Aviation Security: TSA Strengthened Foreign Airport Assessments and Air Carrier Inspections, but Could Improve Analysis to Better Address Deficiencies
Released: 2017-12-04T00:00:00

Letter

Background

DHS Responsibilities for Ensuring the Security of U.S.-Bound Flights from Foreign Countries

Shortly after the September 11, 2001, terrorist attacks, Congress passed and the President signed into law the Aviation and Transportation Security Act (ATSA), which established TSA and gave the agency responsibility for securing all modes of transportation, including the nation’s civil aviation system, which includes the operations of U.S. and foreign-flagged air carriers to, from, and within the United States, as well as the foreign point-to-point operations of U.S.-flagged carriers. Consistent with ATSA and in accordance with existing statutory requirements, TSA is to assess the effectiveness of security measures at foreign airports (1) served by a U.S. air carrier, (2) from which a foreign air carrier serves the United States, (3) that pose a high risk of introducing danger to international air travel, and (4) that are otherwise deemed appropriate by the Secretary of Homeland Security. In carrying out this function, the statute identifies measures that the Secretary must take in the event that he or she determines that an airport is not maintaining and carrying out effective security measures based on TSA assessments. In addition, consistent with ATSA and in accordance with existing statutory requirements, TSA is to conduct inspections of U.S. air carriers and foreign air carriers servicing the United States from foreign airports to ensure that they meet applicable security requirements, including those set forth in an air carrier’s TSA-approved security program.

The Secretary of DHS delegated to the TSA Administrator the responsibility for conducting foreign airport assessments but retained responsibility for making the determination that a foreign airport does not maintain and carry out effective security measures. Currently, the Global Compliance Directorate, within OGS, is responsible for conducting foreign airport assessments and air carrier inspections. Table 1 highlights the roles and responsibilities of certain TSA positions within OGS that are responsible for implementing the foreign airport assessment and air carrier inspection programs.

TSA’s Process for Conducting Foreign Airport Assessments and Air Carrier Inspections

TSA assesses the effectiveness of security measures at foreign airports using select aviation security standards and recommended practices adopted by ICAO, a United Nations organization representing 191 countries. ICAO standards and recommended practices (referred to collectively in this report as ICAO standards unless otherwise noted) address operational issues at an airport, such as ensuring that passengers and baggage are properly screened and that unauthorized individuals do not have access to restricted areas of an airport. ICAO standards also address non-operational issues, such as whether a foreign government has implemented a national civil aviation security program for regulating security procedures at its airports and whether airport officials implementing security controls are subject to background investigations, are appropriately trained, and are certified according to a foreign government’s national civil aviation security program. TSA utilizes the 44 ICAO standards it sees as most critical in conducting its foreign airport assessments, which cover the following areas: airport operations; quality control; access control; aircraft security; passenger and cabin baggage screening; hold baggage screening; security measures relating to cargo, mail and other goods; security measures relating to special categories of passengers; prevention; and security measures relating to the landside.

TSA uses a risk-informed approach to schedule foreign airport assessments by categorizing airports into three risk tiers, with high risk airports assessed more frequently than medium and low risk airports. TSA’s assessments of foreign airports are conducted by a team of inspectors, which generally includes one team leader and one team member. According to TSA, it generally takes 3 to 7 days to complete a foreign airport assessment. However, the amount of time and number of team members required to conduct an assessment varies based on several factors, including the size of the airport, the number of air carrier inspections to be conducted at the airport, and the threat level to civil aviation in the host country.

TSA uses a multistep process to plan, conduct, and record assessments of foreign airports. Specifically, the TSAR must obtain approval from the host government to allow TSA to conduct an airport assessment, and schedule the date for the on-site assessment. After conducting an entry briefing with State, host country officials, and airport officials, the team conducts an on-site visit to the airport. During the assessment, the team of inspectors uses several methods to determine a foreign airport’s level of compliance with ICAO standards, including conducting interviews with airport officials, examining documents pertaining to the airport’s security measures, and conducting a physical inspection of the airport. For example, inspectors are to examine the integrity of fences, lighting, and locks by walking the grounds of the airport. Inspectors also make observations on access control procedures, such as examining employee and vehicle identification methods in secure areas, as well as monitoring passenger and baggage screening procedures in the airport. At the close of an airport assessment, inspectors brief foreign airport and government officials on the results. TSA inspectors also prepare a report detailing their findings on the airport’s overall security posture and security measures, which may contain recommendations for corrective action and must be reviewed by the TSAR, the ROC manager, and TSA headquarters officials. Afterward, a summary of the results is shared with the foreign airport and host government officials. In some cases, TSA requires air carriers to adopt security procedures, such as additional passenger screening, to compensate for deficiencies that TSA identified during a foreign airport assessment.

Along with conducting airport assessments, the same TSA inspection team also conducts air carrier inspections when visiting a foreign airport to ensure that air carriers are in compliance with TSA security requirements. The frequency of air carrier inspections at each airport depends on a risk-informed approach and is influenced, in part, by the airport’s vulnerability to security breaches, since the security posture of each airport varies. In general, TSA procedures require TSA to inspect all air carriers at each airport annually or semi-annually depending on the vulnerability level of the airport, with some exceptions. For example, TSA may elect to inspect all air carriers at a particular airport on an 18-month cycle if the airport has no documented vulnerabilities for the three previous visits and all air carriers at that location have demonstrated full compliance over the past five years. When conducting inspections, TSA inspectors examine compliance with applicable security requirements, including TSA-approved security programs, security directives, and emergency amendments to the security programs.

