Aviation Security: Federal Efforts to Secure U.S.-Bound Air Cargo Are in the Early Stages and Could Be Strengthened
Published: 2007-04-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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 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. 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.

section_title: Letter
paragraphs: 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. 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.
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. It also required that a system be put into place as soon  as practicable to screen, inspect, or otherwise ensure the security of cargo  transported on all-cargo aircraft. The act applies to air cargo transported  into the United States from foreign countries onboard passenger and all- cargo 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. 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. CBP’s efforts include analyzing  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. 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. 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. 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.
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. 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  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. 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  determine the requirements placed on air carriers for ensuring inbound air  cargo security. 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.  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  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. 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.
subsections: section_title: Background
paragraphs: 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.
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. 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.
A shipper may take its packages to a freight forwarder, or regulated agent,  which consolidates cargo from many shippers and delivers it to air  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.
subsections: section_title: TSA and CBP Responsibilities for Ensuring the Security of Inbound Air Cargo
subsections: section_title: TSA’s Responsibilities Related to Securing Inbound Air Cargo
paragraphs: 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. 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,  including those related to air cargo; and (4) conducts research and  development of air cargo security technologies.
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. 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  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.  (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.  Under TSA’s inbound air cargo inspection requirements, passenger air  carriers can exempt certain cargo from inspection. TSA does not regulate  foreign freight forwarders, or individuals or businesses that have their  cargo shipped by air to the United States.
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. 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  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. 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.
section_title: CBP’s Responsibilities Related to Inbound Air Cargo Security
paragraphs: 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. 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. At U.S.  airports, CBP officers may conduct searches of persons, vehicles, baggage,  cargo, and merchandise entering or departing the United States. Since  September 11, 2001, CBP’s priority mission has focused on keeping  terrorists and their weapons from entering the United States. 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. 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. To  support its targeting system, CBP requires air carriers to submit cargo  manifest information prior to the flight arriving in the United States. 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. Shipments identified by CBP as high risk through its ATS targeting  system are to undergo mandatory security inspections. CBP officers may  also inspect air cargo if they determine that a particular shipment is  suspicious or somehow poses a threat.
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. 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.
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. 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.
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.
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.
section_title: International Air Cargo Security Standards and Recommended Practices
paragraphs: 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 cargo- handling 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  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.
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 shippers 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.
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.
section_title: Applying a Risk-Managed Approach for Securing Inbound Air Cargo
paragraphs: 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 risk- based 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 risk- based priorities for defending them, select the most practical and cost- effective ways of doing so, and then develop a plan, budget, and funding to  implement the effort. 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.  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 trade- offs in preparing defenses against acts of terrorism and other threats. We  have recommended that TSA apply a comprehensive risk-based approach  for securing the domestic air cargo transportation system.
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. 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. 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 risk- based 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  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.
section_title: DHS Has Taken Initial Steps to Secure Inbound Air Cargo, and Opportunities Exist to Strengthen These Efforts
paragraphs: 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.
subsections: section_title: 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
paragraphs: 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 risk- based 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. 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. TSA’s Air Cargo Strategic Plan, however, does not include goals  and objectives for addressing inbound air cargo security, which presents  different security challenges than domestic air cargo.
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.
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. 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. As stated previously, TSA,  CBP, and industry stakeholders have also identified the introduction and  transport of a WMD or its component parts as a potential threat. 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.
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. 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.
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  better enable the agency to prioritize its efforts by focusing on high- priority 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.
section_title: 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
paragraphs: 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. For example, TSA  created a new mandatory security regime for domestic and foreign all- cargo 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. TSA  currently requires foreign and domestic all-cargo carriers to inspect a  different percentage of nonexempt items prior to the cargo’s loading.
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  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. 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). 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.
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. 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  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.
section_title: Inspection Exemptions Pose a Potential Vulnerability for Air Cargo Transported into the United States
paragraphs: In our October 2005 report, we noted that TSA’s inspection requirements  allowed carriers to exempt certain types of air cargo from inspection.  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. 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.
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.
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.
The draft programs for all-cargo carriers would require all-cargo carriers  to inspect 100 percent of certain nonexempt air cargo. 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. 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. 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. 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  exemptions would have on air carriers’ operations. 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.
section_title: 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
paragraphs: 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.
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. 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. TSA inspections may include areas of cargo security, such as  cargo acceptance procedures, security testing and training, and ensuring  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. 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  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. 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. 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 all- cargo 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  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.
section_title: TSA Implemented a Risk- Based Scheduling System to Assess Certain Foreign Airports’ Security Measures, but Not All Foreign Airports Have Been Assessed
paragraphs: 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. 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  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. 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.
