Goals and objectives
Implications for air cargo industry
With record air cargo demand showing no signs of slowing, it is no surprise that the Transportation Security Administration (TSA) is focused on reviewing and enhancing aviation security measures for this essential element of the global supply chain. The TSA has released an Air Cargo Security Roadmap, which sets out the TSA's "strategic direction toward modernizing, streamlining, and further securing the air cargo system throughout the next five years". The TSA plans to accomplish four key goals and associated objectives.
Goal one is to "[a]dvance enhanced and risk-based screening capabilities". The objectives of goal one are as follows:
- Objective one – "Assess the security value of cargo shipper vetting through the TSA Known Shipper Program". The TSA will examine the known shipper programme (which allows "known shippers" to transport cargo on passenger aircraft) to assess "its maximum functionality, usefulness, and effectiveness in cargo shipper-vetting" and to "help inform TSA's future approach for risk-based vetting and pre-screening, including whether the [programme] should be retained, modified, or replaced". The TSA will factor into its review increases in e-commerce volume and the recently implemented requirement mandating the same security screening measures for cargo travelling on all-cargo aircraft as on passenger aircraft.
- Objective two – "Analyze pre-screening and advance targeting capabilities". The TSA will review current pre-screening processes used for US inbound international air cargo to determine whether such measures could be used to strengthen intra-US and US outbound international air cargo screening. As part of its review, the TSA will "evaluate the policy, legal, and economic implications of applying pre-screening and targeting systems to international freight originating in the United States".
- Objective three – "Evaluate opportunities to provide all-cargo aircraft operators the capability to use risk data to assist screening in place of physical screening". Industry stakeholders will be invited to propose alternative air cargo security and screening procedures that are risk-based and data-driven. In addition to directing cargo to the most effective screening methods, the TSA's review will examine how non-intrusive data analysis could be used to increase security efficiency while reducing costs for industry.
Goal two is to "[e]xpand knowledge and information sharing between TSA and industry". The objectives of goal two are as follows:
- Objective one – "Provide support for industry to enhance air cargo screening training". The TSA seeks to "enhance its partnership with industry" to support standardised and consistent training for air cargo security personnel. While industry stakeholders are responsible for air cargo screener hiring, training and testing, the TSA will examine whether it can assist industry with addressing training consistency and uniformity challenges.
- Objective two – "Accelerate the speed, and improve the consistency and quality of information sharing between TSA and industry". Information sharing is key to aviation security effectiveness, and the TSA recognises that "strong communication options are essential to ensure industry complies with TSA regulations, meets threat management requirements, and remains up to date on all new and updated security program changes". The TSA will examine current information sharing platforms, such as the Aviation Domain Intelligence Integration & Analysis Cell and the Homeland Security Information Network, to find ways to enhance timeliness of information sharing with industry.
Goal three is to "[e]nhance the air cargo industry's technology posture to support security enhancing innovation within the supply chain". The objectives of goal three are as follows:
- Objective one – "Continue to update TSA screening technology technical standards and functional requirements in line with evolving security threats and emerging technology". The TSA will update and evolve detection requirements and standards to meet new threats. It recognises that capabilities and requirements must "meet evolving and emergent threats and . . . provid[e] industry with flexibility to explore new and emerging capabilities and technologies".
- Objective two – "Collaborate with industry and other R&D establishments to promote the advancement of technology in the air cargo marketplace". Because "the air cargo marketplace lacks key incentives to encourage investment in security technologies", the TSA is committed to establishing partnerships with air cargo screening technology vendors and other providers to provide support for security technology research and development, to include potential funding of future technology pipelines.
Goal four is to "[m]odernize air cargo policy". The objective of goal four is as follows:
- Objective one – "Modernize standard security programs and policy processes". The TSA will review its air cargo policies to "ensure they are outcome-focused and continuously mirror the changing environment". To that end, the TSA pledged to "create enhanced internal mechanisms that drive policy development by [the TSA's Policy, Plans and Engagement division] and provide one voice to industry on policy interpretation issues".
Implications for air cargo industry
The air cargo industry should view the TSA's roadmap as a positive development. In particular, regulated entities that operate under a TSA-approved security program should welcome the TSA's commitment to modernising its regulatory policy framework. Centralising questions of policy interpretation within the TSA's Policy, Plans and Engagement division will provide industry with greater clarity regarding regulatory compliance. This, in turn, should help ensure that the TSA applies its regulatory requirements to similarly situated stakeholders on a uniform basis, thereby eliminating inconsistencies. Above all, the TSA's roadmap provides welcome opportunities for industry to partner with the TSA to facilitate compliance and enhance security in the air cargo supply chain.
For further information on this topic please contact Rachel Welford at Cozen O'Connor by telephone (+1 202 912 4800) or email ([email protected]). The Cozen O'Connor website can be accessed at www.cozen.com.