TSA Revolt News for 11/19/10 - Mega Issue

Here is a sample of the news from about the web regarding the public revolt over the invasive TSA Enhanced Pat Down's and AIT Scanners.

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Gloria Allred on Hanity

Airport security crew has his hand up a mans crotch. One has a security official down a woman's pants. An airline stewardess, who has served for 28 years to remove her breast implant for security for America. Lot of junk being searched for terrorism purposes. Critics are calling these searches sexual harassment. Gloria Allred an attorney about her getting patted down and groped, "first time anybody touched them in a long time and I liked it." The Liberals are funny as hello, however how politically correct the left is. Need to use profiling. This is a hilarious clip from Hannity. Gotta laugh once in awhile. Blame those terrorist bastards. Israel knows how to profile. Great moment on Fox News. MSNBC is just depressing. The TSA screening procedures are kind of far out.

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John c. Dvorak and Adam Curry discuss DA's from several states coming out and saying that TSA officers can be charged with Sexual Assault. For more go to noagendashow.com or listen live at noagendastream.com shot taken from episode #253.

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Ron Paul Debates TSA Screenings - CNN 11/19/10
CNN. November 19, 2010.

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Humor

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Added On November 19, 2010
The TSA gets a smackdown as it defends the pat downs. CNN's Jeanne Meserve reports.

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REVOLT AGAINST THE TSA

The revolt against the TSA is a sign of the times. Popular frustration with the TSA dates back to its establishment during the Bush administration. It is another big government bureaucracy that performs ineptly and with gross inconvenience. It provides far more security theater than security. 

The TSA is bound by a form of political correctness that has long rendered it a joke. With its newly implemented scanning and pat down procedures, however, the TSA has become something worse than a joke.

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New York, Orlando join anti-TSA rebellion, TSA mounts PR effort

New York and Orlando aren't taking the TSA scanner/pat-down controversy lying down. Instead, officials in both places are fighting back. In Orlando, the Sanford airport is reportedly planning to take advantage of a little-known clause that allows airports to opt-out of TSA protection and instead use a federally approved private screening company.

The TSA's counteroffensive

The TSA, for its part, is countering the backlash with a PR offensive. The agency has a new blog post up that claims to rebut alleged myths about the backscatter scanners and pat-downs with facts. Some of the rebuttals work better than others. For instance, take the TSA's response to allegations that the pat-downs are invasive:

Myth: The TSA pat-down is invasive

Fact: Only passengers who alarm a walk through metal detector or AIT machine or opt out of the AIT receive a pat-down. For this reason, it is designed to be thorough in order to detect any potential threats and keep the traveling public safe. Pat-downs are performed by same-gender officers and all passengers have the right to a private screening with a travel companion at any time.

Nowhere in the "Fact" response does the TSA directly answer the allegation of invasiveness, probably because the pat-downs are invasive.

 

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Via: Criminal Justice Degree

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Stand Up Against TSA’s Invasive Security Procedures

Deeplink by Rainey Reitman

The Transportation Security Administration has adopted "enhanced" security procedures — presenting people with the horrible choice of either submitting to body scanners that show passengers unclothed or submit to what are called "groping" pat-down techniques which include touching both breasts and genitalia. As some have noted these processes appear to have little likelihood of increasing the safety of fliers.

Individuals appalled by these procedures have a right to submit formal complaints to the TSA. It is important the passengers and crew submit complaints to showcase the widespread resistance to these procedures. TSA maintains that they have seen no increase in complaints about the new security procedures. EFF will be filing FOIA requests to test this claim, but in the meantime we wanted to make sure that people who wished to complain knew how to make their thoughts and feelings heard.

 

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Top 12 Things to say to your TSA scanner  

1. 1. Would you prefer I said that this was a lethal explosive or that I was just happy to see you?
   2. I've got some baggage in my pants that's been left unattended.
   3. I haven't felt this violated since I read the passage of George W. Bush's book that described the fetus in the jar.
   4. Do you know what censure means? Yeah, me neither.
   5. If you were a member of the Nixon family, you'd be Pat. You know, because of the pats.
   6. If you were an 80's-era female singer, you'd be Pat Benatar. You know, because of the pats.
   7. If you were a member of the Jackson family, you'd be Michael. You know, because of the...
   8. Have you ever seen "The Crying Game"?
   9. You'd think if they were going to make this required, they would at least legalize smoking on board airplanes afterwards.
   10. So, do you come here often?
   11. Is this a bad time to tell you I have this rare condition where if anyone touches a specific dime-sized area of my upper thigh, I make the bond with him for life? I'm part Avatar on my mother's side.
   12. If you touch my junk, I will have you arrested.

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The Revolution Will Be Felt -- by TSA Agents

Finally, the Post-Patriot Act American Revolution has come to a boil -- not in a teabag, but in a viral You Tube video that demands "don't touch my junk." The fickle fingers of TSA agents at airports everywhere have grabbed our sensitive spot and those screams you hear are far from ecstasy. From sea to shining sea, traveling pilgrims are eschewing the spineless acquiescence of freedom fighters in name only to reveal a line at their underwear.

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PBSO Prepared To Detain TSA Security Defiers

WEST PALM BEACH, Fla. -- Deputies may detain Palm Beach International Airport travelers who refuse to submit to a full-body scanner or a pat down, the Palm Beach County Sheriff's Office confirmed Friday.

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Congressman Bob Filner calls for hearings on TSA security practices

• November 19th, 2010 4:29 pm PT

With San Diego accidentally becoming the center of the controversies over new TSA screening devices and techniques, local congressional representative Bob Filner (District 51, Chula Vista) is calling for a hearing on TSA security practices.