As in the case of airport assessments, air carrier inspections are conducted by a team of inspectors, which generally includes one team leader and one team member. An inspection of an air carrier typically takes 1 or 2 days, but can take longer depending on the extent of service by the air carrier. Inspection teams may spend several days at a foreign airport inspecting air carriers if there are multiple carriers serving the United States from that location. During an air carrier inspection, inspectors are to review applicable security manuals, procedures, and records; interview air carrier station personnel; and observe air carrier employees processing passengers from at least one flight from passenger check-in until the flight departs the gate to ensure that the air carrier is in compliance with applicable requirements. Inspectors evaluate a variety of security measures, such as passenger processing (e.g., use of No Fly and Selectee lists), checked baggage acceptance and control, aircraft security, passenger screening, cargo and mail screening, and catering security. Inspectors record inspection results into TSA’s Performance and Results Information System (PARIS), a database containing security compliance information on TSA-regulated entities. If an inspector finds that an air carrier is violating any applicable security requirements, additional steps are to be taken to record those specific violations and, in some cases, pursue them with further investigation.

GAO’s 2011 Review of TSA Foreign Airport Assessment Program

In 2011, we reported on TSA’s foreign airport assessment program, including TSA’s steps taken to enhance its program, the results of TSA’s foreign airport assessments, and opportunities for TSA to make program improvements in several key areas, such as developing criteria and guidance for determining foreign airport vulnerability ratings. We reported that TSA had not taken steps to evaluate its assessment results to identify regional and other trends over time. In addition, we found that TSA had not developed criteria or guidance for determining foreign airport vulnerability ratings. We also reported that there were opportunities for TSA to increase program efficiency and effectiveness by, for example, conducting more targeted foreign airport assessments and systematically compiling and analyzing security best practices. As a result, we recommended that TSA (1) develop a mechanism for trend analysis, (2) establish criteria and guidance to help decision makers with vulnerability ratings, and (3) consider the feasibility of conducting more targeted foreign airport assessments and compiling best practices. DHS concurred with the three recommendations and has since taken several actions to address them all, including developing a mechanism to compile and analyze best practices.

Since 2011, TSA Has Taken Various Steps to Strengthen its Foreign Airport Assessment and Air Carrier Inspection Programs

TSA Has Taken Steps to Better Target Program Resources Based on Risk

TSA established the Northern Virginia ROC. In 2012, TSA created a dedicated ROC in Northern Virginia to oversee North Africa and the Middle East given the high risk associated with many airports in the region. The creation of the Northern Virginia ROC alleviated resource burdens on the Frankfurt ROC, which previously had oversight for both the Europe and Africa-Middle East regions. In addition, the Northern Virginia ROC Manager stated that the small size of the ROC has facilitated strong working relationships because foreign airport officials in the region tend to meet with the same inspectors more frequently.

TSA created the Analysis and Risk Mitigation (ARM) Directorate. In 2013, TSA established a working group to evaluate ways to better integrate risk management in the foreign airport assessment and air carrier inspection programs. This working group developed a risk framework, which, according to TSA documentation, provides a systematic approach for analyzing risk at international airports, supports OGS decision making, and informs efforts to mitigate security deficiencies. In 2015, OGS created the ARM Directorate, which formalized the risk mitigation responsibilities of the working group and serves as the data analysis and evaluation arm of OGS. OGS officials stated that ARM helps the program focus its resources based on risk. For example, ARM analyzes and prioritizes activities, such as training, that are designed to mitigate security vulnerabilities at foreign airports.

TSA conducts more targeted foreign airport assessments. Based on a recommendation in our 2011 report, TSA has taken actions to conduct more targeted foreign airport assessments. For example, TSA developed the Pre-Visit Questionnaire, which host foreign airport officials fill out prior to TSA’s visit. This information enables each TSA foreign airport assessment team to tailor the on-site assessment at each airport and focus TSA’s assessment efforts on specific areas of concern. Additionally, TSA implemented more focused airport assessments, known as targeted risk assessments, in locations where risk is high or there are other factors that require a more focused evaluation of the site’s security posture. For the focused assessments, inspection teams place emphasis on observations, interviews, document reviews, and thorough analysis of specific ICAO standards.

TSA implemented cross-directorate reviews. In 2015, TSA implemented cross-directorate reviews, which bring together experts across the OGS components, such as inspectors and TSARs, to identify critical vulnerabilities at foreign airports and outline an initial plan to mitigate those vulnerabilities. Overall, TSA completed 28 cross- directorate reviews in 2015 and 2016.

TSA Has Taken Steps to Strengthen Foreign Airport Access and the Comprehensiveness of Its Evaluations

TSA took steps to resolve foreign airport access issues. Since our 2011 review, TSA has faced delays in scheduling some foreign airport assessments and obstacles in obtaining full access to airport operations at certain locations. According to TSA officials, TSA has used several tactics to resolve access issues, including deploying the same inspectors over multiple assessments to build rapport with foreign airport officials. For example, in one country in the Western Hemisphere region, TSA’s access to airport operations was initially limited by the host government. However, over time, TSA used a small pool of inspectors who officials said were able to build trust with the host government and gain better access, including the ability to conduct interviews of airport officials and take photographs of the security environment. Additionally, in 2011, we reported on TSA’s challenges in obtaining access to airports in Venezuela. Specifically, we reported that TSA had not been able to assess airports in Venezuela or conduct TSA compliance inspections for air carriers, including U.S. carriers, flying from Venezuela to the United States since 2006. According to TSA officials, in 2014, TSA regained access in Venezuela after establishing dialogue with the new government in place and emphasizing the benefits of the evaluation process.

