Cargo Container Inspections
Preliminary Observations on the Status of Efforts to Improve the Automated Targeting System Gao ID: GAO-06-591T March 30, 2006U.S. Customs and Border Protection's (CBP) Automated Targeting System (ATS)--a computerized model that CBP officers use as a decision support tool to help them target oceangoing cargo containers for inspection--is part of CBP's layered approach to securing oceangoing cargo. GAO reported in February 2004 on challenges CBP faced in targeting oceangoing cargo containers for inspection and testified before Congress in March 2004 about the findings in that report. The report and testimony outlined recommendations aimed at (1) better incorporating recognized modeling practices into CBP's targeting strategy, (2) periodically adjusting the targeting strategy to respond to findings that occur during the course of its operation, and (3) improving implementation of the targeting strategy. This statement for the record discusses preliminary observations from GAO's ongoing work related to ATS and GAO's 2004 recommendations addressing the following questions: (1) What controls does CBP have in place to provide reasonable assurance that ATS is effective at targeting oceangoing cargo containers with the highest risk of smuggled weapons of mass destruction? (2) How does CBP systematically analyze security inspection results and incorporate them into ATS? and (3) What steps has CBP taken to better implement the rest of its targeting strategy at the seaports?
CBP has not yet put key controls in place to provide reasonable assurance that ATS is effective at targeting oceangoing cargo containers with the highest risk of containing smuggled weapons of mass destruction. To provide assurance that ATS targets the highest-risk cargo containers as intended, CBP is (1) working to develop and implement performance measures related to the targeting of cargo containers, (2) planning to compare the results of its random inspections with its ATS inspection results, (3) working to develop and implement a testing and simulation environment, and (4) addressing recommendations contained in a 2005 peer review of ATS. CBP expects to begin using performance measures in June 2006 and enter the final phase of software development for its testing and simulation environment at the same time. However, to date, none of these four initiatives has been fully implemented. Thus, CBP does not yet have key internal controls in place to be reasonably confident that ATS is providing the best information to allocate resources for targeting and inspecting containers that are the highest risk and not overlook inspecting containers that pose a threat to the nation. CBP does not yet have a comprehensive, integrated system in place to analyze security inspection results and incorporate them into ATS. CBP currently adjusts ATS based on intelligence information it receives and has initiated a process to track suggestions submitted by CBP targeting officers at the seaports for modifying ATS. However, CBP has not yet implemented plans to refine ATS based on findings from routine security inspections. Without a more comprehensive feedback system, CBP is limited in refining ATS, a fact that could hinder the overall effectiveness of the targeting strategy. CBP has taken steps to improve implementation of the targeting strategy at the seaports. It has implemented a testing and certification process for its officers who complete the Sea Cargo Targeting Course that should provide better assurance of effective targeting practices. CBP has also made a good faith effort to address longshoremen's safety concerns regarding radiation emitted by nonintrusive inspection equipment by taking actions such as working with longshoremen's unions and other maritime organization to develop public radiation tests on the nonintrusive inspection equipment. Nevertheless, CBP has not been able to persuade one longshoremen's union to permit changes in the procedure for staging containers to increase inspection efficiency at some West Coast seaports where the union's members work.
GAO-06-591T, Cargo Container Inspections: Preliminary Observations on the Status of Efforts to Improve the Automated Targeting System
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Statement for the Record to the Permanent Subcommittee on
Investigations, Committee on Homeland Security and Governmental
Affairs, U.S. Senate:
United States Government Accountability Office:
GAO:
For Release on Delivery Expected at 9:30 a.m. EST:
Thursday, March 30, 2006:
Cargo Container Inspections:
Preliminary Observations on the Status of Efforts to Improve the
Automated Targeting System:
Statement for the Record by Richard M. Stana, Director, Homeland
Security and Justice Issues:
GAO-06-591T:
GAO Highlights:
Highlights of GAO-06-591T, a statement for the record to the Permanent
Subcommittee on Investigations, Committee on Homeland Security and
Governmental Affairs, United States Senate:
Why GAO Did This Study:
U.S. Customs and Border Protection‘s (CBP) Automated Targeting System
(ATS)”a computerized model that CBP officers use as a decision support
tool to help them target oceangoing cargo containers for inspection” is
part of CBP‘s layered approach to securing oceangoing cargo. GAO
reported in February 2004 on challenges CBP faced in targeting
oceangoing cargo containers for inspection and testified before this
subcommittee in March 2004 about the findings in that report. The
report and testimony outlined recommendations aimed at (1) better
incorporating recognized modeling practices into CBP‘s targeting
strategy, (2) periodically adjusting the targeting strategy to respond
to findings that occur during the course of its operation, and (3)
improving implementation of the targeting strategy. This statement for
the record discusses preliminary observations from GAO‘s ongoing work
related to ATS and GAO‘s 2004 recommendations addressing the following
questions:
* What controls does CBP have in place to provide reasonable assurance
that ATS is effective at targeting oceangoing cargo containers with the
highest risk of smuggled weapons of mass destruction?
