Aviation Security: Progress Made, but Challenges Persist in Meeting the Screening Mandate for Air Cargo
Published: 2011-03-09T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Department of Homeland Security's (DHS) Transportation Security Administration (TSA) is the federal agency with primary responsibility for securing the air cargo system. The Implementing Recommendations of the 9/11 Commission Act of 2007 mandated DHS to establish a system to screen 100 percent of cargo flown on passenger aircraft by August 2010. GAO reviewed TSA's progress in meeting the act's screening mandate, and any related challenges it faces for both domestic (cargo transported within and from the United States) and inbound cargo (cargo bound for the United States). This statement is based on prior reports and testimonies issued from April 2007 through December 2010 addressing the security of the air cargo transportation system and selected updates made in February and March 2011. For the updates, GAO obtained information on TSA's air cargo security programs and interviewed TSA officials.
section_title: What GAO Found
paragraphs: As of August 2010, TSA reported that it met the mandate to screen 100 percent of air cargo as it applies to domestic cargo, but as GAO reported in June 2010, TSA lacked a mechanism to verify the accuracy of the data used to make this determination. TSA took several actions in meeting this mandate for domestic cargo, including creating a voluntary program to facilitate screening throughout the air cargo supply chain; taking steps to test technologies for screening air cargo; and expanding its explosives detection canine program, among other things. However, in June 2010 GAO reported that TSA did not have a mechanism to verify screening data and recommended that TSA establish such a mechanism. TSA partially concurred with this recommendation and stated that verifying such data would be challenging. As GAO reported in June 2010, data verification is important to provide reasonable assurance that screening is being conducted at reported levels. As GAO further reported in June 2010, there is no technology approved or qualified by TSA to screen cargo once it is loaded onto a pallet or container--both of which are common means of transporting domestic air cargo on passenger aircraft. As a result, questions remain about air carriers' ability to effectively screen air cargo on such aircraft. TSA has also taken a number of steps to enhance the security of inbound air cargo, but also faces challenges that could hinder its ability to meet the screening mandate. TSA moved its deadline for meeting the 100 percent screening mandate as it applies to inbound air cargo to the end of 2011, up 2 years from when the TSA administrator previously reported the agency would meet this mandate. According to TSA officials, the agency determined it was feasible to accelerate the deadline as a result of trends in air carrier reported screening data and discussions with air cargo industry leaders regarding progress made by industry to secure cargo on passenger aircraft. TSA also took steps to enhance the security of inbound cargo following the October 2010 Yemen air cargo bomb attempt--such as requiring additional screening of high-risk cargo prior to transport on an all-cargo aircraft. However, TSA continues to face challenges GAO identified in June 2010 that could impact TSA's ability to meet this screening mandate as it applies to inbound air cargo. For example, GAO reported that TSA's screening percentages were estimates and were not based on actual data collected from air carriers or other entities, such as foreign governments, and recommended that TSA establish a mechanism to verify the accuracy of these data. TSA partially agreed, and required air carriers to report inbound cargo screening data effective May 2010. However, TSA officials stated while current screening percentages are based on actual data reported by air carriers, verifying the accuracy of the screening data is difficult. It is important for TSA to have complete and accurate data to verify that the agency can meet the screening mandate. GAO will continue to monitor these issues as part of its ongoing review of TSA's efforts to secure inbound air cargo, the final results to be issued later this year.
section_title: What GAO Recommends
paragraphs: GAO has made recommendations in prior work to strengthen air cargo screening. Although not fully concurring with all recommendations, TSA has taken or has a number of actions underway to address them. Continued attention is needed to ensure some recommendations are addressed, such as establishing a mechanism to verify screening data. TSA provided technical comments on the information in this statement, which GAO incorporated as appropriate.

section_title: Letter
paragraphs: I appreciate the opportunity to participate in today’s hearing to discuss the  security of the nation’s air cargo system. In 2009, about 6.5 billion pounds  of cargo were transported on U.S. passenger flights—approximately 56  percent of which was transported domestically (domestic cargo) and 44  percent of which was transported on flights arriving in the United States  from a foreign location (inbound cargo). The October 2010 discovery of  explosive devices in air cargo packages bound for the United States from  Yemen, and the 2009 Christmas Day plot to detonate an explosive device  during an international flight bound for Detroit, provide vivid reminders  that civil aviation remains a key terrorist target. According to the  Transportation Security Administration (TSA), the security threat posed  by terrorists introducing explosive devices in air cargo shipments is  significant, and the risk and likelihood of such an attack directed at  passenger aircraft is high.
