Update Notes: In final rules concerning advanced imaging technology, issued March 3, 2016, the Transportation Security Administration states that "TSA may use advanced imaging technology [AIT] at security screening checkpoints." In the preamble to the final rules, the agency states that alternatives to AIT, such as explosive-detection canines and behavior detection screening, "are not as effective as AIT in screening a large volume of passengers in the least amount of time and require additional costs; however, TSA does use such alternatives whenever available as added layers of security at the airport." Department of Homeland Security, Transportation Security Administration, RIN-1652-AA67: Passenger Screening Using Advanced Imaging Technology. 81 Fed. Reg. 11364 (March 3, 2016). This observation by DHS and TSA may explain the rather lackluster response described by the GAO in the next few paragraphs regarding the implementation of certain recommendations regarding passenger-screening canines. TSA may be increasingly regarding bomb dogs as a secondary and expensive fallback where advanced imaging technology cannot be or has not yet been installed.
In a report released in February 2016, Status of GAO Recommendations on TSA's Security-Related Technology Acquisitions (GAO-16-176), the Government Accountability Office stated:
"In 2013, we recommended that TSA expand and complete testing, in conjunction with the DHS Science and Technology Directorate, to assess the effectiveness of passenger screening canines (PSC) and conventional canines in all areas of an airport deemed appropriate by TSA before deploying more passenger screening canine teams to help (a) determine whether PSCs are effective at screening passengers, and expenditures for PSC training are warranted and (b) inform decisions about the type of canine teams to deploy and their optimal locations in airports. TSA concurred with the recommendation but did not fully address the recommendation. Specifically, in 2014, TSA reported that it had assessed PSC teams deployed to 27 airports, cumulating in a total of 1,048 tests. On the basis of these tests, TSA determined that PSC teams are effective and should be deployed at the checkpoint queue. However, when contacted in December 2014, officials reported that they did no plan to expand or complete testing to compare the effectiveness [of] PSCs with the effectiveness of conventional canine teams as we recommended, citing concerns about potential liability in using conventional canines that have not been evaluated for their suitability for screening passengers in an unfamiliar passenger screening environment and the related risks to the program. We disagreed and pointed out that conventional canines paired with handlers already work in proximity with passengers since they patrol airport terminals, including ticket counters and curbside areas. Given that TSA does not plan on taking further action on this program, we closed the recommendation as not implemented. However, we continue to believe that the recommendation has merit and should be fully implemented."
Recently I flew from Tampa to Newark and noticed that at the beginning of the checkpoint there was a sign indicating that dogs might be present as I went through security area (I have become pre-Check so it isn't as much of a headache as it used to be--I can keep my shoes on). We saw TSA dogs outside the terminal and a few roaming the areas near the gates, but did not see any in the checkpoint area despite the sign.
A GAO report on federal acquisitions (GAO-16-209, January 7, 2016), contains the following statement:
"TSA operates a canine program that uses other transaction agreements to fund local and state participants who provide law enforcement officers to serve as dog handlers at airports, mass transit systems, and maritime and other facilities. Under these agreements, TSA provides the dogs and training for the handlers, among other things. TSA reimburses airports a flat amount per dog handler per year for qualified expenses, including payroll expenses for dog handlers, as well as dog-related costs, such as dog food and veterinary costs. As of the October 2014, there were 78 airports participating in the canine program, including 28 large airports and some smaller, regional airports, and 23 mass transit systems, such as the Metrorail in Washington, D.C."
This general statement cannot be directly compared with data as to the number of canine teams deployed. It must be hoped that the GAO will soon conduct another overall assessment of TSA canine programs.
On June 24, 2014, GAO released a follow-up report: Explosives Detection Canines: TSA Has Taken Steps to Analyze Canine Team Data and Assess the Effectiveness of Passenger Screening Canines. GAO-14-695T. This report updates certain items in the January 2013 report (GAO-13-239), a primary source for the original blog below. Also on June 24, 2014, the Subcommittee on Transportation Security held hearings on using canines to detect explosives and mitigate threats, receiving testimony from several TSA officials as well as from Jenny Grover, Acting Director, Homeland Security and Justice, in the GAO. Witness statements and Rep. Richard Hudson's interrogation of witnesses are posted on the website of the Committee on Homeland Security. If the Subcommittee issues a report, we will either further update this blog or write a new one. Update notes from the GAO's June 2014 report are in red below.
