Q: What is the 100 percent screening requirement, and how will it affect the air cargo industry?
- On Aug. 3, 2007, President Bush signed into law the Implementing Recommendations of the 9/11 Commission Act of 2007 (9/11 Act) P.L. 110-53(2007). The 9/11 Act requires TSA to establish a system for industry to screen 100 percent of cargo transported on passenger aircraft in the United States at the piece-level, commensurate with passenger baggage. The legislation also set an interim milestone of 50 percent screening to be reached by February 2009. By August 2010, cargo not screened in accordance TSA-approved processes and procedures cannot be uplifted by a passenger aircraft in the United States.
Historically, this requirement would fall to the air carrier. However, we understand that there is simply not sufficient capacity or space to meet this requirement without carrier delays, cargo logjams, and increased transit times. Therefore, TSA has established a multi-dimensional strategy to reconcile the requirements of the mandate, the security needs of passengers, and the needs of a U.S. economy that relies on an air cargo industry.
Q: What is TSA’s strategy for industry to meet the 100 percent screening requirement?
- In response to the 100 percent screening mandate, TSA has established a multi-dimensional strategy to reconcile the requirements of the mandate, the security needs of passengers, and the needs of a U.S. economy that relies on an air cargo industry.
This multi-dimensional strategy employs a layered approach of vetting and screening activities to address cargo shipments, conveyances, facilities, and persons involved in the air cargo supply chain.
In addition to TSA’s existing security regime, we have established three programs to assist industry in meeting the 100 percent screening mandate:
- 100 Percent Narrow-Body Screening – 100 percent of cargo uplifted on narrow-body passenger aircraft (for example: B-737, B-757, and A-320 aircraft) is screened at 100 percent as of October 2008. This program accounts for 96 percent of passenger flights originating in the US and its territories.
- The Certified Cargo Screening Program (CCSP) – A voluntary program designed to enable certain vetted, validated, and certified facilities to screen cargo prior to delivering the cargo to the air carrier. As the air carriers do not have sufficient capacity to perform all cargo screening, this program enables increased supply chain flexibility for where cargo screening occurs.
- Indirect Air Carrier (IAC) Screening Technology Pilot – an initiative established to test screening technology in a live environment. Participants in this program are working directly with TSA to provide information and data on cargo, commodity-types, and a certain cargo screening technology. Information collected from this pilot will impact future TSA decisions.
Q: Has TSA made progress with International Harmonization?
- TSA is working closely with its foreign government counterparts to leverage existing air cargo security practices and to work towards comparability across systems to the greatest extent possible. TSA has been working in both bilateral and multilateral forums to better understand the air cargo security regimes currently in place in other countries in order to promote best practices while also enhancing air cargo security systems, where necessary, in order to ensure commensurate levels of security from system to system. This is an ongoing effort and will take considerable time to review and analyze the information, and to coordinate and collaborate with our partners and industry stakeholders in the development of mutually recognizable systems. TSA is hopeful that with the continued cooperation of our international partners, this work will promote uniformity and recognition between States.
Q: What is the Certified Cargo Screening Program?
- The Certified Cargo Screening Program (CCSP) is a voluntary program designed to assist industry in achieving the 100 percent screening requirement. The program was designed to enable TSA vetted, validated, and certified facilities to screen air cargo prior to delivering the cargo to the air carrier.
Facilities that successfully complete the TSA certification process, to include an onsite assessment of the facility, will be designated as a Certified Cargo Screening Facility (CCSF). CCSFs must adhere to TSA mandated security standards, including the employment of secure chain of custody methods to establish and maintain the security of screened cargo throughout the supply chain. TSA will only certify those facilities that demonstrate adherence to these requirements through the TSA certification process.
Participants in the CCSP are regulated under the Code of Federal Regulations (CFR) and TSA has full enforcement authority. By voluntarily applying to the program, applicants agree to an onsite assessment by a TSA-approved validation firm* and periodic inspections by TSA inspectors to ensure adherence to program requirements and standards. TSA’s options for enforcement of CCSP security standards range from counseling to civil penalties, as is currently in place with fully regulated parties such as an Indirect Air Carrier (IAC) or Air Carrier.
TSA’s efforts to harmonize activities with foreign partners will increase global air cargo security and reduce burdens on trade. TSA’s agreements with the European Commission signed on Sept. 30, 2008 and agreement with the quadrilateral (QUAD) Canada, Australia and European Union member states signed on Dec. 2, 2008, will facilitate the signatories’ seeking common and practical solutions to air cargo screening. This harmonization will contribute greatly to achieving the 100 percent screening requirement of the 9/11 Act.
If the CCSF is found to be in violation of any of the program requirements, TSA reserves the authority to revoke the facility’s certification.
*Note: During initial deployment of CCSP, the onsite facility assessment will be performed by a TSA Field Team staff. TSA expects that during full rollout, assessments will be performed by a TSA-approved validation firm.
Q: What are the benefits to participating in the CCSP?
- Facilities that have successfully been certified by TSA, Certified Cargo Screening Facilities (CCSFs) are able to perform piece-level cargo screening at the facility, prior to the cargo arriving at the air carrier.
