reported by the user, 

and provide the information to the FDA. 

Once backscatter units are out of warranty and TSA becomes responsible 

for maintenance, the maintenance contractor is required to notify the 

contracting officer’s technical representative and local TSA if a system 

defect or accidental radiation occurrence is discovered. The maintenance 

contractor will also notify the manufacturer, who in turn will notify the 

FDA. Currently, TSA’s Director, Occupational Safety, Health, and 

Environment, “is responsible for coordinating investigations of radiation 

safety related system defects, damage, malfunctions, and violations of 

radiation safety procedures.” To help ensure that the FDA is notified, 

TSA will revise the statement to include additional language for notifying 

the product manufacturer and the FDA whenever any electronic product 

radiation safety issues meet the criteria of an accidental radiation 

occurrence or defect. 

OIG Analysis: TSA cites the authorities governing notification to FDA 

in the event of accidental radiation occurrences and describes the actions it 

will take for these type occurrences when backscatter units are no longer 

under warranty. However, TSA’s oversight responsibilities should include 

a process to verify that FDA has been properly notified in the event of 

accidental radiation occurrences, whether or not backscatter units are 

under warranty. This recommendation is unresolved and open, pending 

our receipt and review of procedures to confirm that FDA is notified of all 

instances of accidental radiation emissions or overdoses. 

Transportation Security Administration’s Use of Backscatter Units 

Page 20 
Appendix A 

Purpose, Scope, and Methodology 

We conducted this review in response to a request from Congressman 

Edward J. Markey, U.S. House of Representatives. Our objective was to 

assess the manner in which TSA inspects, maintains, and operates 

backscatter units used in passenger scanning. Specifically, we were asked 

to address (1) the effectiveness and reliability of inspection plans to 

resolve issues concerning the operation of backscatter units, (2) the 

efficiency of quality control plans to ensure compliance with the dose-perscreening limit of 25 microrem, (3) how employees are trained to operate 

backscatter units, (4) how accidental overdose information is shared with 

federal agencies, passengers, or employees, and (5) TSA’s coordination 

with other federal agencies with more subject matter expertise. 

We conducted our fieldwork from February to June 2011 at six airports 

that used backscatter units as the primary passenger scanning system. 

These locations were Charlotte, North Carolina; Fort Lauderdale, Florida; 

Seattle, Washington; San Diego, California; Los Angeles, California; and 

Boston, Massachusetts. 

We interviewed personnel from TSA, S&T, Rapiscan, and USAPHC. We 

analyzed relevant documents and statistical data relating to backscatter 

unit radiation safety surveys, quality control measures, TSA training 

criteria, and coordination and information sharing between TSA and other 

federal agencies concerning the safety of backscatter units. As part of our 

analysis, we relied on radiation assessments previously conducted by 

FDA, Rapiscan, NIST, JHU/APL, and a third-party tester. 

To assess the effectiveness of TSA’s radiation safety programs, we 

observed USACPH radiation safety surveys and occupational safety and 

health inspections at Washington Dulles International Airport. We also 

visited the TSA Transportation Security Integration Facility at Ronald 

Reagan Washington National Airport, and the S&T Transportation 

Security Laboratory, Atlantic City, New Jersey, to determine their role in 

TSA’s radiation safety testing. 

This review was conducted under the authority of the Inspector General 

Act of 1978, as amended, and according to the Quality Standards for 

Inspections and Evaluations issued by the Council of the Inspectors 

General on Integrity and Efficiency. 

Transportation Security Administration’s Use of Backscatter Units 

Page 21 
Appendix B 

Management Comments to the Draft Report 

Transportation Security Administration’s Use of Backscatter Units 


Page 22
 

u.s, ncpu,mtnl 0' Homt ll nd Security 

601 South 12th Street 

Afiington, VA ZQ59!1 

Transportation DEC 1 9 2011 Security 

Administration 

INFORMATION 

MEMORA DUM FOR: Carlton I. Mann 

Assistant Inspector Gene ral 

U.S. Department of Homeland Security (DHS) 

FROM: John S. sto ~ n 

Administrator ~ l- S, &.....-~~ Transportatio curity AdminisLration 

SUBJECT: Response to Draft Report, TransporlOlion Security 

Administration's Use o/Bachcaller Unils, October 2011 

Purpose: 

This memorandlml constitutes the Transportation Security Administration's (TSA's) response to 

the DHS Office of the Inspector General (DIG) draft report, Transportation Securily 

Administration 's Use of Backscaller Units, dated October 2011, 

Background: 

In February 2011, DIG initiated a review ofTSA 's use of backscatter units in response to a 

request from Congressman Edward 1. Markey, U,S, House of Representatives. 