TSA increased the number of joint airport assessments in Europe. In 2011, we reported that TSA took a number of actions to assess foreign airports in Europe, including conducting joint assessments with the EC, performing bi-lateral assessments, and executing table-top reviews in place of on-site airports visits. According to EC officials, the main goal under this arrangement was to better leverage resources and reduce the number of TSA visits per year to European airports because of concerns from EU member states about the frequency of visits from EC and U.S. audit teams. However, since our previous review, TSA has limited the use of table-top reviews and now primarily assesses foreign airports in Europe through joint assessments with the EC. Frankfurt ROC officials we met with indicated that TSA’s strong relationship with the EC has afforded the agency excellent access to foreign airports in Europe and a better understanding of vulnerabilities at these locations, which has resulted in more comprehensive assessments. For example, according to TSA, through the joint assessments, inspectors have better access to airport training documents, the ability to observe tests conducted by EC inspectors, and more time at checkpoints to observe screening operations.

TSA developed airport assessment and air carrier inspection job aids. In 2012, TSA developed job aids that provide inspectors with a set of detailed areas to assess for each ICAO standard. For example, a job aid for passenger and cabin baggage screening includes several prompts related to screening roles and responsibilities, the resolution process if a suspicious item is detected, and alternative procedures if screening equipment is not working as intended. TSA also developed job aids for the air carrier inspection process to better ensure that inspectors cover all requirements associated with air carrier security programs. According to OGS officials, these actions have led to more comprehensive evaluations and a better understanding of foreign airport and air carrier vulnerabilities.

TSA Has Worked to Create Operational Efficiencies

TSA established the Honolulu ROC. In 2012, TSA eliminated the Los Angeles ROC and established the Honolulu ROC given its proximity to the Pacific Islands, which allowed the agency to reduce costs and travel time to airports in these locations. Specifically according to TSA documentation, inspectors in the Los Angeles ROC often spent more than 20 hours traveling to and from sites in the Asia-Pacific region because of in-flight transit time and connection requirements. With the creation of the Honolulu ROC, TSA officials told us that inspectors have been better able to meet deadlines for completing foreign airport assessment reports and conduct follow-up visits to resolve noted issues.

TSA developed the Global Risk Analysis and Decision Support System. In 2012, TSA developed the Global Risk Analysis and Decision Support System (GRADS) to streamline the assessment report writing process and strengthen OGS’s data analysis capabilities of its foreign airport assessment results. According to TSA officials, GRADS has provided OGS personnel with a number of benefits, including the ability to run standardized reports, extract and analyze key data, and manage airport operational information, such as data on security screening equipment. According to TSA documentation, prior to 2012, the agency captured the results of its foreign airport assessments in narrative form that often amounted to more than 80 pages, hampering the ability to perform data analysis.

TSA standardized processes. Between 2012 and 2016, TSA deployed standardization teams, called Standardization Effort Teams, to help ensure more consistency among inspectors when conducting air carrier inspections and airport assessments, and to identify and develop best practices in areas such as training, among others. For example, in 2016, a team developed a tool to facilitate performance evaluations of inspectors.

TSA Foreign Airport Assessment Data Showed Variations in Compliance by Region and Across ICAO Standards, while Air Carrier Inspection Data Showed That Most Inspections Were Fully Compliant

Foreign Airports Differed in Level of Compliance by Region and Across ICAO Standards

TSA assesses the overall vulnerability level at each foreign airport using a rating system, ranging from a category “1,” which represents full compliance with ICAO standards, to a “4” or “5,” which involve more serious or egregious issues. Based on our analysis of TSA’s foreign airport assessment data, we found that compliance with ICAO standards varied by region. For example, our analysis showed that some regions of the world had a higher percentage of airports in vulnerability categories 4 and 5. Our analysis also showed that there are differences in compliance across the ICAO standards. Specific information related to TSA’s airport assessment results is deemed Sensitive Security Information.

According to TSA officials, it is difficult to draw conclusions about the cumulative foreign airport assessment results—such as whether the results are generally positive or negative—because the primary concern is not whether security deficiencies are identified, but whether foreign countries are capable and willing to address security deficiencies. Specifically, there is considerable regional variation in the level of compliance because some foreign countries face challenges due to lack of resources or technical knowledge, among other factors. TSA officials stated that while these challenges are not easy to overcome, agency efforts, such as training host country staff, can help foreign airports reduce their vulnerability scores over time. Our analysis of TSA’s foreign airport assessment data confirms that point. Specifically, we found that of the foreign airports categorized with a vulnerability rating of 4 of 5 in fiscal year 2012, the majority of these airports improved their vulnerability score in at least one follow-up assessment during fiscal years 2012 through 2016. According to TSA documentation, in some cases, foreign airports are able to take immediate measures to resolve security deficiencies. On the other hand, there are situations in which foreign airports may struggle to take corrective actions or sustain the improvements over time. Accordingly, TSA’s regulatory authority over air carriers is an important tool. TSA officials indicated that the agency commonly requires air carriers to adopt security procedures, such as passenger screening, to compensate for foreign airport security deficiencies. Moreover, if appropriate, DHS can take secretarial action, which includes the option to prohibit air carriers operating at a foreign airport from providing last point of departure flights to the United States.

