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The submission supports providing an alternative to 100% screening for all-cargo air carriers, arguing that cargo assessed as secure through controls in the air cargo supply chain should be exempt. It also proposes additional risk-based, outcome-focused security measures and explains the security context surrounding ICAO standard changes and U.S. program adjustments.",{"@graph":69,"@context":123},[70,84,106],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":40,"@type":76,"position":81},"https://docshare.wps.com/document/research-report/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/air-cargo-security-options-to-mitigate-costs-of-compliance-with-international-security-requirements-comments-of-the-cargo-airline-association/297787/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/air-cargo-security-options-to-mitigate-costs-of-compliance-with-international-security-requirements-comments-of-the-cargo-airline-association/297787.png","ImageObject",300,407,{"name":92,"@type":93},"Clementine","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-10-19","2026-09-18",true,{"@type":102,"interactionType":103,"userInteractionCount":105},"InteractionCounter",{"@type":104},"ViewAction",12,{"@type":107,"mainEntity":108},"FAQPage",[109,115,119],{"name":110,"@type":111,"acceptedAnswer":112},"What request for information does TSA make in this document?","Question",{"text":113,"@type":114},"TSA issues an RFI seeking public comment on potential options to comply with ICAO international security standards for air cargo.","Answer",{"name":116,"@type":111,"acceptedAnswer":117},"What is the Cargo Airline Association’s main position on 100% screening?",{"text":118,"@type":114},"The Association supports TSA’s intention to provide alternatives to 100% screening, arguing that secure cargo under supply-chain controls should be exempt.",{"name":120,"@type":111,"acceptedAnswer":121},"What alternatives does ICAO provide for achieving compliance?",{"text":122,"@type":114},"ICAO outlines options such as 100% screening prior to loading, establishing a Known Consignor program, or using an alternative framework based on security controls for eligible entities.","https://schema.org",{"og:url":83,"og:type":125,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":127,"canonical":83},"index,follow",{"doc_id":129,"site_id":62},297787,1789748063,{"code":4,"msg":5,"data":132},{"doc_id":129,"user_id":133,"nickname":92,"user_avatar":134,"doc_module":4,"category_id":39,"category_name":40,"doc_title":65,"doc_description":67,"doc_content":135,"file_id":136,"file_url":137,"file_type":138,"file_size":139,"view_count":105,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":140,"language":141,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":142,"faqs":143,"seo_title":144,"seo_description":67,"update_tm":130,"read_time":145,"preview_page_count":4},1374391974564,"https://ap-avatar.wpscdn.com/avatar/14000253aa45c000a9e?x-image-process=image/resize,m_fixed,w_180,h_180&k=1779874745381141002","BEFORE THE  \nTRANSPORTATION SECURITY ADMINISTRATION ARLINGTON, VIRGINIA  \nAir Cargo Security Options To Mitigate Costs of Compliance With International Security Requirements  \nDocket No. TSA-2020-0001  \nCOMMENTS OF THE CARGO AIRLINE ASSOCIATION  \nIntroduction:  \nBy publication in the April 10, 2020, edition of the Federal Register (85 Fed. Reg. 20234 et seq.), the Transportation Security Administration (TSA) issued a Request for Information (RFI) asking for public comment on potential options for complying with standards for international security established by the International Civil Aviation Organization (ICAO) .1  \nThe Cargo Airline Association (the Association) is the nationwide organization representing the interests of all-cargo air carriers, as well as other participants in the air cargo supply chain.2 The Association and its members strongly support TSA’s intention to provide an alternative or alternatives to 100% screening to comply with the applicable ICAO standards. The conceptual program outlined in the RFI is one method of achieving this goal and we pledge to work with TSA to provide the information that will allow TSA to move forward with its  \n1 These Comments were originally due to be filed on or before July 9, 2020 . However, by publication in the June 24, 2020, edition of the Federal Register (85 Fed. Reg. 37958 et seq.), TSA scheduled a public meeting for July 29, 2020, to discuss the concepts set forth in the RFI and postponed the due date for Comments until August 27, 2020 .  \n2 Association members include ABX Air, Amazon, Atlas Air, DHL Express, FedEx Express, Kalitta Air and United Parcel Service. Many of these members will be filing individual comments herein.  \nconcepts. Simply stated, air cargo deemed “secure” because of controls applied in the air cargo supply chain should be exempt from 100% screening by the all-cargo air carriers. In addition, we submit that other risk-based, outcome-focused, security measures can accomplish the same or greater levels of security and should also be part of any alternative frameworks.  \nThe Association submits the following comments in support of these thoughts, as well as answers to the specific questions posed by TSA.  \nThe Security Context:  \nOn September 1, 2016, ICAO notified member states that they should phase out elements of their air cargo security programs that are inconsistent with ICAO Standard 4.6 no later than June 30, 2021 .3 As a practical matter, in the United States this notification means that the existing Account Consignor program for export freight would need to be eliminated for the U.S. to meet the new ICAO standards. Atthe same time, this new ICAO standard does not necessarily mean that 100% of all freight outbound from the United States must be physically screened. On the contrary, ICAO itself sets forth three alternatives to achieve compliance:  \n• Subject all cargo to 100% screening before loading on a commercial aircraft; or  \n• Establish a Known Consignor program for entities that meet certain security standards; or  \n3 On April 22, 2020, the Association, along with Airlines for America (A4A) and the National Air Carrier Association (NACA) filed a request for TSA to delay implementation of this standard in the United States until June 30, 2022 . This request was formally denied by letter from John Beckius dated August 5, 2020 . ICAO denied a similar request proposed by the Global Express Association (GEA) . These requests were based primarily on the time lost due to the chaotic aviation environment caused by the coronavirus pandemic, a situation that continues unabated today. In addition, since the filing of this extension request, TSA has postponed the due date for Comments herein by approximately seven weeks, making it extremely difficult for TSA to finalize, and industry to implement, the required alternative framework in time to meet the June 30, 2021, deadline.  \n• Establish an alternative framework recognizing an entity other than","cbCailkgeuN9M66h","https://ap.wps.com/l/cbCailkgeuN9M66h","pdf",177245,17,"English","# Introduction\n# The Security Context\n## ICAO standards and timelines\n## Alternatives to 100% screening","[{\"question\":\"What request for information does TSA make in this document?\",\"answer\":\"TSA issues an RFI seeking public comment on potential options to comply with ICAO international security standards for air cargo.\"},{\"question\":\"What is the Cargo Airline Association’s main position on 100% screening?\",\"answer\":\"The Association supports TSA’s intention to provide alternatives to 100% screening, arguing that secure cargo under supply-chain controls should be exempt.\"},{\"question\":\"What alternatives does ICAO provide for achieving compliance?\",\"answer\":\"ICAO outlines options such as 100% screening prior to loading, establishing a Known Consignor program, or using an alternative framework based on security controls for eligible entities.\"}]","Air Cargo Security Options To Mitigate Costs of Compliance With International Security Requirements - Comments of the Cargo Airline Association | PDF",43]