Container Security
A Flexible Staffing Model and Minimum Equipment Requirements Would Improve Overseas Targeting and Inspection Efforts Gao ID: GAO-05-557 April 26, 2005In January 2002, U.S. Customs and Border Protection (CBP) initiated the Container Security Initiative (CSI) to address the threat that terrorists might use maritime cargo containers to ship weapons of mass destruction. Under CSI, CBP is to target and inspect high-risk cargo shipments at foreign seaports before they leave for destinations in the United States. In July 2003, GAO reported that CSI had management challenges that limited its effectiveness. Given these challenges and in light of plans to expand the program, GAO examined selected aspects of the program's operation, including the (1) factors that affect CBP's ability to target shipments at foreign seaports, (2) extent to which high-risk containers have actually been inspected overseas, and (3) extent to which CBP formulated and documented strategies for achieving the program's goals.
Some of the positive factors that have affected CBP's ability to target shipments overseas are improved information sharing between U.S. and foreign customs staff and a heightened level of bilateral cooperation and international awareness of the need to secure the whole global shipping system. Although the program aims to target all U.S.-bound shipments from CSI ports, it has been unable to do so because of staffing imbalances. CBP has developed a staffing model to determine staffing needs but has been unable to fully staff some ports because of diplomatic considerations (e.g., the need for host government permission) and practical considerations (e.g., workspace constraints). As a result, 35 percent of these shipments were not targeted and were therefore not subject to inspection overseas. In addition, the staffing model's reliance on placing staff at CSI ports rather than considering whether some of the targeting functions could be performed in the United States limits the program's operational efficiency and effectiveness. CBP has not established minimum technical requirements for the detection capability of nonintrusive inspection and radiation detection equipment used as part of CSI. Ports participating in CSI use various types of nonintrusive inspection equipment to inspect containers, and the detection and identification capabilities of such equipment can vary. In addition, technologies to detect other weapons of mass destruction have limitations. Given these conditions, CBP has limited assurance that inspections conducted under CSI are effective at detecting and identifying terrorist weapons of mass destruction. A lthough CBP has made some improvements in the management of CSI, we found that further refinements to the bureau's management tools are needed to help achieve program objectives. In July 2003, we recommended that CBP develop a strategic plan and performance measures, including outcome-oriented measures, for CSI. CBP developed a strategic plan for CSI in February 2004 that contains three of the six key elements required for agency strategic plans, and CBP officials told us they continue to develop the other three elements. While it appears that the bureau's efforts in this area meet the intent of our prior recommendation to develop a strategic plan for CSI, we will continue to monitor progress in this area. CBP has also made progress in the development of outcome-oriented performance measures, particularly for the program objective of increasing information sharing and collaboration among CSI and host country personnel. However, CBP continues to face challenges in developing performance measures to assess the effectiveness of CSI targeting and inspection activities. Therefore, it is difficult to assess progress made in CSI operations over time, and it is difficult to compare CSI operations across ports.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-05-557, Container Security: A Flexible Staffing Model and Minimum Equipment Requirements Would Improve Overseas Targeting and Inspection Efforts
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
April 2005:
Container Security:
A Flexible Staffing Model and Minimum Equipment Requirements Would
Improve Overseas Targeting and Inspection Efforts:
GAO-05-557:
GAO Highlights:
Highlights of GAO-05-557, a report to congressional requesters:
Why GAO Did This Study:
In January 2002, U.S. Customs and Border Protection (CBP) initiated the
Container Security Initiative (CSI) to address the threat that
terrorists might use maritime cargo containers to ship weapons of mass
destruction. Under CSI, CBP is to target and inspect high-risk cargo
shipments at foreign seaports before they leave for destinations in the
United States. In July 2003, GAO reported that CSI had management
challenges that limited its effectiveness. Given these challenges and
in light of plans to expand the program, GAO examined selected aspects
of the program‘s operation, including the (1) factors that affect CBP‘s
ability to target shipments at foreign seaports, (2) extent to which
high-risk containers have actually been inspected overseas, and (3)
extent to which CBP formulated and documented strategies for achieving
the program‘s goals.
What GAO Found:
Some of the positive factors that have affected CBP‘s ability to target
shipments overseas are improved information sharing between U.S. and
foreign customs staff and a heightened level of bilateral cooperation
and international awareness of the need to secure the whole global
shipping system. Although the program aims to target all U.S.-bound
shipments from CSI ports, it has been unable to do so because of
staffing imbalances. CBP has developed a staffing model to determine
staffing needs but has been unable to fully staff some ports because of
diplomatic considerations (e.g., the need for host government
permission) and practical considerations (e.g., workspace constraints).
As a result, 35 percent of these shipments were not targeted and were
therefore not subject to inspection overseas. In addition, the staffing
model‘s reliance on placing staff at CSI ports rather than considering
whether some of the targeting functions could be performed in the
United States limits the program‘s operational efficiency and
effectiveness.
CBP has not established minimum technical requirements for the
detection capability of nonintrusive inspection and radiation detection
equipment used as part of CSI. Ports participating in CSI use various
types of nonintrusive inspection equipment to inspect containers, and
the detection and identification capabilities of such equipment can
vary. In addition, technologies to detect other weapons of mass
destruction have limitations. Given these conditions, CBP has limited
assurance that inspections conducted under CSI are effective at
detecting and identifying terrorist weapons of mass destruction.
Although CBP has made some improvements in the management of CSI, we
found that further refinements to the bureau‘s management tools are
needed to help achieve program objectives. In July 2003, we recommended
that CBP develop a strategic plan and performance measures, including
outcome-oriented measures, for CSI. CBP developed a strategic plan for
CSI in February 2004 that contains three of the six key elements
required for agency strategic plans, and CBP officials told us they
continue to develop the other three elements. While it appears that the
bureau‘s efforts in this area meet the intent of our prior
recommendation to develop a strategic plan for CSI, we will continue to
monitor progress in this area. CBP has also made progress in the
development of outcome-oriented performance measures, particularly for
the program objective of increasing information sharing and
collaboration among CSI and host country personnel. However, CBP
continues to face challenges in developing performance measures to
assess the effectiveness of CSI targeting and inspection activities.
Therefore, it is difficult to assess progress made in CSI operations
over time, and it is difficult to compare CSI operations across ports.
What GAO Recommends:
GAO recommends that CBP refine its staffing model to help improve the
program‘s ability to target shipments at foreign ports, develop minimum
technical requirements for the detection capabilities of equipment used
in the program, and complete development of performance measures for
all program objectives.
The Department of Homeland Security (DHS) generally concurred with our
recommendations and described corrective actions to respond to them.
The Department of State had no comments.
www.gao.gov/cgi-bin/getrpt?GAO-05-557.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Richard M. Stana at (202)
512-8777 or stanar@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
While CBP Has Enhanced Its Ability to Target Containers Overseas,
Limitations Remain:
Some Containers Not Inspected for a Variety of Reasons:
CBP Has Made Progress Developing a Strategic Plan and Performance
Measures for CSI, but Further Refinements Are Needed:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Objectives:
Scope and Methodology:
Data Reliability:
Appendix II: CSI Performance Measures, as of January 2005:
Appendix III: Comments from the Department of Homeland Security:
Appendix IV: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Staff Acknowledgments:
Related GAO Products:
Tables:
Table 1: CSI Operational Seaports, as of February 2005:
Table 2: CSI Outcome-Oriented Performance Measures:
Figures:
Figure 1: CBP's Domestic Process for Targeting and Inspecting Cargo
Containers:
Figure 2: Commercial Sample Image Produced by an X-ray Imaging Machine
of a Cargo Container Loaded on a Truck Trailer:
Figure 3: CSI Process for Targeting and Inspecting Cargo Containers
Overseas:
Abbreviations:
ATS: Automated Targeting System:
CBP: U.S. Customs and Border Protection:
CSI: Container Security Initiative:
GPRA: Government Performance and Results Act of 1993:
ICE: U.S. Immigration and Customs Enforcement:
NTC: National Targeting Center:
OMB: Office of Management and Budget:
PRD: personal radiation detector:
RIID: radiation isotope identifier device:
RPM: radiation portal monitor:
WCO: World Customs Organization:
WMD: weapons of mass destruction:
United States Government Accountability Office:
Washington, DC 20548:
April 26, 2005:
The Honorable Susan M. Collins:
Chairman:
The Honorable Joseph I. Lieberman:
Ranking Minority Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Norm Coleman:
Chairman:
The Honorable Carl Levin:
Ranking Minority Member:
Permanent Subcommittee on Investigations:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable John D. Dingell:
Ranking Minority Member:
Committee on Energy and Commerce:
House of Representatives:
Ocean cargo containers play a vital role in the movement of cargo
between global trading partners. In 2004, nearly 9 million ocean cargo
containers arrived and were offloaded at U.S. seaports. Responding to
heightened concern about national security since September 11, 2001,
several U.S. government agencies have focused efforts on preventing
terrorists from smuggling weapons of mass destruction (WMD) in cargo
containers from overseas locations to attack the United States and
disrupt international trade.[Footnote 1] Because of its frontline
responsibilities for inspection at U.S. ports of entry, the U.S.
Customs and Border Protection (CBP) has the lead U.S. role in ensuring
ocean container security and reducing the vulnerabilities associated
with the overseas supply chain.
In light of the complexity and interconnectedness of global commerce,
international cooperation is a key factor in reducing the vulnerability
of oceangoing cargo. To help address its responsibility to ensure the
security of this cargo, CBP has in place a program known as the
Container Security Initiative (CSI). The program aims to target and
inspect high-risk cargo shipments at foreign seaports before they leave
for destinations in the United States. Under the program, foreign
governments agree to allow CBP personnel to be stationed at foreign
seaports to use intelligence and automated risk assessment information
to target shipments to identify those at risk of containing WMD or
other terrorist contraband. CBP personnel are to refer these high-risk
shipments to host government officials, who are then to determine
whether to inspect the shipment before it leaves the port for the
United States. Host government officials examine shipments with
nonintrusive inspection equipment (such as X-ray machines) and, if they
deem it necessary, open the cargo containers to physically examine the
contents inside. As of February 2005, the CSI program was operational
at 34 foreign seaports, with plans to expand to an additional 11 ports
by the end of fiscal year 2005.