Most Air Carrier Inspections Were Fully Compliant and TSA Used On-the-Spot Counseling to Resolve the Majority of Deficiencies

According to air carrier inspection data maintained by TSA, between fiscal years 2012 and 2016, air carriers providing last point of departure service to the United States from foreign airports complied with all TSA security requirements in most inspections. For those inspections that identified noncompliance, data from TSA showed that the majority of violations were corrected or addressed immediately through on-the-spot counseling. Inspectors submitted a certain number of violations for investigation because the violations were considered serious enough to potentially warrant an enforcement action. TSA can impose two general types of enforcement actions on air carriers that violate security requirements—an administrative action, such as a warning notice, or a monetary civil penalty. Based on information included in TSA’s investigation module within PARIS, TSA took administrative action in the majority of cases and levied 44 fines during fiscal years 2012 through 2016, which totaled about $575,000 and ranged from $1,000 to $40,500. According to TSA officials, they rely on a system of progressive enforcement and carefully consider whether a civil penalty is warranted based on the compliance history of an air carrier, among other factors.

TSA Addresses Security Deficiencies through Various Capacity Development Efforts, but Enhanced Data Management Could Strengthen Analysis and Decision Making

TSA Assists Foreign Airports and Air Carriers in Addressing Identified Security Deficiencies in Various Ways

Foreign Airports

As part of assisting foreign airports, inspectors work to transfer knowledge on how to mitigate identified airport security deficiencies to foreign airport officials and provide TSA program officials with suggestions for capacity development that could be effective in addressing these deficiencies. Specifically, TSA capacity development assistance to foreign airports includes on-the-spot counseling, training, technical assistance and consultation, and provision of security equipment.

Inspectors counsel foreign airport staff on-the-spot. According to TSA officials, inspectors typically offer counseling during airport assessments when they discover deficiencies, usually of an infrequent, less serious, or technical nature, that can be addressed immediately. For example, during a 2013 assessment of an airport in the Europe region, inspectors observed a total of 53 employees within the restricted area, of which one was not displaying his badge. Airport officials immediately requested that the individual display his badge and informed the TSA inspection team that they will remind all staff to properly display their airport media while in the restricted area. For the remainder of the airport visit, no badge display issues were noted. In another example, during an assessment in the Western Hemisphere region, inspectors observed persons entering a restricted area without undergoing screening. The inspectors counseled the airport’s security officials on the importance of adhering to the airport’s security program, and observed the airport officials take immediate action by implementing escort and screening procedures.

TSA provides security training. TSA may provide training to foreign airport staff to address deeper problems with staff security knowledge or to strengthen staff knowledge in an evolving threat environment. Training may take several forms, including traditional classroom courses or interactive workshops, and can range in length from one or two days to more than one week. Course topics include risk management, screening operations, and airport security, with a broad variety of sub-topics, such as insider risk, cargo security, and inspection techniques. According to TSA, new courses are in development to meet the changing security landscape. New course topics include landside security, behavioral awareness, and the effective use of canines.

TSA arranges for technical assistance and consultation. TSA assists foreign governments in securing technical assistance and consultation provided by TSA and other U.S. and foreign government agencies to help improve security at foreign airports, particularly after security incidents or at airports in developing countries. For example, after the 2016 terrorist attack on Brussels Airport, TSA was invited by airport officials to provide on-site consultation during the reconstitution of the airport facilities. In another example, TSA provided a country in the Africa-Middle East region with on-site technical assistance for configuring and testing explosives detection equipment at baggage screening checkpoints. In addition, State’s Anti-Terrorism Assistance Program augments TSA’s resources in building the aviation security capacity of foreign governments. For instance, State provides recipient nations with courses focused on airport security management, quality control, and fraudulent document recognition as well as multi-day passenger and cargo security consultations. In addition, with regard to capacity development TSA collaborates with other countries. Partners may promote common aviation security goals to other countries when political considerations preclude TSA from doing so, or combine resources with TSA for joint efforts. For example, in one collaboration, a country in the Asia-Pacific region provided resources and facilities, while TSA provided staff so that neighboring countries could attend aviation security training.

TSA loans and donates security equipment. TSA may loan or donate security equipment such as explosives detection devices and metal detection hand wands to lower-income countries. Since fiscal year 2012, TSA has loaned X-ray screening equipment and explosives detection devices to five countries. Enacted in July 2016, the Aviation Security Act expressly authorizes TSA to donate security screening equipment to a foreign last point of departure airport if such equipment can be reasonably expected to mitigate a specific vulnerability to the security of the United States or U.S. citizens. TSA may also provide staff at foreign airports with demonstrations for using equipment that has been loaned or donated by TSA, as well as equipment otherwise acquired by host governments. For instance, in 2016 TSA provided operator training and maintenance assistance to a country in the Africa-Middle East region that had procured passenger body scanners.

Air Carriers

TSA also takes steps to help air carriers address security deficiencies identified during air carrier inspections. TSA primarily offers capacity development support to air carriers through on-the-spot counseling and consultation with IIRs.

Inspectors counsel air carrier representatives on-the-spot. TSA assists air carrier representatives in addressing security deficiencies identified during air carrier inspections. According to TSA, since carriers have TSA-approved security programs, additional training may not be necessary to correct small issues. Rather, officials said that counseling air carrier staff on the proper procedures and follow up observations of them practicing the procedures may suffice. TSA data show that of the instances in which inspectors identified noncompliance with TSA security requirements during fiscal years 2012 through 2016, the majority of instances were resolved through counseling—that is, the security deficiencies were resolved with on-site assistance or consultation provided by TSA. For example, during an air carrier inspection in the Europe region, inspectors observed that a passenger wearing sandals was not screened properly. TSA counseled the screening staff that footwear screening requirements apply to all shoes, including sandals. The inspectors then observed proper rescreening of the passenger. TSA also discussed the matter with airline security representatives, who concurred with TSA.

