Secure Air Cargo Solutions

Air Cargo Screening and Security: A Collaborative Solution for Compliance

Mon, 02 Nov 2009 10:09:07 -0500

Air Cargo Screening and Security: A Collaborative Solution for Compliance

Erik Hoffer, President, CGM Security Solutions, Inc.

Walt Beadling, Managing Partner, Cayuga Partners LLC

Introduction

On August 3, 2007, President Bush signed the 9/11 Act (1) into law with the objective of protecting the United States from terrorist attacks. The legislation, nearly 6 years in the making and 286 pages in length, is well-intentioned, complex and sweeping in scope, yet often lacking in detail.

In particular, those sections related to improving air cargo security are long on what and when, but woefully short on how. Given the ambiguity of the legislation, enormity of the task and the cost and number of players involved, it is not surprising that little substantive progress toward compliance has been made to date.

The objective of this document is, therefore, three-fold:

1. To help both industry and the airlines to better understand the 9/11 Act as it relates to air cargo security, and how they can work within its provisions to help secure our borders and citizens from terrorist attacks using air cargo as a delivery method.

2. To propose a proven, cost-effective solution that can preempt, and prevent, terrorist attacks using air cargo, thereby protecting passenger aircraft carrying cargo, and meeting the objectives of the 9/11 Act within the stated time frames.

3. To establish a consortium of concerned parties � shippers, carriers, industry groups and technology providers � to endorse, and rapidly deploy, this solution as a de facto industry standard.

Overview of the 9/11 Act Legislation and Cargo Screening Program

Regarding improving air cargo on passenger jets and freighters, the law states that 50% of all cargo must be screened to provide a level of security �commensurate with that of passenger checked baggage� within 18 months of enactment (by February, 2009) and 100% within 3 years (by August, 2010). The 100% screening requirement has already taken effect for parcels on narrow body passenger aircraft.

The law places the onus of inspection on the shipper first, the carrier second and lastly those who would assist, for a fee, the other two in screening and subsequently securing cargo to be delivered to a commercial passenger liner for transport. The law does not deal directly with freighter aircraft or the goods that are shipped on freighters, nor does it address couriers, 3PL�s, forwarders and other consolidation facilities that ship air cargo throughout the United States. Further, the law applies only to domestic cargo; obviously we cannot impose, or enforce, U.S. supply chain security standards outside our borders. We must therefore rely on other countries, delivering cargo by air to our shores, to do it in a like manner

In an effort to increase screening capacity, relieve the burden on air carriers and expedite the �flow of commerce�, in early 2008 the Department of Homeland Security�s Transportation Security Administration (TSA) announced the Certified Cargo Screening Program (CCSP), a voluntary program designed to enable vetted, validated, and certified supply chain facilities to screen cargo and thereby increase screening capacity and expedite flow of commerce(2). The CCSP is a facility based program for supply chain entities located domestically, within the borders of the United States. Any facility that tenders cargo directly to an air carrier or indirect air carrier (IAC) may apply to become a CCSF, including manufacturers, warehouses, distribution centers, third party logistics providers (3PL�s), indirect air carriers, airport cargo handlers and independent cargo screening facilities.

The Problem

At this writing it appears highly unlikely that the program objectives will be met within the prescribed timeframes, despite the TSA�s efforts to develop, and pilot, viable screening solutions.

In 2008, an estimated 45 billion Revenue Ton Miles (RTMs) of cargo will be shipped by air within, to, and from the U.S. Given the sheer volume of cargo to be processed and loaded onto aircraft, full electronic screening, as required for passenger baggage, presents significant logistical and operational challenges - and the size and complexity of the air cargo system continues to grow (3).

The operational detail of the 9/11 Act regarding air cargo security, specifically how to inspect cargo and under what conditions, and then how to secure, seal and ensure the chain of custody for inspected cargo, is grey and undefined. At a U.S. Security Conference hosted by Lufthansa Cargo on September 30, 2008, Ed Kelly, the Transportation Security Administration's General Manager, declared that the specific inspection machinery to be used, and how to employ it, is still being determined (4). Adding to the confusion are different requirements and standards for screening shipments on passenger aircraft and cargo carriers.

Despite a lack of specifics regarding the process and an obvious need for clarification, elements of the law have not yet been challenged by shippers or carriers.

Vague, poorly defined processes and procedures

The problem begins with the vague definition of terms in the inspection process itself, e.g., what, exactly, is a �piece of cargo�? Is it an entire air pallet, or a single box? What happens when cargo is interlined, and the air pallet has to be broken? Does this mean that all of the cargo has to be re-screened as single parcels? If so, the argument can be made that all cargo in single units, or in bulk, be screened simultaneously as a unit of measure if destined for the same consignee. In any case, it is known that there are very few ways to securely seal a corrugated box that are compliant with this law.

The inspection process is further compromised by a lack in standardization and consistency of use among the various types of machines installed at different airports. The variability of an inspection process that uses different machines, inspecting different packages for different variables in different ways, calls into question the feasibility of the assumed process and controls mandated by law vs. the ability of personnel and availability of facilities and equipment to accomplish the task. Peter Harris, VP of Strategy and Development at Analogic Corporation, one of the manufacturers involved in screening equipment pilots, affirms that a �concept of operations� - how to do actually do this in and around an airport - has yet to be defined by the TSA(5).

Expensive, complex, unproven technology

The machinery required for inspecting a full air pallet or LD3, though similar to that used for passenger screening, is more massive, complicated, expensive and slow; the availability of space and facilities, throughput rates, cost of inspection and the ability to secure closures are l problematic.

If and when a particular type of equipment is specified, deployed and used by everyone equally, what will happen as technology advances, or the threat becomes more sophisticated, rendering the chosen technology obsolete? Who will fund the necessary modifications, upgrades or replacements, and moreover, who will fund the initial purchases and implementation, given the current state of the art and cost? Brandon Fried, Executive Director of Airforwarders Association (AfA), it may cost up to $200,000 per location to comply with CCSP, a heavy burden for small to medium-sized forwarders to assume without financial assistance, which can only come from our financially-challenged federal government.

Further, because the technologies currently in use have been designed to screen passenger baggage, it is not certain how effective they will be in air cargo applications. According to Fried, none of the technologies tested so far has proven suitable for screening the dense loads typical of industrial shipping, from stacked machine parts to boxes piled on pallets or tightly packed in metal containers(5).

Coordinating a multitude of new supply chain players

There are three supply chain communities that must adhere to the TSA�s CCSF mandate: the shipper, who will soon become known as a Certified Shipper (effectively eliminating the current �Known Shipper� Program); the Certified Screening Facility and the Certified Air Carrier.