Recent reports by the Government Accountability Office, the House Transportation Security Subcommittee, and the Inspector General of the Department of Homeland Security have highlighted a number of problems with the canine programs of the Transportation Security Administration. Although deficiencies in TSA programs for mass transportation and maritime environments are noted in some of the reports, the greatest concern comes from the failure to provide optimal safety to commercial airlines, both symbolically because of 9/11 and practically because of the continued efforts of Al Qaeda to put suicide bombers aboard flights.
In a report released in February 2016, Status of GAO Recommendations on TSA's Security-Related Technology Acquisitions (GAO-16-176), the Government Accountability Office stated:
"In 2013, we recommended that TSA expand and complete testing, in conjunction with the DHS Science and Technology Directorate, to assess the effectiveness of passenger screening canines (PSC) and conventional canines in all areas of an airport deemed appropriate by TSA before deploying more passenger screening canine teams to help (a) determine whether PSCs are effective at screening passengers, and expenditures for PSC training are warranted and (b) inform decisions about the type of canine teams to deploy and their optimal locations in airports. TSA concurred with the recommendation but did not fully address the recommendation. Specifically, in 2014, TSA reported that it had assessed PSC teams deployed to 27 airports, cumulating in a total of 1,048 tests. On the basis of these tests, TSA determined that PSC teams are effective and should be deployed at the checkpoint queue. However, when contacted in December 2014, officials reported that they did no plan to expand or complete testing to compare the effectiveness [of] PSCs with the effectiveness of conventional canine teams as we recommended, citing concerns about potential liability in using conventional canines that have not been evaluated for their suitability for screening passengers in an unfamiliar passenger screening environment and the related risks to the program. We disagreed and pointed out that conventional canines paired with handlers already work in proximity with passengers since they patrol airport terminals, including ticket counters and curbside areas. Given that TSA does not plan on taking further action on this program, we closed the recommendation as not implemented. However, we continue to believe that the recommendation has merit and should be fully implemented."
Recently I flew from Tampa to Newark and noticed that at the beginning of the checkpoint there was a sign indicating that dogs might be present as I went through security area (I have become pre-Check so it isn't as much of a headache as it used to be--I can keep my shoes on). We saw TSA dogs outside the terminal and a few roaming the areas near the gates, but did not see any in the checkpoint area despite the sign.
A GAO report on federal acquisitions (GAO-16-209, January 7, 2016), contains the following statement:
"TSA operates a canine program that uses other transaction agreements to fund local and state participants who provide law enforcement officers to serve as dog handlers at airports, mass transit systems, and maritime and other facilities. Under these agreements, TSA provides the dogs and training for the handlers, among other things. TSA reimburses airports a flat amount per dog handler per year for qualified expenses, including payroll expenses for dog handlers, as well as dog-related costs, such as dog food and veterinary costs. As of the October 2014, there were 78 airports participating in the canine program, including 28 large airports and some smaller, regional airports, and 23 mass transit systems, such as the Metrorail in Washington, D.C."
This general statement cannot be directly compared with data as to the number of canine teams deployed. It must be hoped that the GAO will soon conduct another overall assessment of TSA canine programs.
On June 24, 2014, GAO released a follow-up report: Explosives Detection Canines: TSA Has Taken Steps to Analyze Canine Team Data and Assess the Effectiveness of Passenger Screening Canines. GAO-14-695T. This report updates certain items in the January 2013 report (GAO-13-239), a primary source for the original blog below. Also on June 24, 2014, the Subcommittee on Transportation Security held hearings on using canines to detect explosives and mitigate threats, receiving testimony from several TSA officials as well as from Jenny Grover, Acting Director, Homeland Security and Justice, in the GAO. Witness statements and Rep. Richard Hudson's interrogation of witnesses are posted on the website of the Committee on Homeland Security. If the Subcommittee issues a report, we will either further update this blog or write a new one. Update notes from the GAO's June 2014 report are in red below.
Recent reports by the Government Accountability Office, the House Transportation Security Subcommittee, and the Inspector General of the Department of Homeland Security have highlighted a number of problems with the canine programs of the Transportation Security Administration. Although deficiencies in TSA programs for mass transportation and maritime environments are noted in some of the reports, the greatest concern comes from the failure to provide optimal safety to commercial airlines, both symbolically because of 9/11 and practically because of the continued efforts of Al Qaeda to put suicide bombers aboard flights.
