Supply Chain Security: Examinations of High-Risk Cargo at Foreign
Seaports Have Increased, but Improved Data Collection and
Performance Measures Are Needed (25-JAN-08, GAO-08-187).
Customs and Border Protection's (CBP) Container Security
Initiative (CSI) aims to identify and examine high-risk
U.S.-bound cargo at foreign seaports. GAO reported in 2003 and
2005 that CSI helped to enhance homeland security, and
recommended actions to strengthen the program. This report
updates information and assesses how CBP has (1) contributed to
strategic planning for supply chain security, (2) strengthened
CSI operations, and (3) evaluated CSI operations. To address
these issues, GAO interviewed CBP officials and reviewed CSI
evaluations and performance measures. GAO also visited selected
U.S. and CSI seaports, and met with U.S. and foreign government
officials.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-08-187
ACCNO: A80158
TITLE: Supply Chain Security: Examinations of High-Risk Cargo at
Foreign Seaports Have Increased, but Improved Data Collection and
Performance Measures Are Needed
DATE: 01/25/2008
SUBJECT: Cargo security
Container security
Homeland security
Port security
Security assessments
Security threats
Supply chain management
Weapons of mass destruction
Human capital management
Performance measures
Data collection
Data integrity
Security regulations
Strategic planning
Human capital planning
Risk assessment
Risk management
Customs Service Container Security
Initiative Program
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GAO-08-187
* [1]Results in Brief
* [2]Background
* [3]Vulnerabilities of Containers in the International Supply Ch
* [4]Efforts to Secure Containers in the International Supply Cha
* [5]Core Elements and Security Activities of CSI Program
* [6]CBP Collaborated on the DHS Strategy to Enhance Internationa
* [7]Recently Issued International Supply Chain Security Strategy
* [8]CBP Added Key Elements to the CSI Strategic Plan in Response
* [9]CBP Met Performance Goals to Expand Number of CSI Seaports a
* [10]To Strengthen CSI Operations, CBP Has Taken Steps to Address
* [11]CBP Has Increased Permanent Staffing Levels at CSI Seaports,
* [12]Level of Collaboration between U.S. and Host Customs Officia
* [13]Seaport Environment and Logistics Present Challenges to CSI
* [14]CBP Has Enhanced Its CSI Evaluations at CSI Seaports and Per
* [15]CBP Significantly Improved Its CSI Evaluations to Assess Pro
* [16]CBP Lacks a Process for Systematically Gathering Information
* [17]Host Government Examination Systems--Equipment
* [18]Host Government Examination Systems--People and
Processes
* [19]CBP's Lack of Information on Host Government Examination
Sys
* [20]CBP Made Efforts to Refine CSI Performance Measures, but Did
* [21]Conclusions
* [22]Recommendations for Executive Action
* [23]Agency Comments and Our Evaluation
* [24]Objectives
* [25]Scope and Methodology
* [26]Data Reliability
* [27]Targeting and Examining High-risk Containers
* [28]Equipment Used to Conduct Examinations of Cargo Containers
* [29]GAO Contact
* [30]Staff Acknowledgments
* [31]GAO's Mission
* [32]Obtaining Copies of GAO Reports and Testimony
* [33]Order by Mail or Phone
* [34]To Report Fraud, Waste, and Abuse in Federal Programs
* [35]Congressional Relations
* [36]Public Affairs
Report to Congressional Requesters
United States Government Accountability Office
GAO
January 2008
SUPPLY CHAIN SECURITY
Examinations of High- Risk Cargo at Foreign Seaports Have Increased, but
Improved Data Collection and Performance Measures Are Needed
GAO-08-187
Contents
Letter 1
Results in Brief 5
Background 8
CBP Collaborated on the DHS Strategy to Enhance International Supply Chain
Security, and Met Goals for CSI Expansion and Increased Container
Examination 17
To Strengthen CSI Operations, CBP Has Taken Steps to Address Human Capital
Challenges and Enhance Host Government Relations, but Operational
Challenges Remain 24
CBP Has Enhanced Its CSI Evaluations at CSI Seaports and Performance
Measures but Still Does Not Capture Critical Information about Host
Government Examination Systems 33
Conclusions 44
Recommendations for Executive Action 46
Agency Comments and Our Evaluation 46
Appendix I Objectives, Scope, and Methodology 50
Appendix II Comments from the Department of Homeland Security 54
Appendix III Container Security Initiative Seaports 58
Appendix IV CSI Activities and Equipment 61
Appendix V CSI Performance Measures 67
Appendix VI GAO Contact and Staff Acknowledgments 69
Related GAO Products 70
Tables
Table 1: Major U. S. Initiatives to Secure Oceangoing Containers 11
Table 2: 58 CSI seaports as of September 2007 58
Table 3: CSI Performance Measures 67
Figures
Figure 1: Overview of Key Participants Involved in Shipping Containers in