The first line of defense is the Certified Shipper; to comply with the law he must:

1. In most cases, completely reengineer his infrastructure and facilities to create a secure environment with vetted personnel, fences, gates, locks, guards and cameras.

2. Ensure that no one is allowed into his facilities without authorization, and that no one except trusted employees inspect, pack and seal his cargo.

If this is done to according to TSA standards, his goods can pass �GO� and then be moved, by a secure, vetted and certified carrier, directly to the airlines for shipment. The Certified Shipper must also strictly adhere to the recommended best practices for secure sealing. The TSA has yet to produce a document that specifies exactly what these best practices are, however.

This next step in the process will come under purview of dedicated service providers soon to be known as Certified Inspection Facilities. These controlled access areas will be popping up throughout the USA, first at the major gateway airports - SFO, LAX, ATL, JFK, MIA - and later others, as they become necessary. Certified Inspection Facilities will be managed by independent companies that currently have locations at these airports, secure facilities or ones that will soon become secure, and also those eager to provide this service at a fee to any shipper or carrier in need of it .

This new process will totally disrupt commerce by air as we know it, because many items are shipped through non-gateway airports and by unwilling carriers and uncertified shippers, which will cause a great deal of cargo to be re-routed by unsecured surface transportation to its destination, or shipped as commercial freight, all at a higher cost and at a slower speed.

By necessity, Certified Air Carriers (to be) have been assuming the burden of compliance to this point, but this initiative will be short lived. The cost of such operations in manpower, infrastructure, machinery and facility space makes the prospect daunting for most carriers, and the costs for commercial shippers will be far higher than current levels; the current economic downturn further exacerbates this problem. Such cost increases will put many small shippers at a competitive disadvantage, and will move some portion of the supply chain flow to trucks and other modes of transportation. The next major shakeup in air cargo will come when air carriers are forced to reject tendered cargo because of they are unable to screen it in the volumes delivered thereby causing irreparable harm to shippers and lost revenues to carriers, all in the name of security.

Conflicting approaches and programs

Forcing compliance of foreign nations and carriers poses another difficult dilemma, and exposes further shortcomings in the legislation. Will U.S. carriers who interline be required to do the inspection job of their foreign counterparts when these good arrive and are trans-shipped domestically?

Concurrently, we are trying to protect our borders through the voluntary Customs-Trade Partnership Against Terrorism (C-TPAT)(6), first announced in November, 2001, that provides incentives for shippers to participate by expediting the passage of their cargo through customs and speeding supply chain flow. This �carrot� approach contrasts with the �stick� of 9/11 Act cargo screening provisions that allows no threshold for compliance; they are mandatory and absolute, failure to adhere will result in costly fines to those who ignore the law. Will these programs come into conflict, and if so, which will prevail? Whether we can harmonize the security countermeasures of our foreign partners into an effective, compliant system remains to be seen.

Poorly defined processes and procedures; complex, expensive, unproven technology; a multitude of players; conflicting approaches and programs; yet perhaps the greatest flaw in the legislation is its reliance on a single approach to air cargo security: screening, which may be suitable for human traffic, but, largely due to chain of custody issues, is problematic for air cargo.

A Proposed Solution

Speaking at the recent Lufthansa-sponsored security conference, R. John Hansman, Professor of Aeronautics, Astronautics and Engineering Systems at MIT, referenced Reason�s "Swiss cheese" model(7) to promote a more comprehensive approach to cargo security. It's a layered approach using multiple techniques; whereas one screening method might be 80% effective, it can be 99%+ effective when combined with other solutions that have different vulnerabilities. In other words, by adding layers � or �slices� - to the air cargo security system, it will be almost impossible for evil-doers to find any holes in it.

Also speaking at the conference, Dwayne Baird, TSA spokesperson and public affairs manager, noted that speeding up supply chain flow through commercial and cargo airlines while maintaining security is a recognized concern and key objective of the program. "We want [shippers] to have equipment that can screen large volumes of goods offsite and certify the cargo as secure. As long as they maintain the chain of custody from their facility to our airport, we can consider that shipment as screened and secure."(8) The critical, yet unanswered question is, how can the objective of establishing, and ensuring, the chain of custody be achieved?

CGM Security Solutions Inc.(9) and its partners propose establishment of a consortium to develop and rapidly deploy a layered solution, that will, together with the mandated screening, meet � and exceed - the objectives of the 9/11 Act regarding air cargo security: the �Cargo Brick�. In addition to enhancing the effectiveness of the screening-only solution by ensuring the chain of custody, the Cargo Brick will reduce costs of compliance to shippers, and speed the flow of cargo through the supply chain. This solution currently exists, is proven, uses recommended techniques and materials, complies with the law, and is affordable and immediately available for use to anyone, in a wide variety of formats and configurations.

The CGM Cargo Brick Concept employs:

A pallet bag kit
A Topp Clip
Secure TRAC tape
Standard � � banding and crimping tool
A process for inspecting, securing cargo and ensuring the chain of custody

Pallet Bag

Pallet Bag sealed with Topp Clipp�

The pallet bag is a strong, clear poly bag made to accept a specific size of cargo units bundled into a consistent size bag and sealed for security as one unit. The ability of the bag to show tampering is excellent because it is clear, allowing for easy visual inspection of contents, and impenetrable without leaving an obvious mark. This also makes it compliant with the tamper evident mandate of the law, as described below.

The �Brick� concept also is a tremendous asset to air carriers in bulking out freight in a consistent form, making cubing out an aircraft, or an air pallet, becomes easier and far more efficient. It facilitates the carrier�s ability to visually inspect the freight throughout the logistical cycle in accordance with the mandates of the screening law. The Cargo Brick also reduces the time that carriers have to spend with the cargo, since it can be directly loaded without need of further scrutiny. The Cargo Brick can be made to comply with the size and weight parameters of the electronic inspection devices used by the air carriers or inspection facilities. This speeds up inspection flow as well as the loading and stripping out aircraft.

Indirect Air Carriers such as DHL, FedEx and UPS are perfect candidates for this type of packaging since many of their parcels are of a consistent size and shape and can be packed with this method seamlessly, with the equipment currently in place at their facilities. The USPS would also greatly benefit from this process as their mail sleeves are of a consistent size, weight and shape. These couriers can also create new services and profit centers by providing cargo inspection processes for their clients with a relatively small incremental investment.

Tamper evidency

At the recent Lufthansa Conference, Ed Kelly also said that sealing cargo with a tamper evident tape, such as that manufactured by CGM-AST and supplied by CGM Security Solutions, is an approved method to secure inspected cargo, and compliant with the both recommendations of the TSA and the 9/11 Act itself; so we know that tamper-evidency for cargo is mandated, and that these products provide a level of protection acceptable to TSA as compliant with the law. Experience has shown that screening, together with security seals including Topp Clips� and tapes, is inherently beneficial to all members of the supply chain, and the recipient most of all, through theft reduction and ensuring a secure chain of custody for unattended and nondescript cargo.

