Approximately 16 percent of air cargo transported to, from, or within the United States is shipped on passenger aircraft, while the remainder is transported on all-cargo aircraft. Overall, approximately 20 million pounds of cargo is transported on domestic and inbound passenger aircraft daily. This cargo ranges in size from 1 pound to several tons and in type from perishable commodities to machinery. Air cargo can include such varied items as electronic equipment, automobile parts, clothing, medical supplies, fresh produce, and human remains. As seen in figure 1, cargo can be shipped in various forms, including unit load devices (ULD) that allow many packages to be consolidated into one large container or pallet that can be loaded onto an aircraft, wooden skids or crates, and individually wrapped/boxed pieces, known as loose or break bulk cargo. Participants in the air cargo shipping process include shippers, such as individuals and manufacturers of various product types; freight forwarders, such as a company that accepts packages and ships them on behalf of individuals or manufacturers; air cargo handling agents, who process and load cargo onto aircraft on behalf of air carriers; and air carriers that load and transport cargo. A shipper may take or send its packages to a freight forwarder that in turn consolidates cargo from many shippers onto a master air waybill—a manifest of the consolidated shipment—and delivers the shipment to air carriers for transport. A shipper may also send freight by directly packaging and delivering it to an air carrier’s ticket counter or sorting center, where the air carrier or a cargo handling agent will sort and load cargo onto the aircraft. TSA’s responsibilities for securing air cargo include establishing security requirements governing domestic and foreign passenger air carriers that transport cargo, and domestic freight forwarders. TSA is also responsible for overseeing the implementation of air cargo security requirements by air carriers and freight forwarders through compliance inspections by transportation security inspectors (TSI)—staff within TSA responsible for aviation or cargo security inspections—and, in coordination with DHS’s S&T Directorate, for guiding research and development of air cargo security technologies. Of the over $5.2 billion provided to TSA for aviation security in fiscal year 2010, approximately $123 million is for air cargo security as called for in the Conference Report for the DHS Appropriations Act, 2010. Of this amount, TSA was directed to use $15 million to test, evaluate, and deploy screening technologies; to expand canine teams operated by TSA by transferring 35 teams from those operated by local law enforcement; to deploy technologies to screen skids and pallets; and to increase the number of TSIs who oversee participants in the newly developed Certified Cargo Screening Program (CCSP)—a voluntary cargo screening program for freight forwarders, shippers, and other air cargo industry participants. For fiscal year 2011, TSA has requested approximately $118 million for its air cargo security efforts. U.S. and foreign air carriers, freight forwarders, and certified cargo screening facilities (CCSF)—industry stakeholders that have joined the CCSP—are responsible for implementing TSA security requirements, including maintaining a TSA-approved security program that describes the security policies, procedures, and systems the air carriers, freight forwarders, and CCSFs must implement to ensure compliance. These requirements include measures related to the acceptance, handling, and screening of cargo; training of employees in security and cargo screening procedures; testing for employee proficiency in cargo screening; and access to cargo areas and aircraft. Air carriers, freight forwarders, and CCSFs must also abide by security requirements imposed by TSA through security directives and amendments to security programs. In addition to TSA, CBP and foreign governments play a role in securing inbound cargo. Unlike TSA, which requires screening prior to departure, CBP determines the admissibility of cargo into the United States and is authorized to inspect inbound air cargo for terrorists or weapons of mass destruction upon its arrival in the United States. Foreign governments may also impose their own security requirements on cargo departing from their airports. The 9/11 Commission Act specifies that air cargo screening methods include X-ray systems, explosives detection systems (EDS), explosives trace detection (ETD), explosives detection canine teams certified by TSA, physical search together with manifest verification, and any additional methods approved by the TSA Administrator. However, solely performing a review of information about the contents of cargo or verifying the identity of the cargo’s shipper does not constitute screening for purposes of satisfying the mandate. Figure 2 shows some approved screening methods. TSA has made progress in meeting the 9/11 Commission Act air cargo screening mandate as it applies to domestic cargo, and has taken several key steps in this