June, 2009: Training and Testing Begins!

It's June, 2209 and at this point all systems are go. The only thing left to do is to get my employees trained and tested. As well, I (as the primary security coordinator) had to be tested as did my secondary security coordinator.

here is how is worked:

As the Primary Security Coordinator, I was required to submit a letter requesting the TSA to allow me to self certify myself, so that I may train and certify my Secondary Security Coordinator and employees. The letter outlines the training program as a whole and your procedure for on-the-job training. Basically your are starting with basic class-room type training, with an overview of aviation history, CCSF responsibilities, leading up to actual operations training. This operations training consists of 15 hours or 100 pieces screened with a fake IED (Improvised Explosive Device (IED) – A device that has been fabricated in an improvised manner that incorporates explosives or destructive, lethal, noxious, pyrotechnic, or incendiary chemicals in its design. Generally, an IED will consist of an explosive, a power supply, a switch or timer, and a detonator or initiator.),whichever is completed first. Anyone testing below 85% on any test must be retested.

So I studied and had my secondary security coordinator test me and me test him. After we both certified the other, we worked together to certify our employees. My reasoning to this approach was as we both tested the employees, we were constantly reviewing the information we were required to know.

We all passed with flying colors.........

April, 2009 Time to pick up the pace!

At this point, it had been a good 6 months of a delay in me moving forward with the program. This was largely contributed to me still trying to figure out exactly how I wanted to proceed and of course running my day to day business. I also was guilty of some procrastination due to still being a little intimidated by the project, but time was still on my side at this juncture, and I could feel it coming together a little at a time. Luckily, I received a list of required sections from the TSA for the operations manual. This was a huge help!!

I finally decided it was time to stop delaying and I submitted the first Security Threat Assessment (STA) on myself, which is basically a background check. Per usual, TSA did not delay. I was approved on May 4, 2009. Upon approval, I was given a code that I could use to submit my employee's STA'S via a specific web page and this was a very easy process. Unfortunately, I can not reveal anymore useful information on this topic. Needless to say in pure TSA fashion, my employees were cleared with-in a week or two. We were set....

Quick Recap at this point:

June, 2008: submit initial application and Safety Act application
August, 2008: received first TSA Order
September, 2008: initial application approved
April, 2009: TSA provided required section tabs for the operations manual
April, 2009: submitted initial Security Threat Assessment (STA) on myself
May, 2009: initial STA approved, submitted employee STA's
May, 2009: employee STA's approved

Early October, 2008: Operations Plan and Manual

Here is were it initially gets a little difficult. You see, the TSA Order is really just a book of all the rules, regulations and specifics. It really does not lay out a plan for you. But, like I mentioned previously, TSA did provide us with an initial check-list, so this was helpful in getting ourselves facing in the right direction so to speak. So, based off my readings of the Order several times, I knew I would need to create the entire screening program from scratch. This is the only time in the project were my background in operations really came in handy. Though the overall task was difficult, it was rather easy for me at this point to start to imagine in my mind how this whole project was going to start to "flow" from a day to day operational point-of-view, as well as the certification process overall. But the really difficult part was taking all the information I had gathered from the book, all of my own operational ideas and try to bring them all together for the overall program and in a operations manual! As a result, I am starting to sweat at this point. It was all just a bunch of information and ideas I had to bring together into an actual plan.

Here are a few of the things I need to create for my Operational Plan: ( I have decided to omit this part for now, until I receive the O.K. from the TSA.)

facility map including surrounding areas
facility description of daily operations/type of business
facility escape route/plan in the situation we discover a incendiary device in our cargo including a meeting location for all employees. we chose a close-by fire station
facility class room training/testing procedures.... we will get to that later
on-the-job training (OJT) plan and logs
i created a fake incendiary device out of an old lap top battery for purposes of on-the-job-training
i created a facility plan for the designated screening area, which is off limits to anyone other then your employees who have been vetted by the TSA.

These are just a few things that I had to create from scratch: (There is plenty more but we have to keep in mind a lot of the information is privileged therefore we can not share it)

Late September, 2008: To-do Lists

At this point, I still really had no idea what i was going to do. But after reading the order in it's entirety many times, I decided to formulate a list of tangible things I new that I would need to invest in, in order to make this happen. Let me back up here a moment. I must say this with complete honesty, that the TSA was very efficient about the process thus far. Again, back to the efficiency of the TSA our initial inspection had already happened! Remember, we submitted our application July 25th! And much to my relief, my TSA rep. was; very nice, outgoing, helpful and professional. She supplied me with all the tools that she could at this point. Including an initial check list, for both her and I to follow as I completed tasks along the way. They wanted us to succeed at this! This was fabulous! She actually gave me her cell number!!

