Aviation Security: Transportation Security Administration May	 
Face Resource and Other Challenges in Developing a System to	 
Screen All Cargo Transported on Passenger Aircraft (15-JUL-08,	 
GAO-08-959T).							 
                                                                 
The Implementing Recommendations of the 9/11 Commission Act of	 
2007 requires the Transportation Security Administration (TSA) to
implement a system to physically screen 100 percent of cargo on  
passenger aircraft by August 2010. To fulfill these requirements,
the Department of Homeland Security's (DHS) TSA is developing the
Certified Cargo Screening Program (CCSP), which would allow the  
screening of cargo to occur prior to placement on an aircraft.	 
This testimony addresses four challenges TSA may face in	 
developing a system to screen 100 percent of cargo: (1) deploying
effective technologies; (2) changing TSA air cargo screening	 
exemptions; (3) allocating compliance inspection resources to	 
oversee CCSP participants; and (4) securing cargo transported	 
from a foreign nation to the United States. GAO's comments are	 
based on GAO products issued from October 2005 through February  
2008, including selected updates conducted in July 2008.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-959T					        
    ACCNO:   A82859						        
  TITLE:     Aviation Security: Transportation Security Administration
May Face Resource and Other Challenges in Developing a System to 
Screen All Cargo Transported on Passenger Aircraft		 
     DATE:   07/15/2008 
  SUBJECT:   Air transportation 				 
	     Aircraft						 
	     Aircraft safety					 
	     Airline security					 
	     Airport security					 
	     Aviation security					 
	     Cargo screening					 
	     Cargo security					 
	     Commercial aviation				 
	     Explosives 					 
	     Explosives detection systems			 
	     Inspection 					 
	     Internal controls					 
	     International travel				 
	     Risk assessment					 
	     Search and seizure 				 
	     Security investigations				 
	     Security policies					 
	     Security threats					 
	     Strategic planning 				 
	     Systems analysis					 
	     Transportation safety				 
	     Transportation security				 
	     Assessments					 
	     Foreign countries					 
	     Policies and procedures				 
	     Program implementation				 
	     TSA Certified Cargo Screening Program		 

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GAO-08-959T

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Testimony before the Subcommittee on Transportation Security and 
Infrastructure Protection, Committee on Homeland Security, House of 
Representatives: 

United States Government Accountability Office:
GAO: 

For Release on Delivery: 
Expected at 2:00 p.m. EST:
Tuesday, July 15, 2008: 

Aviation Security: 

Transportation Security Administration May Face Resource and Other 
Challenges in Developing a System to Screen All Cargo Transported on 
Passenger Aircraft: 

Statement of Cathleen A. Berrick: 
Director: 
Homeland Security and Justice Issues: 

GAO-08-959T: 

GAO Highlights: 

Highlights of GAO-08-959T, a testimony before the Subcommittee on 
Transportation Security and Infrastructure Protection, Committee on 
Homeland Security, House of Representatives. 

Why GAO Did This Study: 

The Implementing Recommendations of the 9/11 Commission Act of 2007 
requires the Transportation Security Administration (TSA) to implement 
a system to physically screen 100 percent of cargo on passenger 
aircraft by August 2010. To fulfill these requirements, the Department 
of Homeland Securityï¿½s (DHS) TSA is developing the Certified Cargo 
Screening Program (CCSP), which would allow the screening of cargo to 
occur prior to placement on an aircraft. This testimony addresses four 
challenges TSA may face in developing a system to screen 100 percent of 
cargo: (1) deploying effective technologies; (2) changing TSA air cargo 
screening exemptions; (3) allocating compliance inspection resources to 
oversee CCSP participants; and (4) securing cargo transported from a 
foreign nation to the United States. GAOï¿½s comments are based on GAO 
products issued from October 2005 through February 2008, including 
selected updates conducted in July 2008. 

What GAO Found: 

DHS has taken steps to develop and test technologies for screening and 
securing air cargo; however, TSA has not completed assessments of the 
technologies it plans to use as part of the CCSP. TSA has reported that 
there are several challenges that must be overcome to effectively 
implement any of these technologies, including the nature, type, and 
size of cargo to be screened and the location of air cargo facilities. 
In addition, the air cargo industry voiced concern about the costs 
associated with purchasing the screening equipment. GAO will likely 
review this issue in future work. 

TSA plans to revise and eliminate screening exemptions for some 
categories of air cargo, thereby reducing the percentage of cargo 
transported on passenger aircraft that is subject to alternative 
methods of screening. However, TSA plans to continue to exempt some 
types of domestic and outbound cargo (cargo transported by air from the 
United States to a foreign location) after August 2010. TSA based its 
determination regarding the changing of exemptions on professional 
judgment and the results of air cargo vulnerability assessments. 
However, TSA has not completed all of its air cargo vulnerability 
assessments, which would further inform its efforts. 

