November 2009

For any company with offices in multiple cities, the employee vetting process is a difficult and challenging task. Imagine having to assume this responsibility for unrelated firms in far away places where you may not know the owners or the employees.

Forwarders face this challenge daily, wasting time, energy and money, duplicating efforts on a system that only the Transportation Security Administration (TSA) can fix.

A recent Airforwarders Association (AfA) survey poll identified the management and administration of authorized representatives as one of the foremost challenges faced by forwarders.

TSA’s definition of an authorized representative includes trucking companies used by forwarders to pick up and deliver shipments to the airport for transport on passenger planes. Regulations require that such agents adhere to the requirements in their forwarding customer security programs.

The TSA currently certifies over 4,000 U.S. forwarders and requires each to furnish individual security program requirements to their cartage agents throughout the country. In turn, trucking companies must return lists of data demonstrating that the agents’ employees have satisfactorily completed the security regimen.

Inaccuracies found during TSA trucking company audits usually lead to costly fines, which are assumed by each forwarder in business with the truckers. In addition to this daunting liability, forwarders are also responsible for the cartage agents’ facilities, trucking equipment and the security
related business process.

The thinking behind this illogical policy stems from TSA’s reluctance to regulate authorized airfreight trucking agents. If TSA took control of this situation, truckers would simply be assigned a TSA number allowing forwarders to easily verify certification against a master list. A similar arrangement exists today where airlines check a TSA distributed list assuring compliance before accepting freight from a specific forwarder.

The current TSA policy runs the forwarders through an expensive and time-consuming duplicative process. For instance, it is common for most forwarders to use the same trucking firm in a small city, requiring thousands of forwarding companies to constantly monitor the agent’s compliance. The trucker is forced to hire clerical help to answer related inquiries while the forwarder hires additional people to organize each record received.

Multiplying the number of requesting forwarders by the amount of records sought requires a mathematics degree to understand its impact.
A frequently used airfreight cartage company is a good place for TSA to begin the forwarder audit process, so it is not surprising that agents spend a lot of time there.

If the agency chose to regulate cartage companies, such visits would be refocused on agent compliance where irregularities are immediately addressed. If not in compliance, TSA would simply remove their name from the list.

If TSA does not wish to jump into the deep end of the cartage regulation pool, a hybrid approach to the problem may suffice. Interested truckers could voluntarily submit to TSA regulation, earning their eligibility to haul airfreight. This is similar to shippers deliberately submitting to TSA regulation when joining the Certified Cargo Screening Program to earn the right to screen their own cargo.

Forwarders wishing to maintain exclusive agreements with trucking firms could continue their oversight and responsibility for that company, assuring record and facility accuracy with ultimate accountability to TSA.

If TSA continues not to directly regulate cartage agents, another idea is to create an industry clearinghouse where truckers submit their pertinent compliance records accessible by both forwarders and the TSA. This would alleviate the duplicative effort of thousands of forwarders tapping
the same few trucking companies for identical information.

Many firms have explored this idea, but it has resulted in only a few projects that never received TSA endorsement. The past year has been unkind to the air cargo industry with volume drops exceeding 25 percent worldwide. Forwarders and their beleaguered shippers face an upcoming 100 percent screening mandate with uncertain economic challenges.

Now may be the time for TSA to help the forwarding industry and our partners in the airfreight trucking community avoid further financial despair.

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