the International Supply Chain 9
Figure 2: Map of World with Countries Participating in CSI 13
Figure 3: CSI Targeting and Examination Activities 16
Figure 4: CBP Initiatives in the U.S. Supply Chain Security Strategy 19
Figure 5: Number of Operational CSI Seaports and Percentage of Total
U.S-bound Containers Passing Through CSI Seaports, 2002-2007 22
Figure 6: View of the Physical Layout of a Congested CSI Seaport 31
Figure 7: Stacked Containers on a Shipping Vessel at a CSI Seaport 32
Figure 8: CSI Process for Targeting and Examining High-risk Containers
Overseas 62
Figure 9: CBP Official Using Radiation Isotope Identifier Device to
Examine Container at CSI Seaport 65
Figure 10: Commercial Sample Image Produced by Nonintrusive Imaging X-ray
Equipment of a Container Loaded on a Truck Trailer 66
Abbreviations
ATS Automated Targeting System
C-TPAT Customs Trade Partnership Against Terrorism
CBP U.S. Customs and Border Protection
CSI Container Security Initiative
CSITE Container Security Initiative Team Evaluation
DHS Department of Homeland Security
DOE Department of Energy
NTCC U.S. National Targeting Center Cargo
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
January 25, 2008
The Honorable Daniel K. Inouye:
Chairman:
The Honorable Ted Stevens:
Vice Chairman:
Committee on Commerce, Science, and Transportation:
United States Senate:
The Honorable Joseph I. Lieberman:
Chairman:
The Honorable Susan M. Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Carl Levin:
Chairman:
The Honorable Norm Coleman:
Ranking Member:
Permanent Subcommittee on Investigations:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable John D. Dingell:
Chairman:
Committee on Energy and Commerce:
House of Representatives:
Oceangoing cargo containers play a vital role in the movement of cargo
between global trading partners. In fiscal year 2007, more than 10 million
oceangoing cargo containers arrived at U.S. seaports--meaning roughly
28,000 oceangoing containers arrived each day that year. The terrorist
attacks of 2001 heightened concerns about the ability of both the federal
government and companies participating in international maritime commerce
to identify and prevent weapons of mass destruction from being smuggled
inside cargo containers bound for the United States. Balancing security
concerns with the need to facilitate the free flow of commerce remains an
ongoing challenge for the public and private sectors alike. Oceangoing
cargo containers play a vital role in the movement of cargo between global
trading partners. In fiscal year 2007, more than 10 million oceangoing
cargo containers arrived at U.S. seaports--meaning roughly 28,000
oceangoing containers arrived each day that year. The terrorist attacks of
2001 heightened concerns about the ability of both the federal government
and companies participating in international maritime commerce to identify
and prevent weapons of mass destruction from being smuggled inside cargo
containers bound for the United States. Balancing security concerns with
the need to facilitate the free flow of commerce remains an ongoing
challenge for the public and private sectors alike.
In the federal government, U.S. Customs and Border Protection (CBP), part
of the Department of Homeland Security (DHS), is charged with In the
federal government, U.S. Customs and Border Protection (CBP), part of the
Department of Homeland Security (DHS), is charged with managing, securing,
and controlling the nation's border and in its capacity as the frontline
border security agency, plays a lead role in facing maritime threats. CBP
launched the Container Security Initiative (CSI) in January 2002, which
through partnerships with its foreign counterparts, is designed to help
protect global trade lanes by targeting and examining container cargo that
poses a threat as early as possible in the global supply chain. As part of
the program, foreign governments allow CBP officers to be stationed at
foreign seaports. These officers use intelligence and automated risk
assessment information to target shipments to identify those at risk of
containing weapons of mass destruction (WMD) or other terrorist
contraband. CBP and host government officials share the role of assessing
the risk of U.S.-bound container cargo leaving the seaports of countries
participating in CSI. CBP officers at the CSI seaports are responsible for
targeting high-risk cargo shipped in containers and other tasks, whereas
host government customs officials examine the high-risk cargo--when
requested by CBP--by scanning containers using various types of
nonintrusive inspection equipment, such as large-scale X-ray machines, or
by physically searching the container's contents before it travels to the
United States.