The collateral functionality of CGM�s security products provides users with both enhanced security and direct cost savings. Because this base security platform provides intrinsic benefits to everyone, all shippers should employ secure packaging techniques; and since air carriers and their customers must comply with the imperatives of the 9/11 Act, what better way to do so than with components endorsed by the TSA?

The recommended process uses CGM-AST�s Secure TRAC self wound, tamper evident tape as the primary means of closing boxes. With the following features, Secure TRAC tape is the ideal solution for packaging tamper-evidency and reliability for security throughout the logistical cycle:

As a primary closure, the tape securely seals any corrugated box.
The tape is sequentially numbered and made indigenous to the shipper, thereby further insuring its security and propriety, no matter who handles the cargo.
The tape shows the word �opened�, in any language, if peeled and cannot be resealed in cut.
The tape is made of silicone and cannot be resealed with conventional clear carton sealing tape.
It can be custom printed to define the user, the gateway, the client or the product in any way the shipper deems appropriate or effective.
The tape is machine dispensable and far stronger that conventional clear or colored carton sealing tape.
The sequential numbers allow for specific track and trace of individual boxes and provides a clear evidence of attempted penetration even if you have no idea what the number of the tape should be.
This product is an approved and compliant tamper evident system that is seamless to use and facilitates expediting your cargo through your supply chain regardless if it goes by air, land, rail or sea.

Certified Inspection Facilities can employ security tape on individual packages, but larger freight volumes will require the bundled, Cargo Brick approach. For those applications, and for shippers with larger bulk volume consignees, (such as pharmaceuticals, automotive, clothing and cigarettes) the pallet bag and Topp Clip� can be used to bulk out such cargo.

In summary, post-inspection integrity can only be achieved and maintained through the use of a robust, seamless containment system such as the Cargo Brick and/or self-voiding security tape. The use of proven, tamper-evident security products such as these establishes a clear and visually verifiable chain of custody making the shipper and his carrier compliant, and inherently safer, against many threats than they will be without them. Visibility, consistency, and verifiability throughout the chain of custody are prerequisites for effective security; these products, properly applied, create that condition.

Collaterally, any means by which a shipper uses to secure his cargo from the introduction of contraband is also effective against the removal of goods in the form of cargo theft. Cargo theft in the air industry is rampant, and has no defined remedy. Due to the speed with which air cargo travels, combined with the anonymity of the cargo and difficulty of the inspection task, most air cargo theft goes undetected until it reaches its destination at which time the theft is usually written off as a �mysterious disappearance�. These incidents are rarely covered by insurance. Hence, reduced exposure to theft is another, and potentially substantial, benefit of this approach.

Summary and Recommendations

It is unlikely that the 9/11 Act, which demands 100% screening of cargo carried on passenger aircraft by 2010, will be successfully, and effectively, implemented within this timeframe due to a lack of definition and direction in the legislation. More importantly, the singular, mandated approach � screening air cargo in the same manner as passenger baggage � will not provide the presupposed level of security. In any case, it is apparent that the burden of implementing a system to enable compliance and to achieve the broader goal of securing cargo, aircraft and passengers from terrorist acts falls, by default, squarely on private industry. The sooner a viable solution is found, the better for all concerned.

We therefore urge government and industry and leaders, including the TSA, shippers, logistics services providers and air carriers, to endorse, and immediately commence usage of, the Cargo Brick concept and tamper-evident products described above, as appropriate, to secure cargo carried on passenger - and freighter � aircraft within the U.S. and overseas. CGM Security Solutions will work with these leaders to develop and implement the protocols and support mechanisms required for rapid, effective deployment. The goal of this initiative is the adoption of these solutions, in concert with prescribed screening techniques, as standard operating procedures in the U.S. and, by extension, around the world.

Failing in this, it is hoped that the proposed solutions will be embraced as de facto industry standards, with the concomitant benefits of increased security from terrorist acts, prevention of theft, lower costs of compliance and expedited supply chain flow. Through a focused, collaborative approach to supply chain security we can quickly develop, manufacture and deploy the packaging solutions and processes needed to meet the requirements of the 9/11 Act and to better secure our world.

Notes

1. P.L. 110-53, �Implementing Recommendations of the 9/11 Commission Act of 2007�; http://www.ise.gov/docs/nsis/Implementing911_Act.pdf

2. Statement of Richard L. Skinner, Inspector General, U.S. Department of Homeland Security, before the Subcommittee on Homeland Security on Appropriations, U.S. House of Representatives, February 13, 2008; www.dhs.gov/xoig/assets/testimony/OIGtm_RLS_021308.pdf

3. CRS Report for Congress: Air Cargo Security July 30, 2007. http://www.fas.org/sgp/crs/homesec/RL32022.pdf

4. �TSA Ripped at Security Conference�, Air Cargo News, Volume 7, No. 110, October 6, 2008. http://www.aircargonews.com/081006/FT081006.html

5. �Security's Tools of the Trade�, Mike Seemuth, Air Cargo World Online, http://www.aircargoworld.com/features/0908_3.htm

6. �Securing the Global Supply Chain: Customs-Trade Partnership Against Terrorism (C-TPAT) Strategic Plan�, Customs and Border Protection, Washington DC, November 2004 http://www.cbp.gov/linkhandler/cgov/trade/cargo_security/ctpat/what_ctpat/ctpat_strategicplan.ctt/ctpat_strategicplan.pdf

7. James T. Reason, Human Error, Cambridge University Press, 1990. also: http://en.wikipedia.org/wiki/Swiss_Cheese_model

8. �Swiss Cheese Model for Cargo Screening? MIT Adds Voice to Security Debate�, Jessica Binns, Air Cargo World Online, http://www.aircargoworld.com/features/1108_3.htm

9. CGM Security Solutions Inc., www.secureaircargo.com

TSA is concerned about US shipper�s lack of impact awareness about 100% screening issues

Thu, 24 Sep 2009 05:07:43 -0400

TSA is concerned about US shipper�s lack of impact awareness about 100% screening issues (August 2010)
Background
The Implementing Recommendations of the 9/11 Commission Act of 2007 legislation mandates 50% screening of cargo that is transported by a passenger carrier by February 2009 and 100% screening of cargo that is
transported by a passenger carrier by August 2010. TSA is required to establish a system to ensure 100% of cargo transported on passenger aircraft is screened at a level of security commensurate to that of passenger
baggage. This requires screening at the piece level. Because this screening requirement is not supplemented by congressional funding, it is the air cargo industry�s responsibility to bear all costs.