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No Security Pat-Downs for Boehner

 By JEFF ZELENY

3:37 p.m. | Updated Representative John A. Boehner, soon to be the Speaker of the House, has pledged to fly commercial airlines back to his home district in Ohio. But that does not mean that he will be subjected to the hassles of ordinary passengers, including the controversial security pat-downs.

As he left Washington on Friday, Mr. Boehner headed across the Potomac River to Reagan National Airport, which was bustling with afternoon travelers. But there was no waiting in line for Mr. Boehner, who was escorted around the metal detectors and body scanners, and taken directly to the gate.

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Airport Body Scanners: Less Invasive Technology is Out There

By CBS News Investigative Producer Laura Strickler

Scanning technology exists today that would project only a "stick figure" image of a passenger to a TSA screener and minimize any exposure to radiation according to three U.S. Senators.

The technology known as "automated target recognition" is in use at Amsterdam's Schiphol airport. 

Senators Susan Collins (R-ME), Jon Kyl (R-AZ) and Saxby Chambliss (R-GA) wrote a letter to the TSA back in April  asking for the technology to be used in the United States.

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TSA responds to complaints about kids being patted down at airports

CHARLOTTE, N.C. (WBTV) -  Are children exempt for pat-downs at airport security? Not according to one man who says a TSA employee groped 6 year-old son at Charlotte Douglas International Airport.

 

The commenter says his son was aggressively patted down by a TSA employee.

"He was pleading for me to help him and I was admonished for trying to comfort him," the comment on the blog states. "His genitals area was groped. He walked down to the plane in tears."

 

The TSA issued the following statement to WBTV on Wednesday night:

"Officers are trained to work with parents to insure a respectful screening process for the entire family while providing the best possible security for all travelers."

But that statement didn't answer our main question, which was are TSA workers allowed to pat down children even to the point of touching their private parts.

We asked the TSA on Thursday night if they would be more specific.  They sent us back the exact same sentence, but then added this second sentence.

"After a thorough risk assessment and after hearing concerns from parents, we made the decision that a modified pat down would be used for children 12 years old and under who require extra screening."

We emailed back to ask what exactly "modified" meant but Jon Allen with the TSA replied, "I can't discuss specifics of a security procedure such as a pat down."

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Airport security measures prompt new website

The U.S. Travel Association set up the website, YourTravelVoice.org, after it received more than 1,000 unsolicited comments from travelers about the increased security following recently foiled bomb plots involving U.S. bound parcels.

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Text of HR 6416 introduced by Ron Paul. 

To ensure that certain Federal employees cannot hide behind immunity.

 

H.R.6416 -- American Traveller Dignity Act of 2010 (Introduced in House - IH)

HR 6416 IH

 

111th CONGRESS

 

2d Session

 

H. R. 6416

To ensure that certain Federal employees cannot hide behind immunity.

 

IN THE HOUSE OF REPRESENTATIVES

 

November 17, 2010

Mr. PAUL introduced the following bill; which was referred to the Committee on the Judiciary

 

A BILL

To ensure that certain Federal employees cannot hide behind immunity.

 

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,

 

SECTION 1. SHORT TITLE.

 

This Act may be cited as the `American Traveller Dignity Act of 2010'.

 

SEC. 2. NO IMMUNITY FOR CERTAIN AIRPORT SCREENING METHODS.

 

No law of the United States shall be construed to confer any immunity for a Federal employee or agency or any individual or entity that receives Federal funds, who subjects an individual to any physical contact (including contact with any clothing the individual is wearing), x-rays, or millimeter waves, or aids in the creation of or views a representation of any part of a individual's body covered by clothing as a condition for such individual to be in an airport or to fly in an aircraft. The preceding sentence shall apply even if the individual or the individual's parent, guardian, or any other individual gives consent.

 

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Enhanced pat down leaves Grand Rapids airline passenger in tears

“The female officer ran her hand up the inside of my leg to my groin and she did it so hard and so rough she lifted me off my heels,” she tells WZZM-TV. “I think I yelped. I was in pain for about an hour afterwards. It just felt excessive and unnecessary.”

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TSA: Pilots to be exempt from some airport checks  

WASHINGTON - The Transportation Security Administration has agreed to allow airline pilots to skip security scanning and pat-downs, pilot organizations said Friday.

Pilots traveling in uniform on airline business will be allowed to pass security by presenting two photo IDs, one from their company and one from the government, to be checked against a secure flight crew database, officials at the pilot groups said.

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Flight attendants no so happy with TSA's move for pilots

So the TSA caved to pilots, saying they don't have to get pat-downs. It didn't take long for a major flight attendant union to chime in about unfairness:

Flight attendants have submitted to the same finger printing and 10-year FBI background check as pilots. Flight attendants have completed required FAA mandated initial training and annual recurrent training in safety and security. Flight attendants have voluntarily taken additional TSA crewmember self-defense training on our own time and at our own expense since the federal government refused to make that training mandatory and fund it. Flight attendants are FAA -certified safety and security professionals.

In spite of the invaluable role that flight attendants play in air security, flight attendants are now being subjected to Advanced Imaging Technology (AIT) or "enhanced" body patdowns that are not only invasive, but also humiliating and embarrassing for front line security professionals who put their lives on the line every day. Enhanced TSA screening of flight crews is not only unnecessary, it is a waste of TSA resources that should be directed at the real security risks

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Cancer survivor forced to show prosthetic breast to TSA agents during airport pat-down

A flight attendant and cancer survivor has revealed her horror at being forced to show her prosthetic breast to a security agent during a pat-down at Charlotte Douglas International Airport.