TSA officials stated there may not be enough compliance inspectors to 
oversee implementation of the CCSP and is anticipating requesting an 
additional 150 inspectors for fiscal year 2010. They further stated 
that they have not formally assessed the number of inspectors the 
agency will need. Without such an assessment, TSA may not be able to 
ensure that CCSP entities are meeting TSA requirements to screen and 
secure cargo. To ensure that existing air cargo security requirements 
are being implemented as required, TSA conducts audits, referred to as 
compliance inspections, of air carriers that transport cargo. The 
compliance inspections range from a comprehensive review of the 
implementation of all security requirements to a review of at least one 
security requirement by an air carrier or freight forwarder (which 
consolidates cargo from many shippers and takes it to air carriers for 
transport). GAO reported in October 2005 that TSA had conducted 
compliance inspections on fewer than half of the estimated 10,000 
freight forwarders nationwide and, of those, had found violations in 
over 40 percent of them. GAO also reported that TSA had not analyzed 
the results of compliance inspections to systematically target future 
inspections. 

GAO reported in April 2007 that more work remains for TSA to strengthen 
the security of cargo transported from a foreign nation to the United 
States, referred to as inbound air cargo. Although TSA is developing a 
system to screen 100 percent of domestic and outbound cargo, TSA 
officials stated that it does not plan to include inbound cargo because 
it does not impose its security requirements on foreign countries. TSA 
officials said that vulnerabilities to inbound air cargo exist and that 
these vulnerabilities are in some cases similar to those of domestic 
air cargo, but stated that each foreign country has its own security 
procedures for flights coming into the United States. 

What GAO Recommends: 

GAO has made recommendations to DHS and TSA in prior reports to 
increase the security and screening of air cargo, including completing 
vulnerability assessments and developing a plan for analyzing 
compliance inspections. TSA generally agreed with these recommendations 
and plans to address them. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-959T]. For more 
information, contact Cathleen A. Berrick at (202) 512-3404 or 
[email protected]. 

[End of section] 

Ms. Chairwoman and Members of the Subcommittee: 

We appreciate the opportunity to participate in today's hearing to 
discuss the security of the air cargo transportation system. In 
response to the terrorist attacks of September 11, 2001, the Aviation 
and Transportation Security Act was enacted in November 2001, which 
created the Transportation Security Administration (TSA) and required 
it to provide for the screening of all passengers and property, 
including cargo, U.S. mail, and carry-on and checked baggage that is 
transported onboard passenger aircraft. Recognizing the need to 
strengthen the security of air cargo, Congress enacted, and the 
President signed into law, the Implementing Recommendations of the 9/11 
Commission Act of 2007, which requires TSA to implement a system to 
physically screen 50 percent of cargo on passenger aircraft by February 
2009, and 100 percent of such cargo by August 2010.[Footnote 1] To 
fulfill the requirements of the Act, TSA is developing a program, 
referred to as the Certified Cargo Screening Program (CCSP), which 
would allow the screening of air cargo to take place at various points 
throughout the air cargo supply chain. Under the CCSP, Certified Cargo 
Screening Facilities (CCSF), such as shippers, manufacturing 
facilities, and freight forwarders that meet security requirements 
established by TSA, will volunteer to screen cargo prior to its loading 
onto an aircraft.[Footnote 2] Participation of the air cargo industry 
is critical to the successful implementation of the CCSP. According to 
TSA officials, air carriers will ultimately be responsible for 
screening 100 percent of cargo transported on passenger aircraft should 
air cargo industry entities not volunteer to become a CCSF. 

My testimony today focuses on the challenges TSA may face as it works 
to develop a system to screen 100 percent of cargo transported on 
passenger aircraft by August 2010. Our comments are based on GAO 
reports and testimonies issued between October 2005 and February 2008 
addressing the security of the air cargo transportation system, 
including selected updates to this work conducted in July 2008. In 
addition, this statement includes selected information collected during 
our review of TSA's report on its air cargo screening exemptions as 
mandated by the Implementing Recommendations of the 9/11 Commission Act 
of 2007[Footnote 3]. This review was completed in July 2008 and has yet 
to be publicly issued. We will initiate a review of TSA's efforts to 
meet the requirement to screen 100 percent of cargo transported on 
passenger aircraft in the near future, at the request of the Chairman 
of the House Committee on Homeland Security and Congressman Edward 
Markey. 

We conducted our work 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. 

