The Berlin-based Federal Association for Aviation Security (FASAG) advocates having the same control mechanisms in place in all EU member states for securing air freight shipments. Despite identical framework conditions, the system still resembles a patchwork rug because of different control regimes allowed in one country yet forbidden in another state. "Urgent action is needed to harmonize the control regime, ending current competition distortions evoked by superfluous cargo tourism,” says professor Elmar Giemulla, Chairman of FASAG, in this exclusive interview.
CFG: Mr. Giemulla, in connection with aviation security in the cargo sector, your association speaks of an “Any-Other-Method” procedure for detecting possible explosives. The term sounds
quite imprecise. What exactly is AOM?
EG: The European regulation 2015/1998 on aviation security allows national authorities to approve additional new control methods if they have a sufficient level of security similar to controls by X-ray, explosive trace detection, or explosive detection dogs. On this basis, the national regulator LBA has allowed that certain commodities such as radioactive consignments, liquids in drums, dangerous goods, and some others, are exempt from these standard controls and instead secured through a so-called “AOM procedure”. If no X-ray examination is possible for consignments containing such goods (e.g. due to the density of lead-coated radioactive medicines, for instance), it is permitted to take a sample from the outside of a consignment to officially secure the items. So, instead, a smear test can be performed in order to detect hidden explosives by examining odor samples.
CFG: The German Federal Aviation Authority prohibited the use of the AOM scheme in mid-2019. On what grounds?
E.G.: The key argument was that AOM was not an independent new control scheme, but only a simplified method complementing the scope of standard explosives trace tests. Interestingly, the authorities did not say that the AOM system is insufficient or failing to provide a high level of security.
CFG: In contrast to other EU countries, such as The Netherlands and France, securing air freight using RASCargO, i.e. specially trained dogs, is not permitted in Germany. Did the authorities deliver any official justification for their restrictive course?
E.G.: The so-called “RASCargO procedure” is a scheme in which particle samples of air extracted from a truck are fed to an explosive detection dog. This works without having to control the entire truck or even single consignments. This way, controls are simplified.
There have been several projects in Germany to establish an analogous procedure and get the scheme approved. However, all projects did not achieve the safety standard required by the Luftfahrt-Bundesamt (German Federal Aviation Authority), and were therefore not approved, so all attempts have been stopped. According to the LBA, the approach delivered insufficient and erroneous results. Given this outcome, the decision to stop the RASCargO approach is understandable and supported by our organization, the German Federal Association for Aviation Security. However, this specific approach to secure air freight will no longer be possible unless the regulator comes to different conclusions.
CFG: Generally speaking, what are the consequences of Germany's restrictive air freight security policy for the industry, supply chains, and the environment?
E.G.: There is a saying in the forwarding world: "the freight finds its way". Hence, many forwarders now detour their shipments via France to make them secure using the RASCargO procedure which has become common standard there. Afterwards, they are trucked back to Germany to be onloaded as “secured freight” on board an aircraft in Frankfurt or at other airports. Other consignors decide to have their goods flown off directly from airports located in neighboring European countries. Either way, large parts of the Germany-originating volumes are migrating to The Netherlands, Luxembourg, or Belgium to be uplifted there. This is the consequence of the restrictive security regime practiced in Germany.
The RASCargO scheme has been ruled out as option by the German regulator. However, it is standard in neighboring countries and in compliance with the framework of the EU safety and security regulations. This different practice in EU member states leads to competition distortions. FASAG can no longer stand by and watch such a contradictory situation; action must be taken.
And there is another aspect that needs to be considered as pointed out in your question: the environmental issue. Trucking consignments 300 km or more across Europe for the purpose of securing freight abroad and transporting it back to its country of origin to have it uplifted there is absurd and has nothing to do with the much-cited "sustainability".
CFG: FASAG’s press release warns of "freight tourism" as consequence of the German insular security regime in air freight. Please elaborate.
E.G.: There are no official surveys documenting the cargo volumes secured by RASCargO. What is known, however, is the heavy traffic to Frankfurt that takes a "detour" via France where the shipments are secured before being onforwarded to Rhine-Main. This has become kind of an industry because there are service providers who offer trucking services between Frankfurt and France and back, which only serve the purpose to have the consignments secured across the border. Obviously, this is faster and eventually also cheaper compared to security controls in Frankfurt.
CFG: What should be done to establish air freight control regimes in Germany that are similar to those in neighboring European countries, thus creating a "level playing field" in securing cargo shipments and reduce trucking induced greenhouse gas emissions?
E.G.: We support the position of the industry and forwarding associations BDI and DSLV, demanding the reactivation of the AOM procedure. It is important for all parties involved, that the current unsatisfactory situation must be terminated. This is not a long-term issue but must be solved now in order to further fine-tune the German security regime and stop “freight tourism.” We from FASAG demand that the responsible political bodies take urgent action now.
CFG: We thank you for this interview.
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