As part of its strategic plan, CBP is partnering with international trade
and security groups to develop supply chain security standards that can be
implemented by the world community. By engaging international
organizations, CBP is contributing to the development of global security
standards. Recent legislative actions intended to further enhance maritime
security also updated requirements that affect CSI. In October 2006,
Congress passed and the President signed legislation--the Security and
Accountability for Every Port Act (SAFE Port Act) ^1-- establishing a
statutory framework for CSI, which previously had been an agency
initiative not specifically required by law. The act imposed various
mandates, such as requiring CBP to take risk factors including cargo
volume into account when designating seaports as CSI participants. In
August 2007, the Implementing Recommendations of the 9/11 Commission Act
of 2007 (9/11 Act) was enacted, which requires, among other things, 100
percent scanning of U.S.-bound cargo containers by foreign seaports by
2012, with possible extensions for some ports--replacing a similar
provision in the SAFE Port Act that did not have a deadline.^2
^1 Pub. L. No. 109-347, 120 Stat. 1884 (2006).
We have previously reported on CSI's progress in meeting its strategic
goals and objectives. Our July 2003 and April 2005 reports on CSI
acknowledged the program's important role in helping to enhance homeland
security, but we also recommended actions to enhance the strategic
planning for the program, such as better defining its goals, objectives,
and performance measures. In addition, we recommended actions to
strengthen the program's management and operations, such as conducting
human capital planning (which affects CBP staffing levels at seaports) and
establishing minimum technical capability requirements for equipment used
to examine high-risk containers.^3
Recognizing the importance of the CSI program, you asked us to conduct
another review. For this report, we assessed the following issues:
o How has CBP contributed to strategic planning for supply chain
security efforts and the CSI program in particular, and what
progress has been made in achieving CSI performance goals?
o How has CBP strengthened CSI operations in response to our 2005
review and what challenges, if any, remain?
o How does CBP evaluate CSI seaport operations and assess program
performance overall, and how has this process changed over time?
To address these objectives, we met with CBP officials who have program
responsibilities for CSI, and reviewed available program data and
documentation. Specifically, to review CBP's strategic planning
initiatives, we reviewed national-level strategic planning documents and
those created for DHS, CBP, and CSI. To determine CBP's progress in
achieving its CSI program goals, we reviewed CBP's statistical data on
container cargo and CSI program activities. To learn about how CBP has
strengthened its operations, we reviewed our previous assessments of the
CSI program, and examined CBP's efforts to implement our three prior
recommendations. To assess CBP's progress, we met with CBP officials at
the U.S. National Targeting Center - Cargo (NTCC) in Virginia and three
domestic seaports in different geographical locations and representing
varying volumes of container traffic.^4 We also visited six CSI seaports
located overseas that were selected based on several factors, including
geographic and strategic significance, volume of container traffic, and
when CSI operations began at the seaport. The results from our visits to
seaports provided examples of CBP and host government operations but
cannot be generalized beyond the seaports visited because we did not use
statistical sampling techniques in selecting the seaports.
^2 Pub. L. No. 110-53, S 1701(a) 121 Stat. 266, 489-90 (2007) (amending 6
U.S.C. S 982(b)). Also, see GAO, Maritime Security: Maritime Security: The
SAFE Port Act: Status and Implementation One Year Later. [37]GAO-08-126T .
(Washington, D.C.: Oct. 30, 2007), mainly pages 31 to 35, and 44 to 48 for
more detail on the requirements included in the SAFE Port and 9/11 Acts
that affect the CSI program.
^3 GAO, Container Security: A Flexible Staffing Model and Minimum
Equipment Requirements Would Improve Overseas Targeting and Inspection
Efforts, [38]GAO-05-557 (Washington, D.C.: Apr. 26, 2005), and GAO,
Container Security: Expansion of Key Customs Programs Will Require Greater
Attention to Critical Success Factors, [39]GAO-03-770 (Washington, D.C.:
July 25, 2003).
