The constantly changing landscape of global aviation security poses unique challenges and opportunities to security technology manufacturers. As regulators attempt to stay ahead of the growing threat to aviation security, they are often met with funding challenges and physical, not to mention practical, limitations to deployed technology. When a new threat is discovered, regulators take the necessary measures to identify and test the technology that best serves to mitigate the risk. Quite often however, the threat condition is compromised by the time it takes to get a technology through lab testing and into the field.
This dynamic is particularly challenging in the air cargo screening realm, where the regulators test and certify equipment, but the screening technology is purchased by private entities. Steps should be taken to identify and develop a new generation of cost-effective air cargo screening technology solutions that have significantly better detection and operational capabilities.
Air Cargo Screening Regulatory Background
In the Aviation and Transportation Security Act (ATSA) law, the government is required to screen 100 percent of air cargo commensurate with hold baggage screening. Further to the ATSA law, as part of the implementation of the 9/11 Commission Act of 2007, the U.S. Transportation Security Administration (TSA) mandated security measures on air cargo. The final August 2010 mandate, which is unfunded, requires one hundred percent screening of airfreight at piece level and limited screening of palletised cargo on commercial aircraft.
As the responsibility for screening air cargo ultimately fell to the airlines and Indirect Air Carriers, the concern from the industry was that increased screening would create bottlenecks in the supply chain and impact commerce. In response to this concern, TSA has allowed airlines, as well as freight forwarders and third parties, to become Certified Cargo Screening Facilities (CCSFs) to physically screen cargo using approved screening methods and technologies, essentially pushing the screening requirement further up the supply chain. CCSFs must carry out a TSA approved security programme and adhere to a strict chain of custody requirements. Cargo must be secured from the time it is screened until it is placed on passenger aircraft for shipment.
Current Screening Measures
Under the current air cargo screening programme, X-ray, physical search, and Explosive Trace Detection (ETD) qualify as screening methods to comply with the TSA mandate. TSA took a leadership role in qualifying security technology and the Air Cargo Security Technology List (ACSTL) was developed to give organisations choices in purchasing screening technology for their compliance needs. The ACSTL is divided into three sections: a ‘qualified technology’ section, an ‘approved technology’ section, and a ‘grandfathered technology’ section.
The ‘qualified technology’ section specifies devices, by technology, which have undergone a formal TSA sponsored test process and are deemed qualified for screening operations. When procuring a device from the ACSTL, regulated parties are encouraged to select a device from the qualified technology section.
The ‘approved technology’ section specifies devices, also by technology, which have been conditionally approved for screening operations and are currently undergoing or are scheduled for field test activities. These devices have up to 36 months from the date added to the approved technology section to successfully pass TSA’s suitability-based field test activities. If a device is unable to pass field test activities within the prescribed 36 months, it is removed from the approved technology section on the specified expiration date. Due to this fact, regulated parties who procure a device from the approved technology section do so at their own risk.
TSA notes that additional technologies may be added to the approved technology section at TSA’s discretion. The ‘grandfathered technology’ section specifies devices, which are currently qualified to screen cargo but have a stated expiration date. This allows regulated parties who are using the grandfathered technology an opportunity to gradually phase out the device and transition to devices listed in the qualified or approved sections. Due to this fact, regulated parties should use caution if planning to purchase devices from this section. They may consider instead referencing the qualified or approved sections for their procurement needs. There are 16 manufacturers listed on the ACTSL and over one hundred products. However, many of the screening technologies listed were not specifically designed for the many complex configurations of air cargo, including commodity type and density levels.
“…many of the screening technologies listed were not specifically designed for the many complex configurations of air cargo, including commodity type and density levels…”
Most of the products on the list were designed primarily to screen cabin and hold baggage at much lower density levels. Additionally, air cargo organisations are often faced with having to choose between several types of products for the different types of air cargo they are moving. This can be a drain on resources as often the air cargo organisation must buy several different types of technology to meet their needs.
So what can be done?