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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. EDT:
Wednesday, June 30, 2010:

Aviation Security:

Progress Made but Actions Needed to Address Challenges in Meeting the 
Air Cargo Screening Mandate:

Statement of Steve Lord, Director: 
Homeland Security and Justice Issues:

GAO-10-880T:

[End of section]

Madam Chairwoman and Members of the Subcommittee:

I appreciate the opportunity to participate in today's hearing to 
discuss air cargo screening. In 2008, about 7.3 billion pounds of 
cargo was transported on U.S. passenger flights--approximately 58 
percent of which was transported domestically (domestic cargo) and 42 
percent of which was transported on flights arriving in the United 
States from a foreign location (inbound cargo).[Footnote 1] The 2009 
Christmas Day plot to detonate an explosive device during an 
international flight bound for Detroit provided a vivid reminder that 
terrorists continue to view passenger aircraft as attractive targets. 
According to the Transportation Security Administration (TSA), the 
security threat posed by terrorists introducing explosive devices in 
air cargo shipments is significant, and the risk and likelihood of 
such an attack directed at passenger aircraft is high.[Footnote 2] To 
help enhance the security of air cargo, the Implementing 
Recommendations of the 9/11 Commission Act of 2007 (9/11 Commission 
Act) mandated the Department of Homeland Security (DHS) to establish a 
system to physically screen 50 percent of cargo on passenger aircraft--
including the domestic and inbound flights of foreign and U.S. 
passenger operations--by February 2009, and 100 percent of such cargo 
by August 2010.[Footnote 3] The 9/11 Commission Act defines screening 
for purposes of the air cargo screening mandate as a physical 
examination or nonintrusive methods of assessing whether cargo poses a 
threat to transportation security.[Footnote 4] The act also requires 
that such a system provide a level of security commensurate with the 
level of security for the screening of checked baggage.

According to TSA, the mission of its air cargo security program is to 
secure the air cargo transportation system while not unduly impeding 
the flow of commerce. Although the mandate is applicable to both 
domestic and inbound cargo, TSA stated that it must address the 
mandate for domestic and inbound cargo through separate systems 
because of differences in its authority to regulate domestic and 
international air cargo industry stakeholders. My statement is based 
on a report we are publicly releasing today that assesses TSA's 
progress and related challenges in meeting the air cargo screening 
mandate.[Footnote 5] It addresses the following key issues in our 
report: progress TSA has made in meeting the 9/11 Commission Act 
screening mandate as it applies to (1) domestic air cargo and (2) 
inbound air cargo and related challenges it faces for each.

For our report, we reviewed documents such as TSA's air cargo security 
policies and procedures. We also conducted site visits to four 
category X U.S. commercial airports and one category I U.S. commercial 
airport that process domestic and inbound air cargo.[Footnote 6] We 
selected these airports based on airport size, passenger and air cargo 
volumes, location, and participation in TSA's screening program. At 
these airports, we observed screening operations and technologies and 
interviewed local TSA officials, airport management officials, and 
representatives from 7 air carriers, 24 freight forwarders, 3 
shippers, and 2 handling agents to obtain their views on TSA's system 
to implement the screening mandate.[Footnote 7] We selected these air 
carriers, freight forwarders, shippers, and handling agents based on 
input from TSA and industry stakeholders. More detailed information 
about our scope and methodology is included in our June 2010 report. 
We conducted this work in accordance with generally accepted 
government auditing standards.

In summary, TSA has taken a number of actions to meet the screening 
mandate as it applies to domestic cargo, including creating a 
voluntary program to allow screening to take place at various points 
in the air cargo supply chain and mandating that, effective May 1, 
2010, 75 percent of all cargo transported on passenger aircraft is 
screened. However, TSA faces several challenges in developing and 
implementing a system to screen 100 percent of domestic air cargo, and 
it is questionable, based on reported screening rates, whether 100 
percent of such cargo will be screened by August 2010 without impeding 
the flow of commerce. Moreover, TSA has made some progress in meeting 
the screening mandate as it applies to inbound cargo, but challenges 
exist, in part related to TSA's limited ability to regulate foreign 
entities. TSA does not expect to achieve 100 percent screening of 
inbound air cargo by the mandated August 2010 deadline. We made five 
recommendations to TSA to address these challenges. TSA concurred with 
three of these recommendations, partially concurred with one, and did 
not concur with the remaining recommendation, which we discuss in more 
detail later in this statement.