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.
section_title: CBP Has Begun Efforts to Address the Security of Inbound Air Cargo, but These Efforts Can Be Expanded
paragraphs: 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. 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. Inbound air cargo transported  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. 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.
CBP’s targeting policy describes the roles and responsibilities of CBP  personnel involved in targeting air cargo transported on passenger and all- cargo air carriers that may pose a security risk and inspecting such cargo  once it enters the United States. CBP’s targeting policy also includes  details on the risk scores given to shipments that require inspection by  CBP personnel. 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  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. 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  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. 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. 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. 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  exchange for implementing security policies and procedures, such as pre- employment 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.
section_title: DHS Is in the Early Stages of Testing Technologies to Strengthen Air Cargo Security
paragraphs: 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  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.
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;    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 long- term feasibility of using EDS equipment as a total screening process  for break bulk air cargo;    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.
section_title: 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
paragraphs: 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. 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. 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  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  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.
section_title: Foreign Air Cargo Security Practices and International Harmonization Efforts Have Potential to Enhance Air Cargo Security, but May Be Challenging to Implement
paragraphs: 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. 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.
subsections: section_title: 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
paragraphs: 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. 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.
subsections: section_title: Air Cargo Inspection Technologies and Methods
paragraphs: 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. These machines allow for cargo on pallets to  undergo X-ray inspection without requiring the pallet to be broken down  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 all- cargo 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,  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. 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.
section_title: Percentage of Air Cargo Inspected
paragraphs: 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. 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  maintaining an approved security program. 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 high- risk 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  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.
section_title: Physical Security and Access Controls for Air Cargo Facilities
paragraphs: 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. However, TSA has  no plans to require additional air cargo access control measures.
section_title: Procedures for Validating Known Shippers
paragraphs: 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  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. 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. 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. 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  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.  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.
section_title: 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
paragraphs: 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. 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. 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 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  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.
section_title: DHS Is Working with Foreign Governments and Air Cargo Stakeholders to Harmonize Air Cargo Security Efforts, but Inherent Challenges May Affect Their Progress
paragraphs: 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.
subsections: section_title: TSA and CBP Are Working with Foreign Governments to Develop Uniform Standards
paragraphs: 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.
CBP has also engaged in efforts to develop uniform air cargo security  standards with select foreign countries. Specifically, CBP undertook a  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.
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.
section_title: TSA and CBP Are Partnering with Foreign Governments to Begin Mutual Recognition of Air Cargo Security Requirements
paragraphs: 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. 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.
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  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. 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.
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  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.
section_title: Challenges to DHS’s Harmonization Efforts May Affect Progress
paragraphs: 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.
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. 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  airports within the United States. 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.
section_title: Conclusions
paragraphs: 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  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  additional innovative practices to secure air cargo against a terrorist  attack in this country.
section_title: Recommendations for Executive Action
paragraphs: 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:  (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;  (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 cost- effective, without impeding the flow of commerce.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to DHS for review and comments. On  April 19, 2007, we received written comments on the draft report, which  are reproduced in full in appendix VIII. DHS generally concurred with the  report and recommendations.
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  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  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 all- cargo 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.
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 all- cargo 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  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.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: 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. 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  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  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. 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. 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. 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.  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  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.
section_title: Appendix II: TSA’s Efforts to Assess Air Carrier Compliance with Inbound Air Cargo Security Requirements
paragraphs: 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.
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.
section_title: Appendix III: TSA’s Assessments of Foreign Airport Security Procedures
paragraphs: 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. 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.  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. The agency has not issued a travel advisory or suspended  service solely for air cargo security deficiencies at an airport since its  inception.
section_title: Appendix IV: Description of GAO’s Risk Management Framework
paragraphs: 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.
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.
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.
section_title: Appendix V: DHS and TSA Air Cargo Security Technology Pilot Tests
paragraphs: 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.
subsections: section_title: Air Cargo Explosives Detection Pilot Program
paragraphs: 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. 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. 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  threats in freighter air cargo, 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.
section_title: Pilot Program Evaluating Explosives Detection System Technology
paragraphs: 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. 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 three- phased program testing the use and effectiveness of explosive detection  systems at 12 participating sites. 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  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.
section_title: Air Cargo Security Seals Pilot Program
paragraphs: 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. 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  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.
section_title: Hardened Unit Load Devices/Hardened Cargo Containers
paragraphs: 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. 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. 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  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.
section_title: Pulsed Fast Neutron Analysis Testing
paragraphs: 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.
section_title: Appendix VI: Actions Taken by Select Domestic Air Carriers with Operations Overseas and Foreign Air Cargo Industry Stakeholders to Secure Air Cargo
subsections: section_title: Passenger Air Carriers
paragraphs: Inspect a higher  percentage of cargo  placed on passenger  aircraft than is required by  TSA or host government.
