June 6 - A broad group of associations representing airfreight forwarding companies is calling on the U.S. federal government to solicit input from small and medium-sized forwarders before expanding the Air Cargo Advanced Screening (ACAS) programme.

The programme, which analyses advance data on inbound air shipments to the USA to assess risk, is in a pilot phase, but US Customs and Border Protection (CBP) has signaled that it intends to expand it to apply to all inbound air cargo via a rulemaking.

The Airforwarders Association (AfA), the National Customs Brokers and Forwarders Association of America (NCBFAA), The International Air Cargo Association (TIACA), and the Express Delivery and Logistics Association (XLA) have jointly sent letters to CBP and the Transportation Security Administration (TSA) noting their support of the concept of the ACAS programme's risk-based analysis at the shipment level, but saying "we are concerned about certain issues which we feel have not yet been fully resolved within the ACAS pilot".

In addition to detailing issues regarding potential negative effects on small and medium-sized air forwarding businesses, the letters included requests to meet with both agencies and representatives from air carriers in June to discuss the concerns and try to resolve them. 

The four associations are concerned that the ACAS pilot programme has involved only a handful of forwarders, mostly larger operations that already have integrated supply chains and an overseas infrastructure. Their letters emphasised that the pilot has not included smaller forwarding companies "that rely on an extensive network of independent agents at overseas airports" and for whom "the size and scope of their technology infrastructure…varies widely." 

The groups called for more work to be done to determine how the ACAS programme would be applied to small and medium sized forwarders before they are brought under its requirements.

The associations said any ACAS rule "should maintain the level playing field for all filers. No requirement should create an unfair competitive business advantage for one filer over another."

The groups pointed to other issues of concern, including that ACAS may not take into account variances among US trading partners in the applicability and procedures of their own screening programmes, most notably that not all countries of origination allow forwarders to screen cargo.

On this issue, the letter said that it was important for ACAS "to clarify what the process and verification procedures will be when an ACAS dual-filing is made at a foreign location, first by the forwarder and then by the carrier".

Another key area of concern, pertinent to both TSA and CBP, has to do with the "targeting rule sets" for determining when additional high-risk screening will be performed, the associations said. Specifically, the letter requests that ACAS utilises only those risk-analysis formulas that have been tested in the pilot.

The TSA letter further outlined concerns about operational procedures for forwarders' screening of targeted shipments into the USA, which have also not yet been fully tested. It also raises questions about the potential impact for screening of US export shipments when other countries' advance data programs take effect.