The program is promising, but our previous work has raised concerns
about its management and its ability to achieve its ultimate goal of
improved cargo security. In July 2003, we reported that CBP's
management of CSI had not evolved from a short-term focus to a long-
term strategic approach.[Footnote 2] We recommended that the Secretary
of the Department of Homeland Security (DHS) work with the Commissioner
of U.S. Customs and Border Protection to develop (1) a strategic plan
that clearly lays out the program's goals, objectives, and detailed
implementation strategies; (2) performance measures that include
outcome-oriented indicators; and (3) a human capital plan that clearly
describes how CSI will recruit, train, and retain staff to meet the
program's growing demands as the bureau implements new program
elements. In March 2004, we testified that CBP's targeting system does
not incorporate all key elements of a risk management framework and
recognized modeling practices in assessing the risks posed by
oceangoing cargo containers.[Footnote 3]
In light of the program's planned expansion, we examined selected
aspects of the program's operation and management. This report
addresses the following issues:
1. What factors affect CBP's ability to target shipments at overseas
seaports?
2. Under CSI, to what extent have high-risk containers been inspected
overseas prior to their arrival at U.S. destinations?
3. To what extent has CBP developed strategies and related management
tools for achieving the program's goals?
To address all three objectives, we met with CBP officials in
Washington, D.C., who have program responsibilities for CSI and
reviewed available data and documentation for the program. To ascertain
the degree to which high-risk shipments were targeted and inspected
overseas, we obtained data on CSI targeting and inspection activity for
each of the CSI ports. We also met with CSI teams and host government
officials at four overseas ports. In addition, we observed elements of
the targeting and inspection processes at these ports and obtained and
reviewed documentation of CSI procedures provided by CBP and host
government officials at these ports. We also assessed the reliability
of CBP's data on the number of shipments and containers subject to
targeting and inspection under CSI and found the data sufficiently
reliable for use in our report. In addition, we examined the status of
the bureau's efforts to implement our prior recommendations for
strategic and human capital plans and performance measures for the
program.
We conducted our work from February 2004 through February 2005 in
accordance with generally accepted government auditing standards. More
details about the scope and methodology of our work are presented in
appendix I.
Results in Brief:
We identified both positive and negative factors that affect CBP's
ability to target shipments at overseas seaports. According to CBP
officials, some of the positive factors are improved information
sharing between U.S. and foreign customs operations and a heightened
level of bilateral cooperation and international awareness regarding
securing the whole global shipping system across governments. Related
to these factors, as of February 2005 CBP had successfully negotiated
agreements with host nations to allow CSI to operate in 34 foreign
seaports. As of September 11, 2004, CSI teams were able to target
approximately 65 percent of the U.S.-bound shipments coming through CSI
ports to determine whether they were high-risk and should be referred
to host government customs officials for inspection. This represents
about 43 percent of all shipments transported to the United States by
oceangoing cargo containers. However, other, negative factors limit
CBP's ability to successfully target containers to determine if they
are high-risk. One such factor is staffing imbalances, which impede CBP
from targeting all containers shipped from CSI ports before they leave
for the United States. While CBP has developed a staffing model to
determine the required level of staff, political and practical
considerations have limited the number of staff at some ports. As a
result of these imbalances, 35 percent of U.S.-bound shipments from CSI
ports were not targeted and were therefore not subject to inspection
overseas--the key goal of the CSI program. One of the features of the
CSI staffing model that may contribute to the staffing imbalance is its
reliance on placing staff overseas at CSI ports. Another negative
factor is weaknesses in manifest data, one source of data used for
targeting shipments.
As of September 11, 2004, host government officials inspected the
majority of containers referred to them for inspection by CSI teams.
However, 28 percent of these containers were not inspected for a
variety of reasons. For example, 1 percent of the container referrals
were denied by host government officials, generally because they
believed the referrals were based on factors not related to security
threats, such as drug smuggling. For referred containers that are not
inspected by host governments overseas, the CSI team is supposed to
refer the container for inspection by CBP upon arrival at the U.S.
destination port. Although CBP officials did not have information going
back to the inception of CSI, they noted that between July 2004 and
September 2004, about 93 percent of shipments referred for domestic
inspection were inspected at a U.S. port. CBP explained that some
referred shipments were not inspected domestically because inspectors
at U.S. ports received additional intelligence information that lowered
the risk characterization of the shipments or because the shipments
remained aboard the carrier while in the U.S. port. For the 72 percent
of referred containers that were inspected overseas, CBP officials told
us that no WMD were discovered. However, the inspection equipment used
at CSI ports varies in detection capability and there are no minimum
technical requirements for equipment used as part of CSI. In addition,
technologies to detect other WMD have limitations. As a result, CBP has
limited assurance that inspections conducted under CSI are effective at
detecting and identifying terrorist WMD in containers.
Although CBP has made some improvements in the management of CSI, we
found that further refinements to the bureau's management tools are
needed to help achieve program goals. In July 2003, we recommended that
CBP develop a strategic plan and performance measures, including
outcome-oriented measures, for CSI. CBP issued a strategic plan for CSI
in February 2004 that contains three of the six key elements required
for agency strategic plans: a mission statement, long-term objectives,
and implementation strategies. The director of CBP's Strategic Planning
and Audit Division told us the bureau continues to develop the other
three elements for the CSI strategic plan: (1) describing how
performance goals are related to general goals of the program, (2)
identifying key external factors that could affect program goals, and
(3) describing how programs are to be evaluated. CBP has also made
progress in the development of outcome-oriented performance measures,
particularly for the program objective of increasing information
sharing and collaboration among CSI and host country personnel.
However, CBP continues to face challenges in developing performance
measures to assess the effectiveness of CSI targeting and inspection
activities. Therefore, it is difficult to assess progress made in CSI
operations over time, and it is difficult to compare CSI operations
across ports.
We are making several recommendations to improve the program's ability
to meet its objectives. These include revising its staffing model,
developing minimum detection capability requirements for nonintrusive
inspection equipment used in the program, and completing development of
performance measures for all program objectives. We provided a draft of
this report to the Secretary of DHS and the Department of State for
comment. In its response, DHS noted that CBP generally agreed with our
recommendations and cited corrective actions it either has taken or
planned to take. The Department of State had no comments on the draft
report.
Background:
Several studies on maritime security conducted by federal, academic,
nonprofit, and business organizations have concluded that the movement
of oceangoing cargo in containers is vulnerable to some form of
terrorist action, largely because of the movement of shipments
throughout the supply chain.[Footnote 4] Relatively few importers own
and operate all key aspects of the cargo container transportation
process, which includes overseas manufacturing and warehouse
facilities, carrier ships to transport goods, and the transportation
operation to receive the goods upon arrival. Most importers must rely
on second-hand parties to move cargo in containers and prepare various
transportation documents. Second-hand parties within the cargo
container supply chain may include exporters, freight forwarders,
customs brokers, inland transportation providers, port operators, and
ocean carriers. Every time responsibility for cargo in containers
changes hands along the supply chain, there is the potential for a
security breach; specifically, this change in responsibility creates
opportunities for contraband to be placed in containers and
opportunities for fraudulent documents to be prepared. According to the
U.S. Department of Transportation's Volpe National Transportation
Systems Center, importers who own and operate all aspects of the supply
chain suffer the fewest security breaches because of their increased
level of control.[Footnote 5]
While CBP has noted that the likelihood of terrorists smuggling WMD
into the United States in cargo containers is low, the nation's
vulnerability to this activity and the consequence of such a disaster
are high. With about 90 percent of the world's maritime cargo moving by
containers, terrorist action related to cargo containers could paralyze
the maritime trading system and quickly disrupt U.S. and global
commerce. In a strategic simulation of a terrorist attack sponsored by
the consulting firm Booz Allen Hamilton in 2002, representatives from
government and industry organizations participated in a scenario
involving terrorist activities at U.S. seaports.[Footnote 6] The
scenario simulated the discovery and subsequent detonation of "dirty
bombs"--explosive devices wrapped in radioactive material and designed
to disperse radiological contamination--hidden in cargo containers at
various locations around the country. These "events" led simulation
participants to shut down every seaport in the United States over a
period of 12 days. Booz Allen Hamilton published a report in October
2002 about the results of the simulation, which estimated that the 12-
day closure would result in a loss of $58 billion in revenue to the
United States' economy, including spoilage, loss of sales,
manufacturing slowdowns, and halts in production. Further, according to
the report, it would take 52 days to clear the resulting backlog of
vessels and 92 days to stabilize the container backlog, causing a
significant disruption in the movement of international trade.
CBP's Targeting and Inspection Approach at Domestic Ports:
According to CBP, the large volume of imports and the bureau's limited
resources make it impractical to inspect all oceangoing containers
without disrupting the flow of commerce. CBP also noted it is
unrealistic to expect that all containers warrant such inspection
because each container poses a different level of risk based on a
number of factors including the exporter, the transportation providers,
and the importer. CBP has implemented an approach to container security
that attempts to focus resources on particularly risky cargo while
allowing other cargo to proceed.
CBP's domestic efforts to target cargo to determine the risk it poses
rely on intelligence, historical trends, and data provided by ocean
carriers and importers. Pursuant to federal law, CBP requires ocean
carriers to electronically transmit cargo manifests to CBP's Automated
Manifest System 24 hours before the cargo is loaded on a ship at a
foreign port.[Footnote 7] This information is used by CBP's Automated
Targeting System (ATS). ATS is characterized by CBP as a rule-based
expert system that serves as a decision support tool to assess the risk
of sea cargo.[Footnote 8] In addition, CBP requires importers to
provide entry-level data that are entered into the Automated Commercial
System and also used by ATS. According to CBP officials, ATS uses this
information to screen all containers to determine whether they pose a
risk of containing WMD.
As shown in figure 1, CBP targeters at domestic ports target containers
by first accessing the bills of lading and their associated risk scores
electronically. The assigned risk score helps the targeters determine
the risk characterization of a container and the extent of documentary
review or inspection that will be conducted. For example, containers
characterized as high-risk are to be inspected. Containers
characterized as medium-risk are to be further researched. That is,
targeters are to consider intelligence alerts and research assistance
provided by the National Targeting Center (NTC) to the ports, and their
own experience and intuition, in characterizing the final risk of
shipments. Containers characterized as low-risk are generally to be
released from the port without further documentary review or inspection.
