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. 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.