* How does CBP systematically analyze security inspection results and
incorporate them into ATS?
* What steps has CBP taken to better implement the rest of its
targeting strategy at the seaports?
What GAO Found:
CBP has not yet put key controls in place to provide reasonable
assurance that ATS is effective at targeting oceangoing cargo
containers with the highest risk of containing smuggled weapons of mass
destruction. To provide assurance that ATS targets the highest-risk
cargo containers as intended, CBP is (1) working to develop and
implement performance measures related to the targeting of cargo
containers, (2) planning to compare the results of its random
inspections with its ATS inspection results, (3) working to develop and
implement a testing and simulation environment, and (4) addressing
recommendations contained in a 2005 peer review of ATS. CBP expects to
begin using performance measures in June 2006 and enter the final phase
of software development for its testing and simulation environment at
the same time. However, to date, none of these four initiatives has
been fully implemented. Thus, CBP does not yet have key internal
controls in place to be reasonably confident that ATS is providing the
best information to allocate resources for targeting and inspecting
containers that are the highest risk and not overlook inspecting
containers that pose a threat to the nation.
CBP does not yet have a comprehensive, integrated system in place to
analyze security inspection results and incorporate them into ATS. CBP
currently adjusts ATS based on intelligence information it receives and
has initiated a process to track suggestions submitted by CBP targeting
officers at the seaports for modifying ATS. However, CBP has not yet
implemented plans to refine ATS based on findings from routine security
inspections. Without a more comprehensive feedback system, CBP is
limited in refining ATS, a fact that could hinder the overall
effectiveness of the targeting strategy.
CBP has taken steps to improve implementation of the targeting strategy
at the seaports. It has implemented a testing and certification process
for its officers who complete the Sea Cargo Targeting Course that
should provide better assurance of effective targeting practices. CBP
has also made a good faith effort to address longshoremen‘s safety
concerns regarding radiation emitted by nonintrusive inspection
equipment by taking actions such as working with longshoremen‘s unions
and other maritime organization to develop public radiation tests on
the nonintrusive inspection equipment. Nevertheless, CBP has not been
able to persuade one longshoremen‘s union to permit changes in the
procedure for staging containers to increase inspection efficiency at
some West Coast seaports where the union‘s members work.
www.gao.gov/cgi-bin/getrpt?GAO-06-591T.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Richard Stana at (202)
512-8777 or stanar@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
I appreciate the opportunity to comment on our ongoing work on the U.S.
Customs and Border Protection's (CBP) Automated Targeting System (ATS)-
-a computerized model that CBP officers use as a decision support tool
to help them target oceangoing cargo containers for
inspection.[Footnote 1]
In the aftermath of the terrorist attacks of September 11, 2001, there
is heightened concern that terrorists will attempt to smuggle a weapon
of mass destruction (e.g., a nuclear, biological, or radiological
explosive device) into the United States using one of the 11 million
cargo containers that arrive at our nation's seaports. Because of the
large volume of imported containers, CBP maintains that it is unable to
physically inspect all oceangoing containers without disrupting the
flow of commerce. Thus, CBP uses a multilayered strategy for addressing
the threat posed by the movement of oceangoing containers, of which ATS
is a key component.[Footnote 2] CBP uses ATS to review documentation
and assign a risk score for all containers destined for U.S. ports. CBP
officers located at domestic ports or at 1 of the 40 foreign ports that
participate in the Container Security Initiative (CSI) then use these
scores to help them make decisions on the extent of additional
documentary review and possible physical inspection that will be
conducted at the seaport.
We previously reported in February 2004 on the challenges CBP faced in
targeting oceangoing cargo containers for inspection[Footnote 3] and
testified before this Subcommittee in March 2004 about the findings in
that report.[Footnote 4] The report and testimony outlined
recommendations aimed at (1) incorporating recognized modeling
practices into its targeting strategy, such as conducting simulated
events and initiating an external peer review,[Footnote 5] (2)
periodically adjusting the targeting strategy to respond to findings
that occur during the course of its operation, and (3) improving
implementation of the targeting strategy at domestic seaports. This
subcommittee and other congressional requesters asked that we ascertain
whether CBP had implemented the recommendations we made to improve the
targeting strategy. Our work, in response to this request, has been
under way since last October, and we expect to complete the work and
provide this subcommittee and our other requesters with a report on the
final results later this year. In this statement, I will discuss our
preliminary observations on the status of these recommendations as part
of the following questions:
* What controls does CBP have in place to provide reasonable assurance
that ATS is effective at targeting oceangoing cargo containers with the
highest risk of smuggled weapons of mass destruction?
* How does CBP systematically analyze security inspection results and
incorporate them into ATS?
* What steps has CBP taken to better implement the rest of its
targeting strategy at the seaports?