Figure 1: CBP's Domestic Process for Targeting and Inspecting Cargo
Containers:
[See PDF for image]
[End of figure]
There are, generally, two types of inspections that CBP inspectors may
employ when examining cargo containers--nonintrusive inspections and
physical examinations. The nonintrusive inspection, at a minimum,
involves the use of X-ray or gamma-ray scanning equipment. As shown in
figure 2, the X-ray or gamma ray equipment is supposed to scan a
container and generate an image of its contents. CBP inspectors are to
review the image to detect any anomalies, such as if the density of the
contents of the container is not consistent with the description of the
contents.
Figure 2: Commercial Sample Image Produced by an X-ray Imaging Machine
of a Cargo Container Loaded on a Truck Trailer:
[See PDF for image]
[End of figure]
If an anomaly is apparent in the image of the container, CBP inspectors
are to decide whether to conduct a physical examination of the
container. According to CBP officials, they have a policy to determine
the type of physical examination to be conducted depending on the
location of the anomaly.
CBP inspectors also are to use radiation detection devices to detect
the presence of radioactive or nuclear material. If the detectors
indicate the presence of radioactive material, CBP officials are to
isolate the source and contact the appropriate agency, such as the
Department of Energy, for further guidance.
CBP Extended Its Targeting and Inspection Activities to Overseas
Seaports:
Announced in January 2002, CSI was implemented to allow CBP officials
to target containers at overseas seaports so that any high-risk
containers may be inspected prior to their departure for U.S.
destinations. According to the CSI strategic plan, strategic objectives
for CSI include (1) pushing the United States' zone of security beyond
its physical borders to deter and combat the threat of terrorism; (2)
targeting shipments for potential terrorists and terrorist weapons,
through advanced and enhanced information and intelligence collection
and analysis, and preventing those shipments from entering the United
States; (3) enhancing homeland and border security while facilitating
growth and economic development within the international trade
community; and (4) utilizing available technologies to leverage
resources and to conduct examinations of all containers posing a high
risk for terrorist related activity. Another objective cited by CBP
officials, although not included in the CSI strategic plan, is to raise
the level of bilateral cooperation and international awareness
regarding the need to secure global trade.
To implement CSI, CBP negotiates and enters into bilateral arrangements
with foreign governments, specifying the placement of CBP officials at
foreign ports and the exchange of information between CBP and foreign
customs administrations. CBP first solicited the participation of the
20 foreign ports that shipped the highest volume of ocean containers to
the United States. These top 20 ports are located in 14 countries and
regions and shipped a total of 66 percent of all containers that
arrived in U.S. seaports in 2001. CBP has since expanded CSI to
strategic ports, which may ship lesser amounts of cargo to the United
States but may also have terrorism or geographical concerns. As shown
in table 1, as of February 2005, CSI was operational at 34 ports,
located in 17 countries or regions. For fiscal year 2004, the CSI
budget was about $62 million, with a budget of about $126 million in
fiscal year 2005 for the program.
Table 1: CSI Operational Seaports, as of February 2005:
Country/region: Canada;
CSI port: Halifax;
Date CSI operations began at port: March 2002.
Country/region: Canada;
CSI port: Montreal;
Date CSI operations began at port: March 2002.
Country/region: Canada;
CSI port: Vancouver;
Date CSI operations began at port: February 2002.
Country/region: The Netherlands;
CSI port: Rotterdam;
Date CSI operations began at port: September 2002.
Country/region: France;
CSI port: Le Havre;
Date CSI operations began at port: December 2002.
Country/region: France;
CSI port: Marseilles;
Date CSI operations began at port: January 2005.
Country/region: Germany;
CSI port: Bremerhaven;
Date CSI operations began at port: February 2003.
Country/region: Germany;
CSI port: Hamburg;
Date CSI operations began at port: February 2003.
Country/region: Belgium;
CSI port: Antwerp;
Date CSI operations began at port: February 2003.
Country/region: Belgium;
CSI port: Zeebrugge;
Date CSI operations began at port: October 2004.
Country/region: Republic of Singapore;
CSI port: Singapore;
Date CSI operations began at port: March 2003.
Country/region: Japan;
CSI port: Yokohama;
Date CSI operations began at port: March 2003.
Country/region: Japan;
CSI port: Tokyo;
Date CSI operations began at port: May 2004.
Country/region: Japan;
CSI port: Nagoya;
Date CSI operations began at port: August 2004.
Country/region: Japan;
CSI port: Kobe;
Date CSI operations began at port: August 2004.
Country/region: Hong Kong Special Administrative Region of China;
CSI port: Hong Kong;
Date CSI operations began at port: May 2003.
Country/region: Sweden;
CSI port: Gothenburg;
Date CSI operations began at port: May 2003.
Country/region: United Kingdom;
CSI port: Felixstowe;
Date CSI operations began at port: May 2003.
Country/region: United Kingdom;
CSI port: Liverpool;
Date CSI operations began at port: October 2004.
Country/region: United Kingdom;
CSI port: Southampton;
Date CSI operations began at port: October 2004.
Country/region: United Kingdom;
CSI port: Thamesport;
Date CSI operations began at port: October 2004.
Country/region: United Kingdom;
CSI port: Tilbury;
Date CSI operations began at port: October 2004.
Country/region: Italy;
CSI port: Genoa;
Date CSI operations began at port: June 2003.
Country/region: Italy;
CSI port: La Spezia;
Date CSI operations began at port: June 2003.
Country/region: Italy;
CSI port: Livorno;
Date CSI operations began at port: December 2004.
Country/region: Italy;
CSI port: Naples;
Date CSI operations began at port: September 2004.
Country/region: Italy;
CSI port: Gioia Tauro;
Date CSI operations began at port: October 2004.
Country/region: South Korea;
CSI port: Busan;
Date CSI operations began at port: August 2003.
Country/region: South Africa;
CSI port: Durban;
Date CSI operations began at port: December 2003.
Country/region: Malaysia;
CSI port: Port Klang;
Date CSI operations began at port: March 2004.
Country/region: Malaysia;
CSI port: Tanjung Pelepas;
Date CSI operations began at port: August 2004.
Country/region: Greece;
CSI port: Piraeus;
Date CSI operations began at port: July 2004.
Country/region: Spain;
CSI port: Algeciras;
Date CSI operations began at port: July 2004.
Country/region: Thailand;
CSI port: Laem Chabang;
Date CSI operations began at port: August 2004.
Source: CBP.
[End of table]
To participate in CSI, a host nation must meet several criteria. The
host nation must utilize (1) a seaport that has regular, direct and
substantial container traffic to ports in the United States; (2)
customs staff with the authority and capability of inspecting cargo
originating in or transiting through its country; and (3) nonintrusive
inspection equipment with gamma-or X-ray capabilities and radiation
detection equipment. Additionally, each potential CSI port must
indicate a commitment to (1) establishing an automated risk management
system; (2) sharing critical data, intelligence, and risk management
information with CBP officials; (3) conducting a thorough port
assessment to ascertain vulnerable links in a port's infrastructure and
commit to resolving those vulnerabilities; and (4) maintaining a
program to prevent, identify, and combat breaches in employee integrity.
To prepare for implementation of CSI, CBP sends an assessment team to
each potential CSI port to collect information about the port's
physical and information infrastructure, the host country's customs
operations, and the port's strategic significance to the United States.
CBP then deploys a CSI team, which generally consists of three types of
officials--special agents, targeters, and intelligence analysts. These
officials come from either CBP or U.S. Immigration and Customs
Enforcement (ICE). The team leader is a CBP officer or targeter who is
assigned to serve as the immediate supervisor for all CSI team members
and is responsible for coordinating with host government counterparts
in the day-to-day operations. The team leader is also to prepare a
weekly report on container targeting and inspection activity at the
port. The targeters are team members responsible for targeting
shipments and referring those shipments they determine are high-risk to
host government officials for inspection. The targeter may also observe
inspections of containers. The intelligence analyst is responsible for
gathering information to support targeters in their efforts to target
containers. In addition, the special agents are to coordinate all
investigative activity resulting from CSI-related actions, as well as
liaison with all appropriate U.S. embassy attachés.
CSI Process for Targeting and Inspecting Cargo Containers Overseas:
Although the targeting of cargo at domestic ports is primarily
dependent upon the ATS score, under CSI the targeting of cargo is
largely dependent on CBP targeters' review of the ATS score in
conjunction with reviews of bills of lading, additional information
provided by host government officials, and, in at least one country, a
unique set of targeting rules developed jointly by CBP and host
government officials. As shown in figure 3, on the basis of the initial
review, CBP officials are to either (1) categorize shipments as low-
risk, in which case the container holding the shipment is loaded onto
the departing vessel without being inspected, or (2) conduct further
research in order to properly characterize the risk level of the
shipment.
Figure 3: CSI Process for Targeting and Inspecting Cargo Containers
Overseas:
[See PDF for image]
[End of figure]
Referrals of shipments to the host government for inspection are
handled in one of three ways--shipments are inspected or inspection is
either waived or denied. After receiving a referral for inspection from
CSI teams, host customs officials are to review the bills of lading of
the shipments and the reasons for the referrals to determine whether or
not to inspect the shipments. Some host governments collect information
on U.S.-bound shipments independent of CSI, which host officials also
consider in decisions of whether to inspect the referred shipments.
Finally, if the host government officials determine, on the basis of
their review, that a shipment is not high-risk, they will deny
inspection of the shipment. For any high-risk shipment for which an
inspection is waived or denied, CSI teams are to place a domestic hold
on the shipment, so that it will be inspected upon arrival at its U.S.
destination. However, if CSI team members are adamant that a cargo
container poses an imminent risk to the carrier or U.S. port of arrival
but cannot otherwise convince the host officials to inspect the
container, CSI team members are to contact and coordinate with the
National Targeting Center to issue a do-not-load order for national
security. According to CBP officials, this order advises the carrier
that the specified container will not be permitted to be unloaded in
the United States until a time when any associated imminent risk to the
cargo container is neutralized. Once the risk is neutralized, the
container is to be loaded back onto the carrier and placed on hold for
a domestic examination. According to CBP officials, this type of do not
load order has been implemented six times since the inception of CSI.
As in the domestic inspection process, there are, generally, two types
of CSI inspections--nonintrusive inspections and physical
inspections.[Footnote 9] However, since CBP officials do not have the
legal authority to inspect U.S.-bound containers in foreign ports, the
host government customs officials are to conduct the inspections.