The deficiencies that are found in TSA�s canine programs are not generally due to a lack of funding. TSA funding for the National Canine Program increased from $52 million in fiscal 2010 to $101 million in 2012. Nevertheless, a staff report issued by the House Transportation Security Subcommittee (September 2012) indicates Congressional frustration with TSA�s pace of developing canine resources:
�The number of canine teams deployed to screen air passengers is on the rise, with many law enforcement and security professionals recognizing the broad applicability of this vital resource in the airport environment. Unfortunately, it would take many years at TSA�s current pace just to cover Category X airports with a minimum number of these teams, much less surface modes of transportation.�
Update Note: GAO-14-695T states:
"Of amounts appropriated in fiscal year 2014, TSA received a total of approximately $126.3 million for its canine program. This amount includes an additional $1.25 million above TSA�s fiscal year 2014 budget request to support not fewer than 10 more canine teams for the air cargo and aviation regulation environments. In its fiscal year 2015 budget request, TSA is requesting approximately $127.4 million, a $1 million increase."
A footnote adds:
"In its fiscal year 201 budget request, TSA proposes to consolidate all canine assets, including PSC teams and mass transit teams, within its Aviation Regulation and Other Enforcement account to allow TSA maximum flexibility to utilize the teams in any transportation environment as needed in response to changes in intelligence or capability requirements."
Update Note: GAO-14-695T states:
"Of amounts appropriated in fiscal year 2014, TSA received a total of approximately $126.3 million for its canine program. This amount includes an additional $1.25 million above TSA�s fiscal year 2014 budget request to support not fewer than 10 more canine teams for the air cargo and aviation regulation environments. In its fiscal year 2015 budget request, TSA is requesting approximately $127.4 million, a $1 million increase."
A footnote adds:
"In its fiscal year 201 budget request, TSA proposes to consolidate all canine assets, including PSC teams and mass transit teams, within its Aviation Regulation and Other Enforcement account to allow TSA maximum flexibility to utilize the teams in any transportation environment as needed in response to changes in intelligence or capability requirements."
Canine Programs Currently Operated by TSA
As of September 2012, the National Canine Program (NCP) of the Transportation Security Administration (TSA) had deployed 762 canine teams of the 921 which it is able to fund, meaning that it has yet to deploy another 159 teams. Handlers are either law enforcement officers or transportation security inspectors (TSIs), the latter being employees of TSA. The first four categories involve canines deployed with law enforcement officers, while the last three involve canines deployed with TSIs. Although the number of law enforcement teams certified has remained fairly constant, TSI certification rates have increased substantially since 2008 when such teams were initially deployed. The various types of TSA teams and their numbers are provided in the following table assembled by the GAO in the following table. Numbers in red are taken from an GAO update report issued June 2014 (GAO-14-695T).
Type of Canine Team | Number of Teams for Which Funding is Available | Roles and Responsibilities | TSA Start-up Cost/Team | TSA Annual Cost/Team |
Aviation | 491 (511) | Patrol airport terminals, including ticket counters, curbside areas, and secured areas; respond to calls to search unattended items, such as vehicles and baggage; screen air cargo; and serve as general deterrents to would-be terrorists or criminals | $94,000 | $63,000 |
Mass Transit | 111 (131) | Patrol mass transit terminals; search platforms, railcars, and buses; respond to calls to search unattended items, such as baggage; and serve as general deterrents to would-be terrorists or criminals | $84,000 | $53,000 |
Maritime | 6 (6) | Conduct similar activities as mass transit teams at ferry terminals | $84,000 | $53,000 |
Multimodal | 27 (27) | Patrol and search transportation modes in their geographic area (e.g., aviation, mass transit, and maritime), and screen air cargo | $94,000 | $53,000 |
Air Cargo (TSI) | 120 (120) | Primarily screen air cargo | $218,000 | $159,000 |
TSI Multimodal | 46 (46) | Patrol and search transportation modes in their geographic area (e.g., aviation, mass transit, or maritime), and screen air cargo | $218,000 | $159,000 |
Passenger Screening (TSI) | 120 (144) [to be at 30 airports by end of 2013] | Search for explosives odor on passengers in airport terminals [unless reassigned to cargo or training, as discussed below] | $237,000 | $164,000 |
Total/ Average | 921 (985) | $147,000 | $100,571 |
Update Note: GAO-14-695T states that "NEDCTP has deployed 802 of 985 canine teams for which it is able to fund across the transportation system."
Start-up costs involve training the dog and its handler, while annual costs for law enforcement teams include a stipend that is provided to the handler�s state or local agency. The stipend is intended to cover various expenses, including part or all of the handler�s salary and food and veterinary care for the dog. Any costs greater than the amount of the stipend are the responsibility of the state or local agency. In many cases, state and local law enforcement is able to hire the handler without supplementing the salary, which as the table indicates, means that federally employed handlers earn substantially more than state and local handlers. This disparity may not be equitable, given that many of the state and local handlers often have more experience. Expenses for TSA employees also include costs of their service vehicles, cell phones, etc.