Piece level cargo is the individual item within a shipment. Shipments tendered on skids and shrink- wrapped(typically transported on wide-body aircraft) must be taken apart so pieces can be screened. Most wide-bodycargo flows through freight forwarders (consolidators), who typically �containerize/palletize� this cargo prior totendering it to airlines. Airlines lack space/facilities to �de-palletize�, screen, and re-configure these shipments,
so if �airlines only� must screen all such cargo, they anticipate significant delays, increased processing/cut-off times and costs. Airlines and groups such as the Air Transport Association, and Air Forwarders Association
continue to confirm this concern.

Certified Cargo Screening Program (CCSP)
TSA�s approach to assist industry in attaining the screening mandates is the Certified Cargo Screening Program (CCSP). The CCSP was created to: allow screening of cargo early in the air cargo supply chain by a trusted,
vetted, and audited facility; initiate and maintain the integrity of a shipment throughout the supply chain by utilizing stringent chain of custody methods; and enable entities such as shippers to incorporate physical screening into the packing process.

Who Can Become a Certified Cargo Screening Facility (CCSF?)
Facilities that volunteer to participate in the CCSP program will be able to tender cargo directly to a passenger air carrier or freight forwarder. This includes: Manufacturers, Warehouses, Distribution Centers, Third Party Logistics Providers, and other similar facilities.

Industry Challenges for 100%
As of February 1, 2009, 50% of all cargo is screened at the piece level prior to being loaded on a passenger aircraft.

It may appear to shippers that the 50% mandate was met without significant challenges, but TSA believes they should consider the following issues:
o The economic downturn caused a 35% drop in the movement of cargo compared with 2007.
o Airlines still lack space/facilities to �de-palletize�, screen, and re-configure large shipments.
o Some commodities were screened by an alternate means for a limited time frame (until August 31st,2009).
o 85% of current screening entities (airlines and CCSF freight forwarders) utilize ETD as their primary method of screening. Alarm resolution for ETD (other than physical search) is challenging. There is a high risk of a physical inspection (opening boxes and removing content) resolution as a result of �contamination� while shipments are in forwarder or airline vehicles/docks
o Overall, airlines would not have attained the required percentage without the screening percentages contributed by CCSP freight forwarders, who also use ETD as primary method of screening.

As a result, TSA is concerned that shippers may wait until it is too late to surmount the challenges of August 2010, when 100% of all pieces must be screened individually. We have already seen a decline in applications
for the CCSP, and believe shippers should consider these facts:

o Screening the difficult, complex, skidded cargo still lies ahead - Most shipments screened today are not skidded/move on narrow body aircraft
o Economic recovery will lead to increased cargo volume - Screening 100% of 15 million pounds per day in August 2010 vs. screening 50% of 9 million pounds per day now represents a 300% increase in cargo requiring screening (return to 2007 levels)
o Possible insufficient availability of screening technology (backlogs) for forwarders and airlines
o High risk of airlines/forwarders opening shipments to resolve �contamination� alarms
o If too many shippers wait until the �last minute� to recognize challenges and apply for CCSP, TSA may not have resources to certify them in time for the August 2010 mandate.

TSA is providing an incentive for shippers to join CCSP now!
Shippers who apply and commit prior to September 2009, will be entitled to additional benefits.

Additional Information
For additional information or questions, shippers should visit our website at: http://www.tsa.gov/what_we_do/tsnm/ai...index.shtm or to request an application, email ccsp@dhs.gov.

Things to consider
Only CCSF shippers can ensure the integrity of their packaging and shipments in August 2010!
Only Cargo that is 100% Screened at the Piece Level will be Uplifted on Passenger Planes on August 1, 2010!

Congress has passed the Final Rule for 100% cargo screening for passenger aircraft

Tue, 15 Sep 2009 16:12:01 -0400

Congress has passed the Final Rule for 100% cargo screening for passenger aircraft. The law can be read by clicking here

For information on getting certified call or email CSA at ehoffer@securecargo.org

941 575 0243

Asian assessment of 100% screening

Wed, 09 Sep 2009 03:26:41 -0400

Our analysis:Beware nay-sayers, 100% cargo screening will happen and those who think that it will not affect them are going to be surprised come 8/1/10. If you want to guaranty your air cargo supply chain, get the training necessary to become a CCSF from CSA (Cargo Security Alliance). Please go to www.securecargo.org and find out what the CSA can do to insure the continuity of your business.

Asian cargo industry warns that US 100 percent screening rule threatens trade

By Max Kingsley-Jones

Asia's cargo industry is bracing itself for the impact of a new US regulation requiring 100% screening of air freight being flown into the country.

Amid concerns that the move could bring airport freight transfers to a standstill, one executive said that it threatens to severely disrupt trade and create huge costs to the industry if it goes ahead next year as planned.

The Transportation Security Administration will enforce the rule next August requiring all air cargo arriving in the bellyholds of passenger airliners to be physically screened - either through detection, x-ray, or canine or hand search.

Hong Kong International Airport's cargo manager B S Chow told delegates during the Air Freight Asia 2009 cargo conference at Asian Aerospace that if all the cargo screening was to be undertaken at airports rather than upstream at the supplier or manufacturer "then everything will be at a standstill".

Wally Nahr of Hong Kong Association of Freight Forwarding Agents warns that the rule "will totally disrupt trade to the USA, will have huge cost implications and force cargo to come into the country other ways".

Nahr said that while he believed that 100% screening would improve safety, it would not make cargo operations 100% safe.

This view was shared by every other member of the conference panel, which included David Fielder of air cargo association FIATA, who asks: "Does the cost warrant it on a risk/reward basis?"

Fielder points out that one way to circumnavigate the rule is to fly cargo into Canada, and then truck it across the border. Another is to fly freight on all-cargo aircraft as this does not have to comply with the TSA rule, but it cannot travel beyond its arrival airport by air without being screened. However, Fielder expects the TSA will look to include all-cargo aircraft in the longer term once the belly freight rule has been implemented.

Nahr, who says that the European Union has written to the US government to object to the regulation, believes that a major stumbling block is the fact that the TSA will not have sufficient manpower to complete the certification.

Industry sources expect that while it is unlikely that the USA will delay the timing of the 100% rule, it will work with companies and countries that cannot meet the deadline to avoid serious disruption

100% Cargo Screening on Passenger Aircraft

Wed, 19 Aug 2009 15:49:14 -0400

100 Percent Cargo Screening on Passenger Aircraft

Please Click Here to download Power Point Document

THE CHAOS IN AIR CARGO SCREENING

Mon, 30 Mar 2009 14:23:27 -0400

Readers interested in understanding the Federal laws and requirements for air cargo screening are invited to click on the link below.
By listening to this recording of the Congressional hearing on this topic which happened on 3/17/09, you will quickly understand what is and is not being done to secure our sky�s. The apparent chaos caused by the TSA�s indecision on a screening process is now under scrutiny by Congress.