IIRs assist air carriers with compliance. In addition to counseling provided by inspectors when deficiencies are identified, TSA assigns each air carrier to a representative who assists the carriers in complying with TSA security requirements. Although these representatives, called IIRs, do not participate in air carrier inspections, they do receive inspection results for the carriers with whom they work. IIRs counsel the air carriers and provide clarification regarding TSA security requirements when necessary. For example, they provide air carriers with clarification on the requirements contained in security directives and emergency amendments issued by TSA. In other instances, when an air carrier cannot comply with a TSA security requirement—such as when complying with a TSA security requirement would cause the air carrier to violate a host government security requirement—the air carrier works with its IIR to develop alternative security procedures in a manner consistent with TSA regulations. With alternative procedures, air carriers can deviate from their TSA-approved security program while still meeting the intent of TSA requirements. According to some IIRs with whom we spoke, these alternative procedures are intended to provide a level of security that is equivalent to the level of security provided by TSA’s standard requirements while also affording air carriers with some flexibility in how they achieve the intended security benefit of the TSA requirement. Alternative security procedures are reviewed by the IIR, who submits them to TSA headquarters and field officials for final review and approval.

TSA Has Taken Steps to Leverage Information for Capacity Development, but Could Enhance Data Management

Leveraging Information for Capacity Development

TSA has taken a number of steps to strengthen its analytical processes and better understand the impact of the foreign airport assessment and air carrier inspection programs. According to OGS officials, the establishment and evolution of the ARM Directorate has facilitated better data analysis and enhanced decision making pertaining to capacity development. Specifically, TSA now conducts regional strategy meetings, produces regional risk reports, and approves requests for assistance based on risk.

OGS conducts regional strategy meetings. Since fiscal year 2012, OGS has held strategy meetings to address aviation security threats and vulnerabilities within each region. During these meetings, OGS officials examine trend data for both airport assessments and air carrier inspections, including vulnerability ratings over a multi-year period, identify common areas of non-compliance, and develop capacity building approaches customized to each region. According to agency documentation, these meetings led OGS to recognize that each geographic region faces its own particular challenges and risks and requires unique mitigation approaches, such as at the country or airport level.

ARM develops regional risk reports. In 2016, the ARM Directorate began producing regional risk reports for use by other teams within OGS. The purpose of these reports is to provide OGS personnel operating within each of the four regions with an understanding of known vulnerabilities in the region and their associated risk in order to inform mitigation planning efforts. These reports include such information as key risks at each location and region-wide trends on vulnerabilities. For example, the reports show patterns in noncompliance related to critical ICAO standards. In addition, the reports compare airports by risk level and examine how individual airports compare to a regional average. According to ARM staff, one of the top priorities this year is to centralize analysis results within a web portal that allows users across OGS to sort and filter data. ARM expects the portal to include comprehensive airport profiles that capture the primary details for each location, such as the largest carriers and main risks.

OGS approves requests for assistance based on risk. Requests for capacity development assistance are submitted by OGS personnel, including TSARs and inspectors. TSA’s Capacity Development Branch (CDB) in ARM assesses these requests according to a standardized criterion that includes an airport’s past and present vulnerabilities, the root causes of these vulnerabilities, the timing of the assistance delivery, and the suitability of the intended recipient. For instance, TSA assesses the capabilities of the government or airport that would receive the assistance, and considers such factors as whether the intended recipient has the commitment necessary to institutionalize TSA-sponsored training and the technical expertise to use any equipment that may be loaned or donated by TSA. In addition, according to TSA officials, TSA considers the extent to which the intended recipient has been a cooperative partner in the past and implemented TSA’s previous security recommendations. After CDB’s risk-based assessment of assistance requests, OGS management makes a final determination regarding the provision of assistance.

TSA Could Enhance Data Management

While TSA has taken steps to leverage the results of foreign airport assessments and air carrier inspections to monitor system-wide vulnerabilities and inform capacity development, TSA lacks key information for decision making. For instance, we found that the Open Standards and Recommended Practices Findings Tool (OSFT) — a database for tracking the resolution status of identified foreign airport deficiencies — has gaps and its system for categorization does not result in sufficient specificity of information related to security deficiencies’ root causes and corrective actions.

Root causes represent the underlying reason why an airport is not meeting an ICAO standard and, according to TSA documentation, fall into three general categories: lack of knowledge, lack of infrastructure, and lack of will. For example, a foreign airport might fail to meet an ICAO standard because of lack of knowledge stemming from insufficient training programs or a high rate of staff turnover. According to OGS officials, an understanding of root causes is important because the challenges to addressing security deficiencies at foreign airports vary extensively from country to country and corrective actions need to be tailored to addressing the unique root causes of deficiencies that TSA identifies. Corrective actions are efforts to mitigate security deficiencies and might include training and other capacity building efforts. Corrective actions can be designed to help a foreign airport add a new security capability, enhance an existing capability, or increase the deployment of security measures.

Although root causes and corrective actions are important variables for decision making, we found that the OSFT has gaps in this information. TSARs—the primary liaisons between the U.S. government and foreign governments on transportation security issues—are responsible for following up on progress made by foreign officials in addressing security deficiencies identified during TSA assessments. Specifically, the Foreign Airport Assessment Program SOP states that, for each foreign airport assessed, the assigned TSAR is responsible for entering and updating key information in the OSFT, including root cause and corrective action information. According to the SOP, a thorough understanding of the underlying reasons for each deficiency is critical to selecting the appropriate mitigation activities. However, we found that around two thirds of fiscal year 2016 records in the OSFT exhibited empty fields pertaining to root cause or recommended corrective action. More specifically, root cause data and recommended corrective action data were each not recorded for 70 percent of findings.