To address these questions, we interviewed CBP officials in
headquarters and visited six seaports: Baltimore, Charleston, Los
Angeles-Long Beach, Miami, New York-New Jersey, and Savannah. Because
we did not select a random sample of ports to visit, the results from
these visits cannot be generalized to ports nationwide. We also met
with CBP's contractor responsible for conducting CBP's peer review of
ATS and longshoremen's union representatives. We reviewed CBP's
policies and procedures for targeting and inspecting shipments, and its
documentation on intelligence gathering and dissemination, targeting
strategies, random inspections, training, and radiation safety as well
as its peer review report. We also examined information on officers
trained and certified in CBP's Sea Cargo Targeting Training course. We
did not independently validate the reliability of CBP's targeting
results or test the effectiveness of ATS. We conducted our work in
response to this request from October 2005 through March 2006 in
accordance with generally accepted government auditing standards.
Appendix I contains more detailed information on our scope and
methodology.
Summary:
CBP has not yet put key controls in place to provide reasonable
assurance that ATS is effective at targeting oceangoing cargo
containers with the highest risk of containing smuggled weapons of mass
destruction.[Footnote 6] To provide assurance that ATS targets the
highest-risk cargo containers as intended, CBP is (1) working to
develop and implement performance measures related to the targeting of
cargo containers, (2) planning to compare the results of its random
inspections with its ATS inspection results, (3) working to develop and
implement a testing and simulation environment, and (4) addressing
recommendations contained in a 2005 peer review of ATS. CBP expects to
begin using performance measures in June 2006 and enter the final phase
of software development for its testing and simulation environment at
the same time. However, to date, none of these four initiatives has
been fully implemented. Thus, CBP does not yet have key internal
controls in place to be reasonably confident that ATS is providing the
best information to allocate resources for targeting and inspecting
containers that are the highest risk and not overlook inspecting
containers that pose a threat to the nation.[Footnote 7]
CBP does not yet have a comprehensive, integrated system in place to
analyze security inspection results and incorporate them into ATS. An
integrated system would allow any of the various systems that CBP uses
to manage cargo inspection data to communicate with one another for the
purpose of analyzing combined data. CBP currently adjusts ATS based on
intelligence information it receives and has initiated a process to
track suggestions submitted by CBP targeting officers at the seaports
for modifying ATS. However, CBP has not yet implemented plans to refine
ATS based on findings from routine security inspections. Without a more
comprehensive feedback system, CBP is limited in refining ATS, a fact
that could hinder the overall effectiveness of the targeting strategy.
CBP has taken steps to improve implementation of the targeting strategy
at the seaports. It has implemented a testing and certification process
for its officers who complete the Sea Cargo Targeting Course that
should provide better assurance of effective targeting practices. CBP
has also made a good faith effort to address longshoremen's safety
concerns regarding radiation emitted by nonintrusive inspection
equipment by taking actions such as working with longshoremen's unions
and other maritime organization to develop public radiation tests on
the nonintrusive inspection equipment.[Footnote 8] Nevertheless, CBP
has not been able to persuade one longshoremen's union to permit
changes in the procedure for staging containers to increase inspection
efficiency at some West Coast seaports where the union's members work.
Background:
Oceangoing cargo containers have an important role in the movement of
cargo between global trading partners. Approximately 90 percent of the
world's trade is transported in cargo containers. In the United States
almost half of incoming trade (by value) arrives by containers aboard
ships. If terrorists smuggled a weapon of mass destruction into the
nation using a cargo container and detonated such a weapon at a
seaport, the incident could cause widespread death and damage to the
immediate area, perhaps shut down seaports nationwide, cost the U.S.
economy billions of dollars, and seriously hamper international trade.
The Department of Homeland Security and CBP are responsible for
addressing the threat posed by terrorist smuggling of weapons in
oceangoing containers. To carry out this responsibility, CBP uses a
layered security strategy. One key element of this strategy is ATS. CBP
uses ATS to review documentation, including electronic manifest
information submitted by the ocean carriers on all arriving shipments,
to help identify containers for additional inspection.[Footnote 9] CBP
requires the carriers to submit manifest information 24 hours prior to
a United States-bound sea container being loaded onto a vessel in a
foreign port. ATS is a complex mathematical model that uses weighted
rules that assign a risk score to each arriving shipment in a container
based on manifest information. As previously discussed, CBP officers
use these scores to help them make decisions on the extent of
documentary review or physical inspection to be conducted.
ATS is an important part of other layers in the security strategy.
Under its CSI program, CBP places staff at designated foreign seaports
to work with foreign counterparts to identify and inspect high-risk
containers for weapons of mass destruction before they are shipped to
the United States. At these foreign seaports, CBP officials use ATS to
help target shipments for inspection by foreign customs officials prior
to departing for the United States. Approximately 73 percent of cargo
containers destined for the United States originate in or go through
CSI ports.
ATS is also an important factor in the Customs-Trade Partnership
Against Terrorism (C-TPAT) program. C-TPAT is a cooperative program
linking CBP and members of the international trade community in which
private companies agree to improve the security of their supply chains
in return for a reduced likelihood that their containers will be
inspected. Specifically, C-TPAT members receive a range of benefits,
some of which could change the ATS risk characterization of their
shipments, thereby reducing the probability of extensive documentary
and physical inspection.
