Back on the 9th of January 2007 the United States Congress passed the Implementing Recommendations of the 9/11 Commission Act (9/11 Act). The 9/11 Act was signed into law, as Public Law 110-53, by the President on the 3rd of August 2007.
Included in the 9/11 Act was the Certified Cargo Screening Program, an initiative that required that by the 1st of August 2010 100% of all air cargo flown on passenger flights be screened for explosives. The task of implementing the 100% screening of cargo shipped on commercial flights fell to the Transportation Security Administration (TSA) who as of today is trumpeting that the implementation of the Certified Cargo Screening Program as a complete success … however the success story only exists on paper.
On the surface the Certified Cargo Screening Program (CCSP) is a success, except for a number of troublesome gaping holes in the security of the cargo this program is designed to protect. As the TSA is not equipped to screen each piece of cargo for transportation on passenger flights it has certified more than 900 facilities in the United States to screen cargo to meet the CCSP requirements. Companies, primarily industrial shippers, manufactures and freight forwarders volunteered to become CCSP certified because the TSA would allow manufactures and industrial shippers to screen their own cargo for explosives in house, during the packaging process.
By performing in-house CCSP screening, manufactures and industrial shippers can package their pallets in-house as they normally would, check the pallet for explosives internally and avoid screening backlogs at the airport. This process not only expedites the supply chain, but it also reduces costs and it keeps the TSA from becoming involved in the freight movement process.
In the CCSP process, a certified shipper must supply a chain of custody that each shipment is documented, the company must also ensure cargo is secure and maintained through the shipping process, from CCSP screening to aircraft. Certified shippers must authenticate the methods they used up transfer of shipment from party to party throughout the supply chain.
Those qualified to apply for CCSP certification include Manufacturers, Warehouses, Distribution Centers, Third Party Logistics Providers, Indirect Air Carriers, Airport Cargo Handlers and those setting themselves up as Independent Cargo Screening Facilities.
On the surface the Certified Cargo Screening Program seems to be doing well. On the surface the TSA can publicly state it has reached 100% air cargo screening for all cargo flying on passenger flights…
…except that it can’t.
Allowing the screening for explosives to be undertaken by independent shippers, especially certain shipping facilities that are likely to have high turn over of employees by industry standards, such as shipping warehouses and shipping distribution centers is problematic. Additionally, once a facility hands its CCSP screened cargo off to a third party trucking company, or logistics handler, the chain of custody on paper may be secure, but the actual cargo its self is exposed to potential tampering or contamination in a non-secure environment.
Following a package from a CCSP certified manufacturer shows many gaps in the secure custody of the cargo. A pallet leaves a CCSP certified distribution center on to a truck, from the truck the pallet is transferred to a warehouse, to another truck, to an airside airport facility which loads it on a truck that brings the pallet to the ramp beside the plane. This single CCSP ‘screened’ pallet, just one shipment, leaves the actual CCSP ‘screened’ cargo exposed multiple times.
Even if a CCSP ‘screened’ pallet travels from a CCSP certified warehouse to the airport, plane side, on a single truck, the destination of the pallet is known to the driver, as well as multiple other people and is outside of a controlled environment for a length of time long enough for the cargo to be tampered with … even if it is only five minutes.
The problem with CCSP is that it leaves to many gaps to be covered. Even if a shipper is known, and a facility is certified, the cargo its self is exposed and prone to interference multiple times in the process.
The TSA has done an excellent job in training more than 450 canine teams, with more than 120 canine teams deployed specifically to work in high traffic airport cargo facilities. 120 cargo dedicated canine teams, while sounding impressive, is not nearly enough to search even a fraction of the CCSP ‘screened’ cargo destined for transit on a passenger flight.
While maintaining supply chain is important to international commerce and our global economy, it is the economics of the CCSP program that make it designed to fail from the outset.
If a warehouse gets behind, they are likely to seal a crate or pallet without following all the CCSP steps. If an air forwarder is in a hurry and gets an expedite call from a known client, they’ll skip some steps and get the CCSP freight off to the airport.
An often over looked gap in the Certified Cargo Screening Program … international cargo coming off in-bound international flights and transferring to U.S. domestic flight. International transfer cargo is not likely to be inspected. With countless in-bound international flights arriving in the United States each day with cargo transferring to U.S. domestic flights, this is one more layer of the Certified Cargo Screening Program not achieving the required 100% rate.
Given the logistical complexities of shipping freight on passenger flights, the likelihood of a shipper using cargo as an effective weapon is minimal.
Given the knowledge provided to ‘low level’ workers regarding the flight a cargo container is destined for…the threat largely remains in the hands of those handling the cargo after it has been screened under the Certified Cargo Screening Program.
Cargo should be security cleared before it flies, however the current Certified Cargo Screening Program is not the system that will be the most effective in protecting a global civilization in transit.