Container Security: A Flexible Staffing Model and Minimum	 
Equipment Requirements Would Improve Overseas Targeting and	 
Inspection Efforts (26-APR-05, GAO-05-557).			 
                                                                 
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.				 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-557 					        
    ACCNO:   A22717						        
  TITLE:     Container Security: A Flexible Staffing Model and Minimum
Equipment Requirements Would Improve Overseas Targeting and	 
Inspection Efforts						 
     DATE:   04/26/2005 
  SUBJECT:   Container security 				 
	     Counterterrorism					 
	     Foreign governments				 
	     Harbors						 
	     Importing						 
	     Inspection 					 
	     International cooperation				 
	     International trade				 
	     National preparedness				 
	     Performance measures				 
	     Strategic planning 				 
	     Customs Service Automated Targeting		 
	     System						 
                                                                 
	     Customs Service Container Security 		 
	     Initiative Program 				 
                                                                 

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GAO-05-557

                 United States Government Accountability Office

GAO

                       Report to Congressional Requesters

April 2005

CONTAINER SECURITY

A Flexible Staffing Model and Minimum Equipment Requirements Would Improve
                   Overseas Targeting and Inspection Efforts

GAO-05-557

[IMG]

April 2005

CONTAINER SECURITY

A Flexible Staffing Model and Minimum Equipment Requirements Would Improve
Overseas Targeting and Inspection Efforts

  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
outcomeoriented 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.

                 United States Government Accountability Office

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

                                       1

                                      4 5

                                     17 21

26 33 33 34

  Appendix I Objectives, Scope, and Methodology 36

Objectives 36
Scope and Methodology 36
Data Reliability 37

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 44

GAO Contacts 44
Staff Acknowledgments 44

Related GAO Products 45

  Tables

Table 1: CSI Operational Seaports, as of February 2005 12
Table 2: CSI Outcome-Oriented Performance Measures 30

  Figures

Figure 1: CBP's Domestic Process for Targeting and Inspecting Cargo
Containers 9 Figure 2: Commercial Sample Image Produced by an X-ray
Imaging Machine of a Cargo Container Loaded on a Truck Trailer 10 Figure
3: CSI Process for Targeting and Inspecting Cargo Containers Overseas 15

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

This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
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copyright holder may be necessary if you wish to reproduce this material
separately.

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.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.

1Throughout 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.

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.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

2GAO, Container Security: Expansion of Key Customs Programs Will Require
Greater Attention to Critical Success Factors, GAO-03-770 (Washington,
D.C., July 25, 2003).

modeling practices in assessing the risks posed by oceangoing cargo
containers.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.

3GAO, Homeland Security: Summary of Challenges Faced in Targeting of
Oceangoing Cargo Containers for Inspection, GAO-04-557T (Washington, D.C.,
March 2004).

  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.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

5

control.

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.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

4The 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.

5Department of Transportation, Volpe National Transportation Systems
Center, Intermodal Cargo Transportation: Industry Best Security Practices
(Cambridge, Mass.: June 2002).

6Mark Gerencser, Jim Weinberg, and Don Vincent, Port Security Wargame:
Implications for U.S. Supply Chains, (Booz Allen Hamilton, October 2002).

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.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.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

7Cargo 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.

8An expert system is a model that can chain together input data and
intercept queries in order to make inferences.

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

Source: U.S. Customs and Border Protection.

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

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

                 Source: Host government customs organizations.

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

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 CSI port

Date CSI operations began at port

                Page 12 GAO-05-557 Container Security Initiative
                                                                                                                                                                                                                                                                                                                       Hong Kong                                                                                                                                                                                                                                                                                                                                                                                    
               March           March            February     The               September         Le   December             January                     February          February                 February            October Republic            March                March         May         August       August    Special     Hong  May                    May United              May            October              October             October          October             June    La   June          December         September  Gioia October South       August South         December          Port  March  Tanjung August                July                 July           Laem   August          
Canada Halifax  2002  Montreal  2002  Vancouver     2002 Netherlands Rotterdam      2002 France Havre     2002  Marseilles    2005 Germany Bremerhaven     2003  Hamburg     2003 Belgium Antwerp     2003  Zeebrugge    2004    of     Singapore  2003 Japan Yokohama  2003  Tokyo 2004  Nagoya   2004  Kobe   2004 Administrative Kong 2003 Sweden Gothenburg 2003 Kingdom Felixstowe 2003  Liverpool    2004  Southampton    2004  Thamesport    2004  Tilbury    2004 Italy Genoa 2003  Spezia 2003  Livorno     2004  Naples      2004  Tauro    2004 Korea Busan   2003 Africa Durban     2003 Malaysia Klang  2004  Pelepas   2004 Greece Piraeus 2004 Spain Algeciras 2004 Thailand Chabang   2004          
                                                                                                                                                                                                                              Singapore                                                                                Region of                                                                                                                                                                                                                                                                                                                                                                           Source:  
                                                                                                                                                                                                                                                                                                                         China                                                                                                                                                                                                                                                                                                                                                                                CBP.  

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 attaches.

      CSI Process for Targeting and Inspecting Cargo Containers Overseas