CBP Currently Does Not Have Reasonable Assurance That ATS Is Effective:
CBP does not yet have key controls in place to provide reasonable
assurance that ATS is effective at targeting oceangoing cargo
containers with the highest risk of containing smuggled weapons of mass
destruction. To address this shortcoming, CBP is (1) developing and
implementing performance metrics to measure the effectiveness of ATS,
(2) planning to compare the results of randomly conducted inspections
with the results of its ATS inspections, (3) developing and
implementing a simulation and testing environment, and (4) addressing
recommendations contained in a 2005 peer review. To date, none of these
control activities have been fully completed or implemented.[Footnote
10] Thus, CBP does not yet have key internal controls in place to be
reasonably certain that ATS is providing the best available information
to allocate resources for targeting and inspecting containers that are
the highest risk and thus not overlook inspecting containers that pose
a high threat to the nation.
CBP Does Not Yet Have Performance Measures to Gauge the Effectiveness
of ATS in Targeting Cargo Containers, But is Working to Develop Them:
CBP does not yet have performance measures in place to help it
determine the effectiveness of ATS at targeting oceangoing cargo
containers with the highest risk of smuggled weapons of mass
destruction. The Comptroller General's internal control standards
include the establishment and review of performance measures as one
example of a control activity to help an entity ensure it is achieving
effective results.[Footnote 11] In July 2005, CBP contracted with a
consulting firm to develop such performance metrics. CBP officials and
personnel from this consulting firm told us that the firm's personnel
analyzed shipment information in ATS over a 2-year period to obtain
additional insights into ATS's performance and to determine whether ATS
is more effective at targeting cargo containers for terrorism related
risk than a random sampling inspection approach. CBP officials told us
that the consulting firm's personnel prepared a draft of the results of
their analyses and that, as of March 21, 2006, CBP officials are
reviewing these analyses. They also said that the consulting firm's
personnel are documenting the methodology for their analyses and
related performance measures that CBP can use in the future. CBP
officials expect to receive this methodology and the performance
measures in April 2006, and told us that they expect to begin using the
measures in June 2006. CBP officials also told us that they initially
planned to have performance measures developed by August 31, 2005, but
that this process has taken longer than expected because of delays in
(1) obtaining security clearances for the consulting firm's personnel,
(2) obtaining workspace for the firm's staff, and (3) arranging for the
appropriate levels of access to CBP's information systems.
CBP Is Not Yet Using the Results of Random Inspections to Assess ATS
Effectiveness:
Currently, CBP is not using the results of its random sampling program
to assess the effectiveness of ATS. As part of its Compliance
Measurement Program, CBP plans to randomly select 30,000 shipments
based on entry information submitted by the trade community and examine
those shipments to ensure compliance with supply chain security during
fiscal year 2006.[Footnote 12]
At this time, CBP is unable to compare the examination results from its
random sampling program with its ATS inspection results, as we
recommended in our 2004, report because CBP does not yet have an
integrated, comprehensive system in place to compare multiple sets of
data--like results of random inspections with results of routine ATS
inspections that were triggered by ATS scores and other operational
circumstances. Such a comparison would allow examination of if and why
the outcomes of ATS's weighted rule sets are not consistent with the
expected outcomes possible in the universe of cargo containers, based
on sample projections. Furthermore, the Comptroller General's standards
for internal control state that information should be recorded and
communicated to management and others within the entity who need it in
a form that enables them to carry out their responsibilities.[Footnote
13]
CBP Has Not Yet Tested the Effectiveness of ATS in Targeting Cargo
Containers for Inspection but Has Plans to Do So:
Currently, CBP does not conduct simulated events (e.g., covert tests
and computer-generated simulations)--a key control activity--to test
and validate the effectiveness of ATS in targeting oceangoing cargo
containers with the highest risk of containing smuggled weapons of mass
destruction and has not yet implemented a dedicated simulation and
testing environment. Without testing and validation, CBP lacks a vital
mechanism for evaluating ATS's ability to identify high-risk
containers.
In July 2005, CBP contracted with a consulting firm to obtain
assistance in the development of a computer-generated simulation and
testing environment. CBP officials report that they have the simulation
environment infrastructure in place and have processed mock manifest
data to simulate cargo linked to terrorism in the new environment. CBP
is currently reviewing the results of this test. Further, CBP officials
told us that the consulting firm is continuing to work with CBP to
develop system requirements so that officers can effectively use the
simulation environment. CBP expects to receive the consulting firm's
final input for the simulation and testing environment by June 2006.
CBP officials said that they cannot estimate when this simulation and
testing environment will be fully operational until CBP receives the
consulting firm's final product. As with the development of performance
measures, CBP officials also told us that this process has taken longer
than expected because of delays in (1) obtaining security clearances
for the consulting firm's personnel, (2) obtaining workspace for the
firm's staff, and (3) arranging for the appropriate levels of access to
CBP's information systems.
