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United States Government Accountability Office:
Washington, DC 20548: 

February 6, 2009: 

The Honorable Robert C. Byrd:
Chairman:
The Honorable Thad Cochran:
Ranking Member:
Subcommittee on Homeland Security:
Committee on Appropriations:
United States Senate: 

The Honorable David E. Price:
Chairman:
The Honorable Harold Rogers:
Ranking Member:
Subcommittee on Homeland Security:
Committee on Appropriations:
House of Representatives: 

Subject: Aviation Security: Status of Transportation Security
Inspector Workforce: 

This report formally transmits the enclosed briefing in response to
House Report 110-181, accompanying H.R. 2638, the Department of
Homeland Security Appropriations Bill, 2008. In accordance with
direction in that report, we are reporting on the operation of the
transportation security inspector (TSI) program since it has been
located at the Transportation Security Administration (TSA) within the
Department of Homeland Security, including the size of the TSI
workforce, the roles and responsibilities of TSIs, and the extent to
which TSA has a reasonable basis for determining the size of the
workforce needed to achieve inspection goals. For a summary of the
results of our work, see slides 10 through 13. 

We are sending copies of this report to the appropriate congressional
committees. We are also sending copies to the Secretary of Homeland
Security. This report will also be available at no charge on our Web
site at [hyperlink, http://www.gao.gov]. Should you or your staff have
any questions concerning this report, please contact me at (202)
512-8777 or berrickc@gao.gov. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this Key contributors to this report were William Crocker, 
Assistant Director; Ben Atwater; Scott Behen; Wendy Johnson; Deena 
Richart; Tom Lombardi; and Sally Williamson. 

Signed by: 

Cathleen A. Berrick:
Managing Director, Homeland Security and Justice Issues: 

Enclosures: 

[End of section] 

Enclosure I: 

Aviation Security: Status of Transportation Security Inspector
Workforce: 

Briefing for Congressional Committees: 

February 6, 2009: 

Contents: 

* Introduction: 

* Objectives: 

* Scope and Methodology: 

* Summary: 

* Background: 

* Results: 

* Agency Comments: 

* GAO Contact: 

* Appendix I: 

[End of section] 

Introduction: 

As of September 2008, the Transportation Security Administration
(TSA) employed about 1,200 aviation and cargo transportation
security inspectors (TSI)[Footnote 1] to monitor and enforce regulated
entities’ compliance with security requirements through inspection and
outreach programs. Regulated entities include: 

* domestic airports; 

* aircraft operators and foreign air carriers (both passenger and
cargo); 

* indirect air carriers;[Footnote 2] 

* flight school operators; and; 

* aircraft repair stations. 

Over the past several years, the size of the inspector workforce has
fluctuated while TSI responsibilities have increased. 

In response to House Report 110-181, which accompanies H.R. 2638,
the Department of Homeland Security (DHS) Appropriations Bill,
2008, we are reporting on the operation of the TSI program since
2003—when the program was moved with TSA from the Department
of Transportation to DHS—including the size of the TSI workforce, the
roles and responsibilities of TSIs, and the extent to which TSA has a
reasonable basis for determining the size of the workforce needed to
achieve inspection goals. 

[End of section] 

Objectives: 

What are the roles and responsibilities of TSIs, and to what extent
have they changed since 2003? 

What have been the staffing levels for the aviation and cargo TSI
program since 2005? 

To what extent does TSA have a reasonable basis for determining the
size of the TSI workforce needed to achieve inspection goals? 

[End of section] 

Scope and Methodology: 

To satisfy our objectives, we: 

* Reviewed relevant information and documents, including staffing
levels, annual inspection plans, inspection manuals, security
regulations, inspection results, and relevant legislative provisions to
determine TSI roles and responsibilities, workforce size, and
inspection goals.[Footnote 3] We also compared TSA’s program information
with relevant guidance on effective workforce planning and project
management.[Footnote 4] 

* Observed TSI activities at two airports. We visited these airports
because of their large passenger and cargo operations. While 
information gathered from these visits cannot be generalized to all 
airports, those we visited provided an overview and perspective on the 
general nature of TSI roles and responsibilities as well as the 
operation of the program. 

* Interviewed program officials within TSA’s Office of Security
Operations to obtain information on the size of the TSI workforce,
TSIs’ roles and responsibilities, and their perspectives on the extent
to which the current size of the TSI workforce was commensurate
with TSA’s needs to achieve inspection goals. 

To evaluate the reliability of the data used in this review, we
interviewed knowledgeable officials about the workload hours and
related data elements in TSA’s regulatory reporting system. Based on
this work, we determined that the data were sufficiently reliable for 
our reporting purposes.[Footnote 5] 

Limitations: 

* TSA was unable to provide information on the size of the TSI
workforce prior to fiscal year 2005. 

