X-ray Screening Technology Safety Reports

Overview With Cometary (in black)

TSA’s mission is to keep the traveling public safe and that is done by deploying multiple layers of security, including the best available technology, to detect and disrupt possible attacks before they occur. An important part of this strategy is ensuring that the technology used meets safety standards for [all travelers and employees] while detecting threat items.

Just six months before the December 2009 firecracker event TSA phased out the use of explosive detectors. [0]  And has not returned the equipment to service that we paid millions for?  Actually they just adopted x-ray scanner technology introduced into the prison systems in the late 90's designed to get around 4th amendment warrant search issues.  Odd the bill of rights applies in our jails but not at the airports?

Over the nine years since the agency’s inception, TSA has implemented stringent safety protocols to ensure that technology used at airports to screen people and property is safe for all passengers, as well as the TSA workforce.

In September 2011 DHS/TSA quietly exempted it's staff and personal from screening to enter secure areas.[]  In this authors opinion it was to avoid over exposure from a single radiation source.  This would have required reissuing radiation dosimeters to security personnel to meet federal (OSHA) requirement to track exposure. It would have also limited the time TSA staff could have worked in the radiation areas.  See page NN of the 2001 presidential report. [13]   

Not surprising TSA screeners abused the lack of security to take all sorts of things in and out "sterile" areas.  Backpacks come and go into secure areas with no checks.  One TSA employee was found carrying a gun into a secure area. Hundreds of TSA employees have been arrested for stealing items from the traveling public.[2]  At the same time TSA exempts diplomats, pilots, flight crew, military, CIA, FBI, department of state, law enforcement, members of congress and others from searches. [1]  For a fee a person can be come a "trusted traveler" and avoid the scanning process.[3] This program and policy creates a equal protection issues with a special class of people being exempt from the procedures. It creates an obvious security whole that a trunk could be driven through.  It should apply to ALL or none.  If members of congress and officials were scanned and frisked, soon sanity would return to travel.

Years ago TSA issued dosimeters to staff working around scanners and x-ray luggage equipment.  The dosimeters were quietly phased out 3-5 years ago? Congress is revising this with TSA requesting dosimeter information. [17]

In addition to regular maintenance, each individual machine that uses X-ray technology is regularly tested to ensure the radiation emitted falls within the national safety standards. The testing is conducted by manufacturers and/or third party maintenance providers, per the terms of their TSA contracts.

As scanner manufacturers and DHS/TSA (customer) set the standards little wonder the equipment meets the "standards."  The maximum exposure originally set at 10-urem was quietly increased to 25-urem.  This "standard" change would accommodate the new high power transmission x-ray systems and higher-resolution backscatter systems.  What is not discussed is the use of the whole body does or effective dose units that are NOT applicable to lower energy backscatter systems?  Most of the backscatter exposure is to the skin; Whole-body dose calculations makes the exposure appear about 10 times smaller.  As the measurements and math used in radiation are Greek to most people it is very easy to confuse and deceive the public, press and policy makers.     

 Contract requirements mandate that the manufacturer notify TSA and the Food and Drug Administration (FDA) should any equipment appear to emit radiation at levels above the national standard. In the event that a radiation test for any technology were to reveal that the emission was above the standard, the machine would be taken out of service and repaired. The backscatter technology in use at airports is designed to be physically incapable of producing the amount of energy needed to emit radiation above the national standard in a single scan.

In the past, the TSA has failed properly monitor and ensure the safety of personal working around X-ray devices used on luggage. A 2008 report by the worker safety arm of the Centers for Disease Control and Prevention found that the TSA, and its maintenance contractors had failed to detect when baggage X-ray machines emitted radiation beyond what regulations allowed. They also failed to take action when some machines had been missing or disabled safety features, the report shows.[5]

States require ALL x-ray radiation devices used in dental and medical systems to be regularly inspected. Before TSA took over security states inspected airport x-ray equipment, somehow the TSA is exempt from state regulation? The airports are still under state jurisdiction last I checked. Perhaps some legal trick unknown to the author the units were never sold to a private person or company; they avoid state review? The FDA caved in and the units were placed in a voluntary "non-medical" classification avoiding and meaningful review and over site.  The public health watch dog be came a lap dog.