Summary: 

TSA has taken actions to strengthen the security of air cargo, but may 
face four major challenges as it proceeds with its plans to implement a 
system to screen 100 percent of cargo transported on passenger aircraft 
by August 2010.[Footnote 4] These challenges are: (1) deploying 
effective technologies to screen and secure air cargo; (2) determining 
whether to revise, maintain or eliminate existing TSA air cargo 
screening exemptions; (3) allocating compliance inspection resources to 
oversee CCSP participants; and (4) securing inbound cargo.[Footnote 5] 
First, TSA has identified some technologies that the agency plans to 
allow certified facilities to use for screening and securing cargo, but 
has not yet completed assessments of these technologies. As a result, 
TSA cannot be assured that the technologies it plans to approve for use 
as part of the CCSP can effectively screen cargo. In addition, the air 
cargo industry has expressed concern regarding the costs associated 
with purchasing the screening equipment under the CCSP. Second, 
although TSA has taken steps to eliminate the majority of exempted 
domestic and outbound cargo that it has not required to be screened, 
the agency currently plans to continue to exempt some types of domestic 
and outbound cargo from screening after August 2010.[Footnote 6] TSA 
determined whether to change its exemptions based on professional 
judgment and, to some extent, the results of air cargo vulnerability 
assessments. However, TSA has yet to complete its air cargo 
vulnerability assessments, which could help to identify other potential 
security vulnerabilities associated with the exemptions. In addition, 
while TSA has plans to complete its vulnerability assessments, the 
agency has not established a time frame for doing so. Third, the agency 
has also begun analyzing the results of air cargo compliance 
inspections and has hired additional compliance inspectors dedicated to 
air cargo. TSA officials reported, however, that the agency will need 
additional air cargo inspectors to oversee the efforts of the 
potentially thousands of entities that may participate in the CCSP once 
it is fully implemented. Finally, more work remains in order for TSA to 
strengthen the security of inbound cargo. Specifically, the agency has 
not yet finalized its strategy for securing inbound cargo or determined 
how, if at all, inbound cargo will be screened as part of its proposed 
CCSP. 

Background: 

Air cargo ranges in size from 1 pound to several tons, and in type from 
perishables to machinery, and can include items such as electronic 
equipment, automobile parts, clothing, medical supplies, other dry 
goods, fresh cut flowers, fresh seafood, fresh produce, tropical fish, 
and human remains. Cargo can be shipped in various forms, including 
large containers known as unit loading devices that allow many packages 
to be consolidated into one container that can be loaded onto an 
aircraft, wooden crates, assembled pallets, or individually wrapped/ 
boxed pieces, known as break bulk cargo. Participants in the air cargo 
shipping process include shippers, such as individuals and 
manufacturers; indirect air carriers, also referred to as freight 
forwarders; air cargo handling agents who process and load cargo onto 
aircraft on behalf of air carriers; and air carriers that store, load, 
and transport cargo. A shipper may also send freight by directly 
packaging and delivering it to an air carrier's ticket counter or 
sorting center where either the air carrier or a cargo handling agent 
will sort and load cargo onto the aircraft. 

According to TSA's Air Cargo Strategic Plan, issued in November 2003, 
the agency's mission for the air cargo program is to secure the air 
cargo transportation system while not unduly impeding the flow of 
commerce. TSA's responsibilities for securing air cargo include, among 
other things, establishing security requirements governing domestic and 
foreign passenger air carriers that transport cargo, and domestic 
freight forwarders.[Footnote 7] TSA is also responsible for overseeing 
the implementation of air cargo security requirements by air carriers 
and freight forwarders through compliance inspections, and, in 
coordination with the Department of Homeland Security's (DHS) Science 
and Technology (S&T) Directorate, for conducting research and 
development of air cargo security technologies. Air carriers are 
responsible for implementing TSA security requirements, predominantly 
through a TSA-approved security program that describes the security 
policies, procedures, and systems the air carrier will implement and 
maintain to comply with TSA security requirements. These requirements 
include measures related to the acceptance, handling, and screening of 
cargo; training of employees in security and cargo screening 
procedures; testing employee proficiency in cargo screening; and access 
to cargo areas and aircraft. If threat information or events indicate 
that additional security measures are needed to secure the aviation 
sector, TSA may issue revised or new security requirements in the form 
of security directives or emergency amendments applicable to domestic 
or foreign air carriers. Air carriers must implement the requirements 
set forth in the security directives or emergency amendments in 
addition to those requirements already imposed and enforced by TSA. 