Because there is yet no sustentative and, industry implementable plan, written and approved by TSA to comply with the law; shippers, forwarders, inspection facilities and carriers are left to their own devices as to exactly what to do to become compliant with the law as written. Since the plan and documents given to industry fail to identify an approved or mandated protocol on screening and sealing of cargo suitable to achieve the required chain of custody processes, we feel industry must take steps to defend itself from fines based on inaction.

As the manufacturer of tamper evident security products, specifically made for cargo, we feel that that a defacto sealing standard must become the responsibility of industry. We feel that if industry begins to use a process that it can control and is efficient and cost effective, that the TSA will quickly buy in and agree to make it acceptable. By selecting to use the Rigsecure process of tamper evident self adhesive sealing tape, security labels, pallet bags and topp clips, we can guaranty that you will be in compliance with the essence of the law as defined. Cargo must be physically screened to achieve a �clear passage� through to the aircraft, however without a means to inspect that cargo throughout the process, after physical examination, the systems falls apart.

CGM/Rigsecure has everything you need to get going and can help you decide on a cost effect plan to seal and move cargo.

Link: homeland.house.gov

Statement of John Sammon

Wed, 05 Nov 2008 11:27:54 -0500

United States Department of Homeland Security Transportation Security Administration
Statement of John Sammon , Assistant Administrator, before the subcommittee on Transportation Security and Infrastructure Protection Committee on Homeland Security, United States House of Representatives
July 15, 2008

Good afternoon Chairwoman Jackson Lee, Ranking Member Lungren, and distinguished members of the Subcommittee. I am pleased to be here today to discuss the progress the Transportation Security Administration (TSA) is making toward fulfilling the air cargo security provisions of the Implementing Recommendations of the 9/11 Commission Act of 2007 (9/11 Act), P.L. 110-53.

As you know, implementation of the 9/11 Act�s air cargo provisions�requiring the screening of 50 percent of cargo on passenger aircraft by February 2009 and all such cargo by August 2010�presents significant challenges. To meet these challenges, TSA is emphasizing effective security management of the entire air cargo supply chain by building upon our established programs: air cargo security regulations, standard security programs, security directives, information sharing, and increased use of TSA-certified explosives detection canine teams and Transportation Security Inspectors (TSIs) for cargo. Key to the success of our screening regime will be collaboration with stakeholders�U.S.-based shippers, freight forwarders, and passenger air carriers�through a program that will facilitate screening early in the supply chain using currently approved screening methods and stringent facility and personnel security standards.

TSA�s strategy involves every component of the air cargo shipping system�from the entity originating the freight to the freight consolidators/forwarders, airports, and finally to air carriers who transport the cargo�and the people involved in the process that have access to cargo at every point in the supply chain. The program is designed to harmonize with the international community, since a large portion of air cargo moves on international flights.

TSA is committed to meeting the 9/11 Act�s goals. And, when we meet the 50 percent goal, the vast majority of flights, carrying more than three-quarters of all passengers, will in fact be screened at the 100 percent level.
The 9/11 Act: Reinvention of Air Cargo Security

Approximately 12 million pounds of cargo is transported daily on passenger aircraft. To accommodate this considerable stream of commerce, TSA currently has in place a multilayered, risk-based system for securing cargo traveling on passenger aircraft. As required by applicable security programs and regulations, aircraft operators and foreign air carriers are now primarily responsible for screening a percentage of cargo transported on passenger aircraft. In addition, indirect air carriers (IACs) are required to screen or provide to TSA for screening, all cargo that meets certain high-risk criteria. Regardless of risk, TSA screens 100 percent of cargo at Category II-IV airports.

Currently, required cargo screening is conducted by aircraft operators and air carriers, using the following TSA-approved methods of screening: physical search with manifest verification, x-ray, explosives trace detection (ETD), explosives detection systems (EDS), and decompression chamber. Cargo consolidations built by aircraft operators and air carriers or accepted in that form from shippers and IACs are subject to random screening by TSA-trained and certified explosives detection canine teams. For unique cargo types that do not lend themselves easily to these established screening methods, TSA permits alternative screening methods to be employed, such as verification of the description of the cargo and matching the identity of the shipper with information contained in the shipping manifest.

Additional layers of security augment the required screening. For example, with very few exceptions, cargo may only be accepted for transport on passenger aircraft when there is an established business relationship between the shipper and accepting IAC, aircraft operator, or air carrier. Employees and authorized representatives of aircraft operators, foreign air carriers, and IACs with unescorted access to cargo must undergo a security threat assessment (STA), and the Security Identification Display Area (SIDA) security requirements at regulated airports have been expanded to include areas where cargo is loaded and unloaded. TSA has timely processed and adjudicated 170,000 STAs for IAC employees.

The 9/11 Act mandates significant changes to this regime. Section 1602 of the 9/11 Act amends TSA�s primary screening authority, 49 U.S.C. �44901, to require TSA to implement a cargo screening program that will, no later than August of 2010, achieve the screening of 100 percent of cargo transported on passenger aircraft in a manner that results in a level of security commensurate with that of checked baggage. The 9/11 Act defines the term �screening� to mean �a physical examination or non-intrusive method of assessing whether cargo poses a threat to transportation security� and includes within that definition x-ray systems, EDS, ETD, explosives detection canine teams certified by TSA, and a physical search combined with manifest verification. The 9/11 Act also provides TSA the flexibility to develop additional methods to ensure that the cargo does not pose a threat to transportation security, including a program to certify the security methods used by shippers.

The requirements are easily stated, but the enormity of the task cannot be overstated. Essentially, this legislation mandates the reinvention of air cargo security.

Considerable Challenges
The 9/11 Act�s mandate cannot be achieved by relying on the current system, whereby aircraft operators and air carriers are almost exclusively responsible for screening cargo. Currently, aircraft operators alone do not have the capacity to screen the volume of cargo that is now transported on passenger aircraft daily. Requiring passenger aircraft operators to screen 100 percent of air cargo would result in carrier delays, congestion at airport cargo facilities, backlogs of unscreened cargo, and missed flights�in short, such a requirement would significantly impede the flow of commerce. Likewise, requiring screening of the current volume of cargo carried on passenger aircraft at the airports by parties other than the aircraft operators would be impractical, if not impossible, if only because of the lack of space to accommodate such an operation.

Multiple Stakeholders
To fulfill the 9/11 Act�s requirements, TSA must rely on the wholehearted cooperation of industry. Success will only be achieved by augmenting current screening resources with those of multiple stakeholders and ensuring that screening is conducted at earlier stages in the air cargo supply chain. As discussed more fully below, in connection with the Certified Cargo Screening Program, TSA is working with aircraft operators, IACs, and shippers to create, pilot, and ultimately implement a program in which air cargo security is a responsibility shared by the entire air cargo industry.