The Aviation and Transportation Security Act (ATSA), enacted into law  shortly after the September 11, 2001, terrorist attacks, established TSA and  gave the agency responsibility for securing all modes of transportation,  including the nation’s civil aviation system, which includes air carrier  operations (domestic and foreign) to, from, and within the United States.  For example, ATSA requires that TSA provide for the screening of all  passengers and property, including cargo, transported on passenger  aircraft. ATSA further requires that a system be in operation, as soon as  practicable after ATSA’s enactment (on November 19, 2001), to screen,  inspect, or otherwise ensure the security of the cargo transported by all- cargo aircraft—generally, aircraft that carry only cargo and no  passengers—to, from, and within the United States. To help enhance the  security of air cargo, the Implementing Recommendations of the 9/11  Commission Act of 2007 (9/11 Commission Act) mandated the Department  of Homeland Security (DHS) to establish a system to screen 100 percent of  cargo on passenger aircraft—including the domestic and inbound flights of  foreign and U.S. passenger operations—by August 2010. The 9/11  Commission Act defines screening for purposes of the air cargo screening  mandate as a physical examination or nonintrusive methods of assessing  whether cargo poses a threat to transportation security.  The act further  requires that such a system provide a level of security commensurate with  the level of security for the screening of checked baggage. According to  TSA, the mission of its air cargo security program is to secure the air cargo  transportation system while not unduly impeding the flow of commerce.  Although the mandate is applicable to both domestic and inbound cargo,  TSA stated that it must address the mandate for domestic and inbound  cargo through separate systems because of limitations in its authority to  regulate international air cargo industry stakeholders operating outside  the United States.
My statement today addresses TSA’s progress and challenges in meeting  the 9/11 Commission Act mandate to screen air cargo on passenger flights,  both domestic cargo and cargo transported from a foreign location to the  United States, known as inbound air cargo. My comments are based  primarily on our prior reports and testimonies issued from April 2007  through December 2010 addressing the security of the air cargo  transportation system, with selected updates in February and March 2011.  For these reports, we reviewed documents such as TSA’s air cargo  security policies and procedures and conducted site visits to four category  X airports and one category I airport in the United States that process  domestic and inbound air cargo. We selected these airports based on  airport size, passenger and air cargo volumes, location, and participation  in TSA’s screening program. For the updates, we obtained information on  TSA’s air cargo security programs and interviewed senior TSA officials  regarding plans, strategies, and steps taken to meet the 100 percent  screening mandate since December 2010. More detailed information about  our scope and methodology is included in our reports and testimonies. We  conducted this work in accordance with generally accepted government  auditing standards. We shared the information in this statement with TSA  officials who provided technical comments that were incorporated as  appropriate.
subsections: section_title: TSA Reports that It Met the Screening Mandate as It Applies to Domestic Cargo, but Previously Identified Data Limitations and Other Challenges Persist
paragraphs: TSA took several actions to address the 9/11 Commission Act mandate to  screen 100 percent of air cargo as it applies to domestic cargo transported  on passenger aircraft by August 2010. As of August 2010, TSA reported that  it met the 9/11 Commission Act mandate to screen 100 percent of air cargo  as it applies to domestic cargo, although in June 2010 we reported that  TSA lacked a mechanism to verify the accuracy of the data used to make  this determination.
To help meet the mandate, TSA took several actions, among them:  TSA created a voluntary program to facilitate screening  throughout the air cargo supply chain. Since TSA concluded that  relying solely on air carriers to conduct screening would result in  significant cargo backlogs and flight delays, TSA created the voluntary  Certified Cargo Screening Program (CCSP) to allow screening to take  place earlier in the shipping process, prior to delivering the cargo to the air  carrier. Under the CCSP, facilities at various points in the air cargo supply  chain, such as shippers, manufacturers, warehousing entities, distributors,  third-party logistics companies, and freight forwarders that are located in  the United States, may voluntarily apply to TSA to become certified cargo  screening facilities (CCSF). TSA initiated the CCSP at 18 U.S. airports that  process high volumes of air cargo, and then expanded the program to all  U.S. airports in early 2009.