DHS's U.S. Customs and Border Protection (CBP) has primary 
responsibility for preventing terrorists and implements of terrorism 
from entering the United States. Specifically, CBP screens inbound air 
cargo upon its arrival in the United States to ensure that cargo 
entering the country complies with applicable laws and does not pose a 
security risk. CBP's efforts include analyzing information on cargo 
shipments to identify high-risk cargo arriving in the United States 
that may contain terrorists or weapons of mass destruction, commonly 
known as targeting, and physically screening this cargo upon its 
arrival.[Footnote 8] 

Air carriers use several methods and technologies to screen cargo. 
These currently include manual physical searches and the use of 
approved technology, such as X-ray systems; explosives trace detection 
systems; decompression chambers; explosive detection systems (EDS); and 
certified explosives detection canine teams.[Footnote 9] Under TSA's 
security requirements for domestic and inbound cargo, passenger air 
carriers are currently required to randomly screen a specific 
percentage of nonexempt cargo pieces listed on each airway bill. As of 
October 2006, domestic freight forwarders are also required, under 
certain conditions, to screen a certain percentage of cargo prior to 
its consolidation. TSA does not regulate foreign freight forwarders, or 
individuals or businesses that have their cargo shipped by air to the 
United States. 

DHS Is in the Early Stages of Testing Technologies to Screen and Secure 
Air Cargo: 

DHS has taken some steps to develop and test technologies for screening 
and securing air cargo, but has not yet completed assessments of the 
technologies TSA plans to approve for use as part of the CCSP. 
According to TSA officials, there is no single technology capable of 
efficiently and effectively screening all types of air cargo for the 
full range of potential terrorist threats, including explosives and 
weapons of mass destruction. We reported in October 2005, and again in 
April 2007, that TSA, working with DHS's S&T Directorate, was 
developing and pilot testing a number of technologies to screen and 
secure air cargo with minimal impact on the flow of commerce. DHS 
officials stated that once the department determines which technologies 
it will approve for use with domestic air cargo, it will consider the 
use of these technologies for enhancing the security of inbound cargo 
shipments. These pilot programs seek to enhance the security of cargo 
by improving the effectiveness of air cargo screening through increased 
detection rates and reduced false alarm rates, while addressing the two 
primary threats to air cargo identified by TSA--hijackers on an all- 
cargo aircraft and explosives on passenger aircraft. A description of 
these pilot programs and their status is included in table 1. 

Table 1: TSA and S&T's Pilot Programs to Test Technologies to Screen 
and Secure Air Cargo with Minimal Impact on the Flow of Commerce: 

Pilot program: Air cargo explosives detection pilot program; 
Description: Tests the use of explosive detections systems, explosives 
trace detectors, standard X-ray machines, canine teams, technologies 
that can locate a stowaway through detection of a heartbeat or 
increased carbon dioxide levels in cargo, and manual screening of air 
cargo; 
Status: Consistent with the Conference Report accompanying the 
Department of Homeland Security Appropriations Act, 2006, DHS's S&T is 
reporting on the initial results of the pilots every 6 months after 
initiation of the first pilot.[A] DHS last submitted a report dated 
June 2007, and the latest update is currently undergoing DHS executive 
review. In July 2008, TSA officials provided an update that this pilot 
is complete and that its final report to Congress is due July 2008. 

Pilot program: Explosive detection system (EDS); 
Description: Tests the use of computer-aided tomography to compare the 
densities of objects to locate explosives in air cargo and to determine 
the long-term feasibility of using EDS equipment as a total screening 
process for break bulk air cargo; 
Status: TSA planned to complete this pilot program in May 2008. In July 
2008, TSA officials provided an update that the pilot will be completed 
by the end of 2008. 

Pilot program: Air cargo security seals; 
Description: Explores the viability of potential security 
countermeasures, such as tamper-evident security seals, for use with 
certain classifications of exempt cargo; 
Status: Contract was awarded in June 2007 and TSA planned to start 
evaluating various seals in the spring of 2008. However, in July 2008, 
TSA officials provided an update that the agency is not conducting a 
pilot program in this area. 

Pilot program: Hardened unit loading devices; 
Description: Tests the use of containers made of blast-resistant 
materials that could withstand an explosion onboard an aircraft; 
Status: TSA is finalizing its pilot program to evaluate hardened unit 
loading devices. In July 2008, TSA officials provided an update that 
this pilot will be completed by the end of August 2008. 

Pilot program: Pulsed fast neuron analysis (PFNA); 
Description: Identifies the chemical signatures of contraband, 
explosives and other threat objects; 
Status: In the research and development phase. However, in July 2008, 
TSA officials provided an update that the agency does not plan to 
conduct a pilot program in this area. 

Source: GAO analysis of information provided by TSA. 

[A] H.R. Conf. Rep. No. 109-241, at 53 (2005) (accompanying Pub. L. No. 
109-90, 119 Stat. 2064 (2005)). 