According to CBP, in general, CBP officials are to observe the
inspections and document inspection results. In addition, CBP
officials, along with host government officials, may review the images
produced by the X-ray or gamma-ray equipment to detect any anomalies
that may indicate the presence of WMD.[Footnote 10] Also in
collaboration with host government officials, CBP officials are to
review the output produced by radiation detection devices to assess
whether radioactive or nuclear material is present. On the basis of the
results of the nonintrusive inspection, such as if an anomaly is
apparent in the image of the container, the host government and CBP
officials must decide whether to conduct a physical examination of the
container. Our limited observations at three ports confirmed that host
nation officials allowed CSI team members to observe the inspection
process. CBP and host government officials at the four CSI ports we
visited indicated that if WMD or related contraband were found during a
CSI inspection, the host government would be responsible for taking
appropriate enforcement measures and disposing of the hazardous
material.
While CBP Has Enhanced Its Ability to Target Containers Overseas,
Limitations Remain:
We identified both positive and negative factors that affect CBP's
ability to target shipments at overseas seaports. According to CBP
officials, the CSI program has produced factors that contribute to
CBP's ability to target shipments at overseas seaports, including
improved information sharing between the CSI teams and host government
officials regarding U.S.-bound shipments and a heightened level of
bilateral cooperation on and international awareness of the need for
securing the global shipping system. However, we found several factors
that may limit the program's effectiveness at some ports, including (1)
staffing imbalances at CSI ports and (2) weaknesses in one source of
data CBP relies upon to target shipments.
CSI Successes Have Enhanced CBP's Ability to Target Containers Overseas:
One of the factors assisting with targeting of cargo is improved
information sharing between U.S. and host customs officials. CBP has
successfully negotiated agreements with several foreign governments to
allow for the operation of CSI at their overseas seaports. Through
September 11, 2004, CSI teams were able to target about 65 percent of
the shipments coming through 25 CSI ports to determine whether they
were at risk of containing WMD. This represented about 43 percent of
all oceangoing cargo container traffic to the United States. As of
January 2005, CBP had expanded the program to 34 operational ports,
with plans to further expand the program to a total of 45 ports by the
end of fiscal year 2005. According to CBP officials, the overseas
presence of CBP officials has led to effective information sharing
between the team and host government officials regarding targeting of
U.S.-bound shipments. For example, CBP targeters at one of the ports we
visited said that the presence of CBP officials at CSI ports fosters
cooperation by host nation customs officials, such that more shipments
characterized as high-risk and referred for inspection would be denied
inspection by the host government if CBP officials were not present.
According to CBP officials, information from host government officials
on U.S.-bound shipments has been beneficial to CBP's efforts to target
shipments. They noted that the additional information provided by host
governments can be utilized to address threats posed by U.S.-bound
shipments. Additionally, CBP officials noted that the CSI teams can
provide this information to NTC to incorporate into ATS to enhance
CBP's targeting capabilities. During one of our port visits, host
government officials noted that providing information to CSI teams
allows CBP officials to make more informed decisions about which
shipments are high-risk, reducing the number of shipments deemed high-
risk and referred for inspection by the host government. Additionally,
CBP and host government officials at this same port told us that host
government information also results in additional inspections of U.S.-
bound containers, beyond those referred by the CSI team. For example,
they said that in 2003, this host government identified and inspected
30 high-risk U.S.-bound containers that were not identified as high-
risk by the CSI team.
Another positive factor reported to us is the level of bilateral
cooperation and international awareness regarding the need to secure
global trade. With the discovery and seizure of shipments under CSI of
automatic weapons, ammunition, and other falsely identified contraband,
CBP noted that many customs services around the world without strong
law enforcement capabilities are currently seeking additional legal
authority to strengthen their ability to fight terrorism. For example,
CBP noted that in June 2002, the World Customs Organization (WCO)
passed a resolution to enable ports in all of its member nations to
begin to develop outbound targeting programs consistent with the CSI
model. In addition, in April 2004 the European Union and the Department
of Homeland Security signed an agreement that calls for intensifying
and broadening the agreement on customs cooperation and mutual
assistance in customs matters, to include cooperation on container
security and related matters. For example, the measures adopted in the
agreement include the creation of an information exchange network, an
agreement on minimum requirements applicable for European ports that
wish to participate in CSI, and identification of best practices
concerning security controls of international trade.
CBP Staffing Imbalances Prevent Targeting of All Containers from CSI
Ports:
One factor negatively affecting CBP's ability to target containers is
staffing imbalances across ports and shortages at some ports. Although
CBP's goal is to target all U.S.-bound containers at CSI ports before
they depart for the United States, it has not been able to place enough
staff at some CSI ports to do so. CBP has developed a CSI staffing
model to determine the staff needed to target containers. However, at
some CSI ports CBP has been unable to staff the CSI teams at the levels
called for in the CSI staffing model. In commenting on a draft of this
report, DHS noted that the 35 percent of U.S.-bound shipments that were
not targeted by CSI teams were deemed low-risk by ATS and thus required
no further review at CSI ports. However, our discussions with CSI teams
at two of the four ports we visited indicated that those teams did not
prioritize shipments for targeting based on ATS score but instead
prioritized shipments by departure time. As a result, there is no
assurance that all high-risk shipments are targeted at CSI ports.
CBP has been unable to staff the CSI teams at the levels called for in
the CSI staffing model because of diplomatic and practical
considerations. CBP officials told us it is unrealistic to expect that
CBP can place the number of targeters indicated by its staffing model
needed to review all shipments at every CSI port. In terms of
diplomatic considerations, the host government may limit the overall
number of U.S. government employees to be stationed in the country and
may restrict the size of the CSI team. In terms of practical
considerations, the host governments may not have enough workspace
available for CSI staff and may thus restrict the size of the CSI team.
The U.S. Department of State would also have to agree to the size of
the CSI teams, a decision that has to be balanced with the mission
priorities of the embassy, the programmatic and administrative costs
associated with increases in staffing, and security issues related to
the number of Americans posted overseas. According to the State
Department, the average cost of putting an American position overseas
will be approximately $430,000.[Footnote 11]
One of the features of the CSI staffing model that may contribute to
the staffing imbalance is its reliance on placing staff overseas at CSI
ports. It does not consider whether some of the targeting functions
could be performed in the United States. For example, the model does
not consider what minimum number of targeters need to be physically
located at CSI ports to carry out duties that require an overseas
presence (such as coordinating with host government officials) as
opposed to other duties that could be performed in the United States
(such as reviewing manifests and databases). As we noted in our 2002
report on a staffing framework for use at U.S. embassies, federal
agencies should consider options that improve operational efficiency
and effectiveness and that minimize security risks, such as assessing
which functions can occur in the United States, as part of their
framework for determining the right number of staff to be placed
overseas.[Footnote 12]
CBP has acknowledged that it cannot fully implement the CSI staffing
model and has supplemented staff at the CSI ports with domestic
targeters at NTC. According to CBP officials, CSI teams may contact
these NTC targeters and request that they help target specific
shipments that CSI teams at the ports are unable to target. The NTC
targeters, after targeting the shipments, are to notify the relevant
CSI team with the results of their targeting, including whether the
shipments are high-risk and should be referred to the host government
for inspection. Although the NTC targeters are available to provide
assistance to CSI teams 24 hours a day, 7 days a week, CBP officials
noted that even with the addition of these targeters, the bureau has
been unable to target every U.S.-bound shipment before it departed a
CSI port.
The use of domestic targeters demonstrates that CBP does not have to
rely exclusively on overseas targeters as called for in its staffing
model. Our observations at four CSI ports indicated that having CSI
staff work directly with host nation customs officials was beneficial
to both the targeting and the inspection processes. However, we also
noted that the the targeters' work focused on targeting ATS findings,
as well as consulting various automated databases, and did not include
much interaction with host government officials. For example, at two of
the ports we visited CBP officials told us that typically only one or
two CSI team members dealt directly with host customs officials. In
addition, while CBP officials could not provide us with port-specific
or average costs of the CSI port teams, they stated that it was more
expensive to post staff overseas than in the United States.
One Source of Targeting Data Has Limitations:
Another factor that negatively affects CBP's ability to target
shipments is the existence of limitations in one data source used. For
CSI, CBP relies on manifest information to assess the risk level of
U.S.-bound shipments.[Footnote 13] As we previously reported, terrorism
experts, trade representatives, and CBP officials indicated that
manifest data may contain unreliable information and are sometimes
incomplete.[Footnote 14] We reported that manifests are produced by
second-hand parties (ocean carriers), not the importers or exporters
who have the most contact with and knowledge of the cargo. In addition,
manifests have historically been used to disguise detailed information
about containers' contents, to prevent theft during transport of the
cargo. This is particularly applicable to high-value products, such as
electronics and apparel. In the same previous report, we also noted
that manifest data can be amended up to 60 days after oceangoing
vessels arrive at U.S. seaports, further limiting the use of manifest
data for determining a definitive risk level before cargo
arrives.[Footnote 15] CBP officials at CSI ports we visited indicated
that despite the requirement that carriers submit accurate and complete
manifests to CBP 24 hours prior to the cargo being loaded on the U.S.-
bound vessel, some manifest data in ATS remain vague or incomplete. For
example, a CBP official at one CSI port we visited said that in some
cases the name of the freight forwarder was used in place of the actual
names of the importer and consignee. Although CBP officials told us
that the quality of the manifest data has improved, there is no method
to routinely verify whether the manifest data accurately reflect the
contents within the cargo container. CBP officials told us that to try
to address the shortcomings of manifests, CSI teams consult other data
to obtain information on shipments. As mentioned earlier, entry-level
data are used.
Some Containers Not Inspected for a Variety of Reasons:
Since the implementation of CSI through September 11, 2004, 28 percent
(4,013) of containers referred to host government officials for
inspection were not inspected, generally because of host government
information that suggested the containers were not high-risk or
operational limitations that prevented the containers from being
inspected before they left the port. In 1 percent of these cases, host
government officials denied inspections, generally because inspection
requests were based on factors not related to security threats, such as
drug smuggling. Containers designated as high-risk by CSI teams that
are not inspected overseas are supposed to be referred for inspection
upon arrival at the U.S. destination port. CBP officials noted that
between July 2004 and September 2004, about 93 percent of shipments
referred for domestic inspection were inspected at a U.S. port. CBP
officials explained that some shipments designated as high-risk by CSI
teams were not inspected domestically because inspectors at U.S. ports
received additional information or entry information that lowered the
risk characterization of the shipments or because the shipments
remained aboard the carrier and were never offloaded at a U.S. port.