* TSA does not have a mechanism for tracking time TSIs spend on
nonprogram activities. TSIs are to record the amount of time spent
on duties related to conducting inspections, investigations, other
regulated and operational activities, and outreach in TSA’s
regulatory reporting system. However, TSA does not have an
activity-based time and attendance system that would allow officials
to track time spent on other activities. 

* TSA was unable to provide data prior to fiscal year 2008 reflecting
TSI inspections completed relative to TSA inspection requirements. 

We conducted this performance audit from February 2008 through
February 2009 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 based on our audit objectives. 

[End of section] 

Summary: Roles and Responsibilities: 

As of fiscal year 2003, aviation and cargo TSI roles and
responsibilities included monitoring and enforcing compliance with
security requirements through inspections, investigations, and
outreach. The roles and responsibilities of TSIs grew since fiscal year
2006 because of the addition of regulated entities and the expansion
of duties.[Footnote 6] 

* Newly regulated entities included flight schools,[Footnote 7] while 
expanded duties included participation in activities such as the 
Aviation Screening Assessment Program (ASAP).[Footnote 8] 

* According to fiscal year 2007 data (the most recent data provided by 
TSA officials), TSIs spent about one-third of their time conducting 
inspections. 

Summary: Staffing Levels: 

The number of on-board aviation TSIs has grown from 601 in fiscal
year 2005 to 697 in fiscal year 2008 (an increase of about 16 percent),
while the number of on-board cargo TSIs has grown from 160 in fiscal
year 2005 to 475 in fiscal year 2008 (an increase of about 197
percent). 

As shown in figure 1, the number of on-board aviation and cargo TSI
positions remained below TSA-authorized levels in each fiscal year
from 2005 through 2008.[Footnote 9] TSA officials were uncertain why 
authorized positions were not filled, but they cited attrition and 
transfers to other agencies within DHS as likely reasons. 

Figure 1: TSA-Authorized and On-Board TSI Positions, Fiscal Years 2005 
through 2008: 

[Refer to PDF for image] 

This figure is a stacked vertical bar graph depicting the following 
data: 

TSA-Authorized and On-Board TSI Positions, Fiscal Years 2005 through 
2008: 

Fiscal year: 2005; 
Authorized, TSI-aviation: 882 inspectors; 
Authorized, TSI-cargo: 200 inspectors; 
Total, Authorized: 1082 inspectors; 
On-board, TSI-aviation: 601 inspectors; 
On-board, TSI-cargo: 160 inspectors; 
Total On-board: 761 inspectors. 

Fiscal year: 2006; 
Authorized, TSI-aviation: 681 inspectors; 
Authorized, TSI-cargo: 300 inspectors; 
Total, Authorized: 981 inspectors; 
On-board, TSI-aviation: 680 inspectors; 
On-board, TSI-cargo: 200 inspectors; 
Total On-board: 880 inspectors. 

Fiscal year: 2007
Authorized, TSI-aviation: 657 inspectors; 
Authorized, TSI-cargo: 300 inspectors; 
Total, Authorized: 957 inspectors; 
On-board, TSI-aviation: 554 inspectors; 
On-board, TSI-cargo: 258 inspectors; 
Total On-board: 812 inspectors. 

Fiscal year: 2008
Authorized, TSI-aviation: 778 inspectors; 
Authorized, TSI-cargo: 535 inspectors; 
Total, Authorized: 1313 inspectors; 
On-board, TSI-aviation: 697 inspectors; 
On-board, TSI-cargo: 475 inspectors; 
Total On-board: 1172 inspectors. 

Source: TSA. 

Note: Levels of TSIs by TSA denotes the number of inspector positions 
TSA anticipated filling in each fiscal year. 

[End of figure] 

Summary: Achieving Inspection Goals: 

TSA does not have a reasonable basis for determining the workforce
needed to achieve inspection goals, although it has plans to conduct a
staffing study in fiscal year 2009 to identify the optimal workforce 
size to address its current and future program needs. 

* According to TSA officials, planned aviation inspection goals were
met in fiscal year 2007, but cargo inspection goals were not. In
addition, some planned aviation and cargo inspection goals were
not met in fiscal year 2008. 

* TSA officials noted that cargo inspection goals were not met in
fiscal year 2007 for several reasons, including that TSA did not fill
all of its cargo TSI positions. For fiscal year 2008, officials could
not explain why some goals were not met but speculated that poor
planning or unplanned inspections were contributing factors. 