As we reported in 2004, terrorism experts suggested that testing ATS by
covertly simulating a realistic event using probable methods of attack
would give CBP an opportunity to examine how ATS would perform in an
actual terrorist situation.[Footnote 14] CBP officials told us that
although they are considering implementing this kind of practice, they
do not currently have a program in place to conduct such tests. The
Director of CBP's Management Inspections and Integrity Assurance office
told us that in mid-April 2006, his office will be presenting a
proposal to the Acting Commissioner and other senior management to
request initiation of a program to conduct testing of the CSI program
that will include testing ATS to help ensure that it is appropriately
targeting the highest-risk cargo in the CSI program.
CBP Is Working to Address Peer Review Recommendations:
In response to our 2004 recommendation that CBP initiate an external
peer review of ATS, CBP contracted with a consulting firm to evaluate
CBP's targeting methodology and recommend improvements.[Footnote 15]
Specifically, the contractor identified strengths of the CBP targeting
methodology and compared ATS with other targeting methodologies.
However, the peer review did not evaluate the overall effectiveness of
ATS because CBP did not have the systems in place to allow the
contractor to do so.
The contractor's final report, issued in April 2005, identified many
strengths in the ATS targeting methodology, such as a very capable and
highly dedicated team and the application of a layered approach to
targeting. It also made several recommendations to improve the
targeting methodology that included control activities, such as (1) the
development of performance measures, (2) the development of a
simulation and testing environment, (3) the development and
implementation of a structured plan for continual rules enhancement,
and (4) an evaluation and determination of the effectiveness of the ATS
targeting rules, several of which reinforced the recommendations we
made in our 2004 report.[Footnote 16]
CBP issued a detailed plan, which projected delivery dates, for
responding to the recommendations made in the contractor's final
report. However, about half of these dates have not been met. For
example, CBP projected that it would have its testing and simulation
environment in place by September 30, 2005. Although CBP has been
working on this effort, the environment has not yet been implemented.
As previously discussed, CBP officials said that they cannot provide a
current estimate of when this simulation and testing environment will
be fully operational.
Although CBP Strives to Refine ATS for Intelligence Information and
Officer Feedback, It Is Not Yet Positioned to Use Inspection Results:
CBP strives to refine ATS to include intelligence information it
acquires and feedback it receives from its targeting officers at the
seaports, but it is not able to systematically adjust ATS for
inspection results. CBP does not have a comprehensive, integrated
system in place to report details on security inspections nationwide
that will allow management to analyze those inspections and refine ATS.
CBP officials said that they are developing a system that will allow
them to do so but did not know when it will be fully operational. CBP
officials cautioned that because an inspection does not identify any
contraband or a weapon of mass destruction or its components, it may
not necessarily indicate that a particular rule is not operating as
intended. They noted that terrorist incidents may happen infrequently,
and the rule therefore might operate only when weapons, materials, or
other dangerous contraband is actually shipped. However, without
analyzing and using security inspection results to adjust ATS, CBP is
limited in refining ATS, a fact that could hinder the effectiveness of
CBP's overall targeting strategy.
CBP Adjusts ATS for Targeting Cargo Containers for Inspection Based on
Intelligence:
CBP adjusts ATS's rules and weights for targeting cargo containers for
inspection in response to intelligence received on an ongoing basis.
CBP's Office of Intelligence (OINT) is responsible for acquiring,
reviewing, analyzing, and disseminating intelligence. OINT officials
told us they receive information from the intelligence community, which
includes federal agencies such as the Central Intelligence Agency and
the Federal Bureau of Investigation.[Footnote 17] According to OINT
officials, OINT disseminates information to CBP's offices at the
seaports to, among other things, support these offices' targeting
efforts related to cargo containers. For example, the targeting
officers may use information provided by OINT to search ATS for
information about shipments and containers. OINT officials said they
also disseminate information to CBP's senior management to inform them
about risks associated with cargo containers. CBP uses intelligence
information to refine its targeting of cargo containers for inspection
by incorporating the intelligence information into ATS to readily
identify containers whose manifest information may match or be similar
to data contained in the intelligence information.
CBP documentation and our observations showed that CBP headquarters
personnel incorporate intelligence information into ATS by adjusting
ATS's existing rules and weights and creating new rules and weights
that result in a higher risk score being assigned to a container whose
manifest information may match or be similar to data contained in the
intelligence information. CBP officers can also conduct queries or
create lookouts in ATS that will search all manifest data in the system
to identify those containers whose manifest information may match or be
similar to data contained in the intelligence information.[Footnote 18]
Once ATS identifies these containers, CBP officers are to then
designate these containers for inspection. When CBP receives credible
intelligence information that requires immediate action, CBP officials
also report that they can initiate a special operation to address
specific concerns identified in the intelligence data. CBP officials at
the six seaports we visited reported that they sometimes receive
intelligence information from local sources such as state and local law
enforcement. Officials at five of these seaports reported that they
will use such information to help them make decisions regarding
targeting efforts. Additionally, officials at five of the six seaports
we visited said that if the information they receive has national
implications, they will notify CBP headquarters personnel, who will
make a determination regarding potential adjustments to ATS.