TSA is taking steps to test technologies for screening air cargo. To  test select screening technologies among CCSFs, TSA created the Air  Cargo Screening Technology Pilot in January 2008, and selected some of  the nation’s largest freight forwarders to use these technologies and report  on their experiences. In a separate effort, in July 2009, DHS’s Directorate  for Science and Technology completed the Air Cargo Explosives Detection  Pilot Program that tested the performance of select baggage screening  technologies for use in screening air cargo at three U.S. airports. In March  2009, TSA initiated a qualification process to test these and other  technologies for air carriers and CCSP participants to use in meeting the  screening mandate against TSA technical requirements. In December 2009,  TSA issued to air carriers and CCSFs its first list of qualified technologies  which included X-ray and explosives detection systems (EDS) models that  the agency approved for screening air cargo under the 9/11 Commission  Act. Over the past several years, TSA has evaluated and qualified  additional technologies and has issued subsequent lists, most recently in  February 2011. These technologies were in addition to the canine and  physical search screening methods permitted by TSA.
TSA expanded its explosives detection canine program. As of  February 2011, TSA officials stated that the agency had 113 dedicated air  cargo screening canine teams—operating in 20 airports—and was in the  process of adding 7 additional canine teams. TSA headquarters officials  explained that two CCSFs are participating in a pilot program to test the  feasibility of using private canine teams—that meet TSA standards—to  inspect air cargo. Officials stated that the pilot is expected to continue  through summer 2011.
Even with these actions, TSA continues to face challenges that, among  other things, could limit the agency’s ability to provide reasonable  assurance that screening is being conducted at reported levels. Among the  challenges and recommendations previously identified in our June 2010  report are the following.
Reported screening data. TSA does not have a mechanism to verify  screening data—which are self-reported by industry representatives. In  our June 2010 report, we recommended that TSA develop a mechanism  to verify the accuracy of all screening data through random checks or  other practical means. TSA partially concurred with our  recommendation, and stated that verifying the accuracy of domestic  screening data will continue to be a challenge because there is no  means to cross-reference local screening logs—which include  screening information on specific shipments—with screening reports  submitted by air carriers to TSA that do not contain such information.  Given that the agency uses these data to report to Congress its  compliance with the screening mandate as it applies to domestic  cargo, we continue to believe that verifying the accuracy of the  screening data is important so that TSA will be better positioned to  provide reasonable assurance that screening is being conducted at  reported levels.
Screening technology. TSA has not approved or qualified any  equipment to screen cargo transported on unit-load device (ULD)  pallets or containers—both of which are common means of  transporting air cargo on wide-body passenger aircraft—both domestic  and inbound aircraft. Cargo transported on wide-body passenger  aircraft makes up 76 percent of domestic air cargo shipments  transported on passenger aircraft. The maximum size cargo  configuration that may be screened is a 48-by-48-by-65-inch skid— much smaller than the large pallets that are typically transported on  wide-body passenger aircraft. Prior to May 1, 2010, canine screening  was the only screening method, other than physical search, approved  by TSA to screen such cargo configurations. However, effective May 1,  2010, the agency no longer allows canine teams to screen ULD pallets  and containers given TSA concerns about the effectiveness of this  screening method for those cargo configurations. In addition, TSA is  working to complete qualification testing of additional air cargo  screening technologies; thus, until all stages of qualification testing are  concluded, the agency may not have reasonable assurance that the  technologies that air carriers and program participants are currently  allowed to use to screen air cargo are effective. TSA is conducting  qualification testing to determine which screening technologies are  effective at the same time that air carriers are using these technologies  to meet the mandated requirement to screen air cargo transported on  passenger aircraft. While we recognize that certain circumstances,  such as mandated deadlines, require expedited deployment of  technologies, our prior work has shown that programs with immature  technologies have experienced significant cost and schedule growth.
Inspection resources. As we reported in June 2010, for domestic air  cargo, TSA amended its inspections plan to include inspections of  CCSP participants, but the agency had not completed its staffing study  to determine how many inspectors will be necessary to provide  oversight of the additional program participants that would support  the screening mandate. In our June 2010 report, we recommended that  TSA create milestones to help ensure completion of the staffing study.  TSA concurred and stated that as part of the staffing study, the agency  is working to develop a model to identify the number of required  transportation security inspectors and that this effort would be  completed in the fall of 2010. As of February 2011, TSA officials stated  that the study was in the final stages of review.
section_title: TSA Has Taken Steps to Enhance the Security of Inbound Air Cargo, but Previously Identified Screening Data Limitations and Other Challenges Persist
paragraphs: TSA has taken a number of steps to enhance the security of inbound air  cargo, as discussed below.