Cathy Bossi from South Charlotte has been a flight attendant for over 30 years and has worked for U.S. Airways for the past 28  years.

 

She said she was asked to go through the full body-scanners at the airport in early August which she was reluctant to do because of fears of the radiation from the machine passing through her body.

 

The 3-year-breast cancer survivor agreed, but was then asked by two female Charlotte TSA agents to go to a private room for further screening, and they began what Ms Bossi described as an aggressive pat down.

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TSA Agents Absolutely Hate New Pat Downs, Find Them Disgusting And Morale Breaking

One of the common themes that people keep mentioning in talking about the new TSA pat down procedures is that those involved must "enjoy" the groping they're giving people. But, of course, most TSA agents are normal every day people who don't actually want to grope random people.Chris Tolles points us to a post from BoardingArea.com, who reached out to some TSA agents and found that many TSA agents hate the new rules and find it to be sapping morale to have to grope passengers.

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A Mom's Message For the TSA -- Don't Touch My KIDS!

I am afraid to fly with my family these days. Not because I am afraid of crashing, but because I am afraid of being arrested for assault. The viral YouTube video of the terrified three-year-old being given an invasive body search by a rough Transportation Security Administration (TSA) agent is outrageous and alarming. 

Trust me, if that were my beautiful, modest thirteen-year-old daughter being intimidated and groped, I couldn’t be held responsible for my actions. I have had two children, and my modesty level at this point in life is pretty minimal, but someone touching my kid is another story. That person is likely to get their eyes scratched out, TSA Agent or not. I am not kidding: Moms won’t abide someone messing with our children. Keep the cameras ready; it’s only a matter of time before one of us snaps. Hope it’s not me.

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5 Tips for TSA from Their Government Peers

"I have heard that Israel has a superior approach to this type of security," From Jeff S., a Compliance Officer for the U.S. Department of Agriculture. "Maybe its time for the US to import that method." In response, a TSA employee offered some clarification: "I'll be the first to say that there are areas where we (TSA) can do much better -- including using Israeli methods for detection and prevention. Having said that, you should know that there are only three international airports in Israel. TSA has a presence in over 460 U.S. airports." He also noted: "We have a large and growing Behavior Detection Officer (BDO) program. We use the same techniques and methods that the Israeli's use to profile behavior. We currently have BDOs at 161 airports nationwide."

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TSA screeners at Miami International Airport undergo specialized training

Today, TSA employees at MIA are undergoing special training to be more sensitive to passengers, many of whom seldom fly and to be more attentive to suspicious acting passengers. "We are not just focusing on body language, we are looking at the whole person and what they may be doing before coming toward the screeners," said Lauren Stover, Aviation Security Director at MIA. 

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Breaking: Former Gov. Ventura Will No Longer Fly Due to Abuse He’s Endured at Hands of TSA

Ventura said he made the decision to avoid public aircraft after he found himself becoming too comfortable with being routinely searched. He said he was subjected to pat down and search three or four times a week when he traveled for his television show. Ventura had hip surgery and the metal in his body invariably sets off airport metal detectors.

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TSA Revolt News for 11/18/10

Here is a sample of the news from about the web regarding the public revolt over the invasive TSA Enhanced Pat Down's and AIT Scanners.

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Here’s Ron Paul, again showing his justified outrage at the TSA with Neil Cavuto earlier today. They also discussed tax cuts and public ownership of GM.

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(CNN) -- The TSA is not as bad you think they are.

At least, that's what a list of "myths and facts" issued Thursday by the TSA about pat-downs and other security measures would like you to consider.

Many Americans have reacted with displeasure, or even outrage, over recent high-profile stories about intrusive searches at airports. In one of the instances that reverberated the strongest, a California man's video of his encounter with TSA agents went viral. John Tyner refused an X-ray scan and then famously told agents that, "if you touch my junk, I'll have you arrested."

In its fact sheet, the TSA says that pat-downs only occur when a passenger sets off a metal detector or opts out of an X-ray scan. The latter is what led to Tyner's confrontation with the TSA.

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TRENTON— Senator Michael J. Doherty (R-Hunterdon, Warren) and Senator James Beach (D-Camden) today announced they will present resolutions to the Senate and Assembly calling on the U.S. Congress to end TSA screening procedures requiring full body scans and pat downs at U.S. airports Their action comes in response to widespread concerns over privacy and radiation, as well as reports of inappropriate conduct by TSA agents during the screening process.

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(WTNH) -- A Simsbury, Connecticut man is facing criminal charges after a Transportation Security Administration agent was punched in the chest at an airport in Indianapolis, Indiana.

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Florida airport to opt out of TSA screening

Amid concerns over radiation from scanners, civil lawsuits over pat-downs, and general ineptitude on the part of TSA airport personnel, one Florida airport has thrown in the towel. Orlando Sanford International Airport has announced that it will opt out of the TSA’s screening program.

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NH Grandma groped by TSA blasts ‘invasive’ body search

Pressed for details, the 67-year-old Rye Beach resident said the airport employee put her hands inside the waistband of her pants, felt around her waist, passed her hands over both her breasts, and rubbed her hands up and down the insides of her legs - “twice in front and twice in back.”

“As it got more invasive, I thought, ‘why am I consenting to this?’” she said. “It was totally humiliating.”

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Don't Tread on My Junk
How Republicans learned to hate the TSA all over again.