Update Note: GAO-14-695T states that conventional canine handlers "attend a 10-week training course, and PSC handlers attend a 12-week training course." Also, the "majority of canine teams are trained by TSA�s CTES. However, according to TSA officials, because of resource constraints, TSA contracted with Strijder Group K9, which subcontracted to Auburn University�s Canine Detection Training Center to train some of the PSC teams."
Start-up costs involve training the dog and its handler, while annual costs for law enforcement teams include a stipend that is provided to the handler�s state or local agency. The stipend is intended to cover various expenses, including part or all of the handler�s salary and food and veterinary care for the dog. Any costs greater than the amount of the stipend are the responsibility of the state or local agency. In many cases, state and local law enforcement is able to hire the handler without supplementing the salary, which as the table indicates, means that federally employed handlers earn substantially more than state and local handlers. This disparity may not be equitable, given that many of the state and local handlers often have more experience. Expenses for TSA employees also include costs of their service vehicles, cell phones, etc.
Update Note: GAO-14-695T states that conventional canine handlers "attend a 10-week training course, and PSC handlers attend a 12-week training course." Also, the "majority of canine teams are trained by TSA�s CTES. However, according to TSA officials, because of resource constraints, TSA contracted with Strijder Group K9, which subcontracted to Auburn University�s Canine Detection Training Center to train some of the PSC teams."
The stipends for aviation and multimodal teams are greater than those for other law enforcement teams in part because teams assigned to these responsibilities are required to spend 25% of their time screening air cargo under a cooperative agreement with TSA.
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| TSA Team Screening Passengers (GAO-13-239) |
Annual costs for TSI canine teams include, besides the full salaries and benefits of the handlers, the costs of service vehicles, cell phones, and other equipment. There are also additional training costs for TSI teams, including providing decoys, persons pretending to be passengers who walk around the airport with explosive training aids (i.e., items containing explosive scents).
Certifications and Annual Evaluations Not Sufficiently Objective
Dogs are certified to begin working and then annually re-evaluated. The certification tests are designed to simulate environments in which they will actually work. The GAO report states:
�Canine teams must find a certain percentage of the explosive training aids to pass their annual evaluation. In addition, a specified number of nonproductive responses (NPR)�when a canine responds to a location where no explosives odor is present�are allowed to pass an evaluation and maintain certification. After passing the conventional evaluation, PSC [passenger screening canine] teams are required to undergo an additional annual evaluation that includes detecting explosives on a person, or being carried by a person. PSC teams are tested in different locations within the sterile area of an airport. A certain number of persons must be detected, and a specified number of NPRs are allowed for PSC certification.�
The italicized language indicates that a dog can make false alerts and still be certified. The sterile area of an airport is defined as the portion of an airport under the airport�s security program that provides passengers access to boarding aircraft and to which the access is generally controlled through the screening of persons, luggage, or cargo�i.e., what most of us call �past security.�
Some handlers complained to the GAO that not all evaluators score responses in certification tests the same way:
�[S]ome canine handlers stated that while one evaluator may consider a canine sitting a few feet away from the explosive training aid a 'fringe' response and count it positively, another evaluator would consider the same scenario a nonproductive response (NPR).�
Some evaluators mandate specific distances to declare an alert, but apparently there is some latitude in the TSA testing environment. As a result of these types of complaints, evaluators of teams operating in airport environments are now being themselves evaluated annually. Of course, under the Heisenberg Uncertainty Principle, the evaluation of the evaluators will not necessarily determine future behavior where evaluators know they are not being watched. It might be best to develop test environments where canine teams are videotaped and videotapes are viewed by several observers who independently score the results. This is, of course, standard in canine research environments.
Covert Tests of Canine Teams Discontinued in 2012
TSA collects data on covert tests conducted by field canine coordinators that assess canine teams� operational effectiveness in detecting and responding to possible explosives. These are called �short notice assessments.� The GAO criticizes TSA for not analyzing results beyond pass/fail rates, and for suspending these covert tests in May 2012 because of staffing shortages. TSA has not attempted to determine if certain types of explosives are not being detected, or if certain conditions are likely to result in teams being ineffective.
Update Note: GAO-14-695T states that TSA "reinstated short notice assessment in July 2013."
Update Note: GAO-14-695T states that TSA "reinstated short notice assessment in July 2013."
The GAO was informed by TSA that it is in the process of hiring new field canine coordinators and expects to have them deployed in early 2013, at which time covert tests will be resumed.