TSA moved its deadline for meeting the 100 percent screening  mandate as it applies to inbound air cargo. TSA officials stated that  they plan to meet the 9/11 Commission Act mandate as it applies to  inbound air cargo transported on passenger aircraft by December 2011—2  years earlier than the TSA administrator reported to Congress in  November 2010. According to TSA officials, the agency determined it was  feasible to require air carriers to meet a December 2011 screening deadline  as a result of trends in carrier reported screening data and discussions  with air cargo industry leaders regarding progress made by industry to  secure inbound cargo on passenger aircraft.
Effective May 1, 2010, air carriers were required to submit inbound  screening data to TSA. According to TSA officials, in analyzing this self- reported screening data, TSA found that carriers were screening a higher  percentage of air cargo than TSA had initially estimated. For example, TSA  previously estimated that 65 percent of inbound cargo by weight would be  screened by August 2010. Based on data submitted to TSA by the air  carriers, TSA officials stated that the agency estimates that about 80  percent of inbound cargo by weight was screened for the same time  period. In addition to requiring air carriers to submit screening data to  TSA, in May 2010, TSA also required air carriers to screen a certain  percentage of shrink-wrapped and banded inbound cargo. TSA officials  stated that in implementing this requirement, air carriers determined that  it was more efficient to screen larger groupings of cargo at the point of  origin, which resulted in more than the required percentage being  screened. Therefore, according to TSA officials, continued progress made  by industry will help TSA to meet its December 31, 2011, deadline to  screen 100 percent of inbound passenger cargo.
TSA is working with foreign governments to draft international air  cargo security standards and to harmonize standards with foreign  partners. According to TSA officials, the agency has worked with  foreign counterparts over the last 3 years to draft Amendment 12 to the  International Civil Aviation Organization’s (ICAO) Annex 17, and to  generate support for its adoption by ICAO members. The amendment,  which was adopted by the ICAO Council in November 2010, will set forth  new standards related to air cargo such as requiring members to establish  a system to secure the air cargo supply chain (the flow of goods from  manufacturers to retailers). TSA has also supported the International Air  Transport Association’s (IATA) efforts to establish a secure supply chain  approach to screening cargo for its member airlines and to have these  standards recognized internationally. Moreover, following the October  2010 bomb attempt in cargo originating in Yemen, DHS and TSA, among  other things, reached out to international partners, IATA, and the  international shipping industry to emphasize the global nature of  transportation security threats and the need to strengthen air cargo  security through enhanced screening and preventative measures. TSA also  deployed a team of security inspectors to Yemen to provide that country’s  government with assistance and guidance on their air cargo screening  procedures.
In November 2010, TSA officials stated that the agency is coordinating  with foreign countries to evaluate the comparability of their air cargo  security requirements with those of the United States. According to TSA  officials, the agency has developed a program, the National Cargo Security  Program (NCSP), that would recognize the air cargo security programs of  foreign countries if TSA deems those programs provide a level of security  commensurate with TSA’s programs. TSA plans to coordinate with the top  20 air cargo volume countries, which, according to TSA officials, export  about 90 percent of the air cargo transported to the United States on  passenger aircraft. According to officials, TSA has completed a review of  one country’s air cargo security program and has determined that its  requirements are commensurate with those of the United States. TSA  considers air carriers adhering to NCSP approved programs as being in  compliance with TSA air cargo security requirements, according to TSA  officials. As of February 2011, TSA continues to evaluate the comparability  of air cargo security programs for several other countries. TSA officials  stated that although the December 31, 2011, deadline to achieve 100  percent screening is independent of this effort, the agency plans to  recognize as many commensurate programs as possible by the deadline.