Janet Napolitano was just three months into her tenure as secretary of Homeland Security when Matt Drudge bestowed a nickname on her: "Big Sis." The nickname stuck, thanks to Drudge's perseverance. Since that first story in April 2009, the Big Sis brand has been trotted out for dozens of Napolitano stories, from the scary ("BIG SIS: Napolitano to Kill Spy-Satellite Program") to the silly ("BIG SIS: Napolitano enlists Girl Scouts in effort to combat hurricanes, pandemics, terror attacks") to—most important—the creepy sexual stuff about the Transportation Security Administration. In January 2010, Drudge linked to a story about the government acquiring body scanners by pressing the Caps-Lock key and breaking out a photo illustration of Napolitano eying a scan of a nude: "BIG SIS WANTS TO SEE UNDER YOUR CLOTHES."

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From CNET's Buzz Out Loud-

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CNN- Learn New TSA Rules -

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San Mateo County DA Elect on TSA Searches

Appearing on the Alex Jones Show today, current chief deputy DA and incoming DA of San Mateo County Steve Wagstaffe said his office will prosecute TSA employees who engage in lewd and lascivious behavior while conducting Homeland Security mandated patdowns at the San Francisco International Airport in San Mateo County.

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TSA Screening Concerns Fla. Lawmakers (via WPBF) 

Download now or watch on posterous

TSA_Screening_Concerns_Fla._Lawmakers.flv (9774 KB)

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ABC Nightline -

Passengers are angry over TSA patdowns and full-body scanners

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Another TSA Outrage

As the Chalk Leader for my flight home from Afghanistan, I witnessed the following:

When we were on our way back from Afghanistan, we flew out of Baghram Air Field. We went through customs at BAF, full body scanners (no groping), had all of our bags searched, the whole nine yards.

Our first stop was Shannon, Ireland to refuel. After that, we had to stop at Indianapolis, Indiana to drop off about 100 folks from the Indiana National Guard. That’s where the stupid started.

First, everyone was forced to get off the plane–even though the plane wasn’t refueling again. All 330 people got off that plane, rather than let the 100 people from the ING get off. We were filed from the plane to a holding area. No vending machines, no means of escape. Only a male/female latrine.

It’s probably important to mention that we were ALL carrying weapons. Everyone was carrying an M4 Carbine (rifle) and some, like me, were also carrying an M9 pistol. Oh, and our gunners had M-240B machine guns. Of course, the weapons weren’t loaded. And we had been cleared of all ammo well before we even got to customs at Baghram, then AGAIN at customs.

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TSA Revolt News for 11/17/10

Here is a short recap of todays TSA news regarding the 'Enhanced Pat Down', Advanced Imaging Technology and the public revolt against this invasion of personal privacy and overreaching of personal rights.

During an oversight hearing on the Transportation Security Administration (TSA) today (111710), Senator Kay Bailey Hutchison (R-Texas), Ranking Member on the Senate Commerce, Science, and Transportation Committee, questioned TSA Administrator John Pistole on fining passengers who opt out of passenger screenings and decide not to travel.

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Visit msnbc.com for breaking news, world news, and news about the economy

NBC Nightly News reports on the mass resistance to TSA's 'enhanced pat-downs' & naked body scanners. For 11/17/10

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Rep. John Mica discusses the growing controversy around the TSA and invasive searches. Also, the Federal Law creating the TSA allows for airports to Opt Out of TSA program.

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Former New Mexico Governor Gary Johnson joined the chorus of dissenters recently, appearing on Freedom Watch to denounce the massive ramp up of security measures in airports.

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Ron Paul introduced legislation to protect Americans from physical and emotional abuse by federal Transportation Security Administration (TSA) employees conducting screenings at the nation's airports.

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Nov. 17, 2010 - Steve Bierfeldt of Campaign for Liberty discusses his personal run-in with the TSA, resulting in a lawsuit and policy change.

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"Miracle on the Hudson" pilot Captain Chesley "Sully" Sullenberger says that TSA's intrusive screening methods are not an effective or efficient use of resources.

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Two commercial airline pilots filed suit against the federal government Tuesday claiming new airport screening procedures violate their constitutional rights.

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@OhDoctah Groped by TSA

Even Owen JJ Stone, AKA OhDoctah, has had an issue with TSA and the latest update to the Enhanced Pat Down.

Going through airport security this past weekend, radio host Owen JJ Stone, known as “OhDoctah,” related how he was told that the rules had been changed and was offered a private screening. When he asked what the procedure entailed, the TSA agent responded, “I have to go in your waistband, I have to put my hand down your pants,” after which he did precisely that.

Speaking with The Alex Jones Show today, Stone went further – noting how the TSA thug directly patted down his testicles, penis and backside while his hand was inside Stone’s pants. Stone was initially embarrassed to reveal the full scope of the groping but related the details of what amounted to nothing less than outright sexual molestation.

Excerpt from Scanners, Guilt and Greed

 

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FDA Response to UCSF Concern Letter on Naked Body Scanners

Here is the FDA's response to the UCSF Letter of Concern I posted about here. Any emphasis  added is my own.

This is not to say that I believe the Advanced Imaging Technology is safe. Its not like the FDA or the government has never lied about the safety or effectiveness of any food additive, drug or system before (i.e. asbestos, lead paint and Red Dye #2.)