To determine what progress CBP has made in strengthening its tools for
monitoring and measuring the progress of the CSI program, we reviewed the
performance measures presented in the CSI strategic plan against criteria
developed by the Office of Management and Budget and GAO. We also reviewed
a nonrepresentative sample of CSI team evaluations. While these documents
provided examples about program evaluation methods and CSI program
operations, and generally corroborated our seaport site visit
observations, our findings cannot be generalized to the program as a
whole. We conducted this performance audit from May 2006 through January
2008 in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives. A detailed discussion of our
scope and methodology is contained in appendix I.
^4 At the time of our engagement, we met with officials from the NTC. The
NTC was established in response to the need for proactive targeting aimed
to prevent acts of terror and to seize, deter and disrupt terrorists
and/or implements of terror. The NTC originally combined both passenger
and cargo targeting in one facility. It was later divided into the
National Targeting Center - Cargo (NTCC) and the National Targeting Center
- Passenger (NTCP). By convention, we will use NTCC in our references
since its mission is to support CBP cargo targeting operations.
Results in Brief
CBP contributed to a new strategic planning document to guide efforts to
secure the international supply chain, updated the CSI strategic plan, and
reported achieving key CSI goals by increasing both the number of CSI
locations and the proportion of total U.S.-bound containers passing
through CSI seaports. By supporting the development of the Strategy to
Enhance International Supply Chain Security that DHS was required to
produce in accordance with the SAFE Port Act, and by revising and
enhancing the strategic plan for CSI, as we had previously recommended,
CBP has contributed to overall strategic planning efforts related to
supply chain security. The supply chain security strategy, issued in July
2007, delineates the supply chain security roles, responsibilities, and
authorities of federal, state, local, and private sector entities, and
describes how CBP's portfolio of initiatives to address supply chain
security, including CSI, is coordinated throughout the supply chain. As to
achieving CSI performance goals, in fiscal year 2007, CBP reached its
targets of operating CSI in 58 foreign seaports and having 86 percent of
all U.S.-bound containers passing through CSI seaports--where, according
to CBP, there is an opportunity for the high-risk cargo to be examined at
foreign seaports before reaching the United States. These results
represent a continued increase in both of these measures of CSI
performance since CSI's inception in 2002. Also, CBP reported increases in
the number of high-risk cargo containers examined by host governments at
CSI seaports.
To strengthen CSI operations over the last 2 years, CBP has sought to
address human capital challenges and enhance relationships with host
governments participating in CSI, but operational challenges remain. Our
2005 CSI report noted that CBP had not achieved its goal of targeting all
U.S.-bound containers passing through CSI seaports for high-risk cargo
before they depart for the United States because, in part, the agency had
not been able to place enough staff at some CSI seaports. CBP has
subsequently taken steps to implement related recommendations, including
increasing overall staffing levels just above the 203 positions called for
in its staffing allocation model by, among other things, adding 125
permanent staff to CSI seaports and 15 staff to the NTCC, resulting in a
parallel increase in the volume of container cargo that is targeted.
Nevertheless, CBP continues to rely, in part, on a temporary workforce at
CSI seaports and the NTCC; has yet to determine how to optimize its
staffing resources even as the CSI program expands; and reports
difficulties in identifying sufficient numbers of qualified individuals to
hire for the program. In addition, findings from our CSI port site visits
and our review of select CSI evaluations conducted by CBP suggest that
relationships with host governments have improved over time, leading to
increased information sharing between governments and a bolstering of host
government customs and port security practices, among other things.
However, we also found that levels of collaboration between U.S. and host
government officials varied across CSI seaports and we identified hurdles
to cooperation between CSI teams and their counterparts in the host
government, such as host country legal restrictions that CBP officials
said prevent CSI teams from observing examinations. CBP also continues to
face logistical difficulties inherent in a seaport environment, often
outside of its control, such as high-risk container cargo that is
infeasible to access for examination.