In June 2012, the Science and Technology Directorate in DHS and TSA officials began conducting operational assessments to demonstrate the effectiveness of passenger screening canine (PSC) teams, which is continuing in 2013. The initial assessment was conducted at an airport with PSC teams trained at Auburn University, but similar assessments will be conducted at airports using dogs trained at Lackland. It will be interesting to see if any comparisons of the effectiveness of trained canines from these two sources are made public. Auburn has been monetizing its canine research for some time so coming in first could have commercial value.
Update Note: GAO-14-695T states that "TSA does not plan to conduct a comparison of PSC teams with conventional canine teams as GAO recommended." The GAO report does say, however, that TSA is deploying newly trained PSC teams to the highest-risk airports. As to why a comparison is not being made, the 2014 report elaborates:
"According to TSA, the agency does not plan to include conventional canine teams in PSC assessments because conventional canines have not been through the process used with PSC canines to assess their temperament and behavior when working in proximity to people. While we recognize TSA�s position that half of deployed conventional canines are of a breed not accepted for use in the PSC program, other conventional canines are suitable breeds, and have been paired with LEO aviation handlers working in proximity with people since they patrol airport terminals, including ticket counters and curbside areas. We continue to believe that TSA should conduct an assessment to determine whether conventional canines are as effective detecting explosives odor on passengers when compared with PSC teams working in the checkpoint queue. As we reported, since PSC teams are trained in both conventional and passenger screening methods, TSA could decide to convert existing PSC teams to conventional canine teams, thereby limiting the additional resource investments associated with training and maintaining PSC teams."
Update Note: GAO-14-695T states that "TSA does not plan to conduct a comparison of PSC teams with conventional canine teams as GAO recommended." The GAO report does say, however, that TSA is deploying newly trained PSC teams to the highest-risk airports. As to why a comparison is not being made, the 2014 report elaborates:
"According to TSA, the agency does not plan to include conventional canine teams in PSC assessments because conventional canines have not been through the process used with PSC canines to assess their temperament and behavior when working in proximity to people. While we recognize TSA�s position that half of deployed conventional canines are of a breed not accepted for use in the PSC program, other conventional canines are suitable breeds, and have been paired with LEO aviation handlers working in proximity with people since they patrol airport terminals, including ticket counters and curbside areas. We continue to believe that TSA should conduct an assessment to determine whether conventional canines are as effective detecting explosives odor on passengers when compared with PSC teams working in the checkpoint queue. As we reported, since PSC teams are trained in both conventional and passenger screening methods, TSA could decide to convert existing PSC teams to conventional canine teams, thereby limiting the additional resource investments associated with training and maintaining PSC teams."
Highest Risk Terminals Decline TSA Passenger Screening Teams
Perhaps the most disturbing finding in the GAO report is that passenger screening canine (PSC) teams are not deployed to seven of the highest-risk airport terminals and concourses. The airports were not identified, though news reports have indicated that Orlando has rejected deployment of TSA screening teams. (According to The New York Times, 16 airports have elected, under an opt-out program established by 49 U.S.C. 44920, to use private security, rather than TSA employees, though supervision is still under the TSA.) According to written testimony of TSA Administrator John Pistole, PSC teams will be working at 30 airports by the end of 2013.
Allowing airport operators to reject passenger screening teams is unfortunate as that dogs provide significant backup to fixed security points where primary screening takes place. Bomb dogs and their handlers are mobile and can roam through parking, ticketing, baggage claim, security, seating, restaurant, retail, and gate areas where none of the other screening technologies are employed. The major reason for airport opposition to passenger screening is explained by the GAO as follows:
�TSA officials stated that PSC teams were not deployed to the highest-risk terminals and concourses for various reasons, including concerns from an airport law enforcement association about TSA�s decision to deploy PSC teams with civilian TSI [transportation security inspector] handlers and the appropriateness of TSA�s response resolution protocols. These protocols require the canine handler to be accompanied by two additional personnel that may, but not always, include a law enforcement officer. According to representatives from an airport law enforcement association, these protocols are not appropriate for a suicide bombing attempt requiring an immediate law enforcement response.�
Because TSIs are not law enforcement officers, but rather civilian employees of TSA, their ability to detain subjects who are suspected of carrying explosives is limited (though private citizens can generally act to stop a felony that is progress). Hence, airport operators create response protocols that require that civilian TSA handlers be near law enforcement personnel. These protocols can be difficult to implement if cooperation with local law enforcement agencies is not optimal.