TSA Has Made Progress toward Screening 100 Percent of Domestic Cargo, 
but Remaining Challenges Highlight the Need for a Contingency Plan:

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 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, including those related to industry 
participation and technology.

Progress Made:

TSA has taken several steps to address the air cargo screening mandate 
as it applies to domestic cargo including the following.

TSA increased the amount of domestic cargo subject to screening. 
Effective October 1, 2008, TSA established a requirement for 100 
percent screening of nonexempt cargo transported on narrow-body 
passenger aircraft.[Footnote 8] In 2008, narrow-body flights 
transported about 24 percent of all cargo on domestic passenger 
flights.[Footnote 9] 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 by TSA to ensure that 75 percent of such cargo was screened. 
TSA also eliminated or revised most of its screening exemptions for 
domestic 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 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 conducting outreach efforts to air cargo industry stakeholders. 
Starting in September 2007, TSA began outreach to freight forwarders 
and subsequently expanded its outreach efforts to shippers and other 
entities to encourage participation in the CCSP. TSA is focusing its 
outreach on particular industries, such as producers of perishable 
foods, pharmaceutical and chemical companies, and funeral homes, which 
may experience damage to their cargo if it is screened by a freight 
forwarder or an air carrier.

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.[Footnote 10] 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 November 2008, in 
addition to the canine and physical search screening methods permitted 
by TSA to screen air cargo, TSA issued to air carriers and CCSFs a 
list of X-ray, explosives trace detection (ETD), and explosives 
detection systems (EDS) models that the agency approved for screening 
air cargo until August 3, 2010.[Footnote 11] In March 2009, TSA 
initiated a qualification process to test these and other technologies 
that it plans to allow air carriers and CCSP participants to use in 
meeting the screening mandate against TSA technical requirements.

TSA expanded its explosives detection canine program. TSA has taken 
steps to expand the use of TSA-certified explosives detection canine 
teams. According to TSA, in fiscal year 2009, TSA canine teams 
screened over 145 million pounds of cargo, which represents a small 
portion of domestic air cargo. As of February 2010, TSA had 113 
dedicated air cargo screening canine teams--operating in 20 major 
airports--and is in the process of adding 7 additional canine teams. 
TSA also deployed canine teams to assist the Pacific Northwest cherry 
industry during its peak harvest season from May through July 2009, to 
help air carriers and CCSFs handling this perishable commodity to meet 
the 50 percent screening requirement without disrupting the flow of 
commerce.

TSA established a system to verify that screening is being conducted 
at the mandated levels. The agency established a system to collect and 
analyze data from screening entities to verify that requisite levels 
for domestic cargo are being met. Effective February 2009, TSA 
adjusted air carrier reporting requirements and added CCSF reporting 
requirements to include monthly screening reports on the number and 
weight of shipments screened.

Challenges Facing TSA:

TSA faces industry participation, technology, planning, oversight, and 
other challenges in meeting the air cargo screening mandate as it 
applies to domestic cargo.

Industry Participation. Although TSA is relying on the voluntary 
participation of industry stakeholders to meet the screening mandate, 
far fewer shippers and independent CCSFs have joined the program than 
TSA had targeted. As shown in figure 1, TSA officials have estimated 
that an ideal mix of screening to achieve the 100 percent mandate as 
it applies to domestic cargo without impeding the flow of commerce 
would be about one-third of cargo weight screened by air carriers, one-
third by freight forwarders, and one-third by shippers and independent 
CCSFs.[Footnote 12]

Figure 1: TSA's Reported and Ideal Screening Percentage Breakdowns for 
Domestic Air Cargo Transported on Passenger Aircraft from February 
2009 through March 2010:

[Refer to PDF for image: stacked vertical bar graph] 

Date: February 2009; 
Shipper and independent CCSFs: 1%; 
Freight forwarder CCSFs: 19%; 
Air carriers, TSA canines, and TSA staff: 39%; 
Total: 59%; 
TSA-required screening levels: 50%. 

Date: March 2009; 
Shipper and independent CCSFs: 2%; 
Freight forwarder CCSFs: 15%; 
Air carriers, TSA canines, and TSA staff: 44%; 
Total: 61%; 
TSA-required screening levels: 50%. 

Date: April 2009; 
Shipper and independent CCSFs: 1%; 
Freight forwarder CCSFs: 19%; 
Air carriers, TSA canines, and TSA staff: 42%; 
Total: 62%; 
TSA-required screening levels: 50%. 

