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With the best of intentions, the United States Congress approved the Implementing Recommendations of the 9/11 Commission Act of 2007 on August 3, 2007, which mandates 100% screening of ALL air cargo traveling on passenger aircraft by 2010.

You might ask: how can anyone not be in favor of 100% security screening?

This month, the legislation’s first deadline requiring 50% of all air cargo to be screened went into operation. Over a week later, the airline industry has not imploded nor has the supply chain ground to a halt.  That is the good news.

In fact, this is hardly the first show of the airline industry’s capability to adapt. In October 2008, the industry implemented a 100% screening system for cargo on narrow body airlines (single aisle- B-737, A-320 types). The system is working in both cases, but the critical question we should be asking is whether it is enhancing security or is it just creating additional work for cargo handlers and reports for TSA?

Most of the large airlines fly a mix of narrow & wide body aircraft which gives them a dual set of standards to meet and some flexibility in how to go about doing so.  In order to keep the cargo system moving as advertised, an airline can screen the cargo it receives and place it on either size aircraft. So if an airline has filled the capacity of its  narrow body carriers, the remainder of the cargo can be shunted over to wide body – essentially relieving the need to screen some other items.

This process becomes something akin to managing a municipal water system with various water sources.  One source is processed to achieve a high degree of purity and then is mixed with the alternate source until the total output meets required standards, ultimately finding an acceptable -– but not necessarily the lowest — common denominator.  This sort of maneuvering means that while the current screening law is being met, there is still a large portion of cargo that is never subjected to screening.

The next –- and undoubtedly much more challenging –- compliance deadline facing the industry is August 2010 when 100% of all cargo on passenger airliners will be required to be screened.  In contrast to this month’s deadline which was relatively easy to meet, the 2010 milestone may prove to be the step  when the system breaks down.

Why is getting from 50% to 100% so much more difficult?

The first item that will complicate full compliance is the physical limitations of the current screening equipment.  The InVision CTX machine and L3 eXaminer are the standard screening devices in use today.  Akin to the MRI imaging system used by the medical industry,  airlines use X-rays to measure density within a package.

The big drawback of the existing technology is that these machines have a significant limitation on the size of items which they can screen.  Currently, there is no available machine with a large aperture to handle items commonly shipped on wide body aircraft. The current generation of screening equipment coats on average about $1.6M per machine and there are several hundred in operation.  These machines not only screen cargo — an item accepted for shipment without a passenger — but also the checked luggage accompanying passengers.  To meet upcoming deadlines, the industry will need better machines in higher quantities — at an estimated cost of hundreds of million dollars.  This, of course, will also require additional employees at the airlines to actually perform the screening and will add on more costs to the shippers.  Not exactly an economic stimulus!

These deadlines prove that TSA is working harder, not smarter.  The agency is compiling a great forensic database, which the authorities will be able to effectively mine after a terrorist incident to track down the suspects.  A more effective approach may lie in utilizing 21st century technologies to analyze the pedigree of a package and the shipper to determine if it truly warrants additional scrutiny by being put through a machine or being subject to a dog sniff test.

The existing systems are fully effective in their use, but they are subject to limitations, as well as time and cost considerations.  By intelligently examining shipments based on known risks and their previous chain of custody, there is an opportunity to fast track some items through the system.  Today, we are simply bypassing any sort of screening for a large amount of cargo to comply with the letter of the 50% mandate.  Wouldn’t it be better to expedite the cargo being sent by known, trusted sources and not completely bypassing other items?

TSA needs to integrate operations, policy, and technology to construct a holistic security solution using risk-based approaches. The technology exists and the smart people are available to bring forward a more proactive approach to 100% and re-define the term “screening”.

Kevin McCarthy is a aviation security expert at Catalyst Partners in Washington, DC.  You can read his biography here.