[End of table] 

Although TSA is moving forward with its plans to implement a system to 
screen 100 percent of cargo transported on passenger aircraft, the 
agency has not completed all of its assessments of air cargo screening 
technologies. According to TSA officials, the results of its technology 
tests will need to be analyzed before the agency determines which 
technologies will be certified for screening cargo, and whether it will 
require air carriers and other CCSP participants to use such 
technology. Although TSA has not completed all of its pilot programs or 
set time frames for completing all of them, TSA is planning on allowing 
CCSFs to use explosives trace detection, explosive detection system 
(EDS), X-ray, and other technology under CCSP for screening cargo. 
Without all of the results of its pilot programs or a time frame for 
their completion, however, TSA cannot be assured that the technologies 
the agency plans to approve for screening cargo as part of the CCSP are 
effective. GAO will likely review this issue as part of our planned 
review of TSA's efforts to meet the requirement to screen 100 percent 
of cargo transported on passenger aircraft. 

According to TSA officials, tamper-evident/resistant security seals 
will be essential for ensuring that cargo screened under the CCSP has 
not been tampered with during transport from the CCSF to the air 
carrier. Officials noted that the agency recognizes that the weakest 
link in the transportation of air cargo is the chain of custody to and 
from the various entities that handle and screen cargo shipments prior 
to its loading onto an aircraft. Officials stated that the agency has 
taken steps to analyze the chain of custody of cargo under the CCSP, 
and is drafting a security program that will address all entities 
involved in the transportation and screening of cargo under the CCSP to 
ensure that the chain of custody of the cargo is secure. However, as of 
July 2008, TSA officials stated that the agency is not conducting a 
pilot program to test tamper-evident/resistant security seals. 
Therefore, the effectiveness of security seals to effectively prevent 
cargo shipments from tampering is unknown. GAO will likely review this 
issue as part of our planned review of TSA's efforts to meet the 
requirement to screen 100 percent of cargo transported on passenger 
aircraft. 

In addition, we reported in April 2007 that several air carriers we met 
with were using large X-ray machines at facilities abroad to screen 
entire pallets of cargo transported on passenger aircraft. These 
machines allow for cargo on pallets to undergo X-ray screening without 
requiring the pallet to be broken down.[Footnote 10] We also noted that 
CBP uses this technology to screen inbound air cargo once it enters the 
United States. TSA officials recently stated that the agency planned to 
pilot test large X-ray machines, identifying that large X-ray machines 
could be used to screen certain types of cargo that are currently 
exempt from TSA's screening requirements, as part of the agency's 
efforts to screen 100 percent of cargo transported on passenger 
aircraft. TSA officials stated that the agency plans to evaluate this 
equipment beginning late 2008 as part of its CCSP pilot program and to 
complete the evaluation at the conclusion of the CCSP pilot in August 
2010. 

In addition, as part of the agency's plans to screen 100 percent of 
cargo transported on passenger aircraft, TSA is taking steps to expand 
the use of TSA-certified explosives detection canine teams to screen 
cargo before it is placed onto passenger aircraft. In 2004, TSA 
conducted a pilot program that determined that canine teams had an 
acceptable rate of detecting explosives in an air cargo environment, 
even when the teams were not specifically trained in this area. TSA is 
in the process of adding 170 canine teams to support aviation security 
efforts, of which 85 will be primarily used to screen air cargo. 
[Footnote 11] These teams are to be primarily located at the 20 
airports that receive approximately 65 percent of all air cargo 
transported within the United States. TSA officials, however, could not 
identify whether the additional 85 canine teams will meet the agency's 
increasing screening needs as part of its efforts to screen 100 percent 
of such cargo, thus raising questions regarding the future success of 
the CCSP. 

According to TSA officials, the federal government and the air cargo 
industry face several challenges that must be overcome to effectively 
implement any of these technologies to screen or secure cargo. These 
challenges include factors such as the nature, type and size of cargo 
to be screened; environmental and climatic conditions that could impact 
the functionality of screening equipment; low screening throughput 
rates; staffing and training issues for individuals who screen cargo; 
the location of air cargo facilities; employee health and safety 
concerns, such as worker exposure to radiation; and the cost and 
availability of screening technologies. As TSA takes steps to implement 
the CCSP, it will be critical for the agency to address these 
challenges to ensure the effectiveness of the program. 

As TSA proceeds from piloting to implementing the CCSP, the issue of 
who purchases the technologies to support the program will have to be 
resolved. Specifically, TSA officials stated that under the CCSP, 
certified facilities and air carriers will be responsible for 
purchasing equipment to screen cargo. Officials noted that many air 
carriers already have screening equipment in place at their facilities 
to support this screening, and stated that TSA will reimburse CCSFs for 
the cost of the equipment, such as EDS, for up to $375,000 per facility 
as long as these entities continue to meet security requirements 
established by TSA. The CCSF, however, will be responsible for 
maintaining the screening equipment and purchasing new equipment in the 
future. In addition, CCSFs will be required to train their staff to 
operate the equipment using TSA's training standards. Air cargo 
industry stakeholders have already raised concerns regarding the cost 
of purchasing and maintaining screening equipment to support the CCSP. 
According to some industry estimates, the cost of purchasing air cargo 
screening equipment will be much more than the $375,000 TSA plans to 
reimburse each CCSP participant. In addition, the air cargo industry 
has expressed concern regarding the costs associated with training 
those individuals who will be operating the air cargo screening 
equipment. 