Date: May 2009; 
Shipper and independent CCSFs: 1%; 
Freight forwarder CCSFs: 12%; 
Air carriers, TSA canines, and TSA staff: 49%; 
Total: 62%; 
TSA-required screening levels: 50%. 

Date: June 2009; 
Shipper and independent CCSFs: 1%; 
Freight forwarder CCSFs: 15%; 
Air carriers, TSA canines, and TSA staff: 46%; 
Total: 62%; 
TSA-required screening levels: 50%. 

Date: July 2009; 
Shipper and independent CCSFs: 1%; 
Freight forwarder CCSFs: 22%; 
Air carriers, TSA canines, and TSA staff: 39%; 
Total: 62%; 
TSA-required screening levels: 50%. 

Date: August 2009; 
Shipper and independent CCSFs: 1%; 
Freight forwarder CCSFs: 22%; 
Air carriers, TSA canines, and TSA staff: 39%; 
Total: 62%; 
TSA-required screening levels: 50%. 

Date: September 2009; 
Shipper and independent CCSFs: 1%; 
Freight forwarder CCSFs: 23%; 
Air carriers, TSA canines, and TSA staff: 37%; 
Total: 62%; 
TSA-required screening levels: 50%. 

Date: October 2009; 
Shipper and independent CCSFs: 1%; 
Freight forwarder CCSFs: 24%; 
Air carriers, TSA canines, and TSA staff: 37%; 
Total: 62%; 
TSA-required screening levels: 50%. 

Date: November 2009; 
Shipper and independent CCSFs: 1%; 
Freight forwarder CCSFs: 26%; 
Air carriers, TSA canines, and TSA staff: 38%; 
Total: 65%; 
TSA-required screening levels: 50%. 

Date: December 2009; 
Shipper and independent CCSFs: 2%; 
Freight forwarder CCSFs: 28%; 
Air carriers, TSA canines, and TSA staff: 35%; 
Total: 65%; 
TSA-required screening levels: 50%. 

Date: January 2010; 
Shipper and independent CCSFs: 2%; 
Freight forwarder CCSFs: 29%; 
Air carriers, TSA canines, and TSA staff: 33%; 
Total: 64%; 
TSA-required screening levels: 50%. 

Date: February 2010; 
Shipper and independent CCSFs: 2%; 
Freight forwarder CCSFs: 30%; 
Air carriers, TSA canines, and TSA staff: 35%; 
Total: 67%; 
TSA-required screening levels: 50%. 

Date: March 2010; 
Shipper and independent CCSFs: 2%; 
Freight forwarder CCSFs: 32%; 
Air carriers, TSA canines, and TSA staff: 35%; 
Total: 67%; 
TSA-required screening levels: 50% (75% required as of May 2010). 

Date: TSA's ideal screening breakdown in August 2010; 
Shipper and independent CCSFs: 33%; 
Freight forwarder CCSFs: 33%; 
Air carriers, TSA canines, and TSA staff: 33%; 
Total: 100%; 
TSA-required screening levels: 100%. 

Source: GAO analysis of TSA screening data and information. 

Note: Totals for reported and ideal screening percentage breakdowns 
may not add up precisely because of rounding. 

[End of figure] 

To achieve TSA's ideal mix of screening by August 2010, shipper and 
independent CCSF screening efforts would need to increase by over 
sixteenfold. As shown in figure 1, the total percentage of reported 
screened cargo rose on average by less than a percentage point per 
month (from 59 to 68 percent) from February 2009 through March 2010. 
[Footnote 13] At these rates, it is questionable whether TSA's 
screening system will achieve 100 percent screening of domestic cargo 
by August 2010 without impeding the flow of commerce. Effective May 1, 
2010, TSA requires that 75 percent of air cargo transported on 
passenger aircraft be screened. However, even if this requirement is 
met, an additional 25 percent of domestic air cargo would still need 
to be screened in the 3 months prior to the August 2010 deadline, 
including some of the most challenging types of cargo to screen, such 
as unit load device (ULD) pallets and containers.

TSA and industry officials reported that several factors, such as lack 
of economic and regulatory incentives, are contributing to low shipper 
participation levels. TSA and the domestic passenger air carrier and 
freight forwarder industry association officials we interviewed stated 
that many shippers and freight forwarders are not incurring 
significant screening costs from air carriers. This decreases the 
financial pressure on the entities to join the CCSP and invest 
resources into screening cargo, factors that are making TSA's outreach 
efforts more challenging.