effort, such as increasing the amount of domestic cargo subject to screening, creating a voluntary program—the CCSP—to allow screening to take place at various points along the air cargo supply chain, and taking steps to test air cargo screening technologies, among other actions. However, TSA faces several challenges in fully developing and implementing a system to screen 100 percent of domestic air cargo. For example, shipper participation in the CCSP has been lower than targeted by TSA. Furthermore, TSA lacks information to help ensure that it has the inspection resources it may need to provide effective oversight of CCSP entities. In addition, there is currently no technology approved or qualified by TSA to screen ULD pallets or containers, and TSA is working to complete qualification testing of several air cargo screening technologies to provide reasonable assurance of their effectiveness. Questions also exist about the reliability of the data used to calculate screening levels reported by TSA. Moreover, in-transit cargo—such as cargo that is transferred from an inbound to a domestic passenger flight—is not currently required to undergo physical screening. Finally, TSA has not developed a contingency plan to address CCSP participation and screening technology challenges, which could be implemented should TSA’s current efforts not be sufficient to achieve the 100 percent screening mandate without impeding the flow of commerce. TSA has taken several steps to address the air cargo screening mandate. TSA increased the amount of domestic cargo subject to screening. Effective October 1, 2008, several months prior to the first mandated deadline of 50 percent screening by February 2009, TSA established a requirement for 100 percent screening of nonexempt cargo transported on narrow-body passenger aircraft. In 2008, narrow-body flights transported about 24 percent of all cargo on domestic passenger flights. Effective February 1, 2009, pursuant to the 9/11 Commission Act, TSA also required air carriers to ensure the screening of 50 percent of all nonexempt air cargo transported on all passenger aircraft. Furthermore, effective May 1, 2010, air carriers were required to ensure that 75 percent of such cargo was screened. Although screening may be conducted by various entities, according to TSA regulations, each air carrier must ensure that the screening requirements are fulfilled. Furthermore, TSA eliminated or revised most of its screening exemptions for domestic cargo. For example, TSA eliminated the screening exemptions for palletized shrink-wrapped skids, effective February 2009, and for sealed pharmaceuticals and certain electronics, effective September 2009. As a result of the elimination of exemptions, most domestic cargo is now subject to TSA screening requirements. However, TSA is retaining several of the screening exemptions that apply to sensitive cargo. 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 CCSP to allow screening to take place earlier in the shipping process, prior to delivering the cargo to the air carrier (see fig. 3). Under this decentralized approach, air carriers, freight forwarders, shippers, and other entities each play an important role in the screening of cargo. 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 CCSFs. Once in the program, they are regulated by TSA. According to TSA officials, sharing screening responsibilities across the air cargo supply chain is expected to minimize the potential increases in cargo transit time, which could result if the majority of screening were conducted by air carriers at the airport. While the CCSP allows for a number of entities to conduct air cargo screening, according to TSA regulations, air carriers are responsible for ensuring that all domestic cargo transported on passenger aircraft is screened. TSA officials stated that effective August 2010, unscreened domestic cargo would not be transported on passenger aircraft. 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. CCSP participants were certified to begin screening cargo as of February 1, 2009. The shipper participants were regulated pursuant to an order, and the rules for freight forwarder participants were instituted through an amendment to their security programs. On September 16, 2009, TSA issued an interim final rule (IFR) that effective November 16, 2009, regulates the shippers, freight forwarders, and other entities participating in the CCSP. According to the IFR, to become a CCSF, a facility’s screening measures must be evaluated by TSA or a TSA-approved validation firm. Under its certification process, TSA requires each CCSF to demonstrate compliance with its security standards that include facility, personnel, procedural, perimeter, and information technology security. Prior to certification, the CCSP applicant must submit for review and approval its training programs related to physical screening, facility access controls, and chain of custody, among other things. CCSF applicants must also implement TSA-approved security programs and appoint security coordinators before they can become certified.