TSA implemented additional security measures following the  October 2010 Yemen air cargo bomb attempt. On November 8, 2010,  DHS announced security measures in response to the Yemen incident. TSA  banned cargo originating from Yemen and Somalia from transport into the  United States; banned the transport of cargo deemed high risk on  passenger aircraft; prohibited the transport of toner and ink cartridges  weighing 16 ounces or more on passenger aircraft in carry-on and checked  luggage; and required additional screening of high-risk cargo prior to  transport on an all-cargo aircraft. In addition, TSA is working closely with  CBP, industry and international partners to expedite the receipt of  advanced cargo data for international flights to the United States prior to  departure in order to more effectively identify and screen items based on  risk and current intelligence. Further, in December 2010, TSA, CBP, and  the air cargo industry launched a new joint technology pilot project  referred to as the air cargo advance screening program to enhance the  sharing of electronic shipping information to improve the identification of  high-risk cargo. In February 2011, TSA officials stated that this effort is  currently focused on all-cargo carriers and will expand to passenger  carriers in the future.
Even with these steps to improve the security of inbound air cargo, as we  previously reported in June 2010, TSA faces challenges that could hinder  its ability to meet the 9/11 Commission Act screening mandate as it applies  to inbound cargo.
TSA lacks a mechanism to verify data on screening conducted on  inbound air cargo. As we reported in June 2010, questions exist about  the reliability of TSA’s reported screening data for inbound cargo because  TSA does not have a mechanism to verify the accuracy of the data  reported by industry. In June 2010, we reported that TSA’s screening  percentages were estimated based on screening requirements of certain  countries and were not based on actual data collected from air carriers or  other entities, such as foreign governments. In this report, we  recommended that TSA develop a mechanism to verify the accuracy of all  screening data through random checks or other practical means and  obtain actual data on all inbound screening. TSA concurred in part with  our recommendation and issued changes to air carriers’ standard security  programs that required air carriers to report inbound cargo screening data  to TSA. However, these requirements apply to air carriers and the  screening that they conduct or that may be conducted by a foreign  government, but does not reflect screening conducted by other entities  throughout the air cargo supply chain. As of March 2011, TSA officials  stated that current screening percentages are based on actual data  reported by air carriers, but stated that it is difficult to verify the accuracy  of the screening data reported by air carriers. Given that TSA now plans to  meet the 9/11 Commission Act screening mandate as it applies to inbound  air cargo by December 2011, it will be important for TSA to have complete  and accurate data in hand to verify that this mandate is being met.
TSA has limited authority to regulate foreign governments or  entities. TSA may require that foreign air carriers with operations to,  from, or within the United States comply with any applicable  requirements, including TSA-issued emergency amendments to air carrier  security programs, but foreign countries, as sovereign nations, generally  cannot be compelled to implement specific aviation security standards or  mutually accept other countries’ security measures. International  representatives have noted that national sovereignty concerns limit the  influence the United States and its foreign partners can have in persuading  any country to participate in international harmonization efforts, or make  specific changes in their screening procedures. Thus, TSA authority  abroad is generally limited to regulating air carrier operations, including  the transport of cargo, into the United States. It has no other authority to  require foreign governments or entities to, for example, screen a certain  percentage of air cargo or screen cargo using specific procedures.
No technology is currently approved or qualified by TSA to screen  cargo once it is loaded onto a unit-load device. As we noted earlier  for domestic air cargo, TSA has not approved any equipment to screen  cargo transported on unit-load device (ULD) pallets or containers—both  of which are common means of transporting air cargo on wide-body  passenger aircraft—on both domestic and inbound aircraft. As a result,  questions remain about air carriers’ ability to effectively and efficiently  screen air cargo bound for the United States. This is particularly important  because, as we reported in June 2010, about 96 percent of inbound air  cargo arrives on wide-body aircraft, and TSA has limited authority to  oversee the screening activities of foreign governments or entities. We will  be examining these issues as part of our ongoing review of TSA’s efforts to  secure inbound air cargo for the House Committee on Homeland Security  and Senate Committee on Homeland Security and Governmental Affairs.  We plan to issue the final results later this year.
Mr. Chairman, this concludes my statement. I look forward to answering  any questions that you or other members of the subcommittee may have.
For questions about this statement, please contact Stephen M. Lord at  (202) 512-4379 or lords@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this statement. Individuals making key contributions to this testimony  are Steve D. Morris, Assistant Director; Joel Aldape; Carissa Bryant;  Labony Chakraborty; Tom Lombardi; Linda S. Miller; Rebecca Kuhlman  Taylor; and Meg Ullengren.
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