Joining TSAÆs screening program
Shipper case study: By Eric Kulisch
The Transportation Security Administration has certified about a dozen shippers to inspect their air cargo shipments instead of having it done by logistics partners or airlines.
Faced with the prospect that airlines will be unable to efficiently screen every box of cargo by August 2010 as mandated by Congress, these companies have opted to join the Certified Cargo Screening Program (CCSP) to avoid cargo delays and the possibility that contents can be damaged or stolen as other parties open up shipments to conduct their required inspections. That is an especially important consideration for shippers of perishable, high-tech, pharmaceutical and other high-value products.
Many freight forwarders are expected to join the CCSP to handle screening for customers who do not want to take on that responsibility themselves. But the TSA is encouraging shippers to take advantage of self-inspection as part of its effort to take pressure off the airlines.
Under the program, companies must obtain authority for each facility at which they want to do screening. The process involves background checks for all employees with access to the screening area, meeting security standards and establishing a secure chain of custody for transport to the airport.
As envisioned by TSA, shippers can do inspections with minimal impact by simply training people packing shipments to look for anomalies and properly seal and label the box as screened.
But a major maker of pharmaceutical, surgical and healthcare products has opted to do screening at its adjacent distribution center rather than at the end of the manufacturing line, according to a company representative who asked not to have herself or her company named because of internal politics over who gets credit for public statements.
The administrative burden associated with a large number of background checks, training and recordkeeping was too great considering the hundreds of people involved in the manufacturing process, the manager said. The company also felt that using physical searches was too time consuming.
Instead, the health products provider decided to set up screening across the street at its own distribution center and use technology ' specifically an explosives trace detection (ETD) machine ' the same way a forwarder or other third party might screen individual boxes from multiple customers.
At the warehouse, the company was able to limit the number of background checks, or security threat assessments in TSA parlance, to about 40 people, she said. It also chose to make the entire facility a screening area rather than cage off a portion of the building for screening activity and post-screening storage.
The manufacturer has a half-dozen other plants, but is letting its freight forwarders do the screening at the remaining locations.
Last year, TSA cargo inspectors visited the facility and met with staff to offer advice on how to comply. The company submitted its program application in June. During the next seven months the manufacturer developed a security plan for the facility, submitted names of employees for background checks, issued a purchase order for its ETD machine, received its final contract granting TSA regulatory control of its operation and trained workers on the detection device.
The TSA certified the company in February.
Among the steps the company took to comply with the new security regime are:
'Installed an access control system.
'Determined a process for ensuring chain of custody integrity and shipment certification.
'Provided a response plan if the access control system is breached.
'Obtained from trucking companies the results of their employee background checks to make sure they're secure carriers.
'Notified freight forwarders and motor carriers the DC is a screening facility.
Other necessary steps include posting signs identifying the entrance to the secure area and an emergency contact list, auditing one's program, and conducting periodic radiation leak testing of the ETD device, the manager said.
The company determined that joining the voluntary screening program made sense because it would maintain some control of the shipping process, ensure expedited delivery and reduced outside handling, and receive reimbursement for its costs from the TSA for participating in a demonstration exercise, the manager said.
Negative factors it had to weigh include extra costs associated with training and record-keeping, the need to become a TSA regulated entity, and making an unbudgeted technology acquisition.
The manager said key considerations for whether to become a CCSP facility include the volume of freight moved on passenger planes, the type of industry a company is in, a comparison of freight forwarder or airline screening fees versus program costs, and the impact to current business processes.
The manufacturer was able to easily incorporate CCSP procedures, the manager said, because the company normally places a fiberglass shroud over pallets instead of shrink wrapping them. That step allows the combined shipment to be defined as one piece for screening purposes.
Pfizer International is another pharmaceutical manufacturer that has gone on record about its participation in the CCSP to maintain the integrity and sterility of its shipments.
But there is no universal agreement among freight transportation professionals that self-inspection is necessarily the right strategy for shippers.
Beth Peterson, who heads her own eponymous trade consulting firm in San Francisco, said screening is not a core competency and often should be left to a third-party logistics provider or freight forwarder that is already building the infrastructure to do the job for multiple clients. Even a logistics provider that provides service within a shipper-owned building could leverage its technology and make arrangements to consolidate for other customers there too.
'Look at your cost per supply chain to determine if the people downstream in that supply chain have different processes for handling TSA pre-screened and non-prescreened shipments,' she said. A company 'can determine that the cost benefit just isn't there for certain shipment types or supply chains and leave it to the next party ' to conduct the screening.'