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RAS Cargo und Luftsicherheit
Jan Weiller

Jan Weiller

As Program Manager Global Airfreight, I coordinate our strategy and activities worldwide. My goal is to integrate local requirements into a global strategy in order to meet customer requirements, expand our product and remain innovative.

More security in RAS Cargo thanks to important procedural changes

There are important current changes in RAS-Cargo, which I will present below. France has taken on a pioneering role here. It is about changes that will increase the security of air freight transportation in the future. After all, a not inconsiderable proportion of dangerous goods transported worldwide are now transported by air.

One standard - different interpretations

In the following, I am mainly talking about the situation in European air traffic. But much of this is also transferable to other continents. The harmonization deficits in international trade are similar, regardless of whether we are talking about Europe, Asia or the Americas. The basis for aviation security in Europe is the European Union’s Implementing Regulation 2015/1998 entitled “Laying down detailed measures for the implementation of the common basic standards on aviation security”. The title suggests that we have a common standard of aviation security within the EU member states and work in a harmonized manner. Finally, 142 pages define the safety of people, airports, airplanes, freight and much more.

However, a look at practice quickly reveals that this assumption is far from the truth. Basically, the common standard is limited to understanding when freight is safe or unsafe. The far more exciting part, however, is how freight becomes safe or unsafe. If I imagine a process diagram, it has many branches with different options and scenarios. It is a very complex process and there is a whole range of security control methods available to secure unsafe cargo. Each program has to be considered individually and that is precisely why it is so exciting.

However, the implementation of the above-mentioned implementing regulation in the EU member states varies greatly in some cases, leading to different regulations on how freight is considered safe or unsafe. An EU-wide standard with various national interpretations, so to speak. In practice, this can have controversial consequences. For example, a security control method that is permitted in country A may not be permitted at all or only to a limited extent in country B. We will see in a moment that RAS-Cargo is just such a standard, which is interpreted completely differently in different countries.

But there are positive developments. The legal situation in the EU member states seems to be slowly but surely converging as authorities exchange information and harmonize their guidelines. The current changes to the RAS cargo security control methods adopted in France must be interpreted in the context of these harmonization efforts.

What is RAS-Cargo and why is it important?

RAS-Cargo is a security screening method in which air samples are taken from closed cargo and collected in specially developed filters. The filter is then presented to trained dogs, which can sniff the filter to detect whether it contains prohibited substances such as explosives or narcotics. The dogs compare the smell with reference patterns. The dog sniffs the filter with the sample and then sniffs several comparison samples and indicates an odor sample that serves as a “marker”, i.e. that smells like the identified hazardous substance.

Odorolie
A specially trained dog sniffs out odor samples, which are fed from a warehouse into a training room via a piping system.

This method plays an important role for shippers of dangerous goods or chemicals because many of these substances cannot be secured by other checks, such as X-rays. This is because the substances in question (e.g. liquids, powders, pastes, granulates or solids) are often packaged and transported in hermetically sealed containers (e.g. made of plastic or metal). The above-mentioned combination of substance and container is highly likely to produce a dark X-ray image on X-ray machines because the X-rays cannot penetrate the container. This is known as a dark alarm. Put simply, it is not possible to determine whether prohibited substances are present.

It is also not possible to open the containers (as they are hermetically sealed), which also rules out other control methods such as “sniffing” (explosive trace detection) or searching by hand (hand search). Therefore, only the RAS procedure remains in most cases.

Franco-German freight tourism: Is the RAS procedure reliable?

But RAS-Cargo is certainly a controversial process. There is no consensus among experts as to whether the contents of a hermetically sealed container can actually be sniffed out. After all, no air and therefore no particles of prohibited substances enter or escape. This is also one of the reasons why the responsible authority in Germany, the Federal Aviation Office (LBA), has banned the RAS procedure for cargo that is highly likely to cause a dark alarm since July 2019. Such freight can therefore no longer be guaranteed in Germany.

Our gaze falls on France. The responsible authorities there continue to permit the RAS procedure. However, it is unlikely that dogs in France have a finer nose than dogs in Germany. Nevertheless, the security status granted in France can also be recognized in other EU countries. The EU Implementing Regulation 2015/1998 on the creation of common standards makes this possible. Since July 2019, unsafe freight has therefore been transported by truck from Germany to France, secured there by RAS-Cargo and then transported back to Germany so that it can be loaded onto the aircraft there with the status “safe”. It is not for nothing that RAS-Cargo likes to talk about “freight tourism“.

Dunkelalarm
"Dark alarm": A hermetically sealed container cannot be identified in an X-ray scanner for luggage.

Important change to the RAS procedure in France: No more RAS procedure for large containers

Last November, French authorities announced that their own studies of the RAS procedure in connection with hermetically sealed containers with a volume of more than 25 liters had led to the conclusion that explosives dogs could not reliably sniff out all prohibited contents. The German shepherd can breathe a sigh of relief – his sense of smell is not inferior to his French counterparts after all.

The results were submitted to the European Commission for review. Regardless of the outcome, France has already adopted amendments. In summary, these state that from 01.10.2024 no hermetically sealed containers larger than 25 liters may be secured using the RAS method. From April 1, 2024, a transitional regulation will come into effect that will only allow the RAS procedure until October if the shipper has written approval from the French Aviation Security Authority (DSAC).

From 01.10.2024, RAS-Cargo will only be approved for containers smaller than 5 liters in France. Larger containers up to 25 liters can only be secured with X-rays. However, if a dark alarm occurs, no further security control method is permitted – with the strict consequence that no shipment may be made by air freight.

RAS Cargo new regulations 2024
Own representation based on a letter from DSAC dated 16.01.2024

The way finally seems clear for France to catch up with other EU member states such as Germany and the Netherlands by tightening up regulations and further harmonizing procedures to ensure aviation security. On the one hand, this ensures greater transparency of intra-European processes, which makes it easier in practice for the players involved: the same procedure in all countries. On the other hand, the idea of security in the European Union will be strengthened, which will benefit us all. After all, most of us will sooner or later be passengers on board an airplane and want its cargo to be safe.

Implications for the supply chain

The trend in the market and among the responsible authorities is clear: freight should already leave the shipper’s production facility or warehouse (regardless of whether it is their own warehouse or operated by a 3PL) in a safe condition. Then no additional security control methods are necessary. This is the ideal case. Or rather: the “safest” case. This requires certification as a known consignor, which is linked to strict requirements from the responsible authorities. Among other things, the entire operating site must be equipped with safety technology (outdoor area, yard, building, production facility, etc.) and staff require special safety training. A safety officer must carry out regular checks to ensure that all requirements are met at all times.

The resourceful player could now turn his attention to other European countries that still allow the RAS procedure on a larger scale. But this will only be a short-term solution to buy time. Because other national authorities will certainly soon follow suit with their regulations. In addition, the outcome of the European Commission’s review is still pending and it would be very surprising if the EU were to keep a controversial and supposedly not completely reliable security control method alive. This is in clear conflict with the goal of establishing common basic standards for aviation security.

Anyone who wants to ship dangerous goods or chemicals by air freight in the future must therefore take an even closer look at their supply chain planning and critically discuss the various solutions, as there is no “one size fits all” solution.


Illustrations: khairulz – adobe stock.com; leschaco using diy13 – adobe stock.com; Leschaco using AI Adobe Firefly on 15.04.2024; Leschaco 2024.

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