In a pending peer review report, Arizona State University Physics Professor Dr. Peter Rez reviewed the claimed emission numbers  His findings are that systems are incapable of generating the known image quality using industry-standard detectors, amplifiers and x-ray sources at claimed exposures. In his very detailed technical report, he concludes the numbers are low by a factor of at least four.  As industry standard x-ray measurement tools assume detector is in a uniform x-ray field like that of a chest x-ray or fluoroscope.  The high speed moving x-ray beam used  in the scanners cannot be accurately measured with typical equipment used by contractors.

In the spirit of transparency, TSA is posting reports for all radiation tests, including the annual TSA-mandated test of every X-ray based technology, on www.tsa.gov as they are completed.

Technology Safety Process

Since TSA’s establishment, stringent safety protocols have been developed and implemented to ensure technology is safe for all passengers. This process begins prior to TSA’s decision to use a new technology and continues throughout the life of each individual unit deployed in airports.

For radiation safety, TSA issues procurement specifications that require all manufacturers to comply with nationally-recognized safety standards to ensure the safety of all passengers – including special populations like children, the elderly, and pregnant women – and operators during equipment usage. That means TSA will not begin to test a new technology or consider deploying it to airports until manufacturers validate the technology’s compliance to the relevant safety standards.

Talk to your dentist, radiologist chiropractor or general practitioner about x-raying an expecting woman you will find most are very reluctant to use x-rays unless it is absolutely necessary for the health of the mother.   

The 2001 presidential report regarding ionizing radiation for security, [13] appendix A and in other locations specialty mentions expecting mothers and children should avoid exposure.  It also recommends using methods that don't use ionizing radiation as preferred.  But, x-rays are inexpensive to generate give very high image detail the temptation is too great public health takes a back seat to "security." Having the former DHS director as a consultant lobbyist for the industry does not hurt.[10]     

The X-ray based technologies TSA deploys are required to be in compliance with national standards. For a number of systems, TSA has performed additional independent third-party testing to further validate compliance with these safety standards.

To date (March 2012) NO independent third-party has tested the systems. Unless you think the US Army or manufacture, and TSA is independent.  What reports are available are so redacted review of the published results is impossible.  Critical measurements of resolution, beam currents or how the dose exposure was calculated are missing along with the names of the engineers.  Further confusing the issue measurements were done with spare parts not a production system?

Backscatter imaging technology units are required to comply with the national standard and the machines are designed to be physically incapable of producing the amount of energy needed to emit radiation above the standard in a single screening Like the protection a circuit breaker provides to a home, the machines contain safety systems that prevent the production of radiation levels in excess of established limits.

Comparing a x-ray system with many complex moving mechanical systems run by a computer to a circuit breaker is dishonest. The system uses a high voltage generator (50-150KV) to accelerate and focus electrons at a tungsten target. Two rotating wheels to generate a high speed sweeping beam and a third motor to drive the assembly from toe to head. Add detectors, power supplies, electronics, circuit breakers a few computers and you have a scanner. 

After TSA makes an operational decision to use a technology, manufacturers are then required to perform radiation inspections on each individual unit before it leaves the factory and is shipped to TSA. The manufacturer also must perform a radiation test on each unit once it is installed in the airport.

After installation, TSA requires manufacturers and/or maintenance contractors perform periodic radiation tests in accordance with the applicable standards – this happens at least every 12 months.

Last time this was done the contractors/manufactures got confused with the simple math to average ten readings not very reassuring.[16]

Additionally, radiation tests are performed after any maintenance that could impact the X-ray sources, emissions or containment and if the unit is ever relocated from its initial installation position. At any time, TSA employees may also request a radiation test.

By conducting ongoing radiation inspection surveys throughout the useful life of the technology, TSA is going beyond regulatory safety standards to ensure passengers and operators are not being exposed to excessive X-ray radiation doses.

Third Party Testing and Analysis

Independent certified health physicists at the U.S. Army Public Health Command (Provisional) perform radiation surveys and inspections on carry-on luggage and checked baggage systems, as well as personal radiation dosimeter studies on TSA security officers. To date, the results of these studies and inspections reveal that TSA systems comply with all applicable standards for emission limits, and that radiation doses to TSA employees are well below the federal dose limits.