TSA Plans to Revise and Eliminate Screening Exemptions for Some 
Categories of Air Cargo, but Has Not Completed Air Cargo Vulnerability 
Assessments to Inform Its Efforts: 

TSA plans to revise and eliminate current exemptions for some 
categories of cargo, thereby reducing the percentage of cargo 
transported on passenger aircraft that is subject to alternative 
methods of screening.[Footnote 12] These changes will go into effect in 
early 2009. However, according to agency officials, TSA made these 
determinations based on a limited number of vulnerability assessments, 
as well as professional judgment.[Footnote 13] In February 2008, TSA 
issued a report assessing existing screening exemptions for certain 
kinds of cargo transported on passenger aircraft and evaluated the risk 
of maintaining those exemptions. As part of its assessment, TSA 
officials stated that they considered and determined the threat to and 
vulnerability of the exempted cargo types. TSA officials also stated 
they based their determinations on which screening exemptions to 
revise, maintain or eliminate in part on results from air cargo 
vulnerability assessments at Category X airports they completed in 
accordance with law.[Footnote 14] TSA has completed assessments at 6 of 
the 27 Category X airports. Absent the completed assessments, which 
could help to identify potential security vulnerabilities associated 
with the exemptions, TSA does not have complete information with which 
to make risk-based decisions regarding the security of air cargo. TSA 
officials have acknowledged the importance of completing air cargo 
vulnerability assessments and stated that they will complete them by 
the end of 2009. Officials further stated that as the agency conducts 
additional air cargo vulnerability assessments, they will assess the 
results to determine whether existing screening exemptions should be 
revised, maintained or eliminated. 

TSA Has Taken Actions to Strengthen Air Cargo Compliance Inspections, 
but More Resources May Be Needed to Ensure CCSP Participants Are 
Meeting TSA Screening Requirements: 

To ensure that existing air cargo security requirements are being 
implemented as required, TSA inspects air carriers and freight 
forwarders that transport cargo. Under the CCSP, TSA will also have to 
inspect other entities, such as shippers, who volunteer to participate 
in the program. These compliance inspections range from an annual 
comprehensive review of the implementation of all air cargo security 
requirements to a more frequent review of at least one security 
requirement by an air carrier or freight forwarder. In October 2005, we 
reported that TSA had conducted compliance inspections on less than 
half (49 percent) of the estimated 10,000 freight forwarder facilities 
nationwide, and of those freight forwarders they had inspected, the 
agency found violations in over 40 percent of them. We also reported 
that TSA had not determined what constitutes an acceptable level of 
performance related to compliance inspections, or compared air 
carriers' and freight forwarders' performance against this standard; 
analyzed the results of inspections to systematically target future 
inspections on those entities that pose a higher security risk to the 
domestic air cargo system; or assessed the effectiveness of its 
enforcement actions taken against air carriers and freight forwarders 
to ensure that they are complying with air cargo security requirements. 
We recommended that TSA develop a plan for systematically analyzing and 
using the results of air cargo compliance inspections to target future 
inspections and identify systemwide corrective actions. We also 
recommended that TSA assess the effectiveness of enforcement actions in 
ensuring air carrier and freight forwarder compliance with air cargo 
security requirements. TSA officials stated that, since our report was 
issued, the agency has increased the number of inspectors dedicated to 
conducting domestic air cargo compliance inspections. Officials also 
told us that TSA has begun analyzing compliance inspection results to 
prioritize their inspections on those entities that have the highest 
rates of noncompliance, as well as newly approved freight forwarders 
and air carriers that have yet to be inspected. However, in recent 
discussions with TSA officials regarding their plans to implement the 
CCSP, they stated that there may not be enough compliance inspectors to 
conduct compliance inspections of all the entities that could be a part 
of the CCSP, which TSA officials told us could number in the thousands, 
once the program is fully implemented by August 2010. As a result, TSA 
is anticipating requesting an additional 150 cargo Transportation 
Security Inspectors for fiscal year 2010 to supplement its existing 
allocation of 450 Transportation Security Inspectors. However, TSA 
officials stated that they have not formally assessed the number of 
Transportation Security Inspectors the agency will need. Without such 
an assessment, TSA may not be able to ensure that entities involved in 
the CCSP are meeting TSA requirements to screen and secure cargo. GAO 
will likely review this issue as part of our planned review of TSA's 
efforts to meet the requirement to screen 100 percent of cargo 
transported on passenger aircraft. 