Screening Technology. There is currently no technology approved or 
qualified by TSA to screen cargo once it is loaded onto a ULD pallet 
or container--both of which are common means of transporting air cargo 
on wide-body passenger aircraft. Cargo transported on wide-body 
passenger aircraft makes up 76 percent of domestic air cargo shipments 
transported on passenger aircraft.[Footnote 14] Prior to May 1, 2010, 
canine screening was the only screening method, other than physical 
search, approved by TSA to screen such cargo. However, TSA officials 
still have some concerns about the effectiveness of the canine teams, 
and effective May 1, 2010, the agency no longer allows canine teams to 
be used for primary screening of ULD pallets and containers.[Footnote 
15] Canine teams still may be used for secondary screening of ULD 
pallets and containers; however, secondary screening does not count 
toward meeting the air cargo screening mandate.

In addition, TSA is working to complete qualification testing of 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. 
Qualification tests are designed to verify that a technology system 
meets the technical requirements specified by TSA. Because of the 
mandated deadlines, 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.[Footnote 16] We 
reported that these technology challenges suggest the need for TSA to 
consider a contingency plan to meet the screening mandate without 
unduly affecting the flow of commerce.

Contingency Planning. Although TSA faces industry participation and 
technology challenges that could impede the CCSP's success and the 
agency's efforts to meet the 100 percent screening mandate by August 
2010, the agency has not developed a contingency plan that considers 
alternatives to address these challenges. Without adequate CCSP 
participation, industry may not be able to screen enough cargo prior 
to its arrival at the airport to maintain the flow of commerce while 
meeting the mandate. Likewise, without technology solutions for 
screening cargo in a ULD pallet or container, industry may not have 
the capability to effectively screen 100 percent of air cargo without 
affecting the flow of commerce. We have previously reported that a 
comprehensive planning process, including contingency planning, is 
essential to help an agency meet current and future capacity 
challenges.[Footnote 17] Alternatives could include, but are not 
limited to, mandating CCSP participation for certain members of the 
air cargo supply chain--instead of relying on their voluntary 
participation--and requiring the screening of some or all cargo before 
it is loaded onto ULD pallets and containers. In the report being 
released today, we recommended that TSA develop a contingency plan for 
meeting the mandate as it applies to domestic cargo that considers 
alternatives to address potential CCSP participation shortfalls and 
screening technology limitations. TSA did not concur with this 
recommendation and stated that a contingency plan is unnecessary since 
effective August 1, 2010, 100 percent of domestic cargo transported on 
passenger aircraft will be required to be screened. The agency also 
stated that there is no feasible contingency plan that can be 
implemented by TSA that does not compromise security or create 
disparities in the availability of screening resources. However, we 
continue to believe that there are feasible alternatives that TSA 
should consider to address potential CCSP participation shortfalls and 
screening technology limitations. Thus, it is prudent that TSA 
consider developing a contingency plan that would allow for the 
security and legitimate flow of air cargo.

Inspection Resources. While TSA has amended its Regulatory Activities 
Plan to include inspections of CCSP participants, the agency has not 
completed its staffing study to determine how many inspectors will be 
necessary to provide oversight of the additional program participants 
when the 100 percent screening mandate goes into effect. According to 
TSA, the agency's staffing study is continuing through fiscal year 
2010 and is therefore not yet available to provide guidance in helping 
to plan for inspection resources needed to provide oversight. 
According to our analysis of TSA data, in the next year, inspectors 
will need to at least double their comprehensive inspections of CCSFs 
to reach the agency's inspection goals. 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. If this model includes an analysis of 
the resources needed to provide CCSP oversight under various 
scenarios, it will address the intent of our recommendation.

Reported Screening Data. While TSA reported to Congress that industry 
achieved the February 2009 50 percent screening deadline domestically, 
questions exist about the reliability of the screening data, which are 
self-reported by industry representatives, because TSA does not have a 
mechanism to verify the accuracy of the data reported by the industry. 
We recommended that TSA develop a mechanism to verify the accuracy of 
all screening data through random checks or other practical means. TSA 
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. However, TSA could 
consider a quality review mechanism similar to the compliance 
measurement program used by CBP, which includes regular quality 
reviews to ensure accuracy in findings and management oversight to 
validate results.

