No More Pilots or Test Programs – Implementation Only: The Message of the Cargo Airline Association is Clear

“BEFORE THE TRANSPORTATION SECURITY ADMINISTRATION ARLINGTON, VIRGINIA

Request for Information (RFI)

HSTS02-17-1-3PK9CS Third Party Canines

Response of the Cargo Airline Association

Background: On October 25, 2016, the Transportation Security Administration (TSA) issued RFI HSTS02-17-1-3PK9CS requesting information from the air cargo community on its plans to deploy third party canines for the screening of air freight if TSA establishes such a program.1 Following are the responses of the Cargo Airline Association to the RFI:

The Cargo Airline Association is the nationwide organization representing the interests of the all-cargo segment of the air cargo marketplace. Members include all-cargo air carriers (ABX Air, Atlas Air, FedEx Express, United Parcel Service, Kalitta Air), as well as a major indirect air carrier (DHL Express). Each of these members has a substantial stake in the establishment of a third party canine screening program to meet regulatory and operational requirements. The comments submitted herein are intended to provide an industry overview of the need to establish a third party canine program for the primary screening of air freight; individual Association members will be submitting comments detailing their companies’ need for the program and how they intend to use the canine screeners.

Third Party Canine Screening of Air Cargo: ‘TSA wishes to establish a program that certifies canine teams owned, operated and trained by private industry to detect the same explosive odors as TSA canines, and ultimately permit private industry to use these certified canines to meet TSA requirements to screen air cargo.’ RFI, p.1.

The Cargo Airline Association enthusiastically supports the third party canine screening program envisioned by the RFI. In order to meet industry needs, this program must provide that the canines can be used for the primary screening of the freight and that the program be instituted on an operational, not a test or pilot, level.

All-cargo air carriers provide systems of time-definite transportation to customers worldwide. The industry is composed of a variety of transportation providers including express delivery companies, as well as companies shipping ‘heavy freight’ to virtually every country on Earth. These services include the delivery of critical medical supplies, human organs, and other time critical perishables, as well as operations for government agencies, the military, and nongovernmental organizations such as the United Nations and the World Health Organization.

In today’s world, the screening of air cargo is becoming as important to worldwide security as the screening of passengers. However, the need to provide the most efficient and secure means of screening cargo often gets lost in the rush to protect airline passengers. As a practical matter, the modern technology to screen large quantities of air cargo with the speed necessary to satisfy the worldwide supply chain simply does not exist – and is unlikely to exist for many years. Therefore, the most effective way of filling this ‘screening gap’ is the ‘low tech’ use of third party canines trained to detect explosives for primary screening of air cargo.

The need for canine screening in the air cargo environment will become even greater in the next few years. The International Civil Aviation Organization (ICAO) has established new standards for the transportation of air cargo outbound from the United States that will require greater screening capabilities than now exist. More specifically, it is likely that the final outcome of the new ICAO standards will be a requirement to screen export cargo that cannot be deemed “secure” as that term is ultimately defined. These standards will become effective in five years. The only way to fill the upcoming gap without serious supply chain disruption is the use of third-party canines.

TSA has a cadre of trained canines for use in the screening of both passengers and cargo, but the numbers are small and are today limited to the screening of passengers in an attempt to reduce wait times at passenger checkpoints. Faced with this fact, the only way to create the teams necessary to allow for the primary screening of air cargo is to have TSA establish standards and continuing audit programs for the use of private, third-party canines by the air cargo industry. And this program must be implemented expeditiously to meet current and near term needs.

The Aviation Security Advisory Committee (ASAC) Air Cargo Subcommittee, which includes all segments of the air cargo industry, has recommended the implementation of such a primary third party screening program, correctly pointing out that an almost identical program has been accepted by TSA in the international arena as part of foreign countries’ National Cargo Security Programs (NCSPs). These programs are accepted by TSA as providing an equivalent level of security as programs in the United States. This fact alone provides evidence that the primary screening of air freight can and should be implemented in the United States as quickly as possible. There is simply no need for delaying such implementation with yet more testing or pilot programs.

In terms of implementation, TSA must establish the minimum standards necessary for third party vendors, provide a certification program for the third party canine teams, preferably at a selected site to provide consistency, and provide for a redress process that allows teams that have failed tests to be retrained to bring them up to the required standards. Necessary resources should be obtained from Congress in the appropriations process and, if necessary, existing funds should be reprioritized to permit the expeditious implementation of the program.

Conclusion: The Cargo Airline Association appreciates TSA’s initiation of the process that can lead to a program of primary air cargo screening by third party canines. The Association urges TSA to move expeditiously to implement this program in order to meet the security needs of the country while, at the same time, providing for the necessary robust movement of air freight worldwide.

 

Respectfully submitted,

Stephen A. Alterman

President

Cargo Airline Association

1620 L Street, NW Suite 610

Washington, DC 20036

202-293-1031

salterman@cargoair.org”

http://www.cargoair.org/wp-content/uploads/2016/12/Canine-RFI-Comments.pdf