For the 72 percent (10,343) of containers referred to host government
officials for inspection that were inspected overseas, CBP officials
told us there were some anomalies that led to law enforcement actions
but that no WMD were discovered. However, considering that the
inspection equipment used at CSI ports varies in detection capability
and that there are no minimum requirements for the detection capability
of equipment used for CSI, CBP has no absolute assurance that
inspections conducted under CSI are effective at detecting and
identifying WMD.
Some Containers Not Inspected Overseas because of Host Government
Information:
Some of the containers referred for inspection were not inspected
because of additional information obtained by host government officials
that lowered the risk characterization of the container. An important
aspect of CSI is the information host government officials can provide
in determining whether a U.S.-bound container is at high risk of
containing WMD and should be inspected. For example, at one CSI port we
visited, the host customs official told us that although CBP officials
referred a shipment for inspection because the area from which the
shipment originated had known terrorist activity, the host government's
customs officials had a thorough working history with the importer and
believed the shipment did not pose a threat. On the basis of this
information, the CSI team and the host nation customs officials agreed
that the shipment did not pose a threat and that inspection was not
necessary.
Some Containers Not Inspected Overseas because of Operational
Limitations:
Some containers were not inspected at CSI ports because of operational
limitations that were generally beyond the control of CBP. For example,
since the program's inception through September 11, 2004, some referred
containers were not inspected at CSI ports because the containers had
already been loaded on departing vessels. CBP officials and host
government customs officials explained that a container may already be
loaded on a vessel prior to its being referred for inspection because
the amount of time the container actually stays in the port--dwell
time--may be brief. CSI teams are not always able to target such
containers and refer them for inspection before they are loaded.
According to CBP and host government officials with whom we met,
terminal operators intentionally schedule the arrival and departure of
containers in order to minimize dwell time. However, CSI teams may not
always know when containers are due for departure. Host government
customs officials at one of the ports we visited said that until
recently, the CSI team did not have access to the port schedules for
U.S.-bound containers; therefore, team members could not prioritize the
order in which they reviewed bills of lading for U.S.-bound shipments
based on container dwell time. However, as of July 2004, the CSI team
at this port gained access to port schedule information and now
prioritizes its review of bills of lading based on container departure
time. Host government officials noted that this practice decreases the
number of containers waived for inspection.
Host Nations Deny Inspections for Some Containers Referred by CSI
Teams:
In addition to operational limitations that prevent referred containers
from being inspected at CSI ports, host government officials have
denied inspection for about 1 percent of the containers referred to
them by CBP officials. According to CBP officials, the majority of
these denials occurred early in the program's operation as both CSI
teams and host government officials implemented the program. For
example, host government officials at one CSI port we visited indicated
that some of these denials were for inspection requests based on
factors not related to security threats, such as drug smuggling. They
told us their rationale in denying these requests was that CBP could
inspect these containers in the United States, and identifying customs
violations was not the purpose of CSI. At another port we visited, CSI
team officials told us that host customs officials initially denied
inspections of shipments referred solely because of the shipment's ATS
score, preferring to instead have referrals that were further
researched by the CSI team to help ensure that shipments were truly
high-risk. As noted earlier, if the CSI team members are adamant that a
cargo container poses an imminent risk to the conveyance or the U.S.
port of arrival, they can coordinate with the National Targeting Center
to issue a do-not-load order to prevent the container from being placed
on the ship.
Containers Not Inspected Overseas Can Be Inspected on U.S. Arrival:
Containers with high-risk shipments that are not inspected overseas are
supposed to be referred for inspection upon arrival at the U.S.
destination port. Effective November 21, 2003, CSI team members were
required to place domestic exam holds on high-risk containers that had
not been inspected overseas. That is, the CSI team is supposed to
request a domestic inspection for all containers for which an
inspection was waived or denied by marking, in ATS, the container for a
domestic hold and notifying the director of the U.S.-destination port.
The CSI team is also supposed to request domestic exams for shipments
that were inspected overseas but not to the satisfaction of the CSI
team, such as if there was a disagreement over the interpretation of
the X-ray image produced during the nonintrusive inspection or if the
host nation was not willing to perform a physical exam after an anomaly
was detected. However, not all shipments referred for a domestic
inspection by CSI teams are inspected. Although CBP has not
systematically tracked since the program's inception whether containers
placed on domestic hold are examined, according to CBP, it began
tracking this information in July 2004. CBP officials told us that
between July 2004 and September 2004, 93 percent of the shipments
placed on CSI for domestic exam hold were actually inspected at a U.S.
port. CBP explained that U.S. port officials did not inspect about 2
percent of the shipments placed on domestic exam hold during this time
period because the shipments were either remaining on board at the U.S.
port or additional intelligence information convinced them that the
shipment no longer needed to be characterized as high-risk. For the
remaining 5 percent of shipments that were not inspected domestically,
CBP officials told us the bureau cannot confirm what action was taken
on these shipments because of data input errors by domestic inspectors.
CBP officials also noted that they were unable to confirm whether any
shipments placed on domestic exam hold prior to July 2004 were actually
inspected upon arrival in the United States because of these same data
input errors.
In the Absence of Minimum Technical Requirements, Inspection Equipment
Capabilities Vary:
As of September 11, 2004, host governments had inspected 72 percent
(10,343) of all containers referred to them by CSI teams since the
inception of the program. These containers were inspected using
nonintrusive inspections and physical examinations. According to CBP
and host government officials, variation in the extent of physical
examinations depends on anomalies detected during the nonintrusive
inspection. CBP officials also told us that no WMD have been discovered
under CSI.
There are two different types of radiation detection devices used at
CSI ports to inspect cargo containers--radiation isotope identifier
devices (RIID) and radiation portal monitors (RPM)--each with different
detection and identification capabilities. While both devices can
detect the presence of radioactive material, only the RIID can
determine whether or not the type of radiation emitted by the material
actually poses a threat or whether it is a normal emission of
radiation, such as that found in ceramic tile. In addition, there is
another type of radiation detection device used at CSI ports to help
ensure the safety of CSI team members--personal radiation detectors
(PRD). According to radiation detection experts, PRDs are personal
safety devices to protect against radiation exposure, they are not
adequate as search instruments. A scientist at the Department of Energy
Los Alamos National Laboratory who was involved in the testing of
radiation detection equipment said that PRDs have a limited range and
are not designed to detect weapons-usable nuclear material.
There are also various types of X-ray and gamma-ray imaging machines
used at CSI ports to inspect cargo containers, and their detection and
identification capabilities may vary. According to CBP, there are
various brands of imaging machines used to conduct nonintrusive
inspections at CSI ports. These brands of machines differ in their
penetration capabilities, scan speed, and several other factors.
Despite this variability in detection and inspection capability, CBP
officials told us that the inspection equipment used at all CSI ports
had inspection capabilities at least as good as the nonintrusive
inspection equipment used by CBP at domestic ports. CBP officials told
us that prior to establishing CSI at a foreign port, CBP officials
conducted on-site assessments of the nonintrusive inspection equipment
used at the port. More recently, CBP conducted an assessment of the
capabilities of the equipment in use at each CSI port against the
capabilities of one brand of equipment. This assessment indicated that
with the exception of equipment used in one country, all equipment had
capabilities that met or exceeded those of this brand of equipment. In
addition, technologies to detect other WMD have limitations. According
to CBP officials, the bureau has not established minimum technical
requirements for the nonintrusive inspection equipment or radiation
detection equipment that can be used as part of CSI because of
sovereignty issues, as well as restrictions that prevent CBP from
endorsing a particular brand of equipment. Although CBP cannot endorse
a particular brand of equipment, the bureau could still establish
general technical capability requirements for any equipment used under
CSI similar to other general requirements CBP has for the program, such
as the country committing to establishing an automated risk management
system. Because the CSI inspection could be the only inspection of a
container before it enters the interior of the United States, it is
important that the nonintrusive inspection and radiation detection
equipment used as part of CSI meets minimum technical requirements to
provide some level of assurance of the likelihood that the equipment
could detect the presence of WMD.
CBP Has Made Progress Developing a Strategic Plan and Performance
Measures for CSI, but Further Refinements Are Needed:
Although CBP has made some improvements in the management of CSI, we
found that further refinements to the bureau's management tools are
needed to help achieve program goals. In July 2003, we recommended that
CBP develop a strategic plan and performance measures, including
outcome-oriented measures, for CSI. In February 2004, CBP finalized a
strategic plan for CSI containing three of the six key elements
identified by the Government Performance and Results Act of 1993 (GPRA)
for an agency strategic plan: a mission statement, objectives, and
implementation strategies. CBP officials told us the bureau plans to
incorporate the remaining three elements into the CSI strategic plan,
specifying how performance goals are related to general goals of the
program, identifying key external factors that could affect program
goals, and describing how the program will be evaluated. CBP has also
made progress in the development of outcome-oriented performance
measures for some objectives, particularly for the objective of
increasing information sharing and collaboration among CSI and host
country personnel. However, further refinements are needed to assess
the effectiveness of the other program objectives, including CSI
targeting and inspection activities.
CBP Completed a Strategic Plan for CSI, but Three Key Elements Are
Still under Development:
In July 2003, we recommended that CBP develop a strategic plan for CSI.
CBP developed a strategic plan in February 2004. According to GPRA,
executive agency strategic plans should include:
* a comprehensive mission statement,
* general goals and objectives,
* a description of how the general goals and objectives are to be
achieved,
* a description of how performance goals and measures are related to
the general goals and objectives of the program,
* an identification of key factors external to the agency and beyond
its control that could affect the achievement of general goals and
objectives, and:
* a description of the program evaluations.
These six key elements are required for executive agency strategic
plans and thus serve as a good baseline to measure other long-term
planning efforts. In addition, we have found that high-quality plans
include strategies to mitigate the effects of external factors,
although such strategies are not a legislative requirement.[Footnote 16]
CSI's strategic plan includes three of these key elements:
* a mission statement: "to prevent and deter terrorist use of maritime
containers while facilitating movement of legitimate trade";
* objectives, including (a) pushing the United States' zone of security
beyond its physical borders to deter and combat the threat of
terrorism; (b) targeting shipments for potential terrorists and
terrorist weapons, through advanced and enhanced information and
intelligence collection and analysis, and preventing those shipments
from entering the United States; (c) enhancing homeland and border
security while facilitating growth and economic development within the
international trade community; and (d) utilizing available technologies
to leverage resources and to conduct examinations of all high-risk
containers (another objective cited by CBP officials, although not
included in the CSI strategic plan, is to raise the level of bilateral
cooperation and international awareness regarding the need to secure
global trade); and:
* various descriptions of how general goals and objectives are to be
achieved.