In-Transit Cargo. Cargo that has already been transported on one leg 
of a passenger flight--known as in-transit cargo--may be subsequently 
transferred to another passenger flight without undergoing screening. 
According to TSA officials, though the agency does not have a precise 
figure, industry estimates suggest that about 30 percent of domestic 
cargo is transferred from an inbound flight. TSA officials stated that 
transporting in-transit cargo without screening could pose a 
vulnerability, but as of February 2010, the agency was not planning to 
require in-transit cargo transferred from an inbound flight to be 
physically screened because of the logistical difficulties associated 
with screening cargo that is transferred from one flight to another. 
We recommended that TSA develop a plan with milestones for how and 
when it intends to require the screening of in-transit cargo. TSA 
concurred with our recommendation and stated that the agency has 
implemented changes, effective August 1, 2010, that will require 100 
percent of in-transit cargo to be screened unless it can otherwise be 
verified as screened. Because this is a significant change and 
potentially operationally challenging, it will be important to closely 
monitor the industry's understanding and implementation of this 
requirement to help ensure that 100 percent screening of in-transit 
cargo is being conducted.

TSA Has Made Progress but Faces Several Challenges and Lacks a Plan 
for Achieving 100 Percent Screening of Inbound Cargo:

TSA has taken steps to increase the percentage of inbound cargo 
transported on passenger aircraft that is screened, but the agency has 
not developed a plan, including milestones, for meeting the mandate as 
it applies to inbound cargo. Consequently, TSA officials have stated 
that the agency will not be able to meet the mandate as it applies to 
inbound cargo by the August 2010 deadline.

Steps Taken:

Steps TSA has taken to increase the percentage of inbound air cargo 
that is screened include the following:

* Revising its requirements for foreign and U.S. air carrier security 
programs, effective May 1, 2010, to generally require air carriers to 
screen a certain percentage of shrink-wrapped and banded inbound cargo 
and 100 percent of inbound cargo that is not shrink-wrapped or banded. 
[Footnote 18] According to TSA, implementation of this requirement 
will result in the screening of 100 percent of inbound cargo 
transported on narrow-body aircraft since none of this cargo is shrink-
wrapped or banded.[Footnote 19]

* Obtaining information from foreign countries on their respective air 
cargo screening levels and practices to help assess the rigor and 
quality of foreign screening practices.

* Working to harmonize security standards with those of foreign 
nations.[Footnote 20]

Challenges TSA Faces:

According to TSA, screening inbound air cargo poses unique challenges, 
related, in part, to TSA's limited ability to regulate foreign 
entities. As such, TSA officials stated that the agency is focusing 
its air cargo screening efforts on domestic cargo and on screening 
elevated-risk inbound cargo as it works to address the challenges it 
faces in screening 100 percent of inbound cargo. In April 2007, we 
reported that TSA's screening exemptions for inbound cargo could pose 
a risk to the air cargo supply chain and recommended that TSA assess 
whether these exemptions pose an unacceptable vulnerability and, if 
necessary, address these vulnerabilities.[Footnote 21] TSA agreed with 
our recommendation, but beyond its requirement to screen 100 percent 
of inbound cargo transported on narrow-body aircraft and a certain 
percentage of shrink-wrapped or banded inbound cargo, has not 
reviewed, revised, or eliminated inbound screening exemptions, and did 
not provide a time frame for doing so. We continue to believe that TSA 
should assess whether these exemptions pose an unacceptable security 
risk.

In addition, identifying the precise level of screening being 
conducted on inbound air cargo is difficult because TSA lacks a 
mechanism to obtain actual data on all screening that is being 
conducted on inbound air cargo. TSA officials estimate that 55 percent 
of inbound cargo by weight is currently being screened and that 65 
percent of inbound cargo by weight will be screened by August 2010. 
However, these estimates are based on the current screening 
requirements of certain countries and are not based on actual data 
collected from air carriers or other entities, such as foreign 
governments, on what percentage of cargo is actually being screened. 
[Footnote 22] We recommended that TSA develop a mechanism to verify 
the accuracy of all screening data through random checks or other 
practical means and obtain actual data on all inbound screening. TSA 
concurred in part with our recommendation, stating that as of May 1, 
2010, the agency issued changes to air carriers' standard security 
programs that require air carriers to report inbound cargo screening 
data to TSA. However, as noted in our report, these requirements apply 
to air carriers and the screening that they conduct and not to the 
screening conducted by other entities, such as foreign governments. 
Thus, TSA will continue to rely in part on estimates to report inbound 
cargo screening levels. TSA officials stated that it may be 
challenging to obtain screening data from some foreign governments and 
other entities that conduct cargo screening, but TSA has not developed 
a plan for how it could obtain these data. We recognize that it may be 
challenging for TSA to obtain cargo screening data from foreign 
governments; however, similar to domestic reporting requirements, the 
agency could require air carriers to report on cargo screening for all 
inbound cargo they transport, including the screening conducted by 
other entities.

