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The Impact of Implementing Recommendations of the
9/11 Commission Act of 2007 on US-based Shippers
TSA CCSP Presentation to Shipper Associations
May 20, 2009
NOTIONAL – FOR DISCUSSION PURPOSES ONLY
Table of Contents
Overview & Impact of the “9/11 Act”
TSA Approach to Assist Industry in Attaining Screening Mandates
Attaining 50 & 100% Issues and Challenges
Opportunities for Shippers
Links to TSA
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Overview & Impact of the “9/11 Act”
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100% Screening Legislation
Background
President Bush approved legislation Implementing Recommendations of the 9/11
Commission Act of 2007 on August 3, 2007.
The legislation mandates 100% screening by
August 2010 and requires TSA to:
Establish a system to screen 100% of cargo
transported on passenger aircraft.
Provide a level of security commensurate to that
of passenger baggage (piece level).
No funding provided.
Industry expected to bear all costs.
Congressionally Mandated Cargo Screening Benchmarks
9/11 Act
50%
100%
August 2007
February 2009
August 2010
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Piece Level Screening
Piece level cargo is the individual item within a shipment. The number of pieces is determined
by the number of pieces identified by the shipper-level documentation.
As of February 1, 2009, 50% of all cargo must be screened at the piece level prior to being
loaded on a passenger aircraft.
By August 3, 2010, cargo must be 100% screened at the piece level.
In 2007, over 15 million lbs/day transported on passenger aircraft.
As of 2007, all screening was performed (allowed) only by airlines.
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Screening Technology Tools
TSA Approved Screening Methods (from 9/11 Act)
Physical search (Includes opening boxes, removing and opening all inner cartons)
AT X-ray*
Explosives Trace Detection (ETD)* 1
Explosives Detection System (EDS)*
TSA operated canines
Any other detection equipment accepted in the future by TSA
(1) Equipment of choice (lowest cost technology).
* All technologies must be on the current TSA Screening Technology List which is made available to screening
participants.
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Impact on Air Cargo
Over 65% of all cargo on passenger aircraft is uplifted from 18 major gateways (wide body
aircraft cities).
Most of this is export.
SEA
BOS
DTW
ORD
JFK
EWR
PHL
SFO
IAD
DEN
LAX
ATL
DFW
IAH
HNL
MCO
MIA
Wide body aircraft (B-777, 747, 767, etc.) carry 94% of “passenger aircraft” cargo
from these cities.
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SJU
Challenges for Industry
Most “wide-body” cargo is tendered in skids
(larger shipments).
Most wide-body cargo flows through freight
forwarders (consolidators).
Freight forwarders typically
“containerize/palletize” cargo prior to
tendering to airlines.
If “airlines only” must screen all cargo, they
anticipate significant delays, increased
processing/cut-off times, costs.
Airlines lack space/facilities to “de-palletize”,
screen, and re-configure these shipments.
Potential exists for damage to
packaging/goods.
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TSA Approach to Assist Industry in Attaining
Screening Mandates
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TSA Approach to Assist Industry in Attaining Screening
Mandates
1. Certified Cargo Screening Program
•
Forwarders and shippers
2. Narrow Body Screening
•
Airlines
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TSA Approach to Assist Industry in Attaining Screening
Mandates
Certified Cargo Screening Program created to:
Allow screening of cargo early in the air cargo supply chain by a trusted, vetted,
and audited facility.
Initiate and maintain the integrity of a shipment throughout the supply chain by
utilizing stringent chain of custody methods.
Enable entities such as shippers to incorporate physical screening into packing
process.
Participation in CCSP is voluntary, but requires participant to:
Implement and adhere to facility security standards and access controls.
Train employees and authorized representatives on CCSP and security responsibilities.
Get Security Threat Assessments (STAs) for employees involved in screening.
Screen cargo in accordance with TSA screening standards and processes.
Initiate and maintain chain of custody on all screened cargo.
Permit onsite facility assessments by TSA-Approved Validation firm or PCSA.
Adhere to all program requirements, subject to TSA inspections, after certification.
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Who can become a Certified Cargo Screening Facility?
The CCSP is a facility based program. Facilities screening under the CCSP will be known
as Certified Cargo Screening Facilities (CCSFs).
Shipping
Facilities
Third Party
Logistics Providers
Manufacturing
Facilities
Warehouses/
Distribution
Centers
Contract
Manufacturers
Freight Forwarding
Facilities
Any entity with the desire to screen cargo must have a facility that can be secured.
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TSA Approach (cont.)
Narrow Body Screening
Required airlines to screen 100% of cargo on narrow body aircraft
October 2008.
Primarily small “express” shipments.
No “skids” fit into narrow body aircraft.
No further impact to shippers is anticipated.