TSA Has Not Identified a Strategy for Securing Inbound Air Cargo: 

We reported in April 2007 that more work remains in order for TSA to 
strengthen the security of inbound cargo. As previously stated, TSA is 
currently taking steps to develop a system of screening 100 percent of 
domestic and outbound cargo transported on passenger aircraft. TSA does 
not, however, currently plan to include inbound cargo as part of this 
system. TSA officials acknowledge that vulnerabilities to inbound cargo 
exist, but stated that each foreign country has its own security 
procedures for flights coming into the United States, and further 
stated that TSA does not impose its security requirements on foreign 
countries. According to TSA, it will continue to work with other 
countries to encourage the adoption of uniform measures for screening 
cargo flights bound for the United States as it enhances its 
requirements for screening cargo originating in the United States. TSA 
has begun working with foreign governments to develop uniform air cargo 
security standards and to mutually recognize each other's security 
standards, referred to as harmonization. We reported, however, that 
duplicative air cargo security standards exist, which can impede the 
flow of commerce, expose air cargo shipments to security risk, and 
damage high-value items. For example, to meet TSA requirements, 
passenger air carriers transporting cargo into the United States must 
screen a certain percentage of nonexempt cargo shipments, even though 
these shipments may have already been screened by a foreign government. 
Air carrier representatives stated that meeting TSA screening 
requirements is problematic in certain foreign countries because air 
carriers are not permitted to rescreen cargo shipments that have 
already been screened by foreign government employees and deemed 
secure. These conflicts and duplication of effort could potentially be 
avoided through harmonization. 

According to TSA officials, pursuing harmonization would improve the 
security of inbound cargo and assist TSA in performing its mission. For 
example, officials stated that the harmonization of air cargo security 
standards would provide a level of security to those entities not 
currently regulated by the agency, such as foreign freight forwarders 
and shippers. However, achieving harmonization with foreign governments 
may be challenging because these efforts are voluntary and some foreign 
countries do not share the United States' view regarding air cargo 
security threats and risks. Additionally, foreign countries may lack 
the resources or infrastructure needed to develop an air cargo security 
program as comprehensive as that of the United States. In April 2007, 
we recommended that TSA, in collaboration with foreign governments and 
the United States air cargo industry, systematically compile and 
analyze information on air cargo security practices used abroad to 
identify those that may strengthen TSA's overall air cargo security 
program. TSA agreed with this recommendation and, since the issuance of 
our report, has reviewed the air cargo screening models of two foreign 
countries. According to TSA officials, this review led to the design of 
their proposed CCSP. 

Opportunities exist for TSA to further strengthen its screening efforts 
for inbound cargo in the following three key areas: 

Conducting air cargo vulnerability assessments for inbound cargo. As 
noted earlier, TSA is currently conducting air cargo vulnerability 
assessments at Category X airports, but is not including inbound cargo 
in these assessments. While TSA has plans to conduct vulnerability 
assessments as part of its risk-based approach to securing inbound 
cargo, the agency has not established a time frame for doing so. Such 
assessments could provide information on the potential vulnerabilities 
posed by the transport of inbound cargo. We reported in April 2007 that 
TSA officials stated that they would conduct vulnerability assessments 
of inbound cargo after they had assessed the vulnerability of domestic 
cargo. Nevertheless, TSA officials acknowledged that vulnerabilities to 
inbound cargo exist and that these vulnerabilities are in some cases 
similar to those facing the domestic and outbound air cargo supply 
chain. 

Assessing the vulnerability posed by maintaining screening exemptions 
for inbound air cargo. TSA has not assessed the potential 
vulnerabilities posed by inbound air cargo screening exemptions. In 
April 2007, we reported on the potential vulnerabilities associated 
with inbound air cargo screening exemptions. Specifically, we reported 
that screening exemptions could pose a risk to the inbound air cargo 
supply chain because TSA has limited information on the background of 
and security risks posed by foreign freight forwarders and shippers 
whose cargo may fall into one of the exemption categories. We 
recommended that TSA assess whether existing inbound air cargo 
screening exemptions pose an unacceptable vulnerability to the air 
cargo supply chain and if necessary, address these vulnerabilities. TSA 
agreed with this recommendation and noted that the agency had recently 
revised and eliminated domestic and outbound air cargo screening 
exemptions. However, TSA has yet to address our recommendation for 
assessing inbound air cargo screening exemptions. 