CBP Targeting Officers at the Seaports Have Provided Few Suggestions
for Adjusting ATS:
In the late summer of 2005, CBP headquarters initiated a process to
formally track its targeting officers' suggestions to enhance ATS for
targeting cargo containers for inspection. Targeting officers at all
six seaports we have visited are aware of the process for providing
suggestions to CBP headquarters. According to documentation maintained
by headquarters, CBP officers at the seaports have provided few
suggestions to date.
CBP headquarters officials said that although they have received few
suggestions for modifying ATS, they do not believe this is an
indication of ATS's effectiveness. These officials stated that overall
the feedback they have received from CBP targeting officers at the
seaports related to the operation and usefulness of ATS has been
positive.
We reviewed the report CBP uses to track these suggestions and found
that since it was established, CBP headquarters has received 20
suggestions for enhancing the ATS component responsible for targeting
oceangoing cargo containers for inspection. Some of these suggestions
relate to modifying ATS's rules, while others focused on other aspects
of ATS such as enhancing the organization and presentation of ATS
screens by changing the size of an icon and the fonts or text used.
CBP Is Not Using Inspection Results to Systematically Adjust ATS, but
It Is Developing a System to Allow it to Do So:
CBP is not using inspection results to systematically adjust ATS for
targeting cargo containers for inspection because CBP does not yet have
a comprehensive, integrated system in place that can report sufficient
details for analyzing inspection results. CBP officials said that
although they can analyze inspection results on a case-by-case basis to
identify opportunities to refine ATS, such as when an inspection
results in a seizure of some type of contraband, they currently do not
have a reporting mechanism in place that will allow them to view
inspection results nationwide to identify patterns for systematically
adjusting ATS. CBP is developing the Cargo Enforcement Reporting
Tracking System (CERTS) to document, among other things, all cargo
examinations so that documentation substantiating the examinations will
be available for analysis by management to adjust ATS. CBP officials
said they will begin testing CERTS in the spring of 2006. CBP officials
told us that once testing of CERTS is complete, they will be in a
better position to estimate when CERTS can be fully implemented.
CBP officials cautioned that because an inspection does not identify
any contraband or a weapon of mass destruction or its components, it
may not necessarily indicate that a particular rule is not operating as
intended. They noted that terrorist incidents may happen infrequently
and the rule therefore might operate only when weapons, materials, or
other dangerous contraband is actually shipped. However, without using
inspection results to adjust ATS, CBP may not be targeting and
inspecting containers with the highest risk of containing smuggled
weapons of mass destruction.
CBP Has Taken Steps to Better Implement the Targeting Strategy at the
Seaports:
CBP has implemented a testing and certification process for its
officers who complete the Sea Cargo Targeting Course that should
provide better assurance of effective targeting practices. CBP has also
made a good faith effort to address longshoremen's safety concerns
regarding radiation emitted by nonintrusive inspection equipment.
Nevertheless, it has not been able to persuade one longshoremen's union
to permit changes in the procedure for staging containers to increase
inspection efficiency.
CPB Has Implemented a Testing and Certification Process for Officers
Who Target Cargo Containers for Inspection:
In our 2004 report, we recommended that CBP establish a testing and
certification process for CBP staff who complete the national targeting
training to provide reasonable assurance that they have sufficient
expertise to perform targeting work. [Footnote 19] CBP has implemented
such a testing and certification process.
CBP conducted two evaluations that assessed its targeting training
program--a job performance assessment and a job task analysis. With the
results of these evaluations, CBP concluded that a certification
component should be added to the training program and the Sea Cargo
Targeting Training course content should remain unchanged. CBP
officials then updated the course materials to encompass the inclusion
of the certification component. In October 2004, CBP began certifying
officers who successfully completed the Sea Cargo Targeting Training
course. Since the establishment of the testing and certification
component for the Sea Cargo Targeting Training course, CBP data
indicate that it has trained and certified 278 of its officers
responsible for targeting cargo as of March 24, 2006.[Footnote 20]
While CBP has conducted a job performance assessment prior to the
incorporation of a certification program for Sea Cargo Targeting
Training, it has not yet formally assessed the impact that revised
training and certification has had on officers' targeting of oceangoing
cargo containers. However, a CBP official said that CBP has recently
initiated planning efforts to begin such an evaluation and expects to
complete the evaluation in May 2006. Nevertheless, supervisory officers
from five of the six CBP offices at the seaports we visited said that
the mandatory training and certification program has been beneficial.
These supervisory officers told us that the training and certification
improves the confidence of targeters, provides the ability for officers
to improve their targeting productivity, and provides an opportunity
for officers to gain a broader perspective into the targeting
environment by examining passenger and outbound targeting.