However, CBP has not yet incorporated the other three key elements into
its strategic plan. For example, the CSI strategic plan does not
include a description of how performance goals and measures are related
to program objectives. At the time the strategic plan was developed,
CBP lacked performance goals and measures. We discuss performance
measures in more detail in the next section.
In addition, the CSI strategic plan does not identify external factors
beyond the control of CBP that could affect the achievement of program
objectives. Such external factors could include economic, demographic,
social, technological, or environmental factors. Two external factors
that could be addressed in the CSI strategic plan are the extent to
which host governments can provide additional information to contribute
to the targeting process and the various operational limitations that
prevent all high-risk containers from being inspected overseas.
In addition, the CSI strategic plan does not include a description of
program evaluations. Although evaluations are not described in the CSI
strategic plan, CBP conducts periodic evaluations of CSI ports in order
to determine areas in which implementation of CSI can be improved and
to determine whether CSI should continue to operate at that port.
However, these evaluations do not employ a systematic methodology or
identify the basis on which program success is determined. GPRA defines
a program evaluation as an objective and formal assessment of the
implementation, results, impact, or effects of a program or policy.
Program evaluations are used to ensure the validity and reasonableness
of program goals and strategies, as well as identify factors likely to
affect program performance. Specifically, CBP has not identified and
planned which CSI elements will be assessed at each port; rather,
assessment topics are generated ad hoc. In addition, assessment topics
differ over time, preventing CBP from determining the extent to which
CSI teams addressed issues raised in previous evaluations. For example,
in its July 2003 evaluation of one CSI port, CBP's Office of
International Affairs identified the following problems: (1) lack of
information available to the intelligence research specialist, (2) the
need to make better information available to CSI team members, and (3)
the lack of follow-through on shipments through CSI ports that were
referred for domestic exam. However, none of these issues was discussed
in the Office of International Affairs' next evaluation of this port in
December 2003. Similarly, the assessment topics for CSI port
evaluations also differ across ports, making it difficult to make
comparisons across ports.
In February 2005, CBP officials told us that CBP is revising the CSI
strategic plan to address the elements we raise in this report. While
it appears that the bureau's initial efforts in this area meet the
intent of our prior recommendation to develop a strategic plan for CSI,
we cannot determine the effectiveness of further revisions to the plan
without first reviewing and evaluating them. We will continue to
monitor CBP's efforts in this area.
CBP Has Developed Outcome-Oriented Performance Measures for Some
Program Objectives:
In July 2003, we recommended that CBP expand efforts already initiated
to develop performance measures for CSI that include outcome-oriented
indicators. Until recently, CBP based the performance of CSI on program
outputs such as (1) the number and percentage of bills of lading
reviewed, further researched, referred for inspection, and actually
inspected, and (2) the number of countries and ports participating in
CSI.
As of January 2005, CBP had developed 11 performance indicators for
CSI, 2 of which it identified as outcome-oriented: (1) the number of
foreign mitigated examinations and (2) the percentage of worldwide U.S.-
destined containers processed through CSI ports.[Footnote 17] As
indicated in table 2, both outcome indicators are used to assess CBP's
progress in meeting its objective of increasing information sharing and
collaboration among CBP officials and host country personnel.
Table 2: CSI Outcome-Oriented Performance Measures:
Measure: Number of foreign mitigated examinations, by category;
Scope: The measure will be the number of examinations waived for a
variety of reasons;
FY 2004 baseline: 2,416 (cumulative);
Cumulative FY 2005 target: Increase over baseline; track by categories;
Long-term program goal: Increase information sharing and collaboration
among CSI and host country personnel so that the number of foreign
mitigated container exams is increased and legitimate trade is
facilitated through the port.
Measure: Percentage of worldwide U.S.-destined containers processed
through CSI ports;
Scope: This measure will utilize the annual volume of U.S.-destined
containers processed through all CSI ports prior to lading and divide
it by the annual worldwide number of U.S.-destined containers;
FY 2004 baseline: 48%;
Cumulative FY 2005 target: 68%;
Long-term program goal: Increase information sharing and collaboration
among CSI and host country personnel in order to prevent terrorist
weapons from entering the country.
Source: CBP.
[End of table]
However, the way in which one of these indicators is measured needs
refinement. The measure for the number of foreign mitigated
examinations is the number of shipments referred to host governments
that were not, for a variety of reasons, inspected overseas.
Specifically, according to CBP, an increase in the number of
examinations waived or denied suggests an increase in the number of
unnecessary examinations that were prevented. However, the number of
examinations waived or denied by host nations are not appropriate
measures for the prevention of unnecessary exams. A shipment is
inspected unnecessarily if, when provided with additional information
on the shipment, the CSI team and the host nation would have agreed
that the shipment was not high-risk and, therefore, the inspection
should not have taken place. However, if an inspection is waived
because of operational limitations, the implication may not be that the
CSI team thinks the inspection is unnecessary. To the contrary, the CSI
team and host government may agree that the shipment should be
inspected. Similarly, a host nation denial of an inspection does not
imply that the CSI team believes the inspection is unnecessary.
Conversely, when a referral for inspection is categorized as denied, by
definition, the CSI team believes the shipment should be inspected, but
the host government refuses to conduct the inspection. In response to
our review, CBP officials acknowledged that its inclusion of waivers
because of operational limitations or denials of inspections in this
measure was inappropriate.
CBP noted that each of the performance measures for assessing
information sharing and collaboration with host nations will be pilot-
tested at numerous CSI ports to assess their feasibility, utility,
relevancy, and the likelihood that they will produce information that
is actionable. According to CBP, the measures may be revised based on
the evaluation of the pilot to improve their effectiveness in assessing
program performance and outcomes.
According to Office of Management and Budget (OMB) and CBP officials,
developing outcome-oriented performance measures that measure the
effectiveness of programs that aim to deter or prevent specific
behaviors is challenging. For example, one of CSI's objectives is to
deter terrorists' use of oceangoing cargo containers. However,
according to host government officials at one port we visited and CBP
officials, it is difficult to develop a meaningful measure for the
extent to which implementation of CSI has discouraged terrorists from
using oceangoing cargo containers to smuggle WMD into the United
States. In January 2005, CBP developed a performance indicator to
measure CSI's progress in preventing terrorists' use of oceangoing
cargo containers that measures the amount of terrorist contraband,
illegal drugs, and other illegal activity found during CSI inspections.
However, this indicator may not be a meaningful measure of deterrence
of terrorist activity, since the inclusion of narcotics is not relevant
to the program's objectives, and according to CBP, no terrorist weapons
or weapons material have been detected prior to or during the
implementation of CSI.
According to OMB, when agencies face difficulty in developing outcome-
based performance measures, they are encouraged to develop proxy
measures. Proxy measures are used to assess the effectiveness of
program functions, such as the targeting and inspection processes of
CSI, rather than directly assess the effectiveness of the program. For
example, CBP could develop a proxy measure associated with targeting
and inspection, such as the percentage of containers randomly inspected
domestically that was not characterized by CBP officials as high-risk
that actually contained WMD. CBP could also use random inspections to
measure if containers from CSI ports that were not identified as high-
risk actually contained WMD and, therefore, should have initially been
identified as high-risk. According to terrorism experts and
representatives of the international trade community, random
inspections could be an effective practice to supplement and test CBP's
targeting and inspection processes.
Terrorism experts and shipping industry representatives also suggest
that staging covert, simulated terrorist events could test the
effectiveness of both the targeting and inspection processes of CSI.
Simulated events could include smuggling fake WMD into the United
States using an oceangoing cargo container. Such events could help
determine whether the targeting procedures led to the identification of
the container as high-risk and whether any subsequent inspection
activities actually detected the fake WMD. CBP could, therefore,
develop proxy measures associated with this activity for CSI, such as
the percentage of staged containers that were identified as high-risk
and the percentage of staged containers for which the fake WMD was
detected during the inspection process. In response to our prior work
on container security, CBP officials agreed with our recommendation
that containers be subject to such tests.
CSI lacks performance goals and measures for its objective of enhancing
homeland and border security while facilitating growth and economic
development within the international trade community. Regarding the
enhancement of homeland and border security, there are no performance
goals for CSI. According to host government officials at CSI ports we
visited and shipping industry representatives with whom we met, CSI has
resulted in increased international awareness of supply chain security.
Officials from the World Customs Organization predicted that as more
countries partner with CBP through CSI, there will be increased
consistency in the way in which the supply chain and ports are secured
worldwide. One WCO official also stated that CBP's efforts through
initiatives such as CSI provide guidance for developing countries on
how to improve their supply chain security efforts. While these
testimonials help identify some benefits of CSI, CBP does not have
performance indicators and goals to actually measure the extent to
which the program has resulted in enhanced homeland and border security.
Regarding facilitating economic growth, there are also no performance
measures for CSI. According to host government officials with whom we
met at one CSI port, they are willing to participate in CSI as long as
the program does not disrupt the flow of trade. An example of such a
disruption would be the delayed departure of a vessel because of a CSI
inspection or the instruction not to load a container on a departing
vessel because of a CSI inspection. Discussions with CBP and host
government officials and representatives of the shipping industry
indicate that CBP has been successful in not disrupting the flow of
trade through CSI. However, CBP has not developed associated
performance goals and measures to demonstrate its reported success in
achieving this objective. In commenting on a draft of this report, DHS
noted that CBP is continuing to refine existing performance measures
and develop new performance measures for its program goals. For
example, CBP was developing a cost efficiency measure to measure the
cost of work at a port and to contribute to staffing decisions. CBP
believes that its continued revisions to the CSI strategic plan have
also allowed CSI staff to refine performance measures and the bureau's
data collection methodology.
