Manufacturers of lock boxes often market portable handgun cases, which manufacturers claim meet TSA guidelines. The guidelines for Transporting Firearms and Ammunition, established by the Transportation Security Administration (TSA), define the requirements of a device adequate for transporting a firearm by plane. Firearms may be transported in “a locked hard sided container.” The container “must completely secure the firearm from being accessed.” The guidelines also define, through a catchall list covering all potentially destructive items, what a firearm is. The list can be found in United States Code, Title 18, Part 1, Chapter 44.
TSA guidelines make no mention of how resistant to unauthorized access a locked hard-sided container must be. According to TSA guidelines, “Locked cases that can be easily opened will not be accepted.” The phrase “can be easily opened” is the only language in the guidelines that might be construed to address unauthorized entry, covert, forced, or otherwise. However, the TSA does not actively test hard-sided containers on the market for their accessibility. Therefore the matter of how easily a case may or may not be opened hasn’t been established before a gun owner buys a hard-sided container for travel.
Nor does the TAS police how its Firearm and Ammunition Guidelines are invoked. Since the TSA does not endorse products (or services, or entities), responsibility is left to manufacturers to decide whether their products are TSA compliant. The phrase “TSA compliant” is the only phrase permitted to be used on product labeling. The phrase “TSA approved” is not permitted, though manufacturers commonly use it on product labeling.
In order for the claim that a product is TSA compliant to be meaningful three things will need to happen:
First, the TSA must draft a detailed and well-considered description of what precisely an adequate firearm container is. Any description of the container’s security components, including its locking mechanism and material construction, will need to be guided by input from engineers knowledgeable in security. This description will need to avoid confusion and should not involve creating a new concept for a storage device requiring a special legal description; gun locks and containers should be called what they are, gun locks and containers, nothing else.
Second, the TSA must establish a process for examining firearm containers and for testing them to determine whether they meet the guidelines. This testing process will need to include a thorough examination of the container, a systematic analysis of security vulnerabilities, and testing procedures to evaluate the accessibility of a container through the use of common items that might be lawfully brought aboard an aircraft.
Third, the TSA must actively grant approval for containers intended for use on board an aircraft to store and transport firearms. Approval by the TSA is the only way to remove ambiguity about compliance with TSA Firearm and Ammunition Guidelines.