[End of section] 

Background: 

Originally, aviation and cargo security inspections were conducted by
special agents within the Department of Transportation’s (DOT)
Federal Aviation Administration. These positions were later
transferred to TSA upon its creation within DOT and then moved with
TSA to DHS in 2003, where they were renamed aviation security
inspectors. 

In the latter half of fiscal year 2007, TSA renamed these positions
transportation security inspectors. Since fiscal year 2005, TSI
responsibilities have generally aligned with their given specialization
in either aviation or cargo. 

As seen in figure 2, the TSI program is one aspect of TSA’s layered
approach to security. According to TSA, each individual layer is
capable of stopping a terrorist attack, and in combination, their
security value is multiplied, creating a stronger security system. 

Figure 2: TSA Layers of Security: 

[Refer to PDF for image] 

This figure illustrates the TSA layers of security, as follows: 

Terrorist paths: 

Intelligence: 
Customs and Border Protection: 
Joint Terrorism Task Force: 
No-fly list and passenger screening: 
Crew vetting: 
VIPR: 
Canines: 
Behavior detection officers: 
Travel document checker: 
Checkpoint/Transportation security officers: 
Transportation security inspectors (TSIs): 
Random employee screening: 
Bomb appraisal officers: 
Federal Air Marshall Service: 
Federal flight deck officers: 
Trained flight crew: 
Law enforcement officers: 
Hardened cockpit doors: 
Passengers: 

Source: TSA. 

Note: Visual Intermodal Prevention and Response (VIPR) teams are 
interagency teams involving, among others, TSIs, transportation 
security officers, and federal air marshals, as well as a variety 
of federal and law enforcement components that supplement existing 
security resources, to provide deterrent presence and detection 
capabilities. 

[End of figure] 

TSA’s Regulatory Activities Plan (RAP) serves as the annual baseline
for the development of local inspection plans. It establishes the
minimum number of inspections, depending on airport size and other
factors, TSIs are to conduct for each type of regulated entity. 

* According to TSA officials, since its introduction in fiscal year
2004, the RAP’s development has been a collaborative effort
between headquarters and field officials. For the fiscal year 2009
RAP, headquarters officials took the lead in developing the RAP
in order to provide more national oversight of the TSI program,
according to TSA. However, headquarters officials stated that
they collaborated with field officials on the RAP’s content. 

* Prior to the fiscal year 2009 RAP, versions of this inspection plan
focused on areas deemed to be highest risk. TSA refers to these
as critical inspections. The focus of the fiscal year 2009 RAP is
comprehensive inspections, which are to cover all areas of risk. 

* TSA evaluates risk elements associated with an inspection area
(e.g., access controls, employee training, and catering security),
including whether the area has a single point of failure, is
operational in nature, or involves human factors. Critical
inspections involve the security areas deemed high risk. 

* Comprehensive inspections are in-depth inspections in which TSIs 
review all inspection areas, both high risk and otherwise. 

* According to TSA officials, TSA changed its inspection focus from
critical to comprehensive inspections in the fiscal year 2009 RAP
to provide a baseline assessment of regulated entities’ compliance 
with all security regulations. 

As seen in table 1, TSA budgeted approximately $147 million of its
fiscal year 2008 appropriation for TSI-related activities. 

Table 1: Funding of TSI-Related Activities, Fiscal Year 2008: 

TSI activity: Transportation Security Inspectors - Domestic; 
Fiscal year 2008 funds: $77,106,000. 

TSI activity: Proprietary Canine Teams - Aviation; 
Fiscal year 2008 funds: $4,903,000. 

TSI activity: International Inspectors (Aviation, Cargo, Repair 
Stations); 
Fiscal year 2008 funds: $17,672,000. 

TSI activity: Air Cargo Transportation Security Inspectors. 
Fiscal year 2008 funds: $30,915,000. 

TSI activity: Surface Transportation Security Inspectors; 
Fiscal year 2008 funds: $16,628,000. 

TSI activity: Total; 
Fiscal year 2008 funds: $147,224,000. 

Source: TSA officials. 

Notes: These amounts do not include fiscal year 2007 supplemental 
funding 
for 150 air cargo inspectors and 85 air cargo proprietary canine teams, 
which remained available to fund these activities in fiscal year 2008. 

TSA could not provide information on appropriated funds available for 
TSI-related activities in fiscal years 2004 through 2007. TSA does not
receive a specific appropriation for the TSI program, and there was not 
a separate budget line item for the program in fiscal years 2004 
through 2009. 

[End of table] 

[End of section] 

Results: Roles and Responsibilities: 

As of fiscal year 2003, TSI roles and responsibilities included
monitoring and enforcing compliance with security requirements
through inspections, investigations, and other duties, including
regulatory and operational activities and outreach. (See app. I for a 
list of major TSI duties.) 

