Since the mandate to screen all cargo on passenger planes went into effect in August 2010, the Transportation Security Administration has reported success in meeting the law, at least for domestically shipped cargo. Much of this success can be attributed to the private sector’s voluntary participation in the Certified Cargo Screening Program (CCSP).

Yet, participation doesn’t always mean compliance, and voluntary doesn’t mean free from scrutiny. Over the last few months, TSA has been inspecting Certified Cargo Screening Facilities (CCSFs) to ensure security standards are being met. While most companies and facilities are adhering to the program guidelines and standards, some are not. In one case, TSA watched on video as CCSP workers marked “secure” cargo that had not been screened. For facilities that fall short, TSA is revoking or suspending CCSP status.

The screening mandate was a part of the Implementing Recommendations of the 9/11 Commission Act of 2007. When passed, the private sector was given three years to comply, though the law provided no funding or guidance on how to achieve such a massive undertaking. As the law was written, the burden to screen cargo fell on air carriers, which have neither the resources nor infrastructure to screen the millions of pounds of cargo shipped daily on passenger planes while also ensuring the cargo lifts off when scheduled. By this, the law threatened to disrupt the international supply chain.

Recognizing the challenge, TSA developed CCSP, a program where supply chain stakeholders can gain certification to screen cargo at private facilities. Through widespread participation in the program, the responsibility for screening cargo is distributed throughout the supply chain. For instance, if a forwarder in the CCSP screens cargo at their facility, so long as only CCSP participants move that cargo after it leaves the forwarder, the cargo need not be screened again.

After much effort and education from TSA and the private sector, the August 2010 deadline arrived and passed without catastrophic effects on the international supply chain. Numbers reported by industry to TSA showed that, at least with domestic cargo, the 100 screening mandate had been met.

Since then, over 500 TSA cargo inspectors have been checking in on CCSFs to ensure screening is commensurate with the screening provided by air carriers. Instances where screening falls short could be explained, in part, by a relative newness to the program. Whatever the reason, TSA is watching and inspecting to make sure CCSP participants play by the rules.

CCSP designation is given by facility, so a company is not rejected from the program for the failures of one location. Yet, cases where CCSFs do not satisfy the law (and are suspended from the program) can undermine customer confidence in a forwarder or supply chain stakeholder’s ability to deliver cargo to the next segment of the supply chain secure and on time. Further, if left unchecked, these kinds of violations undercut the legitimacy and effectiveness of the program.

But under TSA’s watchful eye, it seems CCSP participants are being held to the high standard the mandate requires. As the TSA audits and finds deficiencies, the knowledge gained informs new adjustments to security protocols, which keep the supply chain safer for all of us.