I have not seen the new verbiage yet but TSA Regulations have, for as long as I can remember, required that unloaded firearms be placed in a locked, hardsided case, and that the key or combination remain solely with the passenger. Note that the regulations PROHIBIT TSA-style luggage locks, as these present a possible security breach. This is because they don't want anyone (including TSA) other than the passenger to have access to the firearm inside the secured Airport Operations Area (the passenger has already been separated from the firearm and therefore it stays securely locked up). At many stations, the procedure at check-in is to be escorted by the airline to a special screening location where you wait while TSA X-rays your bag. If they need to open it for further inspection, they will ask you, the passenger, to open it. At other stations, the bag goes down with the others for regular screening and the airline will usually ask you to "hang out nearby" in case TSA contacts them with any questions. The declaration that you sign is required to be placed inside the luggage containing the locked firearms case, or in the case of the gun case being checked by itself, inside the locked case.

Here is what is happening at American Airlines - at least at ORD and effective only recently: They now require you to fill out an extra declaration which they then staple to a red "special handling" tag and attach to the outside of the bag. This irresponsible policy implementation is not required by TSA, and will surely lead to the theft of firearms from people's bags. You might as well put a tag on the outside that says "LOTS OF FREE CASH INSIDE FOR THE TAKING." The danger is that it unnecessarily advertises the presence of a firearm, and in doing so, actually places the public in danger (should it be stolen out of luggage and thereby fall into criminals' hands). BOTH pro- AND anti-gun people should be equally concerned about this policy because it will inevitably lead to someone, who shouldn't have a gun, getting one.

The other annoying thing on AA, is that once you check your firearm on the outbound leg of your trip, they notate your record, and you will be unable to check in for subsequent legs in your PNR. When you try, you will get a message stating "We are unable to check in passengers traveling with firearms. Please check in with an agent at the airport." They will also ask you when you check in now, "What kind of gun is it?" It's absolutely none of their business but I always tell them a model that is super expensive or antique, so that when it does get stolen, at least they'll be paying me the max allowance.