Technology

A critical challenge in meeting the requirements of the 9/11 Act is the development of technology to accomplish the contemplated level of screening, particularly given current practices for packing cargo for transportation aboard passenger aircraft. Under current industry practice, a large percentage of cargo that will be placed aboard passenger aircraft, particularly wide-body aircraft, is tendered at the airport in a consolidated state, i.e., it has already been packaged on large pallets for transportation. Without the development of effective technology for dealing with cargo tendered in this manner, screening would require significant costly reengineering of existing packaging and shipping processes.

The new requirements for screening cargo commensurate with passenger baggage will have the biggest impact on cargo that is carried on wide-body aircraft. For efficiency in operation, wide-body aircraft utilize Unit Load Devices (ULDs) to transport the cargo in the lower holds of the aircraft. These ULDs can hold up to 11,000 lbs. of cargo comprised of literally hundreds of pieces/boxes. Some ULDs are hard sided (similar to baggage containers) where the pieces are hand-stacked inside, while other are flat metal pallets on which the pieces are stacked, contoured to the aircraft shape, then shrouded in plastic and covered in heavy netting to prevent shifting in flight. The majority of the wide-body flights are on international lanes. IACs control most of the market (most shippers work through an IAC for many reasons, and do not negotiate directly with carriers). As a result, a very high percentage of ULDs are filled/built by the IAC, not at the air carrier�s facility. This is done not only for efficiency, but also because it enables IACs to obtain better rates than when cargo is tendered �loose� (because less handling by the carrier is required). For international cargo, cut-off times for carriers to receive cargo from IACs (or shippers) is approximately 4 hours prior to departure time.

Without the development of technology to effectively screen cargo built into large pallets and ULDs, screening cannot be executed primarily at airports. If all cargo were to be screened only at airports by air carriers, they would have to either (a) break down/remove cargo from all ULDs previously built-up by IACs, screen the cargo, and re-build the ULDs, or (b) require the IACs to tender the cargo �loose,� and then the carrier would screen the cargo and �build up� all of the containers. Either scenario would be extremely labor intensive, be costly in time, and eliminate rate discounts for industry.

Meeting the Challenges

TSA is well on its way to meeting the 50 percent screening milestone and to having in place the critical regulatory pieces for meeting the 100 percent goal. There are several interlocking pieces that advance us toward the 50 percent goal in the short term and that lay the groundwork for the complete implementation of the 9/11 Act�s requirement for cargo screening.

Near-Term Elements: 100 Percent Screening for Vast Majority of Passenger Flights

A key component of achieving the 9/11 Act�s 50 percent milestone by February 2009 is a 100 percent screening requirement for passenger aircraft that comprise approximately 95 percent of all domestic passenger flights and carry approximately 25 percent of all cargo that is carried on passenger aircraft. This requirement, developed in coordination with air carriers and other appropriate stakeholders, is scheduled to go into effect in October 2008.

Most significantly, this requirement will cover flights that carry more than three-quarters of all passengers. This means that when this requirement becomes effective, the great majority of air passengers will be protected by enhanced screening measures, even in advance of full deployment of our air cargo strategy.

Near-Term Elements: Canine Program

Current TSA security directives and emergency amendments already require that bulk cargo consolidations be made available by aircraft operators and air carriers for screening by TSA-certified explosives detection canine teams. As of July 1, 2008, TSA has trained 450 teams that are deployed and operated by local law enforcement agencies at airports. Standard operating procedures governing these teams require that they devote at least 25 percent of their duty time in the air cargo environment. Canine teams generally are concentrated at or near airports where there are high volumes of passengers and cargo. Under the U.S. Troop Readiness, Veterans� Care, Katrina Recovery, and Iraq

Accountability Appropriations Act, 2007, P.L. 110-28, Congress provided TSA with additional funding to expand the explosives detection canine team program by 170 teams. Of these, half will be proprietary, that is, comprised of TSA-owned dogs and TSA handlers, and devoted exclusively to screening air cargo. The deployment of additional canine resources ensures that a greater number of cargo consolidations that are subject to screening will in fact be screened.

Near-Term Elements: Increased Cadre of Inspectors
At the beginning of FY08, TSA employed 300 Cargo TSIs exclusively dedicated to the oversight of air cargo. Since then, TSA has trained and deployed an additional 130 air cargo TSIs, and another 20 will be added by the end of FY08. Inspectors conducted more than 37,000 compliance reviews in FY07 and initiated more than 2,500 formal investigations based on suspected non-compliance with TSA requirements. Cargo inspectors operate under work plans to ensure that all aircraft operators, air carriers, and IACs are inspected regularly and that those that have had previous compliance issues are inspected more frequently and thoroughly. Cargo inspectors also conduct outreach to all regulated entities to ensure their ability and willingness to comply with the IAC program�s requirements prior to their approval. Along with performing daily oversight of cargo operators, inspectors also conduct covert testing of the air cargo system and participate in �cargo strike� surge activities at our Nation�s largest cargo airports.

Near-Term Elements: Elimination of Alternative Screening Methods
In addition to increasing screening across the board, TSA is in the process of reevaluating and eliminating many of the alternative screening methods previously used for ensuring the security of certain categories of cargo. TSA reported to Congress a comprehensive overview of alternative screening of specific commodities, as required by section 1602 of the 9/11 Act.

Looking Forward: The Certified Cargo Screening Program
TSA is diligently working with all of our partners across the air cargo community to establish the linchpin of our air cargo screening strategy�the Certified Cargo Screening Program (CCSP)�a voluntary program under which TSA will certify cargo screening facilities to screen cargo before it is tendered to aircraft operators for carriage on passenger aircraft. As authorized by the 9/11 Act, we are currently developing an Interim Final Rule (IFR) to implement the CCSP, which we hope to publish by the end of this calendar year. This program, which we anticipate deploying in FY 2009, will establish full supply chain security of air cargo and play a major role in overcoming the hurdles inherent in a 100 percent screening requirement.

Like TSA�s existing security programs, the CCSP will rely on layers of security to provide the best possible protection for cargo on passenger aircraft and the least disruption to commerce. Under the CCSP, facilities upstream in the air cargo supply chain such as shippers, manufacturers, warehousing entities, distributors, and third party logistics companies will be able to apply to TSA to be designated as certified cargo screening facilities (CCSFs). IACs and aircraft operators that screen cargo outside airport perimeters may also apply to be certified to become CCSFs in order to screen cargo for transport on passenger aircraft. CCSFs will be required to screen cargo using TSA-approved methods and to implement chain of custody measures to ensure the security of the cargo throughout the air cargo supply chain prior to tendering it for transport on passenger aircraft. CCSF employees and authorized representatives will be required to successfully undergo TSA-conducted STAs. Before being certified, and periodically thereafter, the CCSF will be required to undergo examination by a TSA-approved validator, who will also need to undergo a TSA-conducted STA. These facilities will also be subject to regular and random inspections by TSA cargo inspectors to ensure their adherence to CCSP requirements.

