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April 07, 2008 

Transportation Security Administration Launches Certified Cargo Screening Program

From Strasburger & Price's Newly Launched Logistics Blog

By Mark J. Andrews and Laura Martino

The Certified Cargo Screening Program (“CCSP”) is a voluntary program that allows certified manufacturers, exporters and forwarders to screen air cargo before it is shipped. The Transportation Security Administration (“TSA”) is now deploying the CCSP in nine pilot cities— Atlanta, Chicago, Dallas, Los Angeles, Miami, New York, Philadelphia, San Francisco and Seattle. By the end of 2008, TSA expects to set up ten to fifteen facilities and deploy TSA Field Teams in each of the selected cities.

The CCSP is intended to ease compliance with the Implementing Recommendations of the 9/11 Commission Act of 2007, P.L. 110-53 (the “9/11 Commission Act”), which requires 100 percent screening of cargo carried on passenger aircraft by August 2010. Currently, air carriers perform most cargo screening. As a result of the increased screening required by the 9/11 Commission Act, much of the burden of cargo screening is likely to shift from air carriers to manufacturing and freight forwarding facilities.

The 9/11 Commission Act requires air cargo screening to reach the same level of security as screening of passenger checked baggage. This means that each individual item of air freight will be subject to some type of screening. To meet the 100 percent screening requirement, CCSP will enable certain facilities to voluntarily screen their own cargo before delivering it to the freight forwarder or air carrier. Eligible facilities must first become a Certified Cargo Screening Facility (“CCSF”). Manufacturers, 3PLs, warehouses and distribution centers may apply to TSA to become a CCSF if their facility directly tenders cargo to a freight forwarder or air carrier. Freight forwarders may also apply.

The benefit of becoming a CCSF is that manufacturers and exporters may screen cargo early in the air cargo supply chain. Under the program, CCSFs are able to screen their own cargo on their own schedule before acceptance at the freight forwarder or air carrier, and without potential damage from invasive screening by the airlines. Shippers using CCSFs may also avoid cargo screening fees. Although CCSP is a voluntary program, the only alternative available to shippers of air freight is to rely on airline screening. However, due to the increased security standard imposed by the 9/11 Commission Act, airline screening of cargo is expected to cause significant delays.

TSA has established “entity standards” for CCSFs. These standards require stringent security measures at participating facilities and throughout the supply chain. For example, CCSFs are required to permit onsite validations and periodic inspections by TSA, and to screen cargo at the piece level. CCSFs must also ensure cargo integrity through chain of custody measures. The following is a summary of the security standards CCSFs must maintain in order to participate in CCSP:
  • CCSFs must set forth procedures to prevent unauthorized entry to facilities where certified cargo is screened, prepared, and stored.
  • CCSFs must control employees, contractors and visitors and protect company assets.
  • CCSFs must screen prospective employees and contractors to TSA standards and periodically check current employees having continued access to passenger air cargo.
  • Certified facilities must erect physical barriers that guard cargo handling and storage facilities against unauthorized access.
  • CCSF must establish password protection of user accounts on automated systems, and be able to identify improper access.
  • Certified facilities must allow initial and ongoing validations by TSA.
  • CCSFs and supply chain participants must ensure that data is documented and accompanies each shipment.
  • CCSFs and supply chain participants must apply tamper evident devices to cargo packaging prior to departure.
  • Documentation must be authenticated upon receipt at each processing point in the chain of custody.
Shippers and carriers should note that the type of screening required for air cargo is left to TSA’s discretion in the 9/11 Commission Act, as long as the level of security is commensurate to that for passenger baggage. Because the 9/11 Commission Act requires TSA to publish implementing regulations in a final or interim final rule, TSA will likely propose a full regulatory framework for cargo screening over and above the multi-city pilot program in the near future.




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