Moreover, the 9/11 Commission Act requires the establishment of a 
system to screen 100 percent of cargo transported on passenger 
aircraft, including inbound cargo. As we have reported in our prior 
work, a successful project plan--such as a plan that would be used to 
establish such a system--should consider all phases of the project and 
clearly state schedules and deadlines.[Footnote 23] TSA officials 
reported that the agency is unable to identify a timeline for meeting 
the mandate for inbound cargo, stating that its efforts are long term, 
given the extensive work it must conduct with foreign governments and 
associations. However, interim milestones could help the agency 
provide reasonable assurance to Congress that it is taking steps to 
meet the mandate as it applies to inbound cargo. In our June 2010 
report, we recommended that TSA develop a plan with milestones for how 
and when the agency intends to meet the mandate as it applies to 
inbound cargo. TSA concurred with our recommendation and stated that 
the agency is drafting milestones as part of a plan that will 
generally require air carriers to conduct 100 percent screening by a 
specific date. If implemented effectively, this plan will address the 
intent of our recommendation.

Madam Chairwoman, this concludes my statement. I look forward to 
answering any questions that you or other members of the subcommittee 
may have.

Contacts and Acknowledgments:

For questions about this statement, please contact Stephen M. Lord at 
(202) 512-4379 or lords@gao.gov. 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 are Steve D. Morris, Assistant Director; Tina Cheng; Barbara 
A. Guffy; David K. Hooper; Richard B. Hung; Stanley J. Kostyla; Linda 
S. Miller; Yanina Golburt Samuels; and Rebecca Kuhlmann Taylor.

[End of section] 

Footnotes: 

[1] For the purposes of this statement, domestic cargo refers to cargo 
transported by air within the United States and from the United States 
to a foreign location by both U.S. and foreign air carriers, and 
inbound cargo refers to cargo transported by both U.S. and foreign air 
carriers from a foreign location to the United States. These cargo 
statistics were provided by the Transportation Security Administration 
from the Bureau of Transportation Statistics.

[2] Specific threat details are classified and are not discussed in 
this statement. Generally, the threat that has been identified by TSA 
is that of an improvised explosive device.

[3] Pub. L. No. 110-53, § 1602, 121 Stat. 266, 477-80 (codified at 49 
U.S.C. § 44901(g)).

[4] See 49 U.S.C. § 44901(g)(5). For the purposes of this statement, 
physical screening is generally used to describe screening for 
purposes of the air cargo screening mandate.

[5] GAO, Aviation Security: TSA Has Made Progress but Faces Challenges 
in Meeting the Statutory Mandate for Screening Air Cargo on Passenger 
Aircraft, [hyperlink, http://www.gao.gov/products/GAO-10-446] 
(Washington, D.C.: June 28, 2010). 

[6] There are about 450 commercial airports in the United States. TSA 
classifies airports into one of five categories (X, I, II, III, and 
IV) based on various factors, such as the total number of takeoffs and 
landings annually, the extent to which passengers are screened at the 
airport, and other special security considerations. In general, 
category X airports have the largest number of passenger boardings, 
and category IV airports have the smallest.

[7] For the purposes of this statement, the term freight forwarder 
only includes those freight forwarders that are regulated by TSA, also 
referred to as indirect air carriers. A freight forwarder is a company 
that consolidates cargo from multiple shippers onto a master air 
waybill--a manifest of the consolidated shipment--and delivers the 
shipment to air carriers for transport.

