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Release Date 11/16/2009

	Contact:
	Brian Everett, Executive Director 952-442-8850 x201

	NASSTRAC Supports TSA’s Certified Cargo Screen Program But Calls For Care In Implementation

	NASSTRAC’s regular members ship freight of all kinds, by air, truck, water and rail carriers, and many such carriers are associate members of the association. NASSTRAC continues to represent the interests of shippers in legal, regulatory and legislative issues affecting transportation, logistics and supply chains. In recent years, NASSTRAC’s focus has been on proposals by agencies of the federal government affecting transportation safety and security, and the NASSTRAC filed comments several years ago in Docket TSA-2004-19515. NASSTRAC is a strong supporter of security measures that are effective and cost-effective. Long before 9-11, NASSTRAC was a frequent participant in rulemaking proceedings dealing with transportation security. For example, NASSTRAC participated as a member of FAA’s Cargo Working Group, which helped develop the Known Shipper program in the aftermath of the explosion of TWA Flight 800. NASSTRAC also has hosted educational programs on security issues, including programs on TSA Certified Cargo Screening Program. In addition, many NASSTRAC shippers are participating in the CCSP. NASSTRAC regards the CCSP as critical to the balancing of costs and benefits that must underlie implementation of the cargo screening requirements of the mandate of Congress as set forth in the 9/11 Commission Act. Simply stated, the intent of Congress must be seen as calling for enhanced security with respect to cargo transported on aircraft that are also carrying passengers, but that intent must also be seen as including the need to maintain the flow of goods, in support of a recovering U.S. economy. When it established the Department of Homeland Security Congress included, as one of the elements of the “primary mission” of DHS, the need to “insure that the overall economic security of the United States is not diminished by efforts, activities and programs aimed at securing the homeland.” 6 U.S.C. Section 11(b)(2)(F). It’s also critical that air cargo screening requirements be implemented in a way that doesn’t inflict irreparable or unreasonable harm on transportation service providers. Passenger airlines are struggling to survive the current recession, and revenues from cargo on passenger planes help the airlines, as well as the indirect air carriers and forwarders that arrange for cargo to be transported by passenger airlines. All-cargo carriers provide excellent service, and transport millions of shipments annually for members of NASSTRAC. However, such carriers lack the capacity to handle all cargo that needs to move by air. In addition, the hundreds of shippers of air freight that belong to NASSTRAC recognize that airports lack the capacity to break down consolidated shipments for screening just before loading onto passenger planes. Accordingly, upstream screening of air cargo by shippers and forwarders is imperative, if freight is to continue to move by air. And air shipment is often a necessity, particularly for time sensitive shipments of high value commodities like pharmaceuticals and electronics. For these reasons, NASSTRAC strongly supports the CCSP, and anticipated the need for extensive pre-screening at certified facilities of shippers and forwarders. Many NASSTRAC members are also participants in CBP’s C-TPAT program, and recognize that certification and validation complement one another. NASSTRAC therefore recognizes the need for validation of personnel and facilities, and this recognition means there must be validators. Given the likelihood that demand for Certified Cargo Screening Facilities will increase with the growth of the CCSP, and with projected increases in the volume of air freight, the use of third parties as validators may sometimes be necessary. However, NASSTRAC shares the preference of express carriers for validation by TSA personnel. If third-party validators are to be used, it’s NASSTRAC’s belief that certain criteria must be met: 1. The applicable standards must be uniform. Many NASSTRAC members have facilities around the U.S., and in other countries, and have well-developed compliance programs. Security measures like the CCSP work best when participants know what is expected and are able to employ training and supervision that are consistent. If third party validators must be used, they must not undermine such consistency. 2. Validators must understand both components of successful programs – enhanced security and the need for goods to move as scheduled, and arrive safely. With particular reference to pharmaceuticals, there are some screening measures can render those goods valueless or even unusable, and shipping pointless. Validators need to know their jobs well. 3. Validators must understand that they may come into possession of information that is commercially sensitive. Many shippers are legitimately concerned about aspects of cargo security that extend beyond terrorism. Cargo theft is a large and growing problem, and many shippers go to great lengths to restrict knowledge of which cartons contain the goods that are most attractive to thieves. There is no inherent inconsistency between CCSP and everyday concerns like these; in fact the two efforts should support each other. However, in implementing CCSP, TSA needs to bear in mind that its screening program needs to be coordinated with many other efforts, by other agencies, by carriers, and by shippers, to enhance transportation security. NASSTRAC is generally supportive of the “layered” transportation security model that has emerged since 9/11. However, NASSTRAC gives encouragement that in adding layers, government agencies work with each other and with stakeholders to minimize inconsistencies and conflicts in the layers that reduce effectiveness, needlessly drive up costs, or compromise other goals of carriers and shippers. To view recent comments filed jointly by NASSTRAC and Health & Personal Care Logistics Conference, click here: http://www.nasstrac.org/newsroom/RecentFilings.asp.