Since fiscal year 2006, TSI roles and responsibilities expanded as
TSA added regulated entities, such as flight schools, and expanded
duties, such as participation in ASAP testing. As a result of this
expansion of duties, inspections account for about one-third of time
spent on all TSI activities, according to the latest available data. 

Aviation and cargo TSIs are to conduct on-site inspections of all
regulated entities to determine their compliance with federal
requirements involving transportation security. For example, at
airports, TSIs may check the integrity of access control systems,
alarms, security lighting, and biometric devices used to restrict public
access to secure areas. 

In addition, TSIs are to investigate findings of noncompliance
discovered during inspections or related to incidents arising from
violations of TSA regulations, security directives, and security
programs, and are to prepare any related enforcement actions for
adjudication. 

Both aviation and cargo TSIs are also responsible for participating in
other regulatory and operational activities that may or may not be
considered part of their inspection duties. Examples include
participation in the following: 

* Visual Intermodal Prevention and Response (VIPR) teams are
interagency teams—involving, among others, TSIs, transportation 
security officers, and federal air marshals, as well as a variety 
of federal and law enforcement components—that supplement existing 
security resources to provide deterrent presence and detection 
capabilities. 

* Aviation Screening Assessment Program (ASAP) is a locally generated 
assessment using inert bombs, bomb parts, and other threat items to 
identify weaknesses and to strengthen screening performance through 
training, procedures, or technology. 

* The Aviation Direct Access Screening Program (ADASP) involves the 
random and unpredictable screening of employees and contractors who 
work in secure areas of airports. 

* High visibility activities, which involve patrols by TSIs wearing
clothing clearly marked “TSA Inspector,” in both public and secure 
areas of the airport, provide a visible deterrent to potential 
terrorists. 

TSIs are also responsible for performing outreach activities, including
encouraging regulated and nonregulated entities to adopt security
best practices, as well as representing TSA at various transportation
consortia and law enforcement agency meetings. 

Both aviation and cargo TSIs are to conduct outreach in their areas of
responsibility on an ongoing basis to provide guidance regarding
transportation security to both regulated (e.g., airports, aircraft
operators/air carriers, indirect air carriers, and flight schools) and
nonregulated (e.g., general aviation airports, airline contract service
providers, law enforcement agencies, and state and local governments) 
entities. 

As of fiscal year 2003, TSIs were responsible for inspecting domestic
airports, domestic and foreign air carrier station operations for both
passenger and cargo operations, and indirect air carriers. Aviation and
cargo TSI responsibilities increased from fiscal year 2006 through 2008 
as additional entities came under regulation and as TSA expanded 
duties. 

The types of regulated entities both aviation and cargo TSIs are
required to inspect increased. In fiscal year 2006, TSIs also became
responsible for inspecting flight schools.[Footnote 10] 

* TSA assigned both aviation and cargo TSIs additional duties from
fiscal year 2006 through fiscal year 2008. The following is a list of
additional duties we identified based on documentation provided by
TSA; however, it does not represent all additional duties. 

- Fiscal year 2006: Airport strikes[Footnote 11] were added. 

- Fiscal year 2007: VIPR teams were added. 

- Fiscal year 2008: High visibility activities, ASAP testing,
participation in ADASP, special emphasis assessments, and off-airport
check-in operations oversight were added. 

As a result of this expansion of duties, TSA officials noted that TSIs 
do not spend the majority of their time conducting inspections. As shown
in figure 3, data from TSA’s regulatory reporting system indicate that
for fiscal year 2007, inspections accounted for about one-third of
inspectors’ time. 

Figure 3: Summary of TSI Hours Spent on Inspection, Investigation, 
Incident, and Outreach Activity Compared to Other Available Inspector 
Hours, Fiscal Year 2007: 

[Refer to PDF for image] 

This figure is a pie-chart depicting the following data: 

Inspection: 33%; 
Incident: 8%; 
Outreach: 5%; 
Investigation: 5%; 
Other: 49%. 

Source: GAO analysis of TSA data. 

TSA officials could not provide documentation identifying how TSIs
spend their time on activities that are not captured in TSA’s regulatory
reporting system. TSA officials noted that those duties, constituting 
the “Other” category in figure 3, may include the following: 

* Local budget/finance monitoring; 

* Support of the screener workforce; 

* Hiring and associated human resource activities; 

* Internal/external meetings and briefings; 

* Daily intelligence and operational reporting review; 

* Support of special activities – for example, disaster preparedness 
and hurricane response; 

* On-the-job instruction (providing or receiving). 