Local Law Enforcement Support of Screening Teams
The Metropolitan Washington Airports Authority guide for police officers at Washington DC airports states that officers assigned to such duties �follow the PSC team from a distance that enables them to observe the operation.� By such shadowing, the police �can provide immediate response and communication as they are already on the scene and may directly observe the situation transpire.� If a subject is cooperative, the police may not need to intervene. If a subject remains uncooperative, the mere arrival of the police may make the subject cooperative. Dealing with an uncooperative subject can be complex:
�If the subject fails to obey police direction, objectively reasonable force may be used to detain the individual if there is reasonable suspicion justifying an investigatory detention. The positive alert of a TSA PSC canine may be considered reasonable suspicion of the possible presence of explosive material transported by an individual.�
A key concern is whether the dog has alerted to an odor on the individual or one on luggage or another item he is carrying or moving. �If the canine alerts on an individual, officers should attempt to keep the subject in a posture of disadvantage, with hands visible, while determining necessary resolution measures.� In addition, �officers should restrict the subject from any movements they feel could further endanger themselves or others.� As to restricting the subject�s movement, the guide states:
�[I]f a suspicious device is located on the front torso of a subject, officers might avoid restraining the individual in a prone position to avert the device from contacting against the floor. Furthermore, it may also be necessary to secure the individual to a fixed object in an effort to prevent his/her movement or escape from the area.�
The Authority notes that officers should be aware of other subjects in the area and remember that an IED can be detonated remotely by radio frequency or digital signals from the types of radios used by police to summon assistance.
The costs of the TSA deployments are not borne by the airports, but the cost of the law enforcement presence to support the canine team often will be. The fact the salaries of federal canine handlers are generally higher�sometimes much higher�than local law enforcement salaries presents a personnel problem for airport operators, so even if the airport wants TSI canine teams, it may find that coordination of those teams with law enforcement officers is a significant management headache. (Conflicts between different groups of canine handlers operating at the same airport have sometimes risen to the level where it must be questioned whether passenger safety may have been compromised, as indicated by a California appellate court decision regarding rival canine teams at the Los Angeles International Airport.)
Passenger Screening Canines Only Deployed in �Sterile Areas�
TSA generally deploys passenger screening canines only to sterile areas, that is, areas where passengers have already been screened. Some airport personnel have suggested that PSC teams might be more effectively deployed in parking garages and lots, curbside areas, and lobbies. They note that in these areas, the dog might detect explosives on a suicide bomber before he ever entered the airport structure. This is a good argument, and should be heeded. (A trial program being tested in Tampa and Indianapolis does involve passenger screening before ticketing of a small portion of passengers arriving at these airports. In testimony in May 2013, GAO-13-469T, Stephen M. Lord, GAO Director of Forensic Audits and Investigative Services stated that TSA continues to test the use of dogs in public (non-sterile) areas of airports.)
Other Logistical Problems for Airports
The Association of Independent Aviation Security Professionals, in a report issued in July 2011, noted certain logistical problems that may be particularly difficult for airports with limited space:
�[D]ogs need additional infrastructure to feed and to answer the call of nature. Airports are not a friendly place for such purposes, especially considering that 200 dogs would require a lot of food and produce a lot of dog waste to clean up each day, which would have to be disposed of accordingly. Dogs need to be kenneled when not in use, with added costs for transport, housing and food and require medical care.�
Also, some recreational and storage areas may have to be built:
�If a dog is asked to find an IED [improvised explosive device], works for hours and finds nothing, the handler then must take the dog out and give it a chance to find the item. Dogs are trained in two different ways�they are rewarded with food or with play when they succeed. That means the airport has to keep at least one, but usually several, samples of each explosive. Since the wide range and small quantities of concern are difficult to store and potentially dangerous, they must be stored in secure bunkers or lockers. To avoid cross contamination of vapors, as well as scent-saturation of dogs, which would render the samples and the dogs useless, each explosive must be stored well removed and in its own vapor-tight container to avoid all the other samples absorbing the odor of the nearest explosive with the highest vapor pressure, or worse, several competing contaminants.�
Such requests from TSA or law enforcement may also explain part of the resistance of some airport operators to permitting passenger screening handlers to work in their facilities.
Passenger Screening Teams Reassigned to Cargo Screening at Some Airports
The failure to deploy canine teams where they would be most useful has economic consequences, as the GAO notes:
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| Screening Air Cargo (GAO-13-239) |
TSA Not Using Its Canine Website System Effectively
TSA collects canine program data on its Canine Website System (CWS), a central management database, which records the amount of time handlers spend on proficiency training as well as the time canine teams screen for explosives and perform other functions. Information on swab samples was also often incorrectly entered into the system, according to the GAO. The Canine Website System did not, as of September 2012, include passenger screening data, though TSA officials informed the GAO that this information would be included by September 2013.