Ok, with our initial inspection out of the way, I needed to make my list of tangible items I knew I was going to need to purchase: proper TSA specific signage, TSA approved labels, hardware to construct a designated screening area with-in my existing shipping facility, security cameras, numbered security tabs for my deliver truck and a fire proof, locking box to safely store my TSA documents, as well as a electronic back-up device (memory stick) to store all documentation.

Second, I begin the tedious task of creating a list of what I needed begin creating my very own Agro Gourmet, LLC/TSA CCSF Operations plan and manual..... Stay tuned.

September, 2008: "But Agro Gourmet, LLC is just a Specialty Produce Shipper! How am i going to pull this off?!!!!"

September 9, 2008 our initial application is ALREADY approved! Things are taking off even more. TSA is not wasting time! So I begin to think: "Man how am I going to do this? Ok, it can't be THAT hard. I survived 10 years on a east coast, wholesale produce market for god sakes! Built my own company from scratch! If I survived (barely) those vultures, I can do this! Where did I put that damn 80 page Order?" In that behemoth I reckoned had to be the answers......... hmm not really.

I spent days reading and re-reading the Order, trying to formulate some sort of plan in my mind at least. I would put it down and re-read it again. This went on for two more months! As well, my poor TSA representative I am sure was already tired of me. (Remember at this point, we still were not approved for anything other then the initial application and on August 27, 2008 we did have our initial facility inspection where we were provided with a basic check list of what we needed to do. Regardless, I wanted to get a head start on this whole program. I had very detailed and horrific visions of: come August 2010, all of my very perishable air freight sitting at the airline cargo facilities for days on end, waiting to be screened by of all people, airline employees!! God no!! These are some of the laziest people known to man, unionized or not! No way was that going to happen if I could prevent it!! Customers are not very forgiving in the perishables industry, and I've got my whole business riding on this literally. And if my product does not ship on time, or arrive in perfect condition, I am toast! No matter what happens in between the order being placed, and it landing at it's destination, if there is a problem, it is the shippers fault.. always.)

Early August, 2008: Things already start to move along......TSA does not mess around!.

Oddly enough, though at this point we had not been approved for anything, we received the first of what is known as the TSA CCSP "Order". Basically, this was an outline of the entire program A-Z. All 80+ pages! Now the worry and panic really took a hold of me. (You see even though you submit an application and it gets approved, that is actually only the beginning. That's the easiest part! You still must create your very own "facility specific" Certified Cargo Screening Program from scratch. As well, you are also subject to an on-site inspection by a TSA Security Rep.) So, not only did I have absolutely no idea how, or what i was going to do to make this work, I had to endure a facility inspection by the TSA! To be honest, I had visions of some wanna-be hard-nosed, government employee coming in just to see me fail at this very important project. Sort of like how some of the airport screeners like to sometimes play boss. But, I could not have been more wrong as I will explain later. So at this point, the only choice I had was to dig in, and make a serious stab at this program. But, I really did not know what the hell I was going to do. Ironically, the 80+ page TSA Order and my TSA Representative become best friends to me and my company Agro Gourmet, LLC .......

June 2008: "The Journey Begins"

As a shipper of specialty perishable produce (Agro Gourmet, LLC, San Diego, CA), it was right around the beginning June of 2008 when I learned of the upcoming TSA Certified Cargo Screening Program (CCSP). Under section 1602 of the Implementing Recommendations of the 9/11 Commission Act of 2007, P.L. 110-53 (2007) (9/11 Act), TSA is required to establish a system to screen 50 percent of air cargo transported on passenger aircraft by February 2009 and 100 percent of air cargo transported on passenger aircraft by August 2010.

As I recall, my first reaction was one of panic and my first thought was: how in the heck am I going to pull this off? I was out of my comfort zone to say the least. I was and remained, very intimidated by the up-coming project at hand. I began by searching the internet for any information I could find. Needless to say my search was fruitless, which proved right then, how new the program was and still is. Luckily, a business associate sent me an article he had found with a link to the TSA CCSP web page, I was off and running.

The first thing I did was download the CCSP application along with an application for agreeing to follow the Safety Act of 2002.

Support Anti-terrorism by Fostering Effective Technologies Act of 2002 (SAFETY Act)

The Support Anti-terrorism by Fostering Effective Technologies Act of 2002 (SAFETY Act) provides “risk management” and “litigation management” protections for Sellers of qualified anti-terrorism technologies and others in the supply and distribution chain. The aim of the Act is to encourage the development and deployment of anti-terrorism technologies that will substantially enhance the protection of the nation.

On June 25, 2008 I submitted my applications. Hurry up in wait.... or so I thought.