100 percent inspection  performed on:  passenger aircraft bound for  the United States.
Freight forwarders, also  known as regulated  agents, are validated by  the government and are  responsible for conducting  inspections.
100 percent of air cargo  loaded onto passenger  aircraft bound for the  United States required to  undergo inspection. (cash paying) customers.  air cargo shipped in or out  of locations deemed high-risk  by the air carrier is inspected  via X-ray. decompression chambers  are used to inspect cargo  that cannot be X-rayed.
Large palletized cargo is  broken down in order to  pass cargo through X-ray  machines. fee when use of  decompression chamber  is required.
Canines used to sniff air  passenger flights to the  United States are inspected  via X-ray. 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. 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.  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. cosigners to prepare for  annual audits; new  identification numbers are  given post-audit to ensure  security of cosigner  identity.
Air cargo workers undergo  additional and stringent  background checks,  including criminal and  employment history  checks. completed by employees;  employees are not  permitted to enter facility if  training lapses or  requirements are not met.
Program provides  monetary incentives to  employees in order to  increase employee  awareness of access  controls, including  rewards for reporting  suspicious individuals.
Managers are required to  remain knowledgeable on  security policies and  regulations in destination  countries.
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.
Threat information is  derived from public/private  intelligence. This  information includes data  on the  sociopolitical/economic  conditions of countries.
Annual audits of carrier  facilities are conducted  using an online  questionnaire; facilities  undergo a certification  process that is linked to  the audits. provided to CBP earlier  than is required by CBP.
Independent risk  assessments are  conducted based on  internal testing to identify  cargo security  weaknesses.
Security incident database  tracks worldwide security  issues. air carrier industry meet to  identify best practices in  aviation security.
Truck drivers entering  carrier facilities to deliver  air cargo are escorted by  an airline representative at  all times.
All employees/visitors are  required to pass through a  metal detector before  entering/exiting cargo  facility. cargo facilities, including  testing of access controls  to identify security  weaknesses.
Security guards control  access to freighters at  every stop made by the  aircraft.
Secured cart system  transports cargo within  cargo storage 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.
Seals and plastic straps  are applied to all cargo  crates, containers, and  boxes to prevent  tampering.
Pallets are locked and  sealed in a completely  enclosed chain-like  container after they are  built to prevent the  possibility of tampering. whenever possible into  larger units and sealed  with steel banding to limit  the possibility of  tampering. surveillance system  monitor all-cargo areas 24  hours a day.
Biometric badge required  to gain access to secured  areas.
Biometric identification  system that scans the  hand to grant access air  carrier facilities and cargo  areas. employees are permitted  to pick up, pack, and  transport cargo to cargo  facilities and the airport.
Strategic placement of air  cargo in the aircraft to  secure the cockpit and  minimize the potential for  a hijacking by a  stowaway.
Fingerprints and  photographs of all truck  drivers that transport  cargo are taken, kept on  file, and used to authorize  access. cargo brought directly to  the ticketing or check-in  counter by an unknown  shipper.
Thorough security review  is conducted of potential  customers prior to  acceptance of their  business or cargo. documented that could  pose a potential security  threat.
Palletized cargo is refused  unless airline security  personnel are present  when pallet is built. brought directly to the  counter.  outbound cargo from  unknown shippers.
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.
section_title: Appendix VII: Actions We Identified That Select Foreign Governments Are Taking to Secure Air Cargo
subsections: section_title: Actions Taken by Select Foreign Governments to Secure Air Cargo
paragraphs: Twenty-four hour holding period  used as form of inspection.
Government, airport, or  methods to avoid detection of  inspection patterns. freight forwarder  representatives are  responsible for  inspecting air cargo. unknown cargo loaded  on either passenger or  all-cargo aircraft is  physically inspected.
Canines used to sniff air samples  from air cargo shipments–Remote  Air Sampling for Canine Olfaction  (RASCO). air cargo inspections. between cargo placed  on passenger aircraft  versus all-cargo aircraft  in regards to type or  degree of inspection.  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.
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.
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.
Developing multicountry database containing information on all known consignors and regulated agents  to facilitate the exchange of information among countries.
Actions Taken by Select Foreign Governments to Secure Air Cargo  Security personnel accompany and surround  aircraft upon landing to guard aircraft and its  contents, including cargo.
Biometric technologies used to control access  to cargo facilities.
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. 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.
Government and airport authority subsidize the costs of purchasing X-ray equipment to inspect air cargo.
section_title: Appendix VIII: Comments from the Department of Homeland Security
section_title: Appendix IX: GAO Contact and Staff Acknowledgments
subsections: section_title: Acknowledgments
paragraphs: 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.