Results: Staffing Levels: 

Staffing levels for the TSI program from fiscal year 2005 through fiscal
year 2008 showed little change in the number of aviation inspectors
but growth in the number of cargo inspectors. 

As shown in figure 4, the number of on-board aviation TSIs in fiscal
year 2008 was 697, more than the 601 on-board in fiscal year 2005
and more than the 680 on-board in fiscal year 2006. However, the
number of on-board cargo TSIs had grown from 160 in fiscal year
2005 to 475 in fiscal year 2008. 

Figure 4: TSA-Authorized and On-Board TSI Positions, Fiscal Years 2005 
through 2008: 

[Refer to PDF for image] 

This figure is a stacked vertical bar graph depicting the following 
data: 

TSA-Authorized and On-Board TSI Positions, Fiscal Years 2005 through 
2008: 

Fiscal year: 2005; 
Authorized, TSI-aviation: 882 inspectors; 
Authorized, TSI-cargo: 200 inspectors; 
Total, Authorized: 1082 inspectors; 
On-board, TSI-aviation: 601 inspectors; 
On-board, TSI-cargo: 160 inspectors; 
Total On-board: 761 inspectors. 

Fiscal year: 2006; 
Authorized, TSI-aviation: 681 inspectors; 
Authorized, TSI-cargo: 300 inspectors; 
Total, Authorized: 981 inspectors; 
On-board, TSI-aviation: 680 inspectors; 
On-board, TSI-cargo: 200 inspectors; 
Total On-board: 880 inspectors. 

Fiscal year: 2007
Authorized, TSI-aviation: 657 inspectors; 
Authorized, TSI-cargo: 300 inspectors; 
Total, Authorized: 957 inspectors; 
On-board, TSI-aviation: 554 inspectors; 
On-board, TSI-cargo: 258 inspectors; 
Total On-board: 812 inspectors. 

Fiscal year: 2008
Authorized, TSI-aviation: 778 inspectors; 
Authorized, TSI-cargo: 535 inspectors; 
Total, Authorized: 1313 inspectors; 
On-board, TSI-aviation: 697 inspectors; 
On-board, TSI-cargo: 475 inspectors; 
Total On-board: 1172 inspectors. 

Source: TSA. 

Note: Levels of TSIs by TSA denotes the number of inspector positions 
TSA anticipated filling in each fiscal year. 

[End of figure] 

According to TSA officials, the reasons why the number of on-board
aviation and cargo inspectors varied from fiscal years 2005 through
2008 are uncertain. 

* Officials attributed some of the variation in on-board aviation
inspectors, from 680 in fiscal year 2006 to 554 in fiscal year 2007,
to inspectors switching to cargo TSI positions; transfers to other
agencies within DHS, such as U.S. Customs and Border Protection; 
and attrition. 

* Officials noted that because they did not track the reasons why
inspectors have left aviation or cargo TSI positions, they could not
provide documentation of these reasons. 

On-board numbers of both aviation and cargo TSIs remained below levels 
authorized by TSA in each fiscal year from 2005 through 2008. TSA 
officials noted that the agency is still actively recruiting to fill
vacant positions. The officials could not provide data or documentation 
explaining why vacant positions remained unfilled. 

Regarding TSA-authorized positions, TSA officials noted that the
number of aviation TSI positions that TSA authorized has varied
because TSA management’s views about the number of TSIs needed
for the program have changed each year. For example, TSA officials
told us the following: [Footnote 12] 

* For fiscal year 2006, TSA decreased its number of authorized
aviation TSIs from 882 to 681 positions. TSA officials noted that
the agency was able to operate the program in fiscal year 2005
with 601 inspectors, but that an authorized number of 681
positions in fiscal year 2006 would leave room for some growth in
the program. 

* For fiscal year 2007, TSA dropped its number of TSA-authorized
aviation TSIs slightly to 657 positions to reflect management
perceptions about the need for more cargo versus aviation TSIs. 

According to TSA, the number of cargo TSI positions it has authorized
has increased primarily because of congressional direction. Around
2005, cargo began moving to the forefront of aviation security
concerns as it was a largely unscreened sector of aviation security (as
opposed to passengers and baggage, for which TSA had basically
completed its screening mandates). As a result of these concerns,
TSA authorized 300 cargo TSI positions in fiscal year 2006, an
increase of 50 percent from fiscal year 2005.[Footnote 13] 

Results: Achieving Required Inspection Objectives: 

TSA does not have a reasonable basis for determining the TSI
workforce needed to achieve inspection goals. According to TSA
officials, TSA does not have a human capital or other workforce plan
for the TSI program, but the agency has plans to conduct a staffing
study in fiscal year 2009 to identify the optimal workforce size to
address its current and future program needs. In addition, not all
inspection goals have been achieved. 

