In today’s volatile security environment, it is not news to anyone that the commercial aviation air cargo industry continues to be threatened by rogue individuals and extremist groups (Threat Actors). Recent global events remind us of this very real and present danger. Threat Actors continuously refine and reinvent ways to conceal Improvised Explosive Devices (IEDs) and expand their knowledge of techniques to circumvent screening technology and other explosive detection countermeasures. Historically, the focus has been on commercial aviation which overlooks the security threats that exist to the entire supply chain. However, the burden of implementing increased security measures has been felt throughout the value chain.
100 Percent Screening Requirement
In August 2007, then-President of the United States George W. Bush signed the Implementing the 9/11 Commission Recommendations Act of 2007 legislation into law. This law required the Secretary of Homeland Security to establish a system to enable the industry to screen 100 percent of cargo transported on passenger aircraft within three years (by 2010). This resulted in a requirement that all cargo must be screened at the piece level by a U.S. Department of Transportation Security Administration (TSA) approved method prior to being loaded onto a passenger aircraft.
49 CFR Part 1544.205 - Acceptance and screening of cargo; outlines the details associated with the 100 Percent Cargo Screening Requirement.
It should be noted that all cargo tenders transported by air are subject to being searched as per federal regulations. In order for the cargo to be accepted for transport, consent must be given to conducting these inspections. Shippers can screen their cargo under the provisions of the Certified Cargo Screening Program however, their air freight shipments are still subject to screening by the TSA.
Certified Cargo Screening Program
The Certified Cargo Screening Program (CCSP) is a TSA program which certifies that cargo screening facilities located throughout the U.S. are implementing the TSA approved security program. These facilities are known as Certified Cargo Screening Facilities (CCSF). This program is found under Title 49 Part 1549 of the United States Code of Federal Regulations.
The Major Change
The major change that is driving the implementation of private sector canines is Amendment 14 of the International Civil Aviation Organizations (ICAO) Annex 17 - Security. ICAO is a United Nations specialized agency, established in 1944 in order to manage the administration and governance of the Convention on International Civil Aviation. The Convention consists of 192 Member States and industry groups. The ICAO works with this Convention to reach a consensus on international civil aviation Standards and Recommended Practices (SARPs) which become the global standards.
The 14th amendment of Annex 17 completely removes the distinction between passenger and cargo operations. Requiring that all cargo be subject to screening for all commercial air transport operations no later than July 1, 2021 for all ICAO member states.
It is a herculean task to screen all cargo prior to transport. A task that will only become more difficult with the extensive growth of e-commerce shipments. Increasing the volume of individual parcel shipments will expand the volume that must be effectively screened every day. In an attempt to mitigate the threat of explosive attacks, millions of dollars have been devoted to the development of technology. Advances in sensor technology to replicate the odor detection capabilities of canines have been fueled by the abundance of high-speed low-cost circuits. Despite these tremendous efforts, no piece of technology has truly been able to match the sensitivity or the reliability of the working dog.
Air cargo screening systems are highly effective and continue to evolve. However, implementing these technology-based solutions has a significant initial cost along with re-certification requirements and maintenance expenses. The lack of Transportation Security Administration (TSA) approved devices capable of screening full pallets containing multiple types of goods remains a challenge, resulting in a labor-intensive and time-consuming process of de-palletizing the goods, screening individual items, and then re-palletizing the packages. The solution to solving this problem is explosive detection canines.
Non-Computed Tomography (Non-CT) Transmission X-Ray Devices (X-Ray Devices) are fixed projection X-ray inspection devices that display digitized transmission radiographic images of an object under inspection following an interrogation.
Currently there are three classifications levels of X-Rays devices. Single View is phasing out over the next 24 months. Dual View that provides two images, and Multi View, which delivers three or more images of the item being screened.
Explosive Trace Detection (ETD) Devices
ETD Devices are desktop or handheld devices that detect explosive residual material on typical cargo substrates through the application and analysis of a swab-based collection process. Currently approved technologies are limited with only four approved devices and three of these are to be phased out by February 2021.
Electronic Metal Detection (EMD) Devices
EMD Devices interrogate items with a time varying electromagnetic field. Secondary magnetic disturbances induced by the primary field are detected by the EMD, and an alarm condition is displayed if threshold levels have been exceeded.
Explosive Detection Systems
EDS Devices use computed tomography and sophisticated algorithms to automatically detect explosive materials. These systems are on the list of grandfathered technologies that will phase out in December 2022.
Explosive detection canines naturally have the ability to identify individual odors along with its source. The canine’s nose contains an estimated 300 million sensory receptors. When air is drawn into the nostrils it stimulates these receptors that are connected to the large olfactory bulb in the dog’s brain. The olfactory is a part of the sensory system that processes smell down to parts per trillion (ppt). These sensors then allow the dog to recognize/detect the target odor’s direction. Not only do working dogs have a remarkable sensitivity to smell they are an intelligent instrument in detection. With each encounter, the canine becomes smarter as it builds a target database from past exposures. This scent database has been developed over the course of thousands of years. Humans have been leveraging outstanding odor detection capabilities of canines for centuries.
What about the TSA?
The TSA's mission is to protect the nation's transportation systems to ensure freedom of movement for people and commerce. The TSA has long recognized the capabilities of canines; establishing the National Explosive Detection Canine Team Program (NEDCTP). In recent years this program has been the focus of multiple Government Accountability Office (GAO) reports. The program has been scrutinized over its costs and ability to produce the required numbers of canine teams to support the air cargo industry.
The TSA’s NEDCTP has concentrated on providing canine security to passenger operations in airport terminals. Focusing on the passenger operations has created a gap in coverage for freight. These gaps jeopardized the integrity of the entire security program. It is vital that the screening technology used to mitigate the risk of an explosive attack be proven, efficient, and reliable. Recognizing the capabilities of canines the TSA is in the final stages of allowing third-party canine cargo screening.
Third Party Canines
Third party canines are the use of private sector canine companies to screen air freight shipments. The TSA has been utilizing working dogs, however, the regulations did not allow private companies to do this work. The primary reason for this limitation was the certification of the canine teams. Each Canine, consisting of a canine and handler, must undergo certification to ensure that they are capable of locating explosive odors in an operational setting. The TSA NEDCTP certification is not open to private sector companies. As a result, the private sector has been unable to step in and fill the gap.
The TSA developed the Third-Party Canine-Cargo (3PK9 or 3PK9-C) Program as the solution to allow private sector companies to undergo a certification process which meets the TSA standards. Under this program, third-party canine teams trained in explosives detection can be certified by a non-governmental entity, acting under the approval of TSA, as meeting TSA's certification standards. Certified 3PK9-C teams can be deployed to screen air cargo for aircraft operators, foreign air carriers, and other TSA-regulated parties operating under a TSA-approved or accepted security program.
Over time the 3PK9 program has under went multiple modifications. The latest operating model is the Certified Cargo Screening Facility - K9 (CCSF-K9).
The Impact of 3PK9
Global K9 Protection Group has been working with multiple companies in the air cargo industry to look at the impact of canines on their operations. The preliminary testing shows that canine screening is 97% faster than current X-ray screening operations. Additionally, by implementing K9 screening, shipments will no longer require the time-intensive disassembly of pallets and other bundled items. Improving the screening processes efficiency might help address some of the other problems that are currently impacting the forwarding industry.
As we move the implementation of third-party canines will undoubtedly have an impact on freight forwarding and air cargo industry. Doing so must be with caution as with any new capability its effectiveness is dependent upon proper utilization.