During this review, DIG visited six airports that used backscatter units as the primary passenger 

scanning system, and interviewed personnel from TSA, DHS Science and Technology (8&1 ), 

Rapiscan, and U.S. Army Public Health Command (USAPHC). OIG also analyzed relevant 

documents and statistical data relating to backscatter unit radiation safety surveys, quality control 

measures, TSA training criteria, and coordination and infonnation sharing between TSA and 

other federal agencies concerning the safety of backscatter units. 

OIO's report concludes that TSA was in compliance with the standard regarding radiation 

exposure limits and radiation safety requirements, and identified six recommendations for TSA. 

Discussion: 

TSA appreciates OIO"s work in planning and conducting its review and issuing this rcport. We 

believe the rcport fully endorses TSA"s extensive efforts to keep the traveling public safe, which 

is our agency's ultimate priority. 
Appendix B 

Management Comments to the Draft Report 

As a result of intense research. analysis. and testing. TSA concludes that potential hcaJth risks 

from a full-body screening with a general-use x-ray security system are miniscule. Several 

groups of recognized expens have analyzed the radiation safety issues associated with this 

technology and have found the systems to be well below the radiation dose limits. These ex pens 

have published recommendations. commentaries, technical reports, and an American national 

radiation safety standard as a result of their analyses. 

TSA has utilized Inter-Agency Agreements with the NationaJ Institute of Standard and 

Technology (NIST) and the U.S. Food and Drug Administration (FDA) to further validate third 

party radiation studies that all vendors must submit prior to testing. Additionally, the TSA 

Office of Occupational Safety, Health, and Environment is working with Certified Health 

Physicists from the U.S. Army Public HeaJth Command to perform radiation safelY surveys of 

the deployed general-use backscatter x-ray advance imaging technologies. 

We have based our evaluation on scientific evid~nce and on the recommendations of recognized 

experts. As a result of these evidence-based, responsible actions, we are confident that full-body 

x-ray security products and practices do not pose a significant risk to the public health. 

Conclusion: 

TSA has already implemented most of the recommendations contained in the report. Our 

specific response to each recommendation follows. 

Transportation Security Administration’s Use of Backscatter Units 


Page 23
 
Appendix B 

Management Comments to the Draft Report 

Transportation Security Administration (TSA) Update to 

Office of Inspector General (OIG) 11-101, 

Transportation Security Administration 's Use of Backscatter Units 

December 2011 , Update 

Recommendation #1: Develop a process to ensure that radiation surveys arc conducted on 

backscatter units after any incident that may have damaged the system and caused unintended 

radiation emissions. 

TSA Concurs: TSA agrees and has already implemented this recommendation. TSA's current 

safety protocols require all equipment manufacturers comply with nationally-recognized safety 

standards to ensure the safety of both passengers and operators. Each general-use backscatter xray Advance Imaging Technology (AIT) unit undergoes a system inspection and radiation survey 

before it leaves the manufacturing facility. The manufacturer must perform a radiation survey on 

each unit once it is install ed in the airport. Radiation surveys are also performed once every 

6 months; whenever a unit is moved; after any maintenance action that affects radiation 

shielding, shutter mechanism. or x-ray production components; and after any incident that may 

have damaged the system. TSA partnered with Certified Health Physicists at the U.S. Army 

Public Health Command (Provisional) to conduct independent radiation surveys and inspections 

to conHrm the regular testing performed by the equipment manufacturer. 

Recommendation #2: Develop controls to ensure that backscatter unit calibrations are 

conducted and documented as required by established standard operating procedures. 

TSA Concurs: TSA agrees and has already implemented the recommendation. The Screening 

Management Standard Operating Procedure. Section 3.2 .• contains the requirements for the 

operation, testing, and maintenance of all backscatter and millimeter wave AIT screening 

equipment. This section also requires that a Supervisory Transportation Security Officer record 

the results of the daily calibration and image quality verification and the test records must be 

maintained for at least 30 days at the checkpoint. After the 30 days, the records must be labeled 

and maintained for I year under the control of the Federal Security Director. 

Recommendation #3: Develop a process to ensure that Transportation Security Officers (TSO) 

satisfy ANSI requirements for radiation safety training. 

TSA Concurs: TSA agrees and has already implemented the recommendation. TSA has 

developed its training to meet American National Standards Institute (ANSI) safety requirements 

for radiation. All security officers are required to complete Radiation Safety Awareness training 

on an annual basis. Our records show that 98 percent of the security officers at airports with 

backscatter technology completed the training in fiscal year 2011 . Employees' training records 

are tracked through the TSA Online Learning Center; the other 2 percent are not actively 

screening. 