According to TSA officials, the TSI staffing study is to be conducted as
part of a larger human capital contract awarded in July 2008 to
Lockheed Martin. In response to a draft of this report, TSA noted that
the study: 

* will include a full workforce analysis, including TSI management
and classification; 

* will determine the number of TSIs needed and effective TSI
placement; and; 

* is scheduled to be conducted in the second quarter of fiscal year
2009 with the results due to the agency in the third quarter of
fiscal year 2009.[Footnote 14] 

Our discussions with airport officials during our two site visits and 
with TSA’s Office of Compliance officials provide examples that support
the need for TSA to examine workforce planning issues. 

* According to officials at both airports, each experienced workforce
planning-related challenges in meeting inspection goals, in part 
because of increased TSI responsibilities and low numbers of TSIs. TSA 
officials at these airports told us that to overcome these challenges, 
at times the airports shifted cargo TSIs to assist aviation work or 
requested overtime from TSA headquarters. 

* According to officials from the Office of Compliance, some airports
used inspections conducted as part of VIPR and cargo strikes in
addition to routine inspections in order meet inspection goals. They 
also said that some airports utilized TSIs from nearby airports to meet 
their RAP inspection goals. 

Future TSI workforce needs will also be affected by additional 
responsibilities in the cargo area. 

* TSIs will be responsible for inspections as part of the Implementing 
Recommendations of the 9/11 Commission Act of 2007 requirement that TSA 
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 15] 

* TSA officials stated that there may not be enough inspectors to 
conduct compliance inspections of all entities, which TSA officials 
stated could number in the thousands, once the 100 percent screening 
requirement is fully implemented by August 2010.[Footnote 16] 

As a result, in July 2008 TSA anticipated requesting funds for an
additional 150 cargo TSIs for fiscal year 2010 to supplement its
existing allocation. However, in commenting on a draft of this report,
TSA officials told us that they have not yet quantified cargo TSI
requirements for fiscal year 2010. 

According to TSA officials, planned inspection goals for aviation
inspections were achieved in fiscal year 2007. However, these
officials noted that TSA did not achieve its planned cargo inspection
goals because, among other reasons, it had not filled all of its TSI
cargo positions. For example, in fiscal year 2007, of the approximately
30,000 inspections planned, about 3,000 were not conducted. 

Cargo inspection goals were not met in fiscal year 2007 for several
reasons, according to TSA officials. These include: 

* authorized cargo TSI positions were not all filled—12 to 15 cargo
TSI positions were vacant throughout 2007; 

* new supervisory cargo TSIs were unable to conduct assigned
inspections while also performing supervisory duties; 

* vacancies existed in the Cargo Inspection and Program Oversight
Office at the headquarters level—between four and eight cargo
TSIs could not complete inspections because they were detailed
to TSA headquarters during 2007; and; 

* several enforcement cases against cargo entities took time away
from inspection duties. 

TSA could not provide documentation identifying the extent to which
the agency met its aviation and cargo inspection goals for fiscal year
2007 or the reasons why goals were not met. 

Some planned aviation and cargo inspection goals were not met in
fiscal year 2008 while others were exceeded. TSA officials speculated
that poor planning or unplanned inspections contributed to this
situation. 

TSA officials stated that they are currently reviewing the fiscal year
2008 data and plan to meet with program managers to determine the
underlying reasons why goals were not met. For fiscal year 2009, TSA
officials told us that headquarters officials are to review inspection
activity at 4-week intervals for any trends that may indicate problems
meeting inspection goals. 

TSA officials attributed some inspection goals being exceeded in fiscal
year 2008 to changes during the year in inspection emphasis at the 
local or national level that were not anticipated when the RAP was 
developed. For example, presidential nomination conventions may have 
led to an emphasis on additional airport inspections and outreach to 
aviation organizations, resulting in some other areas receiving fewer 
inspections. 

[End of section] 

Agency Comments: 

We provided a draft of this report to DHS for comment. In response to
this draft, we received written comments (see enclosure II). DHS 
provided additional information related to its planned workforce study 
and some technical comments, which have been incorporated as 
appropriate. 

[End of section] 

GAO Contact: 

Should you or your staff have any questions on the matters discussed
in this briefing, please contact Cathleen A. Berrick at (202) 512-8777
or berrickc@gao.gov. 

[End of section] 

Appendix I: Aviation and Cargo TSI Major Duties, as of September 2008: 

The following duties apply to both aviation and cargo TSIs: 

* Conducts comprehensive inspections of all parties, airports and 
aircraft operators and indirect air carriers, subject to federal 
regulations involving transportation security. 