With DHS/TSA is a part of department of defense with the Army we fail to see how the Army testing can be considered a independent third party?  As the "standards" panel was dominated by scanner manufactures, customs, prison, department of homeland security and TSA customers we can be assured they were all looking out for the public. Proposed equipment offered would meet the "standards".

Backscatter technology has also been evaluated by numerous third party health experts including the Food and Drug Administration’s (FDA) Center for Devices and Radiological Health (CDRH), the National Institute of Standards and Technology (NIST), and the Johns Hopkins University Applied Physics Laboratory (APL).

Security scanners are oddly classified by FDA as a non-medical device and have been put under a voluntary category.  Never mind you can see bones and kidney stones with some systems.  This gives the FDA a way to NOT to review or regulate the device.  Standard procedure for a similar medical product would require a 510K and formal application and review.  This has never to this authors knowledge happened.  This author has worked for four medical device manufactures and is very familiar with the 510K process and FDA audits.

Regarding NIST ten years later we are still waiting to find out how a office fire could have brought down a modern steel 49 story class-A office building in  nine seconds? [14] [15]  The credibility of this wonderful scientific organization has been tarnished by caving in to political pressure to help cover up the real story of the events of that tragic day.  

The Hopkins report never said the machines were 100 percent safe just that the risk was low.  The Hopkins report and risk estimate was based on dubious scanner measurements and dose calculations.  The questionably low measurements and risk estimates were parroted by FDA the media and security supporters.  When the health risk is greater than the risk you are working to avoid what is the point?  When you add in the loss of liberty, delays, and genetic damage to our DNA you have to say No to the process. We have lost our collective mind in the impossible quest for "security."

Radiation Testing Review

To verify these safety procedures, TSA recently conducted a review of the reports generated from manufacturer and third party maintenance provider radiation testing. Fifteen airports of varying sizes were selected and the last two years of radiation reports were reviewed for a sample of the X-ray based technologies we use in airports. TSA also reviewed the reports for every backscatter advanced imaging technology unit. The other technologies include multi-view advanced technology X-ray units, explosive detection systems, and single projection X-ray systems. The reports confirm that each piece of technology included in the review operated well-within applicable national safety standards when the testing occurred.

Congress has just called for a independent measurement but, the TSA has put that off. [16]

Due to public interest in security technology, and TSA’s commitment to transparency and safety, TSA is posting original reports on www.tsa.gov.

Heavily redacted test results and FOIA law suits to sometimes reach public records is NOT transparent.  The only thing transparent is you!

Evaluation of Contractor Testing Procedures

These reports confirm that each piece of technology reviewed meets all national safety standards. However, during TSA’s review of these reports, inaccuracies were identified in contractor reporting that affected the documentation of some of the test results. These inaccuracies included:

• Lack of notation for the latest calibration date for the machine being tested or the most recent calibration date noted had expired on survey meters
• Information missing regarding warning labels and required labels
• Calculation errors not impacting safety
• Missing survey point readings
• Inconsistent responses to survey questions
• No reading of background radiation noted
• Missing other non-measurement related information

TSA took immediate action to hold contractors accountable, including directing the contractors to re-test each backscatter imaging technology unit, as well as re-testing any other unit with an inaccurate report, by the end of March 2011.

Improvement Measures

TSA is taking immediate steps to build on the already robust safety protocols in place in an open and transparent way. Administrator Pistole has directed TSA to commission an independent entity to evaluate these protocols. Additionally, TSA is:

• Requiring re-testing of all backscatter advanced imaging technology units in airports, as well as all technology with inaccurate reports, by the end of March 2011;
• Requiring contractors to re-train personnel involved in conducting and overseeing the radiation survey process;
• Requesting the National Institute for Occupational Safety and Health (NIOSH) re-evaluate TSA’s safety program and update its 2008 report;
• Expanding an existing partnership with the U.S. Army Public Health Command to conduct additional independent radiation surveys and radiation safety compliance audits at airports equipped with X-ray based technologies;
• Increasing TSA oversight on the overall radiation survey and documentation process; and
• Ensuring all appropriate contractual remedies are considered and implemented, as necessary, in the event that radiation inspections are incomplete or delinquent.

To provide additional transparency, reports for all surveys currently being conducted and all future radiation survey reports will be posted on www.tsa.gov after they are completed.

