CCSP Overview – 9/11 Act Screening Requirement

In 2007, Congress passed the Implementing Recommendations of the 9/11 Commission Act more commonly known as the 9/11 Act. This new law mandated that all cargo transported on a passenger aircraft be screened for explosives by August 1, 2010. At the time, the deadline seemed far off on the horizon, but as we move closer to the summer, 100 percent screening is becoming a reality for all businesses. TSA is urging businesses to closely examine how they ship cargo on passenger aircraft.

TSA recognizes cargo may only be a small portion of your business’s operation, but all businesses must consider how the deadline will affect their operational continuity, punctuality, and customer satisfaction.
Every shipment of cargo carried on passenger aircraft will require screening at piece level, prior to being transported on any passenger aircraft. Skids and pallets will have to be taken apart, screened and reconfigured.

The 9/11 Act specifically identifies the types of screening allowed ranging from physical inspection to various technologies. If airlines are forced to screen cargo, similar to how passenger baggage is screened, there is a potential for delays and damage to shipments. The screening process affects all cargo on passenger planes, but TSA believes large shippers and exporters will feel the greatest impact.

TSA developed the Certified Cargo Screening Program (CCSP) as a solution to help industry reach the 100 percent screening mandate. The program enables freight forwarders and shippers to pre-screen cargo, avoiding any potential bottlenecks at the airport. Most CCSP shipper participants have been able to quickly incorporate physical screening into their shipping process at a small cost to their operation.

TSA is strongly encouraging companies to examine all their options in screening cargo on passenger planes. Shippers should contact their freight forwarders to determine if any of their products are transported on passenger aircraft. Many freight forwarders have already joined CCSP and in many cases will be able to help companies through the screening process.

TSA can assist you in assessing the possible impact for your supply chain, both inbound from suppliers as well as outbound customer shipments. However, there are also certain products that are better suited to being screened by the shippers themselves. TSA is here to help and companies should consider contacting us for more details on CCSP.

CCSP And Your Business

A key component of TSA’s response to the 9/11 Act mandate is the Certified Cargo Screening Program (CCSP). Under CCSP TSA will certify cargo screening facilities located throughout the United States that screen cargo prior to providing it to airlines for shipment on passenger flights. Participation in the program is voluntary and designed to enable vetted, validated and certified supply chain facilities to meet the 100 percent screening requirement.
CCSP is a practical, supply chain solution, which provides security while ensuring the flow of commerce. Cargo is screened at the most efficient and effective point. It is done before individual pieces of cargo are consolidated for shipment.
Certified Cargo Screening Facilities (CCSF) must carry out a TSA approved security program and adhere to strict chain of custody requirements. Cargo must be secured from the time it is screened until it is placed on passenger aircraft for shipment. With the cooperation of the entire air cargo community, the CCSP provides the framework for achieving 100 percent screening domestically.
Benefits
Screening 100 percent of cargo on passenger aircraft is designed to ensure the safety of the traveling public. TSA designed CCSP to provide businesses with the option to screen cargo in a cost effective manner and at various points of the supply chain.

CCSP allows businesses to:
•    Screen cargo where it is packaged
•    Maintain in-house packaging integrity
•    Avoid screening log jams at the airport
•    Build bulk configurations to minimize cost

CCSP:
•    Is supported by the air freight and air carrier industries
•    Leverages best practices from global supply chain programs
•    Allows businesses to choose the best and most effective model for their needs

What Are The CCSP Requirements?
Certified Cargo Screening Facilities must meet the rigorous security requirements for their physical location, personnel, and screening.

Security
CCSP participants must have processes in place to screen prospective employees and contractors to TSA standards. Routine reviews of employees with access to cargo after screening must be conducted. Security threat assessments must be conducted on all employees as described in CCSP regulatory documents. Specialized training is also required for all person who will conduct screening, handle cargo, or have access to designated screening areas.

Screening
CCSP participants must have procedures in place to prevent unauthorized access to cargo facilities where cargo is screened, prepared, or stored. Physical barriers must be in place at cargo handling and storage facilities as well as designated screening areas.

Chain of Custody
Supply chain participants are required to maintain chain of custody standards for screened cargo. The standards must include all of the following:
•    Documentation: Information must be documented and included with the shipment
•    Methods- must be employed to ensure the cargo is secure and maintained throughout the shipping process
•    Authentication- documentation and methods must be authenticated upon receipt by each party and at each point in the supply chain

Key Considerations
Each business should carefully examine the options and determine which method of screening program is right for their entity.
Some factors to consider:
•    Are your shipments carried on passenger aircraft?
•    Will your shipments be comprised if opened for screening?
•    What will screening cost?
•    Are you products sensitive to shipping delays?
•    Are you participating in other supply chain programs? (C-TPAT, cGMP, TAPA or other)
•    Does the amount of shipping justify in-house screening?

Who Is Eligible To Participate?
Any facility that tenders cargo directly to an air carrier or indirect air carrier (IAC) may apply for the Certified Cargo Screening Program.
This includes:
•    Manufacturers
•    Warehouses
•    Distribution Centers
•    Third Party Logistics Providers
•    Indirect Air Carriers
•    Airport Cargo Handlers
•    Independent Cargo Screening Facilities

Certified Cargo Screening Locations
The air cargo shipping community has requested a public list of CCSP program participants from TSA as a means to locate, verify and, validate CCSF entities and locations. TSA believes such a list is beneficial to the shipping public and publishes this list on a weekly basis.
We see this as advantageous for organizations to publicly confirm CCSP status. TSA is aware that some entities may not wish to have their information published and we are sensitive to the thoughts and concerns of our CCSP participants. We have given all CCSP participants the opportunity to withhold their respective information from the public list.

Independent Cargo Screening Facility Screening Locations
Shippers that do not want to become a Certified Cargo Screener but wish to avoid potential delays or damage to their shipments due to the screening process can use a freight forwarder’s Indirect Air Carrier (IAC) services, or use an Independent Cargo Screening Facility (ICSF). An ICSF is an independent cargo screening facility that is authorized by TSA only to screen cargo that will be transported by a passenger air carrier. Most ICSFs are not freight forwarders.

Freight Forwarders (IAC’s) Screening Locations
An IAC means any person or entity within the United States not in possession of a Federal Aviation Administration air carrier operating certificate, that undertakes to engage indirectly in air transportation of property and uses for all or any part of such transportation the services of a passenger air carrier. Specific locations of many IACs have been approved by TSA to screen as well as transport CCSP air cargo only the specific locations on this list are certified by TSA to screen.

Freight Forwarders Authorized to Transport - But Not Screen
For certified shippers or ICSFs who wish to ensure proper handling and secure chain of custody for shipments they have screened, TSA has published a list of IACs who are approved to handle screened cargo. These companies may handle screened cargo at all of their locations in the United States (whereas screening locations for both CCSF-IAC and ICSF are location specific.