Despite CBP Action to Address Longshoremen's Safety Concerns,
Efficiency Concerns Remain on the West Coast:
In our 2004 report,[Footnote 21] we discussed concerns that
longshoremen had regarding the safety of driving cargo containers
through the gamma ray imaging system, one type of nonintrusive
inspection equipment used to examine containers to detect potential
contraband or weapons of mass destruction. Because this equipment emits
radiation as it takes images of the inside of cargo containers, some
longshoremen expressed concerns about the health effects of this
radiation. As a result of these safety concerns, the longshoremen's
union representing West Coast longshoremen established a policy that
prevents its members from driving containers through the gamma ray
imaging system. In response, CBP altered its procedures at ports
affected by this policy. For example, at some West Coast ports, CBP
allows longshoremen to stage cargo containers away from the dock, in
rows at port terminals, so that CBP officers can then drive the gamma
ray imaging system over a group of containers.
However, this procedure can be space-intensive and time-consuming
compared to the procedure utilized at East and Gulf Coast ports,
whereby the gamma ray imaging system machinery is operated by a CBP
officer and parked in place while longshoremen drive the cargo
containers through the machinery.[Footnote 22] At other West Coast
ports, the longshoremen get out of the trucks after transporting the
cargo containers so that CBP officials can drive the gamma ray imaging
system cargo over the container. This is also time-consuming compared
to the procedure utilized at the East and Gulf Coast ports.
In response to our recommendation that CBP work with longshoremen to
address their safety concerns, CBP engaged in two efforts: (1)
establishing CBP's radiation threshold in accordance with the Nuclear
Regulatory Commission's (NRC) federal guidelines for public radiation
exposure and advertising this threshold to longshoremen through the
unions, and (2) working with longshoremen's unions and other maritime
organizations to develop public radiation tests on nonintrusive
inspection equipment. Officials from the West Coast union that
prohibits its members from driving through the gamma ray imaging system
told us that the union is satisfied with CBP efforts to operate the
gamma ray imaging system in an alternative format, to comply with the
union's policy of receiving no amount of man-made radiation. Despite
CBP efforts to assure this union that the amount of radiation emitted
by the gamma ray imaging system is within safe levels, a union
representative told us that CBP will not convince the union to change
its policy unless it eliminates radiation emission from inspection
equipment.
In closing, ATS is an integral part of CBP's layered security strategy.
A well-functioning ATS is crucial to the effective screening of cargo
containers at domestic and CSI foreign ports, as well as cargo shipped
by the trade community participating in C-TPAT. While CBP is working to
make improvements to ATS, our ongoing work indicates that it is not yet
in a position to gauge the effectiveness of ATS. We are continuing to
review CBP's plans and actions to improve ATS and will report to this
subcommittee and the other requesters later this year.
GAO Contacts and Acknowledgments:
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this statement. For further
information about this testimony, please contact me at 202-512-8777 or
at stanar@gao.gov. Debra Sebastian, Assistant Director; Chan-My J.
Battcher; Lisa L. Berardi; Wayne A. Ekblad; and Jessica A. Evans made
key contributions to this report. Additional assistance was provided by
Frances Cook, Kathryn E. Godfrey, Nancy A. Hess, Arthur L. James, Jr.,
Stanley J. Kostyla, and Vanessa R. Taylor.
[End of section]
Appendix I: Scope and Methodology:
To address each of our objectives, we met with U.S. Customs and Border
Protection (CBP) officials in headquarters and six seaports including,
Baltimore, Charleston, Los Angeles-Long Beach, Miami, New York-Newark,
and Savannah. These seaports were selected based on the number of cargo
containers arriving at the seaport and their geographic dispersion as
reported by the U.S. Department of Transportation. At these locations,
we also observed targeting and inspection operations. Because we did
not select a random, probability sample of ports to visit, the results
from these visits cannot be generalized to ports nationwide. We also
spoke with CBP's contractor responsible for conducting CBP's peer
review and longshoremen's union representatives.
To evaluate how CBP provides assurance that the Automated Targeting
System (ATS) targets the highest-risk oceangoing cargo containers for
inspection, we reviewed CBP documentation and prior GAO work on
performance measures. Additionally, we reviewed CBP's peer review
report. To gain an understanding of CBP's random sampling program, we
met with CBP officials responsible for this program and reviewed and
analyzed CBP documentation, including procedures for examining the
randomly selected shipments and documenting the results of the
inspections completed for those shipments. We did not independently
validate the reliability of CBP's targeting results.
To assess how CBP adjusts ATS to respond to findings that occur during
the course of its operational activities, we met with CBP officials
responsible for gathering and disseminating intelligence and for
incorporating intelligence into CBP's targeting operations. Further, we
reviewed CBP policies and procedures on intelligence gathering and
disseminating as well as intelligence received and resulting changes to
ATS rules and weights. We did not assess the quality of intelligence
received or the appropriateness of adjusted rules and weights. To
determine how targeting officers' feedback and inspection results are
used to adjust ATS rules and weights, we met with CBP officials
responsible for collecting and maintaining data on suggestions provided
by targeting officers and reviewed CBP data on the suggestions received
over a 7 month period. Regarding inspection results, we reviewed CBP's
policies and procedures for documenting inspection results.