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CCSP Applications Received/Certifications thru May, 2009
Applications received as of May 2009:
– 1,124+ CCSF applications have been received.
Certification as of May 20, 2009:
– 350 facilities have been certified (90% are freight forwarders).
Application momentum has fallen off since “50% attained”:
– From existing applicants.
– Few new applicants.
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Attaining 50 & 100% Issues and Challenges
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Reaching 50% (Feb 1, 2009)
50% milestone was “seemingly easy” for shipping community, but:
Economic downturn caused over 35% drop in volume of cargo.
Airlines invested significantly in additional technology (primarily ETD).
CCSF (Certified) Freight Forwarders handled some cargo screening on behalf of shippers
(a new program).
TSA provided Air Carriers and IACs with flexibility when determining what to screen at
50%.
- Narrow body shipments helped the equation.
Certain commodities were excluded for a limited time frame (until August 31st, 2009).
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Industry Challenges for 100% (Aug 1, 2010)
The 100% cargo screening deadline is rapidly approaching.
All commodities will require screening, at the piece level, prior to transport.
Alternate Means of screening of certain commodities will be eliminated September 1, 2009.
Most air cargo is still tendered on skids/shrink wrap/banded.
Limited screening technology available
to meet industry’s need (manufacturing backlogs).
• 85% of entities utilize ETD as their primary method of screening.
• Alarm resolution for ETD (other than physical search) is challenging.
• High risk of physical inspection resolution as a result of “contamination” while in forwarder or airline
vehicles/docks.
- Recent example:
- A shipment of venetian blinds was screened by canine and ETD, both recognized alarm.
Resolved by physical inspection and found to be clean.
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Industry Issues
Through extensive interaction with Industry, we have gained insight into some key
issues specific to various industries:
Hi Tech: Some products are sensitive to static discharge.
Perishables: Delay in screening may damage or spoil
goods. Goods may also require refrigeration.
Pharmaceuticals: Many products must be kept refrigerated.
Others are FDA sealed and cannot be opened without
damaging content.
Museums & Galleries: Fine art is fragile, priceless, and
unique; requiring very specific screening processes and
procedures.
Most shippers do not want to risk the possibility of having
their shipments opened for physical resolution of any “false
alarm” issues (contamination).
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TSA Concerns toward 100%
Waning CCSF application flow from shipper community.
Perception that reaching 50% was easy, thus a similar result at 100%.
The hardest part still lies ahead.
Difficult, complex cargo remains.
Most of the shipments screened today are not skidded.
Airport/airline space limitations inhibit ability to break apart, screen, re-skid, etc.
Time constraints – carriers indicate they will require significantly earlier cutoff times.
Risk of delay or damage.
Economic recovery leading to increase in cargo volume.
Screening 100% of 15 million lbs in 2010 vs. 50% of only 9 million lbs in February
2009. This represents a 300% +/- increase in the amount of cargo to be screened!!
Commodities with unique screening needs.
Insufficient availability of technology to meet industry demand (backlogs).
High risk of physical inspection due to potential contamination in transit to carriers.
Maintain integrity of shipper skids.
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Opportunities for Shippers
NOTIONAL – FOR DISCUSSION PURPOSES ONLY
TSA “Stimulus” for Shippers
Early Participation
Future Participation
Extended period of time (90 days) to review
regulatory documents before committing.
Limited time allowed to review regulatory
documentation before required decision.
Free onsite facility assessments by TSA.
TSA-Approved Validation Firms will perform
facility assessment for a fee.
Free Security Threat Assessments for up to
200 individuals per facility.
STA submission for a fee (currently approx.
$28).
Free TSA consultation services – site visits,
examples and templates, step-by-step
guidance through certification.
May need consultant support?
Deferred screening start date option.
Required to commence screening and attain
100% within 90 days of certification.
- Shipper will have an extended period
of time to attain 100% screening level postcertification.
Submit applications by August 1, 2009 to secure early participation benefits.
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Summary
50% was reached thanks to the hard work of Air Carriers and existing CCSFs Freight
Forwarders.
Reaching 100% requires larger community effort to overcome industry challenges and
TSA concerns.
CCSP is the solution for industry to meet the 100% screening mandate, and fully
supported by the air freight and air carrier industries.
Only CCSF shippers can ensure the integrity of their shipments.
Most shippers can readily incorporate “physical search” into packing/shipping process –
without investing in equipment.
TSA is providing an incentive for shippers to join CCSP.
The alternative – only cargo that is fully screened will be uplifted on August 1, 2010.
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Links to TSA
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For more information please visit
http://www.tsa.gov/what_we_do/tsnm/air_cargo/index.shtm
Follow link for more information on the Certified Cargo Screening Program
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