Conclusions:
CBP has made progress in its implementation of CSI, but the program
could be further improved by taking steps to help ensure its
effectiveness in preventing WMD from entering the United States via
cargo containers. First, CBP's inability to staff all CSI ports to the
level suggested by its staffing model and the model's assumption that
all staff should be located at the CSI ports have limited the program's
ability to target potentially high-risk shipments at some foreign
seaports before they depart for the United States. This problem may be
exacerbated as CBP continues to expand CSI to additional overseas
seaports. Second, without minimum technical requirements for the
nonintrusive inspection equipment used as part of CSI, CBP has limited
assurance that the equipment in use can successfully detect all WMD.
While we recognize that establishing such requirements may be a
difficult issue to address, it is important that CBP establish them
because the CSI inspection may be the only inspection of some
containers before they enter the interior of the United States. Third,
CBP has developed a strategic plan for the CSI program and indicated
that it will refine the plan to include key elements described in GPRA.
Although we are not making a recommendation related to its strategic
plan, given the importance of having an effective strategic plan for
the program, we will continue to monitor the bureau's progress in
refining the plan. Finally, while CSI has apparently resulted in some
benefits, such as cooperation with foreign governments and enhanced
international awareness of container security, CBP has not developed
outcome-based performance measures or proxy measures for all of its
program objectives. Without outcome-based performance measures on which
to base program evaluations, CBP will have difficulties assessing the
effectiveness of CSI as a homeland security program.
Recommendations for Executive Action:
To help ensure that the objectives of CSI are achieved, we recommend
that the Secretary of the Department of Homeland Security direct the
Commissioner of U.S. Customs and Border Protection take the following
three actions:
* revise the CSI staffing model to consider (1) what functions need to
be performed at CSI ports and what functions can be performed in the
United States, (2) the optimum levels of staff needed at CSI ports to
maximize the benefits of targeting and inspection activities in
conjunction with host nation customs officials, and (3) the cost of
locating targeters overseas at CSI ports instead of in the United
States;
* establish minimum technical requirements for the capabilities of
nonintrusive inspection equipment at CSI ports, to include imaging and
radiation detection devices, that help ensure that all equipment used
can detect WMD, while considering the need not to endorse certain
companies and sovereignty issues with participating countries;
* develop performance measures that include outcome-based measures and
performance targets (or proxies as appropriate) to track the program's
progress in meeting all of its objectives.
Agency Comments and Our Evaluation:
We provided a draft of this report to the Secretary of DHS and the
Department of State for comment. We received comments from the DHS
Acting Director, Departmental Liaison, that are reprinted in appendix
III. DHS generally agreed with our recommendations and outlined actions
CBP either had taken or was planning to take to implement them. The
Department of State had no comments.
CBP agreed with our recommendation on CSI's staffing model and said
that modifications to the model would allow for program objectives to
be achieved in a cost-effective manner. Specifically, CBP said that it
would evaluate the minimum level of staff needed at CSI ports to
maintain an ongoing dialogue with host nation officials, as well as
assess the staffing levels needed domestically to support CSI
activities. If properly implemented, these actions should address the
intent of this recommendation.
In addressing our recommendation to establish minimum technical
requirements for the capabilities of the nonintrusive inspection
equipment used at CSI ports, CBP agreed to evaluate the feasibility of
making such requirements for the imaging and radiation detection
devices in use at CSI ports but did not commit to implement our
recommendation. CBP noted that because host governments purchase the
equipment for use at CSI ports, a legal issue may exist regarding CBP's
ability to impose such requirements. CBP noted it would also seek
comment and advice from other U.S. government agencies that would be
affected by such a decision. Although CBP cannot endorse a particular
brand of equipment, the bureau could still establish general technical
capability requirements for any equipment used under CSI similar to
other general requirements CBP has for the program, such as the country
committing to establishing an automated risk management system. Because
the CSI inspection could be the only inspection of a container before
it enters the interior of the United States, it is important that the
nonintrusive inspection and radiation detection equipment used as part
of CSI meet minimum technical requirements to provide some level of
assurance of the likelihood that the equipment could detect the
presence of WMD.
CBP agreed with our recommendation on developing performance measures,
noting that it would continue to refine, evaluate, and implement any
and all performance measures needed to track the progress in meeting
all of CSI's objectives. CBP noted that this would be an ongoing
activity. If properly implemented, these plans should help address the
intent of this recommendation.
DHS also offered technical comments and clarifications, which we have
considered and incorporated where appropriate.
If you or your staffs have any questions about this report, please
contact me at (202) 512-8777 or at stanar@gao.gov. Key contributors to
this report are listed in appendix IV. This report will also be
available at no charge on the GAO Web site at http://www.gao.gov.
Signed by:
Richard M. Stana:
Director, Homeland Security and Justice Issues:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
Objectives:
We addressed the following issues regarding the U.S. Customs and Border
Protection's (CBP) Container Security Initiative (CSI):
* What factors affect CBP's ability to target high-risk shipments at
overseas seaports?
* Under CSI, to what extent have high-risk containers been inspected
overseas prior to their arrival at U.S. destinations?
* To what extent has CBP developed strategies and related management
tools for achieving the program's goals?
Scope and Methodology:
To address our first issue--what factors affect CBP's ability to target
shipments at overseas seaports--we first reviewed relevant GAO reports
on CBP's Automated Targeting System (ATS) and CSI. We then met with CBP
headquarters officials to hold discussions and review documents related
to CSI's overall targeting strategy, criteria for identifying high-risk
containers, efforts to evaluate the program, efforts to refine
targeting, training provided to CSI targeters, and the criteria for
staffing at CSI ports. We also visited the National Targeting Center,
which serves as CBP's central targeting facility related to terrorism.
At this facility, we met with cognizant officials and discussed ATS
categorization of containers by risk level, how cargo containers'
scores are transmitted to targeters at CSI ports, the training provided
to the ATS targeters, the types of information and intelligence
utilized by targeters, and recent and planned refinements to ATS. We
also met with officials from the European Commission and the World
Customs Organization (WCO) in Brussels, Belgium, and discussed how the
CSI program has been implemented and its impact on container security.
Also related to this first issue, we visited four overseas CSI ports.
We selected these ports on the basis of the volume of containers
shipped to the United States, geographic dispersion, and time the CSI
team was in operation. At these ports, we met with the CSI teams to
discuss and review documents related to the overall targeting process,
the types of information used in the targeting process, efforts to
evaluate the targeting process, the impact other CBP initiatives may
have had on the targeting process, and requests for information to host
governments. We also observed operations at each of the ports,
including targeters reviewing manifest information.
To address our second issue--to what extent have high-risk containers
been inspected overseas prior to their arrival at U.S. destinations--we
met with officials from CBP headquarters and CSI port teams to hold
discussions and review documents related to the overall inspection
process, types of inspections, inspection equipment used, statistics on
inspections conducted at CSI ports, and levels of cooperation with host
governments. At the four ports we visited, we also met with foreign
government customs officials to discuss the role of the CSI teams in
the inspection process, the criteria they use in deciding whether to
inspect a container that was referred for inspection by the CSI team,
the criteria they use in deciding the type of inspection to be
conducted, the procedures they use to safeguard containers once
inspected, and the types of inspection equipment they used.
To address our third issue--to what extent has CBP developed clearly
formulated and documented strategies for achieving the program's goals-
-we reviewed GAO reports examining management factors that were
necessary components for the successful management of cabinet
departments, agencies, and, by extension, individual programs.
Specifically, we focused our review on two management factors--the
development of performance measures and strategic planning--because of
their general importance in the literature. We reviewed Office of
Management and Budget (OMB) and Government Performance and Results Act
of 1993 (GPRA) guidance on performance measures and goals to assess the
extent CBP has incorporated them into the CSI program. We also
discussed CSI strategies for achieving program goals with officials
from CBP headquarters, CSI teams, and host governments. We also
obtained and reviewed CBP evaluations of CSI port teams to assess the
methodology used to conduct evaluations.
We conducted our work from February 2004 through February 2005 in
accordance with generally accepted government auditing standards.
Data Reliability:
To assess the reliability of CBP's data on the number of shipments and
containers subject to targeting and inspection under CSI, we (1)
obtained source data on targeting and inspection activity for two 1-
week periods from CSI teams at two ports, (2) compared the source data
with the data generated by CBP's Automated Targeting System (ATS) for
the same 2-week period, (3) discussed discrepancies between the source
data and ATS data with CBP officials at these ports, and (4) obtained
CBP headquarters' responses to our questionnaire regarding the
reliability of ATS and the data that are produced by the system.
Although our initial reliability testing indicated that there were some
inconsistencies between the source data and the data generated by ATS,
generally because of human input error, we were able to work with CSI
team officials to resolve most of the discrepancies. In addition, the
differences between the source data and ATS data were so small that the
results of our analysis, at least for this 2-week period, would have
remained the same regardless of which data we used. Therefore, we
determined that the CSI targeting and inspection data generated by ATS
are sufficiently reliable for use in supporting our findings regarding
the extent to which high-risk containerized shipments are identified
and inspected prior to arrival at U.S. destinations.
[End of section]
Appendix II: CSI Performance Measures, as of January 2005:
Measure: Outcome measures.
Measure: Number of foreign mitigated examinations, by category;
Scope: The measure will be the number of examinations waived because of
a variety of reasons;
FY 2004 baseline: 2,416 examinations (cumulative);
Cumulative FY 2005 target: Increase over baseline; track by categories;
Long-term program goal: Increase information sharing and collaboration
among CSI and host country personnel so that the number of foreign
mitigated container exams is increased and legitimate trade is
facilitated through the port.
Measure: Percentage of worldwide U.S.-destined containers processed
through CSI ports;
Scope: This measure will utilize the annual volume of U.S.-destined
containers processed through all CSI ports prior to lading and divide
it by the annual worldwide number of U.S.-destined containers;
FY 2004 baseline: 48%;
Cumulative FY 2005 target: 68%;
Long-term program goal: Increase information sharing and collaboration
among CSI and host country personnel in order to prevent terrorist
weapons from entering the country.
Measure: Information measures:
Measure: Number of intelligence reports based on CSI foreign sources;
Scope: This measure will track the number of memorandums of information
received (MOIR), which are narratives of intelligence gathered from CSI
foreign sources;
FY 2004 baseline: 17 cases;
Cumulative FY 2005 target: Increase over baseline;
Long-term program goal: Increase information sharing and collaboration
among CSI and host country personnel in order to prevent terrorist
weapons from entering the country.