CBP has enhanced how it collects data about CSI operations by
strengthening its approach to on-site evaluations of teams of CBP officers
at CSI seaports and has refined certain programwide performance measures,
but weaknesses remain in CBP's evaluation and performance measurement
efforts. Also, CBP lacks a process for systematically gathering
information on the equipment, people, and processes used by host
governments to examine U.S.-bound cargo containers identified as
high-risk. Specifically, CBP has recently improved its process for
conducting evaluations at CSI seaports by, among other things, testing the
proficiency of the CBP officers who must identify high-risk cargo, and by
introducing an electronic tool that enables CBP evaluation teams to
systematically record their evaluative data. However, evaluators do not
always use the data collection tools as intended, which makes it difficult
for CBP to ensure that evaluations are consistently carried out or that
evaluative data are reliable for management decisions. Also evaluators do
not always follow up on recommendations made in previous evaluation
reports--so CBP cannot ensure that previously identified problems have
been addressed. Also, CBP has not set minimum technical capability
criteria for equipment used at CSI seaports as we recommended in April
2005 and as required under the SAFE Port Act for CSI and the 9/11 Act for
future 100 percent scanning of U.S.-bound containers. Without such
criteria and systematically collected information on equipment, people and
processes involved in each host government's cargo, CBP does not have a
sound basis for determining the reliability of the examination systems
used at CSI seaports, which is of particular importance because only a
small fraction of U.S.-bound high-risk containers are reexamined upon
arrival in the United States. With respect to assessing CSI performance
overall, over the past 2 years, CBP has revised its performance
measurement system to provide decision makers with more accurate
indicators of the program's progress--by setting some specific performance
targets and modifying some existing measures--and to reflect CSI's
continuing maturation. However, we identified limitations with the CSI
performance measures, such as the omission of measures for a key core CSI
function, the lack of annual performance targets, and misleading or
confusing methods for calculating several performance measures. These
limitations may potentially make it difficult for CBP and DHS managers and
Congress to appropriately provide program oversight.
We are recommending that the Secretary of Homeland Security direct the
Commissioner of CBP to take actions to help ensure that the agency has the
information necessary to ensure that CSI is operating efficiently and
effectively. Specifically, we are recommending that CBP (1) strengthen
it's process for evaluating CSI teams at overseas ports by maintaining
evaluation data, ensuring evaluation teams follow procedures, and
monitoring the completions of recommendations from previous evaluations;
(2) improve, in collaboration with host government officials, the
information gathered about the host governments' examination systems to
determine their reliability and whether mitigating actions or incentives
are necessary to provide the desired level of security; and (3) enhance
CSI performance measurement processes to better assess CSI performance
overall.
We provided a draft of this report to the Department of State and DHS for
their review and comment. The Department of State did not provide written
comments but provided technical comments, which have been incorporated
into the report as appropriate. DHS provided written
comments--incorporating comments from CBP--on December 20, 2007, which are
presented in Appendix II. In its written comments, DHS and CBP concurred
with our recommendation on strengthening its process for evaluating CSI
teams at overseas locations. CBP partially concurred with our
recommendation to improve information gathered about host government
examination systems. CBP agreed on the importance of an accepted
examination process and noted it continues to take steps to address
improvements in the information gathered about host governments'
examination systems at CSI ports by working directly with host government
counterparts, through the World Customs Organization, and providing
capacity building training and technical assistance. While CBP does engage
in capacity building with some CSI host governments, it does not
systematically collect or assess information on the people, processes, or
technology used by these host governments to examine high-risk U.S.-bound
containers, and thus has limited assurance that CSI host government
examination systems can detect and identify WMD. Finally, CBP partially
concurred with our recommendation to enhance CSI performance measures to
better assess CSI performance overall. CBP stated that it believes its
current measures address core program functions of targeting and
collaboration with host governments to mitigate or substantiate the risk
of a maritime container destined for the United States. We disagree. As
discussed in this report, a core element of the CSI program, specifically
the extent to which U.S.-bound containers carrying high-risk cargo are
examined at CSI seaports, is not addressed through CBP's performance
measures.
Background
Vulnerabilities of Containers in the International Supply Chain
Seaports are critical gateways for the movement of commerce through the
international supply chain. The facilities, vessels, and infrastructure
within seaports, and the cargo passing through them, all have
vulnerabilities that terrorists could exploit. The containers carrying
goods that are shipped in oceangoing vessels are of particular concern
because they can be filled overseas at many different locations and are
transported through complex logistics networks before reaching U.S.
seaports.
