The Transportation Security Administration is worried. TSA thinks that shippers aren't keeping up with the timetable for complying with a new law requiring that 100 percent of cargo moved on passenger aircraft be screened on a per-piece level - just like passenger baggage. Things were going well for awhile, the agency says, then the pace of compliance began to fall off. Now, some shippers face the prospect of big delays in the movement of their freight, if they don't get back on track.

Based on recommendations by the 9/11 Commission, the law mandated 50-percent screening of cargo carried in passenger planes by February of this year, and 100 percent by August of 2010. And that means checking each individual piece for traces of explosives. Acceptable screening methods include X-ray machines, Explosive Trace Detection (ETD) technology and dogs operated by TSA personnel. Officially, the burden falls on carriers to ensure that the screening occurs, but by the time they take possession of cargo, it's often on skids and shrink-wrapped. Faced with freight volumes of 12 to 15 million pounds a day, airlines don't have the time or resources to take apart and reassemble pallets - nor would they accept the resulting risk of freight damage and delays if they did.

That puts the onus for screening squarely on shippers, forwarders and other intermediaries. To help them get the job done, TSA has established a voluntary Certified Cargo Screening Program, or CCSP. It allows for early screening of cargo, before it is wrapped or palletized and tendered to the carrier, so long as shippers can show an unbroken chain of custody throughout the process. In addition, they must open their freight-handling facilities to TSA inspectors.

The benefits of participation in CCSP are obvious; it reduces the risk of delays or inspection further down the line. What's more, says TSA air cargo manager Doug Brittin, shippers avoid the problem of "false positives," where traces of explosives are detected in a clean shipment during a late-stage screening. Such errors can occur if a container or trailer was contaminated by an earlier shipment. Or, the screening device can be flat-out wrong. That's cold comfort for a time-sensitive shipper who has to undergo lengthy delays in order to prove its innocence.

Getting to 50-percent screening was relatively easy, says Brittin, with big freight forwarders stepping in to help hit the target. Even as late as April of this year, TSA was seeing "a nice ramp-up" in applications to join CCSP. After that, however, the pace slackened. Brittin thinks shippers might have grown complacent because freight volumes dropped significantly in recent months, meaning that the 50-percent goal became easier to reach. But if the economy recovers in the coming year, and freight activity returns to the levels of 2007, shippers would be faced with an estimated 300-percent increase in the amount of cargo to be screened. Moreover, freight yet to be screened is mostly carried on widebody aircraft, so there are many more skids and pallets with which to deal.

Cost, as always, is a factor. Brittin says many intermediaries are reluctant to charge for the screening because they don't want to drive customers away. But without compensation for this additional service, they won't be able to invest in the technology and training that are needed to make the system work smoothly. Says Brittin: "It's not inexpensive."

For now, he says, many shippers appear to be "waiting, delaying, seeing how things go." But they won't have the luxury of waiting much longer. Those who submitted applications for CCSP by August 1 of this year can secure "early participation benefits." They included a longer time in which to review regulatory documents before committing to the program, free on-site facility and security-threat assessments by TSA, and an extended ramp-up period. Such is the carrot. Here, in the words of TSA  (www.tsa.gov), is the stick: "Only cargo that is 100-percent screened at the piece level will be uplifted on passenger planes on August 1, 2010." So get ready.

- Robert J. Bowman, SupplyChainBrain

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