During our interviews with TSARs, half (4 out of 8) indicated that they believed the OSFT to be a cumbersome tool that has limitations for recording status updates, among other issues, or that they preferred to use other mechanisms, such as spreadsheets stored locally, in order to avoid using the OSFT for certain functions. TSA headquarters officials indicated that OGS began requiring staff to record root cause and corrective action information in 2015 and that institutionalizing this requirement to facilitate consistent data entry will take time. However, complete data on root causes and corrective actions would help TSA systematically monitor airport performance in addressing deficiencies and leverage information for decision making regarding capacity development. For example, with complete information TSA would be in a better position to determine the extent to which airports were able to effectively close security vulnerabilities based on TSA’s capacity building efforts, as well as conduct trend analysis within and across its four regions, including identifying potential linkages between root causes and corrective actions. Specifically, TSA could determine the extent to which corrective actions seem to align best with certain root causes. For example, while training might be an appropriate remedy if foreign airport personnel lack knowledge, it might not be an appropriate solution for lack of will.

We also found that the OSFT has limitations related to the categorization of root causes and corrective actions. The Foreign Airport Assessment Program SOP indicates that root causes may relate to three broad categories, as explained earlier, and twelve subcategories: aviation security infrastructure, communication, cultural factors, human factors, management systems, physical infrastructure, procedures, quality control, resources, supervision, technology, and training. However, the OSFT does not include a field to categorize root causes according to these subcategories or other more specific areas. As a result, it does not capture more granular information that would better explain the specific root cause of an identified security issue.

Moreover, information on recommended corrective actions is stored entirely in OSFT narrative fields without a drop-down list or other type of categorization mechanism. For example, according to OSFT data, in one Western Hemisphere region country, inspectors observed insufficient employee screening and access control. The recommended corrective action—”Fencing around the terminal area will be enhanced and airport personnel counseled about employee screening”—would be difficult to include in quantitative analysis without manual intervention. The OSFT also includes a field for the final corrective action—how an airport ultimately resolved a security issue. However, the categories in the OSFT for final corrective action do not account for many key types of TSA’s mitigation efforts (e.g., training, loaning or donating equipment, and directing an air carrier to mitigate an airport vulnerability). Specifically, for fiscal year 2016, we found that the OSFT only included data for three high-level categories of final corrective actions: “airport authorities resolved,” “national authorities resolved,” and “other.”

ARM staff stated that they recognize that the classification of data currently contained in the OSFT could be improved, but that they have not had an opportunity to address the issues because they have been focused on developing the newest release of GRADS. TSA staff also indicated that they are exploring opportunities to better classify data in future releases of GRADS. However, according to the Foreign Airport Assessment Program SOP, a thorough understanding of the underlying reasons for each deficiency is critical to properly selecting the appropriate mitigation activities. Moreover, federal internal control standards suggest that agencies should design information systems to obtain and process information to meet each operational process’s data requirements and to respond to the entity’s objectives and risks. By classifying information on root causes and corrective actions with additional specificity, and through a standard system of categorization that would allow for system- wide analysis, TSA would be better positioned to assure that corrective actions accurately address the specific, underlying reasons for security vulnerabilities.

Conclusions

TSA’s foreign airport assessment and air carrier inspection programs play a vital role in ensuring the security of the aviation system. TSA has taken a number of steps to enhance foreign airport assessments and air carrier inspections since 2011, including targeting resources based on risk, strengthening access to foreign airports and the comprehensiveness of its assessments and inspections, and creating operational efficiencies. While TSA does not have authority to impose or otherwise enforce security requirements at foreign airports, the agency makes a concerted effort to help foreign airports improve their security posture and address security deficiencies identified during assessments. Moreover, TSA is commonly able to resolve air carrier security deficiencies with on-the-spot counseling.

While TSA uses various mechanisms for capacity building, better data management would help strengthen analysis and decision making. Specifically, fully capturing and more specifically categorizing data on the root causes of security deficiencies that TSA identifies and the associated corrective actions would provide the agency with a more comprehensive understanding of the security environment at foreign airports. For example, TSA could leverage this information for trend analysis, including evaluating potential linkages between root causes and corrective actions, and determining the extent to which airports that received specific types of capacity development services were able to close security vulnerabilities. Accordingly, TSA would have better visibility over the different types of capacity development that the agency offers and the overall return on investment for these efforts.

Recommendations for Executive Action

We are making the following two recommendations to TSA:

The Assistant Administrator for the Office of Global Strategies should ensure that data regarding the root causes of security deficiencies and corrective actions are consistently captured in accordance with TSA guidance. (Recommendation 1)

The Assistant Administrator for the Office of Global Strategies should update TSA’s data systems to include more specific categories for TSA’s data on the root causes and corrective actions related to security deficiencies. (Recommendation 2)

Agency Comments and Our Evaluation

We provided a draft of our report to DHS for its review and comment. DHS provided written comments, which are noted below and reproduced in full in appendix II. DHS concurred with both recommendations in the report and described actions underway or planned to address them. With regard to the first recommendation that TSA ensure that data regarding the root causes of security deficiencies and corrective actions are consistently captured in accordance with TSA guidance, DHS concurred and stated that TSA will use a new tool, the Vulnerability Resolution Tool (VRT), to capture and categorize root causes and corrective actions. During the next fiscal year, TSA plans to train its staff in the use and importance of the VRT, and estimates that it will complete this process by October 31, 2018. If TSA consistently captures root causes and corrective actions in the new tool, TSA’s planned actions would address the intent of the recommendation. With regard to the second recommendation that TSA update TSA’s data systems to include more specific categories for TSA’s data on the root causes and corrective actions related to security deficiencies, DHS concurred and stated that TSA plans to include more specific categories for root causes and corrective actions in a future iteration of GRADS, and expects to complete the updates by October 31, 2018. If fully implemented, these actions should address the intent of the recommendation.