In addition, transporting such a shipping container from its international
point of origin to its final destination involves many different
participants and many points of transfer. The materials in a container can
be affected not only by the manufacturer or supplier of the material being
shipped, but also by carriers who are responsible for getting the material
to a port and by personnel who load containers onto the ships. Others who
interact with the cargo or have access to the records of the goods being
shipped include, among others, exporters who make arrangements for
shipping and loading, freight consolidators who package disparate cargo
into containers, and forwarders who manage and process the information
about what is being loaded onto the ship. Figure 1 illustrates many of the
key participants and points of transfer involved from the time that a
container is loaded for shipping to its arrival at the destination seaport
and ultimately the importer.
Figure 1: Overview of Key Participants Involved in Shipping Containers in
the International Supply Chain
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 cargo throughout the supply
chain. Every time responsibility for cargo in containers changes hands
along the supply chain there is the potential for a security breach, and
thus, vulnerabilities exist that terrorists could take advantage of by
placing a WMD into a container for shipment to the United States. While
there have been no known incidents of containers being used to transport
WMDs, criminals have exploited containers for other illegal purposes, such
as smuggling weapons, people, and illicit substances, according to CBP
officials. Finally, 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 consequences of such an
attack are potentially high. In 2002, Booz Allen Hamilton sponsored a
simulated scenario in which the detonation of weapons hidden in cargo
containers shut down all U.S. seaports over a period of 12 days. The
results of the simulation estimated that the port closure could result in
a loss of $58 billion in revenue to the U. S. economy, along with
significant disruptions to the movement of trade.
Efforts to Secure Containers in the International Supply Chain
The federal government has taken many steps to secure the supply chain,
including the cargo in containers destined for the United States. While
CBP officials at domestic seaports continue efforts to identify and
examine high-risk imports arriving in containers, CBP's post-September 11
strategy also involves focusing security efforts beyond U.S. borders to
target and examine high-risk cargo before it enters U.S. seaports. CBP's
strategy is based on a layered approach of related initiatives that
attempt to focus resources on potentially risky cargo shipped in
containers while allowing other containers carrying cargo to proceed
without unduly disrupting commerce into the United States. CBP has
initiated most of these efforts, shown in table 1. However, the Department
of Energy (DOE) has led U.S. efforts to detect radiation in cargo
containers originating at foreign seaports.
Table 1: Major U. S. Initiatives to Secure Oceangoing Containers
Initiative and year
introduced Department Description
Automated Targeting DHS CBP uses this computerized decision
System, (ATS), 1995 support tool to review documentation,
(prototype) including electronic manifest
information submitted by ocean carriers
on all cargo destined for the United
States to help identify shipments
requiring additional scrutiny. ATS
utilizes complex mathematical models
with weighted rules that assign a risk
score to each shipment based on
manifested information. CBP officers
review the rule firings that support the
ATS score to help them make decisions on
the extent of documentary review or
examination to be conducted.
24-hour rule, 2002 DHS CBP generally requires ocean carriers to
electronically transmit cargo manifests
to CBP's Automated Manifest System 24
hours before the U.S.-bound cargo is
loaded onto a vessel at a foreign
seaport. Carriers and importers are to
provide information to CBP that is used
to strengthen how ATS assigns risk
scores. The cargo manifest information
is submitted by ocean carriers on all
arriving cargo shipments, and entry data
(more detailed information about the
cargo) are submitted by brokers.
Container Security DHS CSI places staff at participating
Initiative (CSI), 2002 foreign seaports to work with host
country customs officials to target and
examine high-risk cargo to be shipped in
containers for weapons of mass
destruction before they are shipped to
the United States. CBP officials
identify the high-risk containers and
request that their foreign counterparts
examine the contents of the containers.
Customs-Trade DHS CBP develops voluntary partnerships with
Partnership Against members of the international trade
Terrorism (C-TPAT), community comprised of importers;
2002 customs brokers; forwarders; air, sea,
and land carriers; and contract
logistics providers. Private companies
agree to improve the security of their
supply chains in return for various
benefits, such as a reduced likelihood
that their containers will be examined.
Megaports Initiative, DOE DOE installs radiation detection
2003 equipment at key foreign seaports,
enabling foreign government personnel to
use radiation detection equipment to
screen shipping containers entering and
leaving these seaports, regardless of
the containers' destination, for nuclear
and other radioactive material that
could be used against the United States
and its allies.