Once the program is implemented, CCFS-screened cargo will contribute greatly toward meeting the 50 percent and 100 percent cargo screening requirements of the 9/11 Act.

Certified Cargo Screening Pilot Programs
As part of the process of establishing this regulatory program, TSA is testing the concept of screening earlier in the supply chain by conducting two pilot programs: (1) the CCSP (Phase One) pilot involving shippers and other entities such as manufacturers, distributors and third party logistics companies, and (2) the Indirect Air Carrier (IAC) technology pilot. The pilot program with shippers is being conducted at the following major gateway airports: San Francisco, Chicago, Philadelphia, Seattle, Los Angeles, Dallas-Fort Worth, Miami, Atlanta, and New York/Newark. The pilot with IACs is running at these airports and additionally at Dulles, Honolulu, Intercontinental Houston, Boston/Logan, Detroit, Denver, San Juan and Orlando.

Over 65 percent of all cargo transported on passenger aircraft is from these 18 pilot airports. Approximately 61 percent of cargo transported on wide-body aircraft originates at just 6 of these airports. By focusing its outreach in the pilots on the entities using the airports with the highest volume of cargo transported on wide body passenger aircraft, we have been able to maximize the impact of the pilots.

The IAC technology pilot is evaluating the effectiveness of cargo screening equipment recommended by TSA, such as Advanced Technology X-ray (AT X-Ray), ETD machines, and EDS, by commodity class at each participant�s consolidation facility. Congressional appropriations provided TSA with funds for the screening of air cargo. TSA is using these funds to assist in the deployment of appropriate screening technology for use in the IAC pilot program. In addition to testing the equipment itself, the IAC pilot is also evaluating the volumes of cargo the IAC community is able to screen and the use of chain of custody procedures.

Industry has responded enthusiastically to TSA�s call for participation in the pilots. During the first 4 months of 2008, TSA teams met with over 225 shippers, 550 IACs, and 100 air carriers in these cities to explain the impact of the regulation as well as the solution provided by the CCSP. To date, TSA is working with over 70 IAC pilot locations as well as over 100 shipper locations that are undergoing the validation process to become certified to screen as part of the pilot. Fourteen major IACs are committed to participating in the pilot and are in various stages of certification. The final steps in the process will be their purchase of approved technology and subsequent completion of the necessary training on use of that equipment. In addition to the IACs who are formally participating in the pilot, we have received applications from 47 IAC facilities in the 18 cities that wish to become certified and plan to purchase the approved technology on their own.

We feel that this approach has many benefits, not the least of which is that moving the screening of cargo for these larger IAC operations away from the airports will allow the carriers to utilize their capacity to screen cargo from smaller IACs and shippers who do not have the volumes of cargo or the financial ability to invest in the infrastructure needed to screen cargo themselves.

Looking Forward: Research and Development
To address the technological challenges, TSA is working collaboratively with the DHS Science and Technology Directorate (S&T) to identify technology gaps and to prioritize research and development (R&D) requirements. Together, we are working to develop and qualify technologies in the areas of automated break-bulk and bulk explosives detection; trace explosives detection; alternative screening technologies such as metal detection, non-linear junction device detectors, and Improvised Explosives Device (IED) disruptor technologies; blast mitigation technologies; stowaway detection technologies; and supply chain integrity technologies. Our collaboration includes the conduct of laboratory and field assessments of AT X-Ray and pallet-sized x-ray technologies in conjunction with S&T�s Transportation Security Laboratory (TSL).

TSA and S&T completed technology readiness evaluations of bulk air cargo screening technologies last year, and research is continuing on promising technologies under Cooperative Research Development Agreements (CRDAs). Formal qualification testing of break-bulk (box/piece) air cargo screening technologies is scheduled to commence this Fall with a view toward adding successful technologies to an air cargo screening technology Qualified Products List (QPL). In addition, TSA is working with S&T to prioritize bulk (palletized/containerized) air cargo screening technology requirements for future investments.

TSA has been conducting a Hardened Unit Loading Device (HULD) Pilot Program for which interim test results were released in November 2007. Based on these results, TSA has decided to put the HULDs on a QPL. The final test results and report for the HULD Pilot Program are expected to be completed and released by August 31, 2008.

Finally, TSA is also working closely with the S&T Cargo Pilot Program, which assessed air cargo screening costs for three levels of automation. S&T will submit a report to Congress on the results of the pilot, after which TSA will report to Congress the cost 7
estimates for doing 100 percent screening of air cargo at various airports on all-cargo and on passenger aircraft.

Success Is the Only Option
TSA�s mission is to protect the security of the Nation�s entire transportation system. Our current risk-based, layered security approach has served us well in fulfilling that mission. We anticipate that the current program, along with the new CCSP, will enable us to achieve the 100 percent air cargo screening requirement envisioned by the 9/11 Act in a manner that does not disrupt the flow of commerce.

Thank you, again, for the opportunity to bring you up to date on our progress with this important mandate. I will be happy to answer any questions you may have.

TSA Ripped At Security Conference

Wed, 08 Oct 2008 16:18:28 -0400

By now it is clear that the USA Transport Security Administration (TSA) delivers attitude plus an enforcement-driven agenda to air cargo.

But if the agency listens at all to what the market is saying, TSA should think a bit about the heavy criticism directed toward the agency from many life-long air cargo professionals that attended Lufthansa Cargo's security conference last week in New York.

�Separate but unequal securities,� is how one observer described TSA dealings with all-cargo versus belly lift edicts.

TSA in fact says all air freight transported on board passenger aircraft is a potential means of terrorist attacks and thus officially ranked as highly insecure while boxes and packages flown by all cargo carriers are not regarded as prime target of criminal intents.

"We see different risk potentials because the threat factor on passenger and cargo is different," stated Ed Kelly, the Transportation Security Administration's General Manager during the U.S. Security Conference held by Lufthansa Cargo on September 30, at Garden City, Long Island.

Consequently, the TSA mandates different levels of shipment screening from the industry: 100% on all U.S. domestic passenger flights already under way, 50% of in- and outbound transport as of Feb. 9, next year, and 100% on all passenger flights commencing in August 2010.

Kelly and his TSA's security architecture was opposed by most participants who strongly recommended a single standard for both passenger and all-cargo air freight.