We are sending copies of this report to interested congressional committees and the Secretary of Homeland Security, the Secretary of State, the Administrator of the Transportation Security Administration, and the TSA Assistant Administrator for the Office of Global Strategies. In addition, the report is available at no charge on the GAO website at http://gao.gov.

If you or your staff members have any questions about this report, please contact Jennifer Grover at (202) 512-7141 or groverj@gao.gov, or Jessica Farb at (202) 512-6991 or farbj@gao.gov. Key contributors to this report are listed in appendix III.

Appendix I: Objectives, Scope, and Methodology

The Aviation Security Act of 2016 includes a provision for GAO to review the efforts, capabilities, and effectiveness of TSA to enhance security capabilities at foreign airports and determine if the implementation of such efforts and capabilities effectively secures international-inbound aviation. This report (1) describes steps TSA has taken to enhance foreign airport assessments and air carrier inspections since 2011, (2) describes the results of TSA’s foreign airport assessments and air carrier inspections, and (3) examines steps TSA takes to address any deficiencies identified during foreign airport assessments and air carrier inspections.

To collectively address all three objectives, we reviewed the relevant laws and regulations pursuant to which TSA conducts foreign airport assessments and air carrier inspections. We reviewed various TSA documents on program management and strategic planning and interviewed TSA officials located at TSA headquarters and in the field. We interviewed other federal and nonfederal stakeholders, such as the Department of State (State), the European Commission (EC), and airport and air carrier representatives. We outline the specific steps taken to answer each objective below.

To obtain a greater understanding of the foreign airport assessment and air carrier inspection processes, including how TSA works with host nation officials and air carrier representatives, we accompanied a team of TSA inspectors during an air carrier inspection at an airport in Europe. We based our site selection on several factors, including the air carrier locations TSA had plans to inspect during the course of our audit work and host government willingness to allow us to accompany TSA. In addition, we spoke with officials at a separate European airport, including the airport operator and representatives from two air carriers.

To understand how TSA assesses and manages its foreign airport and air carrier risk information, we obtained and reviewed documents on TSA’s methodology for assigning individual risk rankings (called tier rankings) to each foreign airport it assesses. TSA’s rankings are based on the likelihood of a location being targeted, the protective measures in place at that location, and the potential impact of an attack on the international transportation system. Airports are then categorized as high, medium, or low risk. We also reviewed TSA’s methodology for grouping air carriers based on risk, which is influenced by the foreign airport risk tiers.

To describe the steps that TSA has taken to enhance foreign airport assessments and air carrier inspections since 2011, we reviewed various TSA documents on program management and strategic planning. Specifically, we reviewed TSA’s 2016 Foreign Airport Assessment Program Standard Operating Procedures (SOP), which prescribes program and operational guidance for assessing security measures at foreign airports, and informs TSA personnel at all levels of what is expected of them in the implementation of the program. We also reviewed the job aids that TSA inspectors use during each assessment and inspection, which ensure that the TSA-specified International Civil Aviation Organization (ICAO) aviation security standards and recommended practices (referred to collectively in this report as ICAO standards unless otherwise noted) and air carrier security program requirements are fully evaluated during each assessment. In addition, we reviewed TSA’s Office of Global Strategies (OGS) Strategic Plan for fiscal years 2014 through 2018, and documents describing changes to the OGS organizational structure since 2011.

To obtain stakeholder views and perspectives on steps TSA has taken to enhance its foreign airport assessment program since 2011, we interviewed and obtained information from various federal stakeholders. Specifically, we interviewed OGS officials located in the Global Compliance (GC), Global Affairs, and Analysis and Risk Mitigation (ARM) directorates. In addition, we also conducted site visits to three of the six TSA regional operations centers (ROC), located in Reston, Miami, and Frankfurt, where we met with ROC managers, transportation security specialists (henceforth referred to as inspectors) who conduct TSA’s foreign airport assessments and air carrier inspections, TSARs who follow up on host governments’ progress in addressing identified security deficiencies, international industry representatives (IIR) who liaise with air carriers, and regional directors (RD). We based our site visit selections on the number and type of staff available at each location and geographic dispersion. We also conducted telephone interviews with personnel from the Honolulu ROC and other OGS staff stationed worldwide. In total, we interviewed 4 of the 6 ROC managers, 19 of the 94 inspectors, 8 of the 29 TSARs, 8 of the 16 IIRs, and all 4 RDs. During these interviews, we discussed these officials’ responsibilities related to the assessment and inspection programs.

To describe the results of TSA’s foreign airport assessments and air carrier inspections, we interviewed TSA officials on the results of its evaluations, obtained and reviewed relevant program documents, and conducted our own independent analysis of TSA’s assessment and inspection results. Specifically, we obtained and reviewed TSA’s foreign airport assessment program vulnerability results tracking sheet used by GC to compile and track current and prior-year assessment results. This tracking sheet included records of TSA’s compliance assessments for each airport that TSA assessed from fiscal years 2012 through 2016. Specifically, the tracking sheet recorded assessment results for each of the ICAO standards used in the airport assessments, as well as an overall vulnerability score of 1 through 5 assigned after each assessment. This overall vulnerability score is a representation of compliance or noncompliance with all the ICAO standards against which TSA assesses foreign airports. We interviewed OGS officials on the steps taken to develop the tracking sheet, including how TSA manages and updates data. In addition, we conducted our own independent analysis of TSA’s assessment results from fiscal years 2012 through 2016, the five-year period since our previous review. Specifically, we analyzed data from TSA’s foreign airport assessment program vulnerability results tracking sheet to identify the number of airports in each vulnerability category by region. We also analyzed TSA assessment results data to determine the frequency with which foreign airports complied with particular ICAO standards, such as access control, quality control, passenger screening, and baggage screening, among others.

