screening resources wasted because a competent regulator is requesting that the IATA Cargo tackles security Highlighting what is for IATA, an unequivocal aspect of security, Ken Dunlap, IATA’s director security says that beyond all else, security must be multilayered. “You just can’t come up with one brilliant idea that can get translated into a perfect cargo security programme. You can’t come up with one piece of cargo technology that’s going to screen everything – you can’t have a cargo checkpoint of the future – all of that’s not going to happen,” he said in Geneva recently.
For IATA Cargo, the very rapid changes in the security environment for the air cargo supply chain have evolved, in rather rapid pace, into a three-fold philosophy: Leverage cargo data; complement with technology; and take an entire supply chain approach.
Crucial, Dunlap says, is to concentrate on data and delivery of advance cargo data to regulators in order for them to do cargo targeting. But, one of the key problems with cargo data is that there are varying levels of maturity amongst regulators, in terms of their capabilities to accept cargo data. This is where IATA’s work on the E-cargo Security Declaration comes into play. The idea is to have something that ‘immature’ regulators and parts of the industry can use in a paper version, but provides a foundation for future electronic modes when they reach the necessary level of maturity for undertaking targeted security screening.
The next principle involves technology, where Dunlop notes there needs to be a faster process in getting technology from the laboratory to the warehouse floor. He cites the current issues with technology being unable to screen full palates resulting in breaking down of palates on-airport, “turning a nice built-up palate into a jigsaw puzzle on the ground.” “We want to work with manufacturers and governments to get the technology to where it needs to be so it can complement the intelligence screening we’re doing with the cargo data,” he said.
The third key principle is that security should involve the entire supply chain, not simply one or two key points in it.
Challenges
But as Dunlop notes there are a number of major challenges in the current security environment that make these principles difficult to achieve. Chief amongst these is the fact that states are largely acting independently and not neccesarly accepting other state’s security programmes and the states are not in concert with the global rule and standard-setting body for the aviation industry, the International Civil Aviation Organisation (ICAO). “The worst thing that can happen is to have your security screening resources wasted because a competent regulator is requesting that the security screening of another competent regulator is duplicated.
“We want to have ICAO as the focal point for collaboration between governments, but some governments are outpacing ICAO and it’s important to get from ICAO global standards and global definitions – those need to be the foundation of future security programmes,” Dunlap emphasizes.
As an example he cites the large number of emergency regulations that have been issued by various governments which can have unintended consequences such as the complete stoppage of mail for instance, which happened after the 2010 printer cartridge bomb attempt. The proliferation of lists is another problem – ‘red lists’, ‘blacks lists’, etc – with many countries drawing up lists of countries with suspect security environments which are then subject to restrictions or outright bans.
“These do not necessarily increase security,” says Dunlop, but instead create problems that are unmanageable for the supply chain.” He also underscores the fact that the so-called ‘list’ states must be given the ability to get off the list, but this can only be done through capacity building.
Governments must also move to mutually recognise comparable security programmes and work together to not create overlapping security programmes. The pace of mutual recognition must be sped up and the US, for instance, needs to get more countries onboard its programmes. He added that industrydeveloped security programmes also need recognition within government security programmes.
And then there is also what he says is the “growing problem” with how transshipment cargo is handled in state programmes. The problem, Dunlop notes, is that some regulators require screening of cargo at the last point of departure before arrival. This means in the case of a transshipment point, that the cargo must be removed from the aircraft, rescreened – and in the case of large palates, broken down – rescreened, rebuilt and reloaded onto the aircraft. This, says Dunlop, while not just inefficient, actually creates more security vulnerabilities because of the fact secure cargo has been removed from the aircraft and transferred to another location that may introduce new security issues.
Multilayered approach
When viewing security from a multilayered approach, the first layer is advance electronic information. Sent to regulators, this data on the shipment enables them to analyse the shipment and identify those with high risk that need additional, potentially physical, screening.
And there is in fact a standard for this already, defined by the World Customs Organisation’s (WCO) SAFE Framework of Standards. The framework, consisting of 21 data fields for shipments, defines who should send what information and when according to Frederic Leger, IATA’s head, Cargo Business Process and Standards present cargo security (e-security declaration and Secure Freight), who adds, “the ‘when’ is very important.” Today, the ‘when’ is at ‘wheels up’ if it’s a short-haul flight and four hours prior to arrival when its long haul. Many countries have implemented advance electronic data requirements based on this WCO standard, Leger notes. For example, recently South Korea, Ghana, Israel, the US have announced plans to introduce such a requirement and the US, in particular, is reviewing its requirements with its recently announced ACAS pilot programme. Europe meanwhile, has its Import Control System (ICS) and Export Control System (ECS) which is itself an advance electronic data programme.