* Performs complex and technical inspections of all regulated parties to
determine overall security posture and compliance. 

* Monitors compliance with applicable security policies, regulations, 
and agreements to identify potential problem areas or deviations from
prescribed standards. Ensures overall adequacy, effectiveness, and
efficiency of security posture and TSA-approved security programs. 
Identifies and responds to security violations or potential violations. 

* Responds to transportation security incidents and other incidents as
defined by the National Incident Management Systems or as directed by
the Federal Security Director. 

* Performs technical reviews and analyzes and makes appropriate
recommendations concerning security measures implemented through
TSA-approved security programs. 

* Conducts outreach to encourage best security practices by regulated 
and nonregulated entities. 

* Performs tests and audits and validates and inspects security 
processes, procedures, systems, and equipment in connection with 
compliance inspections and vulnerability assessments. 

* Prepares written analysis of inspections and assessments, and
determines the adequacy of corrective measures required to improve
security posture or to restore compliance. 

* Conducts civil investigations related to alleged or suspected security
violations. 

* Identifies, collects, and preserves evidence used to support 
enforcement actions. 

* Determines when enforcement action should be initiated, prepares
enforcement investigation reports and recommends to TSA counsel the
type of action and level of penalty commensurate with the nature and
severity of the violation. 

* Provides testimony and participates in enforcement proceedings. 

* Enters data pertinent to investigations, inspections and incidents 
into the national database, Performance and Results Information System. 

* Reviews and analyzes assessment reports and testing results, paying
specific attention to identifying unusual trends or actions that appear 
to have the potential for developing a security/safety problem. 

* Formulates recommended or alternative courses of action to be pursued 
by regulated parties in order to satisfy security requirements. 

* Evaluates the integration of new technology, traditional measures, and
human factors to ensure operational effectiveness and efficiency of the
overall security system. 

* Develops and authors circulars and letters of instruction to airports 
and air carriers. 

[End of section] 

[End of enclosure] 

Enclosure II: 

U.S. Department of Homeland Security: 
Washington, DC 20528: 

February 2, 2009: 

Ms. Cathleen A. Berrick: 

Managing Director, Homeland Security and Justice: 
Government Accountability Office: 
441 G Street, NW: 
Washington. DC 20548: 

Dear Ms. Berrick: 

The Department of Homeland Security (DHS) appreciates the opportunity 
to review and provide comments on the Government Accountability 
Office's (GAO draft report GAO-09-123SU titled Aviation Security Status 
of Transportation Security Inspector Workforce. Your reported findings 
will be useful in guiding the Department's future Transportation 
Security Inspector (TSI) staffing decisions. 

As you report, the TSI workforce is a crucial element of our Nation's 
layered transportation security effort. Consequently, it is important 
that TSIs are deployed in numbers and to locations that optimize their 
effectiveness in thwarting terrorist attacks. Not only has the 
Department, specifically the Transportation Security Administration 
(TSA), hired. trained, and fielded a robust national TSI workforce over 
the past 5 years. but our TSI cadre's performance has been, and 
continues to be, exemplary. Though we have gone to great lengths in 
developing a vital TSI program, we welcome your suggestions for 
improvement. 
 
Your report suggested that to correct a shortfall in the number of 
inspections we targeted for TSIs in 2007 and 2008, we undertake a TSI 
stalling study having a defined scope and timeframe. As you are aware, 
'USA has contracted with Lockheed Martin to complete a comprehensive 
TSI staffing study in 2009. The study will have two prongs: (1) a full 
workforce analysis. including TSI management and classification: and 
(2) a determination of the number of TSIs needed and effective TSI 
placement. The study is scheduled to be conducted in the second quarter 
of fiscal year (FY) 2009. with the results made evadable to TSA in the 
third quarter of FY 2009. We look forward to reviewing the study's 
results. 

As you acknowledge in your report, however, the shortfall in TSI 
inspections is attributable to our Nation's shifting transportation 
security landscape. Our risk-based approach to transportation security 
emphasizes TSI flexibility and mobility. TSIs often are deployed when 
and where intelligence and other sources determine they are most 
needed, even if those deployments deviate from the annual inspection 
goals projected for them. For example. TSA assigned numerous TSIs to 
the 2008 Presidential conventions, resulting in a shift from 
inspections in other areas. 

We would like to clarify the following facts listed in your report: 

* Contrary to the report's findings, TSIs are not yet responsible for 
monitoring and enforcing aircraft repair stations' compliance with 
transportation security requirements. A notice of proposed rulemaking 
to establish security regulations for aircraft repair stations is under 
review. 

* The report states that in 2007. This were assigned the additional 
duty of testing airport compliance with the transportation security 
regulations. Airport testing has always been an element of our 
inspections. 