For air carrier inspection results, we analyzed data from PARIS on each air carrier that TSA inspected from fiscal years 2012 through 2016. Our analysis included the overall level of compliance, as well as the frequency with which each air carrier complied with particular security program requirements, such as aircraft search and passenger screening. We also interviewed TSA managers, inspectors, and TSARs about their roles and responsibilities in determining and documenting assessment and inspection results. To assess the reliability of TSA’s assessment and inspection data, we reviewed program documentation on system controls, interviewed knowledgeable officials from OGS and checked TSA’s data for any potential gaps and errors. Based on our overall analysis of the data, we determined that the data were sufficiently reliable to provide a general indication, by type or category, of the standards TSA assesses against and the level of compliance, and frequency of compliance, for TSA’s foreign airport assessments and air carrier inspections over the period of our analysis.

To examine the steps TSA takes to address deficiencies identified during foreign airport assessments and air carrier inspections, we interviewed ARM and other TSA staff. Specifically, we discussed the full range of options that are available to TSA for addressing airport and air carrier security deficiencies, including a variety of capacity development tools and collaboration with domestic agencies, such as State, and foreign partners, such as Australia, Canada, Chile, New Zealand, Singapore, South Africa, and the United Kingdom. During these interviews, we discussed the circumstances in which each option is typically used and the factors determining when an option is used. We also reviewed program management tools TSA uses to track and manage the status of foreign airport security deficiencies and records pertaining to capacity development assistance deliveries from fiscal years 2012 through 2016, including equipment loaned or donated, training courses provided, and technical assistance delivered.

To obtain information on the extent to which TSA provided oversight of its assessment and inspection efforts, we obtained and reviewed various TSA program management documents and tools that TSA uses to track and manage information for the programs. Specifically, we reviewed the fiscal year 2017 Global Compliance Master Work Plan, which TSA uses to track its foreign airport assessment schedule, including when various airports are due to be assessed. We also reviewed the Open Standards and Recommended Practices Findings Tool, which the TSA Representatives (TSAR) use to monitor and track a foreign airport’s progress in resolving security deficiencies identified by TSA inspectors during previous assessments. In addition, we reviewed the tracking sheet TSA uses to compile and track airport assessment results, including individual airport vulnerability scores and information on which specific ICAO standards were in noncompliance. Finally, we reviewed the results of air carrier inspections that are contained in the inspections and investigations modules of TSA’s Performance and Results Information System (PARIS).

To identify challenges affecting TSA’s foreign airport assessment program, we interviewed TSA officials, such as TSA’s Director of Global Compliance, and field officials located at the TSA ROCs about the challenges they experience obtaining access to foreign airports to conduct assessments, the performance of data management systems, and the provision of aviation security capacity development assistance to foreign governments. We also obtained their perspectives on foreign governments that have been reluctant to allow TSA inspectors to visit their airports. We also interviewed TSA’s Director of Global Compliance and headquarters and field staff on the agency’s use of databases and other tracking mechanisms to manage assessment and inspection results. In addition, we obtained the perspective of TSARs on challenges to ensuring that foreign airports address security deficiencies. We also interviewed officials within TSA’s Capacity Development Branch to better understand the scope and types of requests for assistance that they receive from foreign countries, the challenges that they experience in attempting to provide assistance, and their experience collaborating with State.

We met with State officials to better understand how they coordinate with TSA through their Office of Anti-Terrorism Assistance and other related efforts aimed at assisting foreign partners’ capacity to secure their airports. In addition, we met with officials from the EC and the International Air Transport Association to discuss efforts and programs these organizations have in place to enhance international aviation security.

In addition, during our interviews with ARM staff, we discussed the extent to which TSA uses information at its disposal to inform capacity development efforts. We also compared these efforts to criteria for obtaining and processing information in federal internal control standards. To identify opportunities for TSA to better leverage information to inform capacity development, we reviewed relevant program management documentation and tools that TSA uses to track and analyze assessment results. Specifically, we reviewed the 2016 Foreign Airport Assessment Program SOP and program management tools TSA uses to track and manage the status of foreign airport security deficiencies. We also reviewed our prior work concerning how risk- informed and priority driven decisions can help inform agency decision makers in allocating finite resources to the areas of greatest need.

Information from our interviews with government officials and members of the aviation industry provide insight into their perspectives on TSA’s foreign airport assessment and air carrier inspection programs. However, this information cannot be generalized beyond those with whom we spoke because we did not use statistical sampling techniques in selecting individuals to interview.

The performance audit upon which this report is based was conducted from August 2016 to October 2017 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate, evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. We subsequently worked with TSA from September 2017 to December 2017 to prepare this nonsensitive version of the original sensitive report for public release. This public version was also prepared in accordance with these standards.

Appendix II: Comments from the Department of Homeland Security

Appendix III: GAO Contacts and Staff Acknowledgments

GAO Contacts

Staff Acknowledgments

In addition to the contacts above, Jason Bair and Chris Ferencik (Assistant Directors); Anthony C. Fernandez (Analyst-in-Charge); Bryan Bourgault; Elizabeth Dretsch; Jesse Elrod; Eric Hauswirth; Christopher Lee; Tom Lombardi; Amanda Miller; and Adam Vogt made key contributions to this report.