Participation in the program will allow CCSFs to screen cargo and build bulk configurations that, unless subject to random and risk-based screening later in the supply chain, will not be broken down at the indirect air carrier or air carrier. This capability allows the air cargo supply chain greater flexibility and capacity to perform cargo screening, while mitigating the impact of piece-level screening on cargo flow and throughput.
As part of the certification process, applicants will be subject to a facility assessment performed by a TSA-approved Validation Firm. These firms are responsible for providing an assessment report to TSA on the manner and quality of the applicant’s adherence to CCSP security standards and requirements and the cost of the Validation Firms services are the responsibility of the applicant. During Phase One, this facility assessment will be performed by a TSA Transportation Security Inspector at no cost to the applicant.
Q: How can I join the CCSP as a Certified Cargo Screening Facility (CCSF)?
- Any facility that is a regulated party or which tenders cargo directly to a regulated party (air carrier or indirect air carrier) may apply to become a Certified Cargo Screening Facility (CCSF). This includes manufacturers, warehouses, distribution centers, third party logistics providers, indirect air carriers and ICSFs. Entities interested in participating in the program must submit an application for each facility to be considered, and submit to an onsite facility assessment prior to receiving TSA certification. Applications and/or requests for applications must be submitted directly to TSA (via CCSP@dhs.gov), and a TSA representative will respond.
Q: What is a facility assessment?
- Once a facility application is accepted by TSA, an onsite facility assessment will be performed by a TSA-Approved Validation Firm*. This assessment is required to confirm an applicant’s adherence to CCSP security standards and requirements. TSA will evaluate a facility’s application, supporting documentation, and the facility assessment performed by the Validator to make a determination of certification. TSA alone retains responsibility for all decisions regarding facility designations and certifications will be issued solely by TSA. TSA reserves the right to perform a secondary facility assessment prior to granting certification. If this occurs, a TSA representative will visit the facility at no cost to the applicant. The original facility assessment is performed at the cost of the individual applicant facility.
*Note: During initial deployment of CCSP, the onsite facility assessment will be performed by TSA Field Team staff. TSA expects that during full rollout, assessments will be performed by a TSA-approved validation firm.
Q: What is the IAC Screening Technology Pilot and how is it related to CCSP?
- The Indirect Air Carrier (IAC) Screening Technology Pilot is an initiative established to test screening technology in a live environment. Participants in this program are working directly with TSA to provide information and data on cargo, commodity-types, and a certain cargo screening technology. Information collected from this pilot will impact future TSA decisions. Pilot participants must also apply to the CCSP in order to become Certified Cargo Screening Facilities.
TSA has made a limited amount of funding available for the purchase and deployment of technology at higher volume facilities to ensure accurate testing and data collection of screening technology capabilities.
Q: What are the chain of custody requirements for certified cargo?
- Certified Cargo Screening Facilities (CCSFs) are required to follow specific procedures when tendering screened cargo to an IAC or air carrier. Chain of custody standards must be applied, documented, and authenticated from the point of screening through to the point where the cargo is loaded onto a passenger aircraft. Acceptable chain of custody methods fall into two categories, procedures and technology and include; vehicle escorts, tamper-evident technologies (e.g. seals, tapes, labels), GPS tracking, or other methods. Additionally CCSF cargo must be tendered with a certification identifying this cargo as screened and coming from a CCSF.
The Certified Cargo Screening Facility (CCSF) is responsible for screened cargo until the cargo is tendered to, and accepted by, a currently regulated Indirect Air Carrier (IAC) or Air Carrier.
Q: Will TSA recognize a company with C-TPAT certification as a Certified Cargo Screening Facility?
- TSA will not recognize C-TPAT certification as an alternative to completing the application, facility assessment, and certification process for the Certified Cargo Screening Program (CCSP).
The CCSP is a facility-level, not a company, certification; and requires that each and every facility be subject to a facility assessment prior to receiving any program benefits. The CCSF designation enables a facility to screen cargo using TSA-approved screening methods and technology. TSA recognizes that C-TPAT-compliant companies may already have many of the security measures required under CCSP, and those entities are encouraged to seriously consider participation in this program. However, all CCSP applicants are required to submit an application and submit to a facility assessment as part of the certification process.
Q: What is the difference between the Known Shipper Program and the Certified Cargo Screening Program?
- The Known Shipper Program is an initiative to positively identify valid businesses in the United States. Only shippers who are “known” can ship cargo on passenger aircraft.
The Certified Cargo Screening Program designates facilities that can screen known shipper cargo prior to the cargo being loaded onto a passenger aircraft.
Q: What does it mean to become a “regulated” entity?
- A regulated entity is an individual, facility, business, or industry that is subject to the rule and regulation published in the Code of Federal Regulations (http://www.gpoaccess.gov/CFR). The Code of Federal Regulations (CFR) is the codification of the general and permanent rules and published in the Federal Register by the executive departments and agencies of the Federal Government. TSA has published an interim final rule (IFR) associated with the 100 percent screening mandate which includes provisions to the various components of CCSP. This rule, once final, will be incorporated into the CFR.
TSA regulatory authority extends only to those areas that are related or relevant to an entities participation in CCSP. If an entity is found to be non-compliant, TSA will work with your facility to meet the standards in a progressive enforcement manner, ensuring the proper security methods are in place.