Updating TSA's Air Cargo Strategic Plan to address inbound cargo. As 
part of TSA's risk-based approach, TSA issued an Air Cargo Strategic 
Plan in November 2003 that focused on securing the domestic air cargo 
supply chain. However, in April 2007, we reported that this plan did 
not include goals and objectives for securing inbound cargo, which 
presents different security challenges than cargo transported 
domestically. To ensure that a comprehensive strategy for securing 
inbound cargo exists, we recommended that DHS develop a risk-based 
strategy to address inbound cargo security that should define TSA's and 
CBP's responsibilities for ensuring the security of inbound cargo. In 
response to our recommendation, CBP issued its International Air Cargo 
Security Strategic Plan in June 2007. While this plan identifies how 
CBP will partner with TSA, it does not specifically address TSA's 
responsibilities in securing inbound cargo. According to TSA officials, 
the agency plans to revise its Air Cargo Strategic Plan in the fall of 
2008, and will address TSA's strategy for securing cargo from 
international last points of departure, as well as its collaborative 
efforts with CBP to secure this cargo. 

Ms. Chairwoman, this concludes my statement. I would be pleased to 
answer any questions that you or other members of the subcommittee may 
have at this time. 

GAO Contact and Staff Acknowledgments: 

For further information on this testimony, please contact Cathleen 
Berrick at (202) 512-3404 or at [email protected]. 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 include Steve D. 
Morris, Assistant Director; Lara Kaskie; Tom Lombardi; Meg Ullengren; 
and Margaret Vo. 

[End of section] 

Footnotes: 

[1] See Pub. L. No. 110-53, ï¿½ 1602, 121 Stat. 266, 477-80 (2007) 
(codified at 49 U.S.C. ï¿½ 44901(g) (mandating the screening of all cargo 
transported on passenger aircraft and defining "screening" for purposes 
of satisfying the mandate)). 

[2] A freight forwarder consolidates cargo from many shippers and takes 
it to air carriers for transport. 

[3] See Pub. L. No. 110-53, ï¿½ 1602(b), 121 Stat. 266, 479-80 (2007). 

[4] "Screening" as defined by the Implementing Recommendations of the 
9/11 Commission Act of 2007 means a physical examination or 
nonintrusive methods of assessing whether cargo poses a threat to 
transportation security. See 49 U.S.C. ï¿½ 44901(g)(5). Such methods of 
screening include X-ray systems, explosives detection systems (EDS), 
explosives trace detection, explosives detection canine teams certified 
by TSA, or a physical search together with manifest verification. While 
additional methods may be approved to ensure that cargo does not pose a 
threat to transportation security, these additional methods cannot 
include solely performing a review of information about the contents of 
cargo or verifying the identity of a shipper of the cargo if not 
performed in conjunction with other authorized security methods, 
including whether a shipper is registered in the known shipper 
database. 

[5] Inbound air cargo is cargo that is transported into the United 
States from abroad by either U.S. or foreign-operated air carriers. 

[6] Cargo transported by air within the United States is referred to as 
domestic air cargo, and cargo transported by air from the United States 
to a foreign location is referred to as outbound air cargo. 

[7] TSA also establishes security requirements for domestic and foreign 
all-cargo carriers that transport cargo to, from, and within the United 
States. 

[8] For the purpose of the statement, the term "targeting" refers to 
the use of information obtained from the screening process to identify 
high-risk air cargo shipments for inspection. 

[9] Explosives Trace Detection requires human operators to collect 
samples of items to be screened with swabs, which are chemically 
analyzed to identify any traces of explosive material. Decompression 
chambers simulate the pressures acting on an aircraft by simulating 
flight conditions, which cause explosives that are attached to 
barometric fuses to detonate. An explosive detection system uses 
computer-aided tomography X-rays to examine objects inside baggage and 
identify the characteristic signatures of threat explosives. Certified 
explosives detection canine teams have been evaluated by TSA and shown 
to effectively detect explosive devices. 

[10] GAO, Aviation Security: Federal Efforts to Secure U.S.-Bound Air 
Cargo Are in the Early Stages and Could Be Strengthened, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-07-660] (Washington, D.C.: April 
2007). 

[11] There are currently 370 TSA-certified explosives detection canine 
teams that are cross-trained to work in multiple aviation environments, 
including air cargo. 

[12] For certain types of cargo, TSA has authorized the use of TSA- 
approved alternative methods for screening cargo transported on 
passenger aircraft. Alternative methods can include verifying shipper 
information and conducting a visual inspection of the cargo shipment. 

[13] TSA officials made these statements during our review of TSA's 
report on its air cargo screening exemptions. We completed this review 
in July 2008 and the results have yet to be publicly issued. 

[14] See Pub. L. No. 110-28, 121 Stat. 112, 140-41 (2007) (providing 
that the $80 million appropriated for air cargo shall be used to 
complete air cargo vulnerability assessments for all Category X 
airports, among other purposes). TSA classifies the commercial airports 
in the United States into one of five security risk categories (X, I, 
II, III, and IV). In general, category X airports have the largest 
number of passenger boardings, and category IV airports have the 
smallest. Categories X, I, II, and III airports account for more than 
90 percent of the nation's air traffic. 

[End of section] 

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