Secure Freight DHS, DOE Pilot program at selected CSI seaports
Initiative, 2007 to scan 100 percent of U.S.-bound cargo
containers for nuclear and radiological
materials overseas using integrated
examination systems that couple
nonintrusive inspection equipment and
radiation detection equipment.
Source: GAO.
Note: Cargo manifests are prepared by the ocean carrier and are composed
of bills of lading for each shipment of cargo loaded on a vessel to
describe the contents of the shipments. The bill of lading includes a
variety of other information, such as the manufacturer of the cargo and
the shipping line.
In January 2002, CBP began CSI to target container cargo at overseas
seaports so that high-risk cargo could be examined prior to departure for
the United States. More recently, Congress passed legislation affecting
the CSI program, including (1) the SAFE Port Act enacted in October 2006
that established a statutory framework for CSI and, among other things,
required a pilot program, now known as the Secure Freight Initiative, to
determine the feasibility of 100 percent scanning of U.S.-bound cargo
containers at foreign seaports; and (2) the 9/11 Act enacted in August
2007, that, among other things, requires by 2012, the scanning of all
U.S.-bound containers at foreign seaports with potential exceptions if a
seaport cannot meet that deadline.
For the CSI program, CBP officials stated that DHS expended about $138
million and $143 million, respectively for fiscal years 2006 and 2007. The
President's budget for fiscal year 2008 requested $156 million for CSI.
CSI is now operating at 58 seaports in 33 foreign countries, as shown in
figure 2. Appendix III lists the specific CSI seaports.
Figure 2: Map of World with Countries Participating in CSI
Core Elements and Security Activities of CSI Program
According to CBP, the three core elements of CSI include (1) CBP
identifying high-risk containers; (2) CBP requesting, where necessary,
that host governments examine high-risk containers before they are
shipped; and (3) host governments conducting examinations of high-risk
containers. To integrate these elements into CSI operations, CBP
negotiated and entered into bilateral, nonbinding arrangements with
foreign governments, specifying the placement of CBP officials at foreign
seaports and the exchange of information between CBP and foreign customs
administrations. To participate in CSI, a host nation must meet several
criteria developed by CBP. The host nation must utilize (a) a seaport that
has regular, direct, and substantial container traffic to seaports in the
United States; (b) customs staff with the capability of examining cargo
originating in or transiting through its country; and (c) nonintrusive
inspection equipment with gamma or X-ray capabilities and radiation
detection equipment. Additionally, each potential CSI port must indicate a
commitment to (d) establish an automated risk management system for
identifying potentially high-risk container cargo; (e) share critical
data, intelligence, and risk management information with CBP officials;
(f) conduct a seaport assessment to ascertain vulnerable links in a port's
infrastructure and commit to resolving those vulnerabilities; and (g)
maintain a program to prevent, identify, and combat breaches in employee
integrity.
As part of the arrangements with foreign governments participating in CSI,
CBP most often stations teams of CBP officers at each foreign seaport to
conduct CSI activities in collaboration with host government customs
officials. While the number of CBP officers stationed at CSI seaports
varies by location, typically a CSI team consists of (1) a CSI team
leader, who manages the team and monitors the relationship with the host
country; (2) CBP officers, who target high-risk cargo and observe (where
possible) the host government's examination of containers carrying the
cargo; (3) an intelligence research specialist, who assimilates data to
support timely and accurate targeting of containers; and (4) a special
agent responsible for CSI-related investigations at the seaport. According
to CBP, it is ideal for the CSI team to be located in close physical
proximity with host government customs counterparts to facilitate
collaboration and information sharing. However, CBP officials also stated
that the agency uses CBP officers stationed at the NTCC as needed to
support the CBP officers located at the CSI seaports. The CBP officials at
NTCC assist the CSI teams at high-volume seaports to ensure all containers
that pass through CSI seaports are targeted to identify high-risk
container cargo; carry out CSI targeting responsibilities for CSI seaports
that do not have CBP officials stationed there; and, according to CBP
officials, conduct targeting for U.S.-bound container cargo that does not
pass through CSI seaports using national sweeps to identify high-risk
container cargo.