By the Numbers

• One year of naturally occurring background radiation: 300 millirem
• Annual recommended limit to the public of radiation from man-made sources: 100 millirem
• Chest X-ray: 10 millirem
• Flight from New York to Los Angeles: 4 millirem
• One day of natural background: approximately 1 millirem
• Drinking three glasses of water a day for a year: 0.045 millirem
• One backscatter X-ray screening: approximately 0.005 millirem

While the above numbers are correct for natural sources. However scanning backscatter falls into a different class of radiation:

The radiation is focused not random thus delivering a very high skin entrance dose.

The x-rays are less penetrating (lower energy) concentrating the exposure to the skin and underlying tissues (breast, thyroid, testicles). 

High dose rate of low energy x-ray will generate statistically more DNA damage some of which goes unprepared.

Cosmic sources received in flight are high energy and do not interact with matter as strongly as the lower energy backscatter x-rays.  Also the random cosmic rays are distributed over the whole body not just the skin.  This would appear counter intuitive but, this is how the physics works.  In a nut shell chemical bonds are made with electrons and have specific binding energies. A photon (light/x-ray) that is slightly greater than the will strongly interact with that bond.  The lower energy x-rays (23Kv mean) will break more bonds like potassium (2kv) that makes the sugar backbone of our DNA.   

At the end of it all good intentions has turned into a monster.  Corporate profits are more important than pubic health.  Too many jobs are at stake to pull the plug on the monster that will bring down the house.  It is easier to lie, irradiate, frisk and harass the traveling public than admit the current security system is not working.

Source: Radiation dose comparisons from the Health Physics Society (http://hps.org/documents/WholeBodyScanners.pdf (hps.org)) and other safety experts (http://www.cbsnews.com/2300-204_162-10005685-3.html (cbsnews.com)).

Additional Information

For more information on AIT safety, visit: http://www.tsa.gov/research/reading/index.shtm.

Freedom of Information Act (FOIA) Overview

Electronic Reading Room
Submitting FOIA Requests

Submitting Privacy Act Requests

TSA Employee Records

Click here For U.S. Army Public Health Command surveys of backscatter imaging technology and cabinet X-ray systems.
Click here for surveys of checked and carry-on baggage screening equipment.
Click here for surveys of backscatter imaging technology machines.
Click here for U.S. Army Public Health Command Dosimeter Study.

Due to the nature of these redacted documents they may not be fully Section 508 compliant.

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References:

[0] http://blog.tsa.gov/2009/05/explosive-trace-detection.html

[1]  http://newyork.cbslocal.com/2010/11/23/tsa-some-govt-officials-exempt-from-scans-pat-downs/

[2] http://www.tsofficer.net/index.php?threads/list-from-bill-fishers-tsa-crimes-synopsis.16/

[3] http://www.infiniteunknown.net/2010/11/26/tsa-top-us-government-officials-exempt-from-screenings/

[4] TSA phases out puffer exposive detection machines.  http://blog.tsa.gov/2009/05/explosive-trace-detection.html

[5] http://www.usatoday.com/news/washington/2011-03-11-tsa-scans_N.htm

[5] http://www.cdc.gov/niosh/topics/airportscreener/

[6] http://www.state.in.us/isdh/files/X-ray_Machine_Frequencies.pdf

[7] http://911research.wtc7.net/wtc/attack/wtc7.html

[8]  http://911research.wtc7.net/wtc/attack/wtc7.html

[9] http://www.schneier.com/blog/archives/2008/09/tsa_employees_b.html

[10]  http://www.usatoday.com/news/washington/2010-11-22-scanner-lobby_N.htm

[11] http://news.slashdot.org/story/11/11/02/0511245/how-x-ray-scanners-became-mandatory-in-us-airports

[13] http://publicintelligence.net/presidential-report-on-effects-of-ionizing-radiation-from-human-scanning-systems-july-2003/

[14] http://911research.wtc7.net/wtc/attack/wtc7.html

[15] http://www.infowars.com/building-7-implosion-the-smoking-gun-of-911/

[16] http://www.propublica.org/article/tsa-puts-off-safety-study-of-x-ray-body-scanners

[17] http://news.slashdot.org/story/12/01/07/0214240/tsa-interested-in-purchasing-dosimeters

Key Word; Umar Farouk Abdulmutallab, Detroit, airliner bomb, explosive detection, puffer,