Additionally, we reviewed CBP's manuals identifying the specific
details of an inspection completed and observed officers entering
inspection results into the ATS findings module during our site visits.
Further, during these visits, we discussed how CBP offices at the
seaports may use inspection results to enhance their targeting efforts.
Last, we met with CBP officials and reviewed CBP documentation on its
current and planned findings module.
To determine the status of recommendations from GAO's February 2004
report to (1) establish a testing and certification process for CBP
staff who complete the national targeting training to provide assurance
that they have sufficient expertise to perform targeting work and (2)
work with longshoremen's unions to address fully their safety concerns
so that the nonintrusive inspection equipment can be used to conduct
inspections efficiently and safely, we reviewed and analyzed data on
the number of officers trained and certified in sea cargo targeting. We
also reviewed CBP's Sea Cargo Training Manual as well as CBP
evaluations assessing the quality of its Sea Cargo Training course. We
did not assess the quality of this training. Regarding longshoremen's
union concerns, we reviewed scientific literature related to radiation
safety and the Nuclear Regulatory Commission guidelines on radiation
levels. We also spoke with longshoremen's representatives to discuss
whether CBP had addressed their concerns since we issued our 2004
report. Last, we also met with CBP's Radiation Safety Officer to gain a
further understanding of the potential risks associated with CBP's
inspection equipment and actions he took to address longshoremen's
concerns. We did not assess the appropriateness of radiation safety
levels used by CBP.
We conducted our work from October 2005 through March 2006 in
accordance with generally accepted government auditing standards.
FOOTNOTES
[1] A model is a physical, mathematical, or otherwise logical
representation of a system, entity, phenomenon, or process.
[2] In addition to ATS, CBP's multilayered strategy includes the (1)
Compliance Measurement Program, which randomly selects additional
containers to be physically examined; (2) the Container Security
Initiative, whereby CBP places staff at foreign seaports to work with
foreign counterparts to inspect high-risk containers before they are
shipped to the United States; and (3) the Customs-Trade Partnership
Against Terrorism which is a cooperative program between CBP and
members of the international trade community in which private companies
agree to improve the security of their supply chains. A supply chain
consists of all stages involved in fulfilling a customer request,
including stages conducted by manufacturers, suppliers, transporters,
retailers, and customers.
[3] GAO, Homeland Security: Challenges Remain in the Targeting of
Oceangoing Cargo Containers for Inspection, GAO-04-352SU (Washington,
D.C.: Feb. 20, 2004).
[4] GAO, Homeland Security: Summary of Challenges Faced in Targeting
Oceangoing Cargo Containers for Inspection, GAO-04-557T, (Washington,
D.C.: Mar. 31, 2004).
[5] External peer review is a process that includes an assessment of
the model by independent and qualified external peers.
[6] For purposes of this statement, when we state that CBP uses ATS to
target oceangoing cargo containers to identify weapons of mass
destruction, we are also including the different components that could
be used to create a weapon of mass destruction.
[7] Internal control is an integral component of an organization's
management that provides reasonable assurance that the following
objectives are achieved: (1) effectiveness and efficiency of
operations, (2) reliability of financial reporting, and (3) compliance
with applicable laws and regulations.
[8] Nonintrusive inspection equipment uses technology to help determine
the contents of a container without opening it.
[9] Cargo manifests are prepared by the ocean carrier to describe the
contents of a container.
[10] The Comptroller General's internal control standards state that
internal control activities help ensure that management's directives
are carried out. Further, they state that the control activities should
be effective and efficient in accomplishing the agency's control
objectives. GAO, Standards for Internal Control in the Federal
Government, GAO/AIMD-00-21.3.1, p. 11 (Washington, D.C.: November
1999).
[11] See GAO/AIMD-00-21.3.1, pps. 11 and 14.
[12] Entry information is documentation to declare items arriving in
the United States. Entry information allows CBP to determine what is
included in a shipment. Entry information provides more detail on a
container's contents than manifest information.
[13] See GAO/AIMD-00-21.3.1, p. 18.
[14] See GAO-04-352SU.
[15] See GAO-04-352SU.
[16] See GAO-04-352SU.
[17] The intelligence community is a federation of executive branch
agencies and organizations that work separately and together to conduct
intelligence activities necessary for the conduct of foreign relations
and the protection of the national security of the United States.
[18] A query is a search an individual officer creates to seek
information from ATS about shipments and containers based on specific
criteria to assist in the officer's targeting decisions. A lookout is a
query that CBP headquarters or officers at the seaports can create that
will notify all officers making targeting decisions when a shipment's
manifest data are similar to or match the search criteria. .
[19] See GAO-04-352SU.
[20] A CBP official estimated that CBP has approximately 300 officers
responsible for targeting oceangoing cargo containers. However, CBP is
currently surveying its offices to determine a more precise estimate
and will have this information available within the next month.
[21] See GAO-04-352SU.
[22] See GAO-04-352SU.
