By Second Officer Bill McReynolds (FedEx), ALPA’s President’s Committee for Cargo
Air Line Pilot, May 2003, p. 34

For many years, ALPA has been working to get corrected the significant gaps in safety and security that exist for all-cargo carriers; but since 9/11, the union’s role as advocate for cargo pilots has become even more important.

Most security gaps are not inadvertent—they are an integral part of existing federal regulations covering all-cargo operations.

And cargo carrier managements are ignoring real security concerns, whether these managers are lobbying to prevent cargo pilots from carrying firearms to defend the cockpit or working to avoid, delay, or void requirements to install hardened cockpit doors.

Currently, no regulations require a mandatory, uniform air cargo security program. Most of the existing programs consist of procedures that the certificate holder and the local FAA principal operations inspector (POI) have developed. A congressional committee is now considering a requirement for a standardized air cargo security program. For this legislation to succeed, labor must be a part of the process and design of any program.

Operations in the cargo sector face vulnerabilities different from those of their passenger-carrying counterparts. Although the terrorist threats against all-cargo carriers may be the same as those against passenger carriers (according to one all-cargo airline’s legal department and former FAA Administrator Jane Garvey), many threats are different and must be addressed specifically.

Among these different threats are having on board horse handlers who are foreign nationals and business jumpseaters whose actual criminal history is unknown. Other security issues unique to cargo include compliance with FAA and TSA directives on cockpit door security. The federal government—not certificate holders, whose motivations are based on unimpeded flow of revenue, regardless of whether sound security procedures and policies are in place—must address the unique security issues.

Managers of all-cargo carriers continually state that their operations are the most secure in the industry and set the standard for other carriers. However, several reports to ALPA indicate that this is not the case. An individual drove a large SUV on a Memphis cargo ramp unchallenged for several minutes. An elderly man at a location overseas gained access to an A300 cockpit for several minutes without security stopping him. These people weren’t trying to cause damage to the operations, but they easily gained access to "secure" areas.

To date, the Government Accounting Office has made no risk assessment concerning all-cargo operations specifically as to their aircraft operations, ramps, passenger carriage, and cockpit security. The Association has conducted an informal security assessment, and a national organization is making a formal assessment; but to date, the lack of additional layers of security that exists in all-cargo operations has no officially recognized basis.

The following areas of discussion illustrate the need for cargo security concerns to be addressed at the federal level—not at the local level with a handshake between the certificate holder and a local POI.

• Legislative issues—The wording of proposed legislation to address Part 121 all-cargo security concerns is weak, and many cargo carriers would have to do little, if anything, to comply with it. Two proposed Senate bills regarding air cargo security, S-169 and S-2949, are very vague. The airlines are trying to ensure that security programs and legislation that apply to cargo carriers can be implemented and complied with at little or no cost.

• Cargo security—The primary method for ensuring cargo security is the "known shipper" program, which provides an insufficient level of security. Cargo that is "unsafe" to be shipped on passenger carriers can be sent on cargo aircraft, with little or no screening required. The known-shipper program was easily circumvented during an anthrax hoax against a large nonprofit organization. Other measures, including detailed profiling and random screenings, should be considered.

• Uniform administration and enforcement of security measures—Currently, security directives determine most all-cargo security procedures, but policy and implementation issues are left to the certificate holder and the local FAA POI. Security plans, regulations, and policies differ substantially among Part 121 all-cargo carriers.

• Aircraft security—Since 9/11, the FAA, all-cargo carriers, and ALPA have been in discussions about the carriage of non-flightcrew "passengers" on cargo aircraft. Security policies differ on pilot jumpseating and carriage of non-flightcrew-related passengers; pilot-in-command authority; cockpit door procedures; PIC role in the carriers’ security plan; access of untrained nonpilot employees to perform security-related duties on the flight deck (a Security Supernumerary Assistant, or SSA) and other areas. Because of last-minute airline lobbying, the Federal Flight Deck Officer program currently excludes all-cargo pilots from carrying firearms to defend the flight deck.

ALPA’s Cargo Committee is working to get the following accomplished:

• Convening an All-Cargo Carrier Industry Working Group to make recommendations on issues involving all-cargo operations, and participating in Aviation Security Advisory Committee Subcommittees on Cargo Security.

• Adopting a One Level of Security and Safety approach to regulations for Part 121 all-cargo carriers and removing non-SIDA [Secure Identification Display Area] exclusions as they pertain to all-cargo operations. We urge the TSA to develop the proposed federal air cargo security program, to allow cargo pilots to carry firearms, and to ensure that cargo carriers are not exempt from cockpit door-hardening legislation and compliance.

• Mandating the following:

—standard 10-year fingerprint-based criminal history record check on all-cargo employees who work in the airport operations area;

—PIC security training and access to carrier security plans;

—carriage of "passengers" on all-cargo aircraft to comply with current FARs; and

—use of affordable and available technology in screening for intentional contamination.

Under current regulations, a convicted felon can legally work at our company, be eligible to ride the jumpseat, and act as an SSA, because of all the exclusions and exemptions that exist in the cargo sector. A recent communication regarding this from a major all-cargo carrier manager who was writing about criminal background checks implies that the TSA will accept a certain vendor’s background/credit history/employment screening as a criminal history record check. The TSA, in recent discussions, has indicated that this vendor’s program is only one of at least three methods the agency uses to screen its own employees. The mandated 10-fingerprint-based criminal history record check is the standard in use for criminal history checks and must be conducted on TSA employees. The TSA stated that using background/credit history/employment screening checks alone was unacceptable because it doesn’t uncover all of an individual’s criminal activities and arrests.

• Enacting federal regulations and mandates that are clear and enforceable.

Despite the airline industry’s woes, many air cargo carriers are doing well financially. This does not mean that ALPA should turn a blind eye to the glaring security gaps that exist and that many all-cargo certificate holders condone. We must implement policies and procedures based upon an independent threat assessment, as was done with the passenger industry, and not just take the word of someone in the corporation that everything is O.K.