The problem, part of the fast-paced evolution of air cargo security, is that following the printer cartridge incident regulators have become concerned about the timeliness of the data, because in many cases, by the time they’ve received the advance data and done their risk assessment, the cargo is already onboard the aircraft. The solution to this was to ensure this information is made available before the cargo is aboard the aircraft and this has led regulators to review the timelines based on their need to have access to the cargo data even prior to aircraft loading.
To help facilitate an efficient global standard, the IATA customs advisory group developed an industry position paper which Leger says has been shared with other industry groupings including the International Federation of Freight Forwarders Associations (FIATA). The paper describes the procedures, the roles and responsibilities, as well as the timelines for the provision of standard advance electronic information.
In a nutshell, shippers or freight forwarders provide information as early as possible to the regulator in the form of the goods (house waybill level) information which will be used for risk assessment and later in the process the carriers provide the cargo (flight manifest level) information. But Leger notes flight manifest will likely not be used for risk assessment as it is too aggregated and not detailed enough. As for how far in advance this information will be required, this is still being assessed by many regulators.
Leger notes that the paper describes the process only for the conventional carriers and not for the express or mail operators and neither does it cover the physical screening which is another separate layer for risk assessment.
IATA’s position paper also conveys the expectation of what Leger says is ‘dual filing’, meaning that the importing and exporting regulators will communicate with each other so that the information will not have to be provided separately to both parties.
The next step now that the position paper has ciruculated will be for IATA to continue to engage with WCO and ICAO and support industry and regulators, particularly the US with their Air Cargo Advance Screening (ACAS) pilot, as well as the EU and their ICS/ECS programmes.
Second layer
The second layer of security is the physical screening of cargo, says Leger which is guided by ICAO’s Annex 17 which specifies measures to ensure that cargo carried on aircraft is secure from the point security controls are applied until departure. This includes the responsibility of regulated agents with oversight by national authorities. Also important in Annex 17, if the cargo is secured upstream in the supply chain then it needs to be accompanied by a security declaration that provides and audit trail of who has secured what, when and how. “This is critical to ensure that cargo that is going on an aircraft has been screened by someone along the supply chain,” notes Leger.
The issue of the security declaration is of course a crucial issue for IATA as Leger notes. “That is a critical point for us, because we don’t want this piece of paper moving along the supply chain, we want an electronic security declaration,” he says.
There are a few key issues involved in this however, with Leger noting that IATA believes the air waybill (AWB) should not be used because it is a transport document and the industry is already moving towards an e-AWB. On the other hand, if a separate document is used it will potentially lack harmonisation between countries and there could also be lack of standardisation between airlines. All of this of course, adds complexity, inefficiency and greater risk of non-compliance in the air cargo supply chain.
The solution IATA has been working on, is to develop a standardised electronic consignment declaration that meets all legal requirements, provides and audit trail, will be accepted by regulators, simplifies the business and can be exchanged electronically. It can also be used as a printed document if electronic messaging is not available. The document is the result of work by the Electronic Consignment Security Declaration Advisory Group, comprised of TIACA, FIATA, IATA, other industry players and also regulators from the UK, the Netherlands and the European Community. At present the document has been endorsed by the IATA-FIATA Consultative Council (IFCC), adopted by IATA as a Recommended Practice, presented to regulators with positive feedback, considered by ICAO for future Guidance Material, piloted in UK and Netherlands with support of regulators and expressions of interest by over half-a-dozen countries, including Singapore, South Korea and the United Arab Emirates in Asia and the Middle East.
Secure freight
Meanwhile, IATA’s Secure Freight programme continues and while somewhat overshadowed by ICAO’s amendments to Annex 17 which stole much of the thunder of Secure Freight, Dunlap notes IATA is still pushing ahead with pilots – two new in Kenya and Mexico this year – as well as getting further formal recognition by regulators – currently Australia officially recognises the programme. One of the key advantages of the programme is that it is useful for countries which have little or no security programme in place.