October 12, 2010

Dr. John P. Holdren
Assistant to the President for Science and Technology
Director, Office of Science and Technology Policy
Executive Office of the President
New Executive Office Building
725 17th St. NW
Washington, DC 20502

Dear Dr. Holdren,

Thank you for sharing the April 6 letter you received regarding general-use full-body x-ray screening systems used for airport security. As with all x-ray security products, justified application demands a balancing act: The radiation dose delivered must be sufficient to do the job—in this case to identify security threats—while presenting no more than a miniscule risk to people being scanned, including special populations.

The overriding concern expressed in the letter is the extent to which the safety of the security devices has been adequately demonstrated. Since 1990, the Food and Drug Administration (FDA) has regulated manufacturers to ensure the radiation safety of full-body x-ray security screening systems. The FDA consulted its Technical Electronic Product Radiation Safety Standards Committee (TEPRSSC) about these products during several meetings from 1998 through 2003. TEPRSSC is the independent advisory committee to FDA with expertise in electronic product radiation issues. This expert committee raised several issues during these meetings and FDA responded by initiating work on a consensus radiation safety standard through the American National Standards Institute (ANSI) and Health Physics Society (HPS). FDA assembled a working group of experts that included representatives from manufacturers, security agencies, and other regulatory agencies. The working group produced a national standard, Radiation Safety for Personnel Security Screening Systems Using X-rays¹, which was published in July 2002. The 2002 standard required facilities to ensure that no individual scanned received an effective dose in excess of 0.25 mSv (25 mrem) in any 12-month period. The standard also provided other guidelines specific to the radiation safety aspects of the design and operation of these systems. This annual dose limit is based on the National Council of Radiation Protection and Measurements² (NCRP) recommendations for the annual effective dose limit for individual members of the general public³. NCRP’s dose limitation recommendations for the general public were made with the understanding that the general public includes special populations that are more sensitive to radiation, such as children.

In September 2002 FDA asked the NCRP to undertake a study that led to NCRP Commentary No. 16 (2003), Screening of Humans for Security Purposes Using Ionizing Radiation Scanning Systems. The committee that prepared this commentary included representatives from the Milton S. Hershey Medical Center, Columbia University, FDA’s Center for Devices and Radiological Health, the U.S. Environmental Protection Agency, and the NCRP Secretariat consulting staff. This commentary introduced the concept of general-use and limited-use systems. Commentary No. 16 recommended g eneral-use systems should not exceed the dose limit set in the 2002 standard and can be used mostly⁴ without regard to the number of individuals scanned or the number of scans per individual in a year.

FDA brought the issue of consistent federal evaluation and justification of security screening practices that used ionizing radiation to the Interagency Steering Committee on Radiation Standards (ISCORS)⁵. ISCORS was established to foster early resolution and coordination of regulatory issues associated with radiation standards and guidelines. ISCORS published Guidance for Security Screening of Humans Utilizing Ionizing Radiation (2008) to assist Federal agencies in determining when the use of ionizing radiation for security screening of humans is warranted and to provide guidelines for establishing a radiation safety program. The Transportation Security Administration (TSA), FDA, Occupational Safety and Health Administration, National Institute of Standards and Technology (NIST), U.S. Army Center for Health Promotion and Preventive Medicine, Nuclear Regulatory Commission, Environmental Protection Agency, Federal Bureau of Prisons, Department of Energy, Customs and Border Protection, Central Intelligence Agency, Maryland Department of the Environment, and Pennsylvania Bureau of Radiation Protection collaborated in developing this federal guidance.

Since publication of the original 2002 standard, a number of new system designs have been developed, including portal systems, multi-source systems, vehicle scanners meant for screening occupied vehicles, scanners for inspecting casts and prosthetic devices, and scanners using a radioisotope as the source of radiation. New uses for these systems include the use of vehicle and cargo scanners to inspect people and the limited use of higher-dose systems as defined in NCRP Commentary No. 16. Consequently, FDA and NIST chaired a working group to revise the national standard⁶. The revised standard, Radiation Safety for Personnel Security Screening Systems Using X-Ray or Gamma Radiation⁷, was published November 2009. It includes requirements that cover these new designs and uses. This standard applies to security screening systems in which people are intentionally exposed to primary beam x-rays and provides guidelines specific to radiation safety in the design and operation of these systems.The standard covers doses to individuals scanned, safety systems, operational procedures, information to provide to screened individuals, training for operators, and other issues. The revised standard retained the annual effective dose limit for members of the public of 0.25 mSv (25 mrem). This standard defines a general-use x-ray screening system as one that delivers less than 1/1000 of this dose per screening (0.25 µSv (25 µrem)). The rationale for the annual and per screening dose limits is presented in the standard⁸.

TSA requires that the full-body x-ray security systems approved for deployment (Advanced Imaging Technology (AIT)) conform to the requirements in the 2009 standard for general-use systems. Surveys of the recently deployed backscatter x-ray personnel security screening systems have been performed by an independent party to confirm compliance with the radiation dose-per-screening limits for general-use of the 2009 standard.  All systems surveyed to date have been found to comply with the general-use dose-per-screening limit in that standard.  In addition, our independent survey teams are gathering area radiation dose data by mounting dosimeters on (within the inspection zone) select systems.

Regarding the specific “Red Flag” issues raised in the letter:

First, the letter is correct to note that the TSA-deployed product is a recent model. However, the specification for the x-ray tube for the deployed model is almost identical to the original 1991 product. The stated concern was, “The majority of their energy is delivered to the skin and the underlying tissue.” We agree. However, the concern that “the dose to the skin may be dangerously high” is not supported. The recommended limit for annual dose to the skin for the general public is 50,000 µSv⁹. The dose to the skin from one screening would be approximately 0.56 µSv¹⁰ when the effective dose for that same screening would be 0.25 µSv¹¹. Therefore the dose to skin for the example screening is at least 89,000 times lower than the annual limit.