Measure: Number of operational CSI ports;
Scope: This measure identifies the total number of ports where CSI has
been implemented;
FY 2004 baseline: 30 ports;
Cumulative FY 2005 target: 45 ports;
Long- term program goal: Increase information sharing and collaboration
among CSI and host country personnel in order to prevent terrorist
weapons from entering the country.
Measure: Number of positive findings, by category;
Scope: This measure includes identifying the number and type of
"positive findings" documented because of CSI participation. Positive
findings occur when examinations performed on containers yield a
positive result such as implements of terror, narcotics, forced labor,
uninvoiced or unmanifested good, restricted merchandise, hazardous
materials, or other results. Note that the CSI goal is to find
implements of terror;
other categories are peripheral benefits;
FY 2004 baseline: Baseline to be established;
Cumulative FY 2005 target: Target to be established;
Long-term program goal: Prevent terrorists, means of terrorism, illegal
drugs, and other illegal activity.
Measure: Number of investigative cases initiated because of CSI
intelligence;
Scope: This measure tracks the number of investigative cases opened
either in the United States or at a foreign location because of
intelligence gathered by CSI staff at foreign ports;
FY 2004 baseline: 20 cases;
Cumulative FY 2005 target: 10 percent increase over the baseline--22
cases;
Long-term program goal: Increase information sharing and collaboration
among CSI and host country personnel in order to prevent terrorist
weapons from entering the country.
Measure: Efficiency measure:
Measure: Average cost per CSI port to achieve operational status;
Scope: The average cost per CSI port includes site assessments and
certifications, telecom circuit installation, local area network (LAN)
and office equipment, commercial off-the-shelf software, office
furniture, radiation isotope identification devices (RIID), purchase of
automobiles, initial lease and utilities costs, and initial shipping
costs;
FY 2004 baseline: $395,000;
Cumulative FY 2005 target: $403,000;
Long-term program goal: Increase information sharing and collaboration
among CSI and host country personnel so that the number of foreign
mitigated container exams is increased and legitimate trade is
facilitated through the port.
Measure: Implementation measures:
Measure: Cumulative number of countries with signed declarations of
principles;
Scope: This measure records the number of declarations of principles
signed with countries where CSI ports are planned;
FY 2004 baseline: 20 countries;
Cumulative FY 2005 target: 30 countries;
Long- term program goal: Not applicable.
Measure: Cumulative number of CSI ports with completed capacity
assessments;
Scope: These data will come from the number of completed pre-
operational assessments that are on file for CSI ports;
FY 2004 baseline: 43 ports;
Cumulative FY 2005 target: 51 ports;
Long-term program goal: Not applicable.
Measure: Number of CSI ports with completed infrastructures;
Scope: This measure records the engineering statements of work that
have been completed for candidate CSI ports;
FY 2004 baseline: 28 ports;
Cumulative FY 2005 target: 38 ports;
Long-term program goal: Not applicable.
Measure: Number of CSI ports transitioned to permanent status;
Scope: This measure keeps track of the number of ports where CSI
operations have been transitioned from temporarily assigned staff to
permanent staff;
FY 2004 baseline: 2 ports;
Cumulative FY 2005 target: 15 ports;
Long-term program goal: Not applicable.
Source: CBP.
[End of table]
[End of section]
Appendix III: Comments from the Department of Homeland Security:
[See PDF for image]
[End of figure]
[End of section]
Appendix IV: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Richard M. Stana (202) 512-8777;
Stephen L. Caldwell (202) 512-9610:
Staff Acknowledgments:
In addition to those named above, Mark Abraham, Kristy N. Brown,
Kathryn E. Godfrey, Stanley J. Kostyla, and Deena D. Richart made key
contributions to this report.
[End of section]
Related GAO Products:
Cargo Security: Partnership Program Grants Importers Reduced Scrutiny
with Limited Assurance of Improved Security. GAO-05-404 (Washington,
D.C.: March 11, 2005).
Homeland Security: Process for Reporting Lessons Learned from Seaport
Exercises Needs Further Attention. GAO-05-170 (Washington, D.C.:
January 14, 2005).
Port Security: Planning Needed to Develop and Operate Maritime Worker
Identification Card Program. GAO-05-106 (Washington, D.C.: December 10,
2004).
Maritime Security: Better Planning Needed to Help Ensure an Effective
Port Security Assessment Program. GAO-04-1062 (Washington, D.C.:
September 30, 2004).
Maritime Security: Substantial Work Remains to Translate New Planning
Requirements into Effective Port Security. GAO-04-838 (Washington,
D.C.: June 30, 2004).
Border Security: Agencies Need to Better Coordinate Their Strategies
and Operations on Federal Lands. GAO-04-590 (Washington, D.C.: June 16,
2004).
Homeland Security: Summary of Challenges Faced in Targeting Oceangoing
Cargo Containers for Inspection. GAO-04-557T (Washington, D.C.: March
31, 2004).
Rail Security: Some Actions Taken to Enhance Passenger and Freight Rail
Security, but Significant Challenges Remain. GAO-04-598T (Washington,
D.C.: March 23, 2004).
Department of Homeland Security, Bureau of Customs and Border
Protection: Required Advance Electronic Presentation of Cargo
Information. GAO-04-319R (Washington, D.C.: December 18, 2003).
Homeland Security: Preliminary Observations on Efforts to Target
Security Inspections of Cargo Containers. GAO-04-325T (Washington,
D.C.: December 16, 2003).
Posthearing Questions Related to Aviation and Port Security. GAO-04-
315R (Washington, D.C.: December 12, 2003).
Homeland Security: Risks Facing Key Border and Transportation Security
Program Need to Be Addressed. GAO-03-1083 (Washington, D.C.: September
19, 2003).
Maritime Security: Progress Made in Implementing Maritime
Transportation Security Act, but Concerns Remain. GAO-03-1155T
(Washington, D.C.: September 9, 2003).
Container Security: Expansion of Key Customs Programs Will Require
Greater Attention to Critical Success Factors. GAO-03-770 (Washington,
D.C.: July 25, 2003).
Homeland Security: Challenges Facing the Department of Homeland
Security in Balancing Its Border Security and Trade Facilitation
Missions. GAO-03-902T (Washington, D.C.: June 16, 2003).
Transportation Security: Federal Action Needed to Help Address Security
Challenges. GAO-03-843 (Washington, D.C.: June 30, 2003).
Transportation Security: Post-September 11th Initiatives and Long-Term
Challenges. GAO-03-616T (Washington, D.C.: April 1, 2003).
Border Security: Challenges in Implementing Border Technology. GAO-03-
546T (Washington, D.C.: March 12, 2003).
Customs Service: Acquisition and Deployment of Radiation Detection
Equipment. GAO-03-235T (Washington, D.C.: October 17, 2002).
Port Security: Nation Faces Formidable Challenges in Making New
Initiatives Successful. GAO-02-993T (Washington, D.C.: August 5, 2002).
FOOTNOTES
[1] Throughout this report, we use the term weapons of mass destruction
to refer to chemical, biological, radiological, or nuclear agents or
weapons. Some agencies define WMD to include large conventional
explosives as well. Another term being used almost synonymously with
WMD is weapons of mass effect, which refers to a terrorist attack that
would not explicitly fit this definition of WMD. As clearly
demonstrated by the events of September 11, a terrorist attack would
not have to fit the definition of WMD to achieve mass effect in terms
of mass casualties, destruction of critical infrastructure, economic
losses, and disruption of daily life nationwide.
[2] GAO, Container Security: Expansion of Key Customs Programs Will
Require Greater Attention to Critical Success Factors, GAO-03-770
(Washington, D.C., July 25, 2003).
[3] GAO, Homeland Security: Summary of Challenges Faced in Targeting of
Oceangoing Cargo Containers for Inspection, GAO-04-557T (Washington,
D.C., March 2004).
[4] The supply chain consists of all stages involved, directly or
indirectly, in fulfilling a customer request. These include the
manufacturer, suppliers, transporters, warehouses, retailers, and
customers. A supply chain involves the flow of information, product,
and funds between the different stages.
[5] Department of Transportation, Volpe National Transportation Systems
Center, Intermodal Cargo Transportation: Industry Best Security
Practices (Cambridge, Mass.: June 2002).
[6] Mark Gerencser, Jim Weinberg, and Don Vincent, Port Security
Wargame: Implications for U.S. Supply Chains, (Booz Allen Hamilton,
October 2002).
[7] Cargo manifest transmission requirements are located in regulations
promulgated under Section 343 of the Trade Act of 2002, Public Law 107-
210, as amended by Section 108 of the Maritime Transportation Security
Act, Public Law 107-295. Cargo manifests are composed of bills of
lading for each shipment laden on a vessel. A bill of lading includes
the name of the shipping line, importer, consignee (recipient of the
shipment), and manufacturer. The bill of lading also identifies the
commodity being shipped, the date the shipment was sent, the number of
containers used to transport the shipment, the port where the
containers were laden on the U.S.-bound vessel, and the country from
which the shipment originated.
[8] An expert system is a model that can chain together input data and
intercept queries in order to make inferences.
[9] Host government officials at one of the four CSI ports we visited
conducted physical inspections of all containers referred to them by
the CSI team.
[10] Host government officials at one of the four CSI ports we visited
also used an explosive detection device during nonintrusive inspections.
[11] U.S. Office of Management and Budget, Department of State and
International Assistance Programs, Budget of the United States
Government, Fiscal Year 2006 (Washington, D.C.: February 2005).
[12] GAO, Overseas Presence: Framework for Assessing Embassy Staff
Levels Can Support Rightsizing Initiatives, GAO-02-780 (Washington,
D.C.: July 2002).
[13] According to CBP officials, importers typically do not submit
entry-level data to CBP at the same time that manifest data are
submitted. As a result, only limited entry-level data are available at
the time of review.
[14] GAO, Homeland Security: Summary of Challenges Faced in Targeting
Oceangoing Cargo Containers for Inspection, GAO-04-557T (Washington,
D.C.: February 20, 2004).
[15] GAO-04-557T. The regulations governing submission of amended
manifest data are located in 19 CFR 4.12.
[16] GAO, Results-Oriented Government: GPRA Has Established a Solid
Foundation for Achieving Greater Results, GAO-04-38 (Washington, D.C.:
March 10, 2004).
[17] In addition to the outcome measures listed in table 4, CBP also
developed what the bureau calls information measures to gauge CBP's
progress in increasing information sharing and collaboration among CSI
and host country personnel. See appendix II for a description of these
and other CSI performance measures.
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