At CSI seaports, CBP officers share responsibilities with host
governments' customs officials to target and examine high-risk container
cargo. Figure 3 describes the activities carried out by CBP officers and
host government customs officials, respectively, to target and examine
high-risk container cargo at CSI seaports.^5
^5 We selected the terms for this report based on definitions provided in
the SAFE Port Act and in consultation with CBP. Also, see appendix IV for
more details about these CSI activities.
Figure 3: CSI Targeting and Examination Activities
CBP Collaborated on the DHS Strategy to Enhance International Supply Chain
Security, and Met Goals for CSI Expansion and Increased Container Examination
CBP has undertaken strategic planning to guide efforts to secure the
international supply chain and, more specifically, to manage the CSI
program. CBP contributed to an international supply chain security
strategy DHS recently issued that builds on DHS's existing strategic
framework for maritime security. In 2006 CBP enhanced its strategic plan
for CSI by including three key elements missing from the plan's previous
iteration, and has achieved two performance goals by expanding CSI
locations and increasing the percentage of total U.S.-bound containers
that pass through CSI seaports. Concurrently, CBP reported an increase in
the number of high-risk containers examined by host governments
participating in CSI.
Recently Issued International Supply Chain Security Strategy Builds on DHS's
Existing Strategic Framework for Maritime Security
When it published the Strategy to Enhance International Supply Chain
Security in July 2007, DHS filled a gap that had existed between broad
national strategies and program-specific plans in the federal government's
strategic planning framework for maritime security. Over the last 5 years,
DHS has made progress in developing a multilayered strategic framework for
securing the maritime domain, including the international supply chain.
This framework consists of high-level national strategies, such as the
National Strategy for Maritime Security and the Maritime Commerce Security
Plan, which describe the federal government's broad approach to maritime
security. These plans are supplemented by a related hierarchy of documents
that includes the DHS strategic plan, the CBP strategic plan, and the CSI
program's own strategic plan.
Prior to July 2007, the federal government's maritime security framework
touched on many specific aspects of maritime trade and commerce, such as
how the CSI program contributes to securing containers bound for U.S.
seaports. However, it did not provide a detailed description of how
federal, state, and local authorities were to collaborate on supply chain
security specifically. In addition, Congress included a provision in the
SAFE Port Act of 2006 requiring DHS to develop a strategic plan to enhance
the security of the international supply chain. Moreover, the DHS fiscal
year 2007 appropriation act withheld $5 million from DHS until a
comprehensive strategic plan for port, cargo, and container security,
which included specific elements, had been submitted to specified
congressional committees. In response, CBP contributed to the Strategy to
Enhance the International Supply Chain Security, which DHS developed and
issued in July 2007. According to DHS, the supply chain security strategy
is not meant to replace other strategic planning documents, but seeks to
harmonize the goals of the various plans and programs into a multilayered,
unified approach that can be further developed by DHS components,
including CBP.
This new strategic planning document for supply chain security delineates
the supply chain security roles, responsibilities, and authorities of
federal, state, local, and private sector entities. The strategy seeks to
build on the current multilayered strategic framework for maritime
security by establishing an overarching framework for the secure flow of
cargo through the supply chain--from point of origin to final destination.
The strategy describes how CBP's portfolio of supply chain security
initiatives--including CSI, C-TPAT, cargo screening using ATS, the 24-hour
rule, and the use of nonintrusive inspection equipment to examine
containers--addresses the various stages in the supply chain. In addition,
the strategy provides details on how other organizations' programs or
efforts--such as DOE's Megaports initiative, which places radiation
detection equipment at foreign seaports--contribute to different aspects
of supply chain security. Figure 4 describes the major components of the
supply chain and the CBP initiatives that operate to secure them.
Figure 4: CBP Initiatives in the U.S. Supply Chain Security Strategy
CBP Added Key Elements to the CSI Strategic Plan in Response to our 2005
Recommendation
At the program level, CBP has revised its CSI strategic plan, an important
component of the DHS strategic framework described above, incorporating
three critical elements that were absent from the plan's previous
iteration. In our April 2005 report on CSI, we reported that the CSI
strategic plan lacked three of the six key elements identified by the
Government Performance and Results Act of 1993 for an agency strategic
plan, including descriptions of
1. how performance goals and measures are related to program
objectives,
2. the external factors beyond the control of CBP that could
affect the achievement of program objectