Amazing, how fast a year goes by. In the summer of 2009, the Transportation Security Administration was warning air-cargo shippers, carriers and freight forwarders that they needed to prepare for the 100-percent screening for explosives of cargo moving on passenger aircraft. But the deadline of August 1, 2010 seemed so distant, and the industry had more immediate concerns - such as surviving the Great Recession. Now the date is upon us.

To be sure, a number of major industry players signed up early with TSA's Certified Cargo Screening Program, or attended one of several "Town Hall" sessions conducted by the agency earlier this year. And the big freight forwarders had little trouble getting up to the interim 50-percent screening requirement by February of 2009. But there's still some doubt as to how prepared the entire industry is for full implementation of the new rule. The Government Accountability Office issued a report in June which found that shipper participation in a voluntary screening program "has been lower than targeted by TSA." According to the agency, "It is questionable, based on reported screening rates, whether 100 percent of such cargo will be screened by August 2010 without impeding the flow of commerce." In other words, thanks to a whole lot of laggards, we might be in for some serious delays.

The requirement stems from the work of the National Commission on Terrorist Attacks Upon the United States, better known as the 9/11 Commission, whose recommendations were adopted by Congress in 2007. Under the new law, all air cargo must be screened at the piece level, prior to being loaded onto passenger aircraft. Officially, it's the job of carriers to ensure that the screenings take place, but they've argued, rightly so, that they can't do it alone. For one thing, many shipments are tendered on shrink-wrapped skids, and no carrier wants to take the time and trouble to break them down for verification. (Nor would any shipper tolerate it.) For another, the volume of airfreight is just too large for carriers to manage the process on their own. Prior to August 1, 75 percent of cargo moving on passenger planes was being screened, and that amounted to some 19 million pounds a day.

Airfreight forwarders and shippers have to step up, too. Not only must they arrange for most of the screenings, they need to inform carriers that the procedure has taken place, so that shipments won't be delayed, rejected, or broken down. As far as TSA is concerned, there's no wiggle room for error.

The technology required to carry out the screenings isn't a major obstacle. It was available more than a year ago, according to Rob DiVincenzo, president of international services with Pitney Bowes Inc. Acceptable methods include X-ray machines, Explosive Trace Detection (ETD) technology and dogs operated by TSA personnel. Any snags in compliance will be caused by the failure of carriers and forwarders to incorporate the screenings into their everyday procedures.

DiVincenzo is especially keen on seeing the new rule work smoothly. Pitney Bowes deals in the mailing and distribution of huge volumes of publications, financial documents, direct-marketing material and other mail-related products. It also handles parcels for e-tailers and retailers throughout the U.S. Most of its shipments are delivered within three to 14 days, so ocean transport is not an option.

DiVincenzo admits that there's a big investment in equipment, time and management required to comply. Still, he says, it's vital that freight forwarders and shippers alike ensure that their partners are ready for August 1. Merchants should be grilling their providers about what steps they've taken, either to conduct the necessary screenings or appoint a third party to do them.

"The mandate is very clear," says DiVincenzo. "If you arrive at an airline with pre-screened material, it's going to travel as it has [before] - very quickly. If you drop unscreened cargo off, you have the chance of it being delayed. There will be two lanes - one for screened [freight], and one for not."

Descartes Systems Group is among the supply-chain software vendors to address the issue on the technology side. Julie Calcunovitch, vice president of air products, says some customers are only now checking to see whether they have the proper tools in place. "Certainly there has been quite a bit of confusion among some freight forwarders and carriers as to what their responsibilities will be," she says.

Forwarders need to build into their procedures the capability to inform carriers that screenings have taken place. Descartes' software allows for such notification to occur at the time of an electronic booking, utilizing two International Air Transport Association (IATA) handling codes, one for passenger flights and one for freighters. If a shipment hasn't been scanned, the system automatically adjusts the expected processing time so that the forwarder can plan for the delay.

Still, Calcunovitch says, there's a sense within the freight community that a certain amount of freight delays are likely, as participants scramble to comply. On top of that, expect higher shipment costs, as carriers pass along the expense of dealing with the new rule.

It all sounds fairly straightforward, but new regulations on transportation are rarely implemented without a glitch or two. And you're in for worse than that, if you haven't prepared for the 100-percent screening requirement. Says Calcunovitch: "It will be interesting to see, when it comes to August, how organized this will be."

Next, I'll look at an even tougher challenge: the full scanning of ocean containers.

- Robert J. Bowman, SupplyChainBrain

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