Second, radiation safety protection quantities are stated as ‘effective dose’¹². NCRP Commentary No. 16 says, “The purpose of effective dose¹³ is to place on a common scale the radiation doses: (1) from different types of ionizing radiation that have different biological effectiveness, and (2) in different organs or tissues that have different radiation sensitivities.” Comparing effective doses from different sources is appropriate. The comparison between the effective dose from cosmic ray exposure or a medical diagnostic chest x-ray and the effective dose from a security screening is intended to be a clear means of risk communication.

The third point relates to a concern “that real independent safety data do not exist.” In fact, independent safety data do exist. Independent measurements have been made on various versions of this product and all results are consistent with the dose specified by the manufacturer. Examples include:

• Sandia National Laboratories, measurements made July 1991. Published as Sandia Report:Evaluation Tests of the SECURE 1000 Scanning System (1992), National Technical Information Service, DE92013773
• FDA, dose measurements re-verified via computational evaluation, September 15, 1998
• N43.17 working group, measurements made at Folsom State Prison on November 15, 1999
• FDA & NIST, Assessment for TSA, July 21, 2006
• Johns Hopkins University Applied Physics Laboratory (JHU APL), Assessment for TSA, October 2009

Fourth is the concern that “the relevant radiation quantity, the Flux [photons per unit area and time (because this is a scanning device)] has not been characterized.” We disagree that flux is the appropriate quantity. The air kerma (or skin entrance exposure) for one screening can be determined by a direct measurement of the total charge produced in the air contained in an ion chamber during one complete screening when the meter is correctly calibrated¹⁴. Additionally, measurements to determine the amount of material required to reduce the intensity of the x-ray exposure by half¹⁶ are necessary to convert air kerma (or exposure) to effective dose¹⁵. These measurements can most practically be made —and indeed have been repeatedly made— at locations where these products are installed and can be made without altering a scanner’s normal operation. These are the same sorts of measurements made to characterize the output of medical x-ray systems¹⁷.

Fifth is the assertion that “if the key data (flux-integrated photons per unit values) were available, it would be straightforward to accurately model the dose being deposited in the skin and adjacent tissues using available computer codes [. . .]” In fact, we have done better. FDA and NIST used software called PCXMC¹⁸ to estimate the individual organ doses and to calculate effective dose. This analysis was part of an evaluation performed under contract for TSA. The input information required by the PCXMC program required considerably more information than simply the x-ray flux. Its parameters include 1) the x-ray tube anode angle, 2) anode voltage, 3) total filtration, 4) x-ray field size, 5) location of the field on the body, 6) focus-to-skin distance (FSD), and 7) entrance skin exposure. Every parameter was measured, calculated, or verified by indirect measurement. The modeling results revealed that the dose to the skin is approximately twice the effective dose¹⁹.

The letter continues: “[. . .] which would resolve the potential concerns over radiation damage.” Direct measurements of the exposure or air kerma from one screening combined with measurements to determine the half-value layer provide sufficient information to adequately estimate the effective dose. There are a number of available publications by groups of recognized experts regarding the biological effects of ionizing radiation and the risk of detriment related to the effective dose. These documents include Health Risks from Exposure to Low Levels of Ionizing Radiation : BEIR VII Phase 2 (2006) and NCRP report no. 115 Risk Estimates for Radiation Protection, as well as the documents that specifically address security screening of people with ionizing radiation mentioned in this letter.

Other specific concerns expressed in the letter are based on the assumption that a screening results in skin or other organ doses that are orders of magnitude higher than the effective dose per screening. The dose to other organs is less than, equal to, or at most approximately three times the effective dose²⁰ for the deployed product. The annual dose limit for security screening is the same as the NCRP recommendations for the annual effective dose limit for the general public including special populations²¹. An individual would have to receive more than 1000 screenings to begin to approach the annual limit.

With regard to concerns about the hardware itself, the standard requires that products have safety systems to terminate emission of the primary beam in the event of any system problem that could result in abnormal or unintended radiation emission. The scan motion cannot be adjusted. If the scan motion were intentionally redesigned and changed to scan the groin at a slower rate than the rest of the body, the point of measurement to determine the dose per screening would also change. The dose per screening measurement must be made at the point of maximum exposure in order to comply with the standard. Manufacturers are required to report changes to a product’s performance specifications when those changes can affect radiation safety, as would be the case with any change to dose per screening.

These products have been available commercially in the United States since 1992. Manufacturers of any type of electronic product that emits radiation -- including full-body x-ray security systems -- are required to notify FDA immediately upon discovery of any accidental radiation occurrence or radiation safety defect. TSA policy is to require a survey of x-ray systems annually, after any maintenance that could affect radiation shielding, and after any impacts that could affect radiation shielding. FDA regulations require notifications if the manufacturer or FDA determines that an electronic product emits radiation unnecessary to the accomplishment of its primary purpose creating a risk of injury, including genetic injury, to any person. Such a product is then considered to have a radiation safety defect. Unless a manufacturer can provide evidence that a significant risk to public health is not created by a defect, the manufacturer is required to repair, repurchase, or replace its products. Raising the dose delivered without gaining a commensurate increase in safety could be grounds to declare that a product emits radiation unnecessary to the accomplishment of its primary purpose and thus has a radiation safety defect. Products and practices that comply with the American national radiation safety standard²² do not present a significant risk to public health.