Update Note: GAO-14-695T states:
"In April 2013, TSA reminded canine handlers of the requirement to submit swab samples of their canines� final responses, and reported that the number of samples submitted that same month, increased by 450 percent, when compared with sample submissions in April 2012. CEU [NEDCTP's Canine Explosives Unit] is producing reports on the results of its analysis of the swab samples for the presence of explosives odor."
The bizarre jump in samples submitted no doubt reflects the fact that many handlers are reluctant to submit samples when only a limited number of alerts result in a finding of target odors in the samples. This occurs for several reasons, including the fact that a target odor may be present but not precisely on the location swabbed. Swabbing and testing samples thus can create a poor record for the dog, and the procedure adds significantly to the cost of deployment due to the costs of collecting, handling, packaging, shipping, receiving, processing, and logging of the sample It will be curious to see whether these factors are taken into account in determining the reliability of dogs and the effectiveness of programs.
Disturbingly, TSA admitted that some possible uses of the data that the GAO brought to TSA�s attention had never occurred to the agency. This suggests that there may be management weaknesses inside of TSA�s IT operations.
Private Contractors Could Expand Canine Screening of Cargo
Statutes and regulations require cargo screening, but allow it to be accomplished by an explosives detection system or one or more of the following: �(1) A bag-match program that ensures that no checked baggage is placed aboard an aircraft unless the passenger who checked the baggage is aboard the aircraft; (2) Manual search; (3) Search by canine explosives detection units in combination with other means; (4) Other means of technology approved by the Under Secretary [of Transportation for Security].� (49 U.S.C. 44901(e), emphasis added) Regulations also mention that cargo can be screened by �TSA-approved x-ray systems, explosives detection systems, explosives trace detection, explosive detection canine teams certified by TSA, or a physical search together with manifest verification, or other method approved by TSA.� (49 CFR 1544.205 (g)(2) (cargo); 49 CFR 1546.205(g)(2) (cargo, foreign air carriers)). Notice that the regulations specify that TSA certify the teams, but do not specify that they be handled by TSA employees, or come from any particular source.
From January to August 2011, TSA conducted a pilot program using private companies to screen air cargo. (Letter of John S. Pistole, Adminstrator, TSA, to Mike Rogers, Chairman, Subcommittee on Transportation Security, November 15, 2012) TSA found a number of issues that would have to be addressed, and apparently made little progress after the pilot study was concluded. In September 2012, the majority staff report of the House Subcommittee on Transportation Security stated:
�[S]ubstantial delays are leading to a missed opportunity to expand canine resources, create private sector jobs and leverage the private sector toward better air cargo security. TSA needs to finalize its efforts to develop a certification program for private companies to enable them to use their own canines, certified to TSA standards, to meet federal air cargo screening mandates. Leveraging private sector resources will introduce much-needed additional canines into the cargo screening system.�
The Aviation Security Advisory Committee noted, in a meeting held in September 2012 that �TSA operated dogs� are �used primarily for secondary, not initial, screening of air cargo and are currently limited to operations in airport facilities in approximately 20 cities.�
The Advisory Committee recommended that �private canines should be available in both the passenger and all-cargo environments and, where appropriate, should be used for primary, as well as secondary, screening. By expanding the available canine pool, and using this expanded pool for primary, as well as secondary, screening, specific discrete problem areas can better be addressed.� Thus, dogs �can and should be used � where physical or equipment-assisted screening methods are not available, not optimally-effective or are cost-prohibitive.� (In hearings held on June 2 and July 12, 2011, the House Subcommittee on Transportation Security heard various witnesses recommend that TSA "should provide access to their TSA-owned EDC training center for testing and certification of private sector dogs.")
Dogs may sometimes be the optimal screening method according to the Committee:
�In some limited circumstances, canines may be more appropriate than technology to screen specific commodities. For example, the application and introduction of expensive, limited use, technologies to screen limited and market-specific complex commodities (for example, liquids in barrels) is neither cost effective for industry nor an efficient use of limited research resources for the TSA. TSA should therefore establish a process whereby companies can request and receive authority to have TSA canines perform this function.�
This is not how TSA has always thought, so it may take some time for these recommendations to work through the agency�s hierarchy.