[8] TSA exempts some categories of air cargo from physical screening 
and requires alternative methods of screening, such as verifying 
shipper and cargo information and visually inspecting the cargo 
shipment, rather than opening the shipment and physically searching 
its contents or screening it with technology. For the purposes of this 
statement, the phrase "exempt cargo" and the word "exemption" refer to 
cargo that is subject to such alternative screening measures. Narrow- 
body aircraft, such as Boeing 737s and Airbus 320s, are defined by 
fuselage diameter, and most narrow-body aircraft have only one aisle. 
Narrow-body aircraft that fly in the United States do not carry unit 
load devices (ULD) that allow packages to be consolidated in a 
container or pallet. Wide-body aircraft are also defined by fuselage 
diameter and can carry ULDs.

[9] According to statistics provided by TSA from the Bureau of 
Transportation Statistics, narrow-body aircraft make up 97 percent of 
domestic passenger flights and transport more than 90 percent of 
passengers traveling on domestic passenger flights.

[10] Initially, the Air Cargo Screening Technology Pilot was limited 
to high-volume freight forwarders (i.e., freight forwarders processing 
at least 200 shipments annually per location that contain cargo 
consolidated from multiple shippers). However, in November 2008, TSA 
sought additional high-volume freight forwarders and independent cargo 
screening facilities to apply for the pilot. Moreover, entities that 
do not participate in the pilot will not receive TSA funding to 
purchase screening technology.

[11] ETD requires human operators to collect samples of items to be 
screened with swabs, which are chemically analyzed to identify any 
traces of explosive material. EDS uses computer-aided tomography X-
rays to examine objects inside baggage and identify the characteristic 
signatures of threat explosives. In December 2009, TSA extended the 
expiration date of the approved technologies to January 2012.

[12] The CCSP allows air cargo industry stakeholders, such as an air 
cargo handling agent, to establish independent cargo screening 
facilities to provide screening services for shippers or freight 
forwarders that have not joined the program and do not want the air 
carriers to screen their cargo. These independent facilities screen 
cargo for a fee, according to CCSP guidelines. For the purposes of 
this statement, we refer to independent cargo screening facilities as 
independent CCSFs. 

[13] The screening percentages in fig. 1 have been rounded to the 
nearest percentage point. The actual percentages for March 2010 sum to 
68 percent.

[14] Cargo may be screened before it is loaded onto ULD pallets or 
containers.

[15] TSA canine teams conduct primary and secondary screening of 
cargo. Primary screening counts toward meeting the air cargo screening 
mandate. Secondary screening provides spot checks of the screening 
already conducted by air carriers and CCSFs.

[16] See GAO, Defense Acquisitions: Measuring the Value of DOD's 
Weapon Programs Requires Starting with Realistic Baselines, 
[hyperlink, http://www.gao.gov/products/GAO-09-543T] (Washington, 
D.C.: Apr. 1, 2009).

[17] GAO, Federal Law Enforcement Training Center: Capacity Planning 
and Management Oversight Need Improvement, [hyperlink, 
http://www.gao.gov/products/GAO-03-736] (Washington, D.C.: July 24, 
2003).

[18] Details on TSA's screening requirements are Sensitive Security 
Information and are not discussed in this statement. Prior to May 1, 
2010, TSA generally required air carriers to screen 50 percent of 
nonexempt inbound cargo transported on passenger aircraft and a 
certain percentage of all inbound cargo transported on passenger 
aircraft. Banded cargo is cargo with heavy-duty metal, plastic, or 
nylon bands that secure all sides of the cargo shipment or secure the 
cargo shipment to a skid.

[19] According to statistics provided by TSA from the Bureau of 
Transportation Statistics, in 2008, narrow-body flights made up 69 
percent of inbound flights and transported 45 percent of inbound 
passengers. 

[20] The term harmonization is used to describe countries' efforts to 
coordinate their security practices to enhance security and increase 
efficiency by avoiding duplication of effort. Harmonization efforts 
can include countries mutually recognizing and accepting each other's 
existing practices--which could represent somewhat different 
approaches to achieve the same outcome--as well as working to develop 
mutually acceptable uniform standards.

[21] 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/products/GAO-07-660] (Washington, D.C.: Apr. 30, 
2007).

[22] According to TSA officials, the agency does not know the 
screening requirements for every country that transports air cargo 
into the United States. TSA assumes that other countries are in 
compliance, at a minimum, with TSA's regulation that a certain 
percentage of inbound air cargo be screened.

[23] GAO, 2010 Census: Cost and Design Issues Need to Be Addressed 
Soon, [hyperlink, http://www.gao.gov/products/GAO-04-37] (Washington, 
D.C.: Jan. 15, 2004).

[End of section] 

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