In summary, the potential health risks from a full-body screening with a general-use x-ray security system are miniscule. Several groups of recognized experts have been assembled and have analyzed the radiation safety issues associated with this technology. These experts have published recommendations, commentaries, technical reports, and an American national radiation safety standard as a result of their analyses. This technology has been available for nearly two decades and we have based our evaluation on scientific evidence and on the recommendations of recognized experts. Public meetings were held to discuss these products with FDA’s advisory panel (TEPRSSC), and the American national radiation safety standard was available for public comment both before its initial publication and before its recently published revision. There are numerous publications regarding the biological effects of radiation and the appropriate protection limits for the general public that apply to these products. As a result of these evidence-based, responsible actions, we are confident that full-body x-ray security products and practices do not pose a significant risk to the public health.

We enclose a list of references to some of the relevant reports, commentaries, and the current safety standard. If you have any further questions or concerns, please contact either of the individuals listed below.

Sincerely yours,

 

John L. McCrohan
Deputy Director for Technical and Radiological Initiatives
Office of Communication, Education, and Radiation Programs
Center for Devices and Radiological Health
Food and Drug Administration

Karen R. Shelton Waters
Deputy Assistant Administrator / Chief Administrative Officer
Designated Safety and Health Official
Transportation Security Administration

Enclosure

REFERENCES

• ANSI/HPS N43.17-2009 Radiation Safety for Personnel Security Screening Systems Using X-Ray or Gamma Radiation (http://hps.org/hpssc/)
  • More information on the ANSI standards setting process is available on the ANSI website (http://www.ansi.org/standards_activities/overview/overview.aspx?menuid=3 )
• Interagency Steering Committee on Radiation Standards (ISCORS), Guidance on Security Screening of Humans Using Ionizing Radiation (GSSHUIR) Report (http://www.iscors.org/doc/GSSHUIR%20July%202008.pdf)
• NCRP commentary 16, Screening of humans for security purposes using ionizing radiation scanning systems (2003) (http://www.ncrppublications.org/Commentaries/16)
  • Press release regarding commentary no. 16 (May 26, 2010) (http://www.ncrponline.org/Press_Rel/Commentaries/Comm_16_Press_Release.pdf)
• NCRP Statement 10, Recent Applications of the NCRP Public Dose Limit Recommendation for Ionizing Radiation (2004) (http://www.ncrponline.org/Publications/Statements/Statement_10.pdf)
• NCRP report no. 115 Risk Estimates for Radiation Protection (1993)
• NCRP report no. 116 Limitation of Exposure to Ionizing Radiation (1993) (http://www.ncrppublications.org/index.cfm?fm=Product.AddToCart&pid=9143114606)
• NCRP report no. 160, Ionizing Radiation Exposure of the Population of the United States (2009)(http://www.ncrppublications.org/Reports/160)
• HPS Position Statement Use of Ionizing Radiation for Security Screening Individuals(http://hps.org/documents/securityscreening_ps017-1.pdf)
• American College of Radiology (ACR) Statement on Airport Full-body Scanners and Radiation(http://www.acr.org/SecondaryMainMenuCategories/NewsPublications/ FeaturedCategories/CurrentACRNews/archive/StatementonAirportFullbodyScanners.aspx).
• U.S. Transportation Security Administration’s (TSA) web site regarding advanced imaging technology (http://www.tsa.gov/approach/tech/imaging_technology.shtm).
• Information on laws and regulations applicable to manufacturers of people screening security systems that use x-rays is available on FDA’s X-Ray & Particulate Products other than Medical Diagnostic or Cabinet page (http://www.fda.gov/Radiation-EmittingProducts/ RadiationEmittingProductsandProcedures/HomeBusinessandEntertainment/ucm116416.htm )
• The concept of justification based on a societal benefit appears in the International Commission on Radiological Protection (ICRP) report 60 (see paragraph S14). (http://www.icrp.org/downloadDoc.asp?document=docs/Summary_B-scan_ICRP_60_Ann_ICRP_1990_Recs.pdf)
• Health Physics Society fact sheet on Environmental radiation (http://hps.org/documents/environmental_radiation_fact_sheet.pdf)
• Security screening with x-rays was discussed at several Technical Electronic Product Radiation Safety Standards Committee (TEPRSSC) meetings (http://www.fda.gov/AdvisoryCommittees/CommitteesMeetingMaterials/Radiation-EmittingProducts/TechnicalElectronicProductRadiationSafetyStandardsCommittee/default.htm). The last discussion took place during the October 1, 2003 meeting (http://www.fda.gov/ohrms/dockets/ac/cdrh03.html#TechnicalElectronicProduct).
• Sandia Report: Evaluation Tests of the SECURE 1000 Scanning System (http://www.ntis.gov/search/product.aspx?ABBR=DE92013773)
• Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII Phase 2 (2006) (http://www.nap.edu/openbook.php?record_id=11340&pag)
• Assessment of the Rapiscan Secure 1000 ® Body Scanner for Conformance with Radiological Safety Standards. July 21, 2006, produced for TSA, measurements made at FDA, report completed at NIST (http://www.tsa.gov/research/reading/index.shtm)
• Radiation Safety Engineering Assessment Report for the Rapiscan Secure 1000 in Single Pose Configuration ,Johns Hopkins University Applied Physics Laboratory, Assessment for TSA, October 2009 and revised August 2010 (http://www.tsa.gov/research/reading/index.shtm)

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¹ ANSI/HPS N43.17-2002 Radiation Safety For Personnel Security Screening Systems Using X-rays

² NCRP was founded in 1964 by the U.S. Congress to “cooperate with the International Commission on Radiological Protection, the Federal Radiation Council, the International Commission on Radiation Units and Measurements, and other national and international organizations, governmental and private, concerned with radiation quantities, units and measurements and with radiation protection.”