* TSA has not projected that it will submit a budget request for 150 
additional Cargo TSIs for FY 2010. contrary to the report's findings 
Our TSI-Cargo requirements for FY 2010 are being considered under the 
budget process. 

The Department of Homeland Security is committed to staffing the most 
effective TSI workforce possible and will carefully consider any GAO 
recommendation designed to assist us in meeting that commitment. We 
appreciate the opportunity to provide comments on this draft report and 
look forward to working with you on future homeland security issues. 

Sincerely, 

Signed by: 

Jerald E. Levine Director: 
Departmental GAO/OIG Liaison Office: 

[End of enclosure] 

Footnotes: 

[1] Aviation TSIs focus their efforts on airports and the passenger
operations of air carriers, while cargo TSIs focus their efforts on 
air carriers’ cargo operations as well as organizations involved in 
air cargo transportation such as indirect air carriers. 

[2] An indirect air carrier (IAC) is any person or entity within the
United States that engages passenger air carriers to transport 
property. Examples include United Parcel Service of America, Inc., and 
FedEx, but not the United States Postal Service (USPS) or an entity 
acting on behalf of USPS. 

[3] Two categories of TSA inspectors—surface and international 
TSIs—were not included in this review. Surface TSIs inspect security 
programs associated with surface transportation, such as freight 
railroads. International TSIs conduct inspections for foreign airports 
and the international operations of both foreign and U.S.-based air 
carriers outside the United States. 

[4] GAO, Human Capital: Key Principles for Effective Strategic 
Workforce Planning, [hyperlink, http://www.gao.gov/products/GAO-04-39] 
(Washington, D.C: Dec. 11, 2003); GAO, Maritime Security:Coast Guard 
International Port Security Program Has Made Progress, but Additional 
Workforce Planning Is Needed, [hyperlink, 
http://www.gao.gov/products/GAO-08-335SU] (Washington, D.C.:Apr. 4, 
2008); GAO, A Model of Strategic Human Capital Management (Exposure 
Draft), [hyperlink, http://www.gao.gov/products/GAO-02-373SP] 
(Washington, D.C.: March 15, 2002); and Project Management Institute, A 
Guide to the Project Management Body of Knowledge, Third Edition 
(2004). 

[5] GAO found, and TSA acknowledged, that workload hours associated 
with certain activities may not be fully captured in the summary 
description of workload hours as reported by TSA. TSA reported that the 
agency is making improvements in how it collects these data. 

[6] TSA could not provide information reflecting any changes to TSI 
roles and responsibilities from fiscal year 2003 through fiscal year 
2006. 

[7] In fiscal year 2006, TSA also determined that TSIs would be 
responsible for the inspection of aircraft repair stations. However, 
according to TSA officials, aircraft repair stations will not be 
inspected until TSA publishes an aircraft repair station final rule. 
TSA anticipates publishing a Notice of Proposed Rulemaking to this 
effect in fiscal year 2009. 

[8] ASAP is a locally generated assessment at airports using inert 
bombs, bomb parts, and other threat items to identify weaknesses in the 
screening process in order to strengthen screening performance through 
training, procedures, or technology. 

[9] TSA-authorized levels denotes the number of TSI positions that TSA 
expected to fill based on anticipated funding levels each fiscal year. 

[10] In fiscal year 2006, TSA also determined that TSIs would be 
responsible for the inspection of aircraft repair stations. However, 
according to TSA officials, aircraft repair stations will not be 
inspected until TSA publishes an aircraft repair station final rule. 
TSA anticipates publishing a Notice of Proposed Rulemaking to this 
effect in fiscal year 2009. 

[11] Airport strikes involve marshaling additional TSIs to perform 
localized inspections. 

[12] officials could not provide documentation to support how these 
staffing determinations were made. 

[13] TSA officials could not provide any documentation to support how 
its authorized staffing determinations were made for cargo TSI 
positions. 

[14] TSA did not provide any additional details such as a project 
statement or other documentation identifying which entities are to 
perform these tasks and the related time frames. TSA officials noted 
that Lockheed Martin is preparing a draft project statement to support 
its contribution to the TSI workforce planning study, and that TSA’s 
Office of Human Capital is to prepare an additional project statement 
for another of TSA’s onboard contractors to conduct a job analysis of 
the TSI position. 

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

[16] GAO, Aviation Security: Transportation Security Administration May 
Face Resource and Other Challenges in Developing a System to Screen All 
Cargo Transported on Passenger Aircraft, [hyperlink, 
http://www.gao.gov/products/GAO-08-959T] (Washington, D.C.: July 15, 
2008). 

[End of section] 

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