"You are just as dead if you are hit by a passenger plane or a cargo plane," Howard Safir, former Police Commissioner of NYC said.

"Airplanes with their hundreds of gallons of kerosene are potential weapons with no difference, if freighters or passenger aircraft," Safir said, leaving no doubt that TSA's policy doesn�t sound right or doesn�t even nearly convince him that it is sound.

Captain Bill McReynolds of FedEx and Chairman ALPA's Committee on Cargo Security added.

"Air cargo security must be a part of a multi-layered approach to protect airline crews, passengers, airplanes and cargo shipments from threat.�

So far �TSA's concept has focused on passenger airlines and little has been done to air cargo security," the pilot and transportation leader and expert said.

�The imposed February 50% deadline for x-raying passenger cargo seems to be a highly ambitious undertaking since the TSA has not even validated the screening devices yet.�

"We have meanwhile been audited by TSA experts but did not get any feedback which of our products and devices fully complies with the administration's requirements," said Hans Zirwes, General Manager of Wiesbaden-based Smiths Heimann GmbH when approached by Air Cargo News FlyingTypers.

Only when this infrastructural topic is solved however, can agents, warehouse tenants and airlines begin to place their orders for licensed screening equipment. "From the very day we get the purchase order we will need about three months to produce the x-ray machines if we don't have them in stock," Zirwes emphasizes.

Other devices producers will need a comparable timeframe for starting their mass production of x-ray machines.

The technical infrastructure however, is only one precondition of having masses of shipments being screened. The other is trained personnel who can only get to work after the devices are delivered and put in place.

Both unsolved preconditions and ample space needed for installing the equipment at airports or warehouses make it highly unlikely that February 9 can be maintained as launching day for the 50% x-raying of air cargo.

Instead, most likely is a transition time of some months to give the cargo industry a chance to comply TSA's mandate.

This move was recommended by a number of high ranking representatives at the security event but Ed Kelly did not wave the white flag by scrapping the February deadline.

Rather the executive cited his �mandate�.

�The 50% and 100% milestones are fast approaching, congressionally mandated and therefore not flexible," he declared.

Other critics favored a different architecture to increase air freight security.

John Hansman, Professor Aeronautics and Astronautics at The Massachusetts Institute of Technology favored a 'Swiss Cheese Model' with different security layers, from canines to scanning, bio-sensors or manual inspection of shipments.

"This variable layer architecture is the better long term strategy delivering higher security than the single approach screening concept."

But no matter what security concept might finally be imposed by the U.S. administration everybody agreed on one aspect: the additional costs security will demand.

Klaus Holler, Lufthansa Cargo VP The Americas in his final remarks noted:

"We had to make a tremendous investment in security.

�Therefore, a screening fee will have to be imposed or fares increased."

Meanwhile Lufthansa reported a major benefit due to tightened security:

"Ever since we implemented our security hub system, thefts have dropped by 98 percent," announced proud Harald Zielinski, the German cargo carrier's Head of Security and Environmental Management at the New York meeting.

Still you might wonder, with important deadlines coming and going for air cargo security, how is it possible for TSA to present itself as stoic, inflexible and impenetrable?

If last weeks round of emergency USA government financial bailout activity proved anything, it is that there is indeed flexibility and sense, above partisan politics, for the common good.

The TSA has some politically-driven decrees with deadlines on one hand.

On the other TSA can listen and learn and act in an enlightened manner and stop pointing fingers and snapping off demands as answers like they did last week in Garden City.

World transportation deserves better.

Kudos to Lufthansa Cargo for hosting this important event.

Heiner/Geoffrey

Secure Air Cargo Solution

Wed, 08 Oct 2008 12:58:58 -0400

Today, air carriers do not have a reliable way of knowing if the contents of packages have been surreptitiously penetrated, or if contraband has been introduced (e.g., drugs, WMD, bombs, etc.). There is no simple, standardized way to know this easily, with certainty, and without special skills and/or training. Further, there is no visually inspectable, physically secure method of packaging available that ensures the chain of custody is maintained, and that the integrity of the package has not been compromised.

Secure Air Cargo Solution

The Problem

The Solution

A Secure Air Cargo Packaging and Inspection Protocol, adaptable to specific industries and individual customer applications within those industries, that guarantees a clean chain of custody and insures package integrity for unattended cargo tendered for air transportation on commercial airliners in compliance with the new Federal security mandates for air cargo (specifically, compliance with the Known and Certified Shipper and Air Cargo Security initiatives).

The solution provides a set of proven tools, a standardized process to certify, implement and use these tools, and a training program for auditors and users.

The solution is based on a Cargo Brick concept that provides a consistent visual, inspectable template for a given shipper that is the same every time so readily identifiable, visually inspectable, uniquely numbered, verifiable and accountable. The Cargo Brick consists of a Pallet Cover Protection Kit that includes a 5 � 6 mm thick waterproof, scuff-proof LLDPE Bag, standard � inch nylon banding with crimping tool, Topp Clip, and numbered and tamper evident seals or Secure TRAC tape. There are two general solution types:

1. For Bulk Shippers:

a. �Cargo Bricks�, to establish a consistent, standardized size/weight package for that particular shipper in a tamper evident format.

b. Specialized Seals for �A Containers� �LD3�and Igloos (when bundling)

2. For small, LTL Shippers: customized, serial-numbered self wound tamper evident tapes, seals and banding / Topp Clip strapping locks that provide tamper-evidence for corrugated boxes, plastic containers, bags, envelopes, pallets, pails, barrels, drums, totes, palletainers and other types of containers.

This solution is designed to be seamless to the current sealing and inspection processes currently in use, so it is readily and quickly accepted by personnel across the logistics supply chain. Implementation of the Secure Air Cargo Packaging Protocol begins with a Security Audit for Known Shippers consisting of the following elements: Building and grounds certification, packaging process evaluation, inspection equipment suggestions, throughput design and other requirements yet to be approved by TSA and DHS. Additionally we are able to offer on line training for personnel, vetting of employees and transportation vendors.

The Benefits:

1. Shipping and receiving standards of care are set at a TSA approved level which will be higher than the current standard of care.

2. TSA and/or carrier employees are trained, enabled and empowered to inspect cargo for penetration without prior knowledge of the bag�s or boxes condition.

3. Carrier: maximizes cube and weight for every aircraft

4. Shipper gets an automatic inspection bye because he is compliant, speeding up delivery of goods with reduced insurance costs

5. Recipient is assured goods received are as shipped. Reduced loss, shrinkage and vulnerability.

6. Pallet bags can be scanned and secured simultaneously

7. Paper Manifests are eliminated

8. Cargo is protected from water damage, abrasion and crushing.

9. Costs of superfluous seals are eliminated.

10. Pallet bags can be recycled and re-used.