³ NCRP report no. 116 Limitation of exposure to ionizing radiation (1993); pages 45-47, 56

⁴ “Mostly” refers to the unlikely situation where individuals are routinely screened so many times in one 12-month period that the annual dose limit would be exceeded. For example, an individual can be screened 19 times each week and would not receive more than the annual dose limit.

⁵ Initial presentation October 20, 2003

⁶ 1st work group meeting May 11, 2006

⁷ ANSI/HPS N43.17-2009 Radiation Safety for Personnel Security Screening Systems Using X-Ray or Gamma Radiation

⁸ Ibid (ANSI/HPS N43.17-2009): “Various organizations have studied the biological effects of ionizing radiation exposure. The National Council on Radiation Protection and Measurements (NCRP) reviewed two independent studies, one by the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR 1988) and the other by the National Academy of Sciences/National Research Council, Committee on the Biological Effects of Ionizing Radiation, known as BEIR V (NAS/NRC 1990). Based on this review, the NCRP recommends that, for radiation protection purposes, an incremental lifetime risk of fatal cancer of 5% per sievert be used for the general population (NCRP 1993). The 5% per sievert risk is also consistent with the more recent BEIR VII report (NAS/NRC 2006). Application of this risk estimate means that each 0.01 μSv (1 μrem) of effective dose received is considered to contribute 5 × 10^-10 (one chance in two billion) to an individual's risk of contracting a fatal cancer during his or her lifetime. These low-dose estimates assume a “linear no-threshold” relationship between radiation exposure and health effects.

Both the NCRP and the International Commission on Radiological Protection (ICRP) recommend that members of the general population who are frequently exposed to ionizing radiation not exceed an annual effective dose of 1 mSv (100 mrem) from all man-made, non-medical sources (NCRP 1993; ICRP 2007). Further, the NCRP recommends that institutions ensure that the individuals they expose do not repeatedly exceed the 1 mSv yearly limit from all non-medical sources. Information relating to other sources of radiation exposure may be difficult to obtain, so institutions have the option to ensure that the radiation sources under their own control do not contribute to an individual more than an annual effective dose of 0.25 mSv (25 mrem).

General-use systems operating in accordance with this standard produce a maximum reference effective dose of 0.25 μSv (25 μrem) per screening. Therefore, an individual may be screened up to 1,000 times each year without exceeding the annual 0.25 mSv (25 mrem) limit. The associated incremental risk of death is 1 in 80,000,000 per screening.”

⁹ NCRP report no. 116 Limitation of exposure to ionizing radiation (1993), page 56

¹⁰ FDA & NIST Assessment of the Rapiscan Secure 1000® Body Scanner for Conformance with Radiological Safety Standards. July 21, 2006, produced for TSA. This skin dose is an estimate based on dose modeling. This estimate is only for products with very similar x-ray output. The difference between skin and effective dose is smaller for products that use higher energy or more filtration.

¹¹ The actual dose per screening specification is 0.05 µSv or less http://www.rapiscansystems.com/rapiscan-secure-1000-single-pose-health.html. The JHU APL assessment report confirms that the product meets this specification.

¹² NCRP report no. 158 Uncertainties in the Measurement and Dosimetry of External Radiation, page 22

¹³ Radiation doses from exposures that may result in delayed stochastic effects are expressed in the quantity effective dose (E):

E =	ΣwTHT,
	T

where H_T is the equivalent dose in an organ or tissue T, and w_T is the tissue weighting factor that accounts for the radiation sensitivity of organ or tissue T.

¹⁴ ANSI/HPS N43.17-2009 Radiation Safety for Personnel Security Screening Systems Using X-Ray or Gamma Radiation, section ‘C.3.2 Calibration’

¹⁵ This quantity is called the half-value layer (HVL). HVL is often expressed in terms of the thickness of aluminum required.

¹⁶ ANSI/HPS N43.17-2009 Radiation Safety for Personnel Security Screening Systems Using X-Ray or Gamma Radiation, section ‘6.0 Dose Limitation’ and ‘A.1 Reference Effective Dose’

¹⁷ Nationwide Evaluation of X-Ray Trends (NEXT) (http://www.fda.gov/Radiation-EmittingProducts/RadiationSafety/ NationwideEvaluationofX-RayTrendsNEXT/default.htm)

¹⁸ Servomaa, A. and Tapiovaara, M. Organ dose Calculation in Medical X Ray Examinations by the Program PCXMC. Radiation Protection Dosimetry 80, 213-219 (1998).

¹⁹ FDA & NIST Assessment of the Rapiscan Secure 1000® Body Scanner for Conformance with Radiological Safety Standards. July 21, 2006, produced for TSA.

²⁰ FDA & NIST Assessment (2006); Our dose modeling reveals that a screening that delivers 0.25 µSv effective dose would deliver approximately 0.12 µSv to the uterus or 0.69 µSv to the testes. This estimate applies to products with very similar x-ray output.

²¹ NCRP Statement 10, Recent Applications of the NCRP Public Dose Limit Recommendation for Ionizing Radiation (2004) and NCRP report no. 116 Limitation of exposure to ionizing radiation(1993).

²² ANSI/HPS N43.17-2009 Radiation Safety for Personnel Security Screening Systems Using X-Ray or Gamma Radiation

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