In a memo issued in September 2014 (OIG-14-142), the Inspector General of the Department of Homeland Security stated:
"We [the Inspector General's staff] identified vulnerabilities ... caused by human and technology-based failures. We also determined that TSA does not have a process in place to assess or identify the cause for equipment-based test failures or the capability to independently assess whether deployed explosive detection systems are operating at the correct detection standards. The compilation of the number of tests conducted, the names of airports tested, and test results are classified, or designated as Sensitive Security Information. According to TSA, the component [presumably some subdivision of TSA] spent $540 million for checke baggage screening equipment and $11 million for training since 2009. Despite that investment, TSA has not improved checked baggage screening since our last report in 2009."
Conclusion
TSA apparently prefers to hire its own handlers when it has the funding to do so, at least at airports. By paying them more than state and local handlers, however, it may be getting less bang for its buck than it could and it may also be creating frictions between its own TSI handlers and law enforcement support personnel. The agency is right to want to check on handler proficiency annually, but should move towards more objective testing environments where evaluations can be double-blinded and conducted and reviewed objectively. Covert tests should be a standard procedure.
Private contractors and alternative technologies should be evaluated for cargo and passenger screening. Although recent reports have not focused on overseas screening of air cargo coming into the U.S. on commercial flights, this continues to be an area of concern, particularly in some countries where a cultural disdain for dogs makes establishing canine programs difficult.
Most importantly, high risk airports should not be able to reject passenger screening teams, but such teams should be regularly deployed �before security.� (John Pistole, in written testimony to the House Subcommittee on Transportation Security, March 14, 2013, indicate that teams are increasingly being deployed before security. He did not provide specific statistics on this, however. Airport based law enforcement personnel should not attempt to establish overly complex protocols to respond to situations encountered by TSA civilian canine handlers. Nevertheless, TSA personnel should be sensitive of the need to cooperate with state and local law enforcement officers assigned to airport duties.
This blog was written by John Ensminger and L.E. Papet. The authors thank Dennis Civiello for comments and suggestions.
Sources:
- Association of Independent Aviation Security Professionals, Using Dogs/K9 to Screen for Explosives at the Passenger Screening Checkpoint is Ineffective, Impractical and Unrealistic (July 26, 2011).
- Aviation Security Advisory Committee. Meeting Summary (September 18, 2012).
- Department of Homeland Security. Privacy Impact Assessment for the Canine Website System (January 13, 2012).
- Department of Homeland Security, Office of Inspector General. Efficiency and Effectiveness of TSA�s Visible Intermodal Prevention and Response Program Within Rail and Mass Transit Systems (August 15, 2012).
- Government Accountability Office. Aviation Security: TSA�s Revised Cost Comparison Provides a More Reasonable Basis for Comparing the Costs of Private-Sector and TSA Screeners. GAO-11-375R (March 4, 2011) (raising issues about cost comparisons regarding TSA vs. private screening costs at airports).
- Government Accountability Office. Department of Homeland Security: Progress Made and Work Remaining in Implementing Homeland Security Missions 10 Years after 9/11. GAO-11-881 (March 2011) (stating that "TSA also reported a new approach for the Transit Security Grant Program, which focuses on resources, on the highest risk 'shovel ready' transit infrastructure projects, while prioritizing operational deterrence activities such as training and canine teams.").
- Government Accountability Office. DHS and TSA Continue to Face Challenges Developing and Acquiring Screening Technologies. GAO-13-469T (May 8, 2013) (testimony of Stephen M. Lord, GAO Director of Forensic Audits and Investigative Services, stating: "As of April 2013, TSA concluded testing with DHS S&T of passenger screening canine teams in the sterile areas of airports, and TSA is still in the process of conducting its own testing of the teams in the sterile and public areas of the airports.").
- Government Accountability Office. Federal Acquisitions: Use of "Other Transaction' Agreements Limited and Mostly for Research and Development Activities. GAO-16-209 (January 7, 2016).
- Government Accountability Office. TSA Explosives Detection Canine Program: Actions Needed to Analyze Data and Ensure Canine Teams Are Effectively Utilized. GAO-13-239 (January 31, 2013).
- House of Representatives, Report 112-492, Department of Homeland Security Appropriations Bill, 2013 (May 23, 2012).
- Metropolitan Washington Airports Authority, Office of Public Safety. General Order 4-411, Passenger Screening Canine Alert Procedures (July 25, 2012).
- Pistole, John, Written Testimony before Transportation Security Subcommittee, March 14, 2013.
- Subcommittee on Transportation Security, Committee on Homeland Security, Majority Staff Report. Rebuilding TSA into a Smarter, Leaner Organization (September 2012).
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