Recommendation #4: Develop a process to verify the completion of annual and refresher 

training by TSOs operating backscatter units. 

TSA Concurs: TSA agrees and has already implemented the recommendation. At the local 

level. each individual's learning plan contains the required trainings he or she must complete to 

remain a certified officer. Airport management. to include supervisors and training managers, 

routinely monitor the training plans of officers to ensure training is completed by the required 

Transportation Security Administration’s Use of Backscatter Units 


Page 24
 
Appendix B 

Management Comments to the Draft Report 

completion date. At the Headquarters (HQ) level, training rcquircments are incorporated into 

TSA', Management Control Objective Plan, which is a summary report rolling up perfonnance 

data from each airport. Included in that plan is the compliance rate of the officers at each airport 

to complete required training by the mandated completion date. While this reporting process 

does not break down completion compliance by individual courses, it does alert executive 

leadership, both in the field and at HQ, when an airport's stalf is not completing required 

training, which can then prompt leadership to generate reports showing which officers are 

delinquent and ensure training is completed. Using both systems to validate completion of 

training is the process developed to verify completion of training for officer's operating all 

equipment to include backscatter units. 

Recommendation #5: Conduct an assessment to determine the appropriate amount of on-thejob-training (OJD training for TSOs operating backscatter units. 

TSA Concurs: TSA agrees and has already implemented the recommendation. TSA detennined 

the minimum number of OJT hours required for backscatter units by considering input from 

sub t-matter experts, feedback from Operational Test and Evaluation, and the backscatter 

cours: content. This process is used to establish the minimum number of hours to become 

proficient. The OJT Monitor assesses each Omcer throughout the OJT process to ensure 

profidency in operating the equipment prior to certifying the Officer and releasing from OJT. If 

the Officer is not proficient after 8 hours, the officer continues with additional OJT until 

proficiency is achieved. 

Recommendation #6: Ensure that procedures are established to notify FDA of any instances of 

accidental radiation emissions or overdoses. 

TSA Concurs: The general-use backscatter x-ray system is classified as an electronic product 

and therefore, the FDA has regulatory authority over the manufac turer under the Electronic 

Product Radiation Control (EPRC) provisions of the Federal Food, Drug, and Cosmetic Act 

(FFDCA). Under this Act. the original equipment manufacturer (OEM) is required to investigate 

and repcrt any Accidental Radiation Occurrence (2 1 CFR 1002.20) to the FDA and immediately 

notify the FDA in the event they become aware of a defect (21 CFR 1003.10). In addition, 

ANS1IHPS N43 . I 7-2009, paragraph 7.6, Records To Be Maintained by Manllfact1lrers, 

subparagraph (h), requires the OEM to establish and maintain records of any incidents involving 

unplanned exposures as reported by the user, and provide the infonnation to the FDA. 

Once the system is out of warranty and TSA becomes responsible for maintenance, the 

maintenance contractor is required to notify the Contracting Officer Technical Representative 

and local TSA if a system defect or accidental radiation occurrence is discovered. The 

maintenance contractor will also notify the manufacturer. who in turn will notify the FDA. 

Currently, Section 27.5(a)(l I) of the TSA Occupational Safety and Health Manual provides that 

the Director, OSHE, is responsible for "Coordinating investigations of radiation safety-related 

system defects, damage, malfunctions. and violations of radiation safety procedures." To help 

ensure the FDA is notified, we will revise the statement to state: "Coordinating investigations of 

radiatiotl safety-related system defects, damage, malfunctions, and violations of radiation safety 

procedures. In addition, notifying the product manufacturer and the FDA whenever he/she 

becomes aware of any electronic product radiation safety issues that meet the criteria of an 

accidental radiation occurrence per 2 J CFR 1002.20 and/or a defect in an electronic product 

per 21 CFR 1003. 10. " 

Transportation Security Administration’s Use of Backscatter Units 


Page 25
 
Appendix C 

Major Contributors to this Report 

Deborah Outten-Mills, Chief Inspector 

Jacqueline Simms, Senior Inspector 

Shawntae Hampton, Inspector 

Megan Thompson, Inspector 

Rahne Jones, Inspector 

Transportation Security Administration’s Use of Backscatter Units 

Page 26 
Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Administrator, Transportation Security Administration 

TSA Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

Transportation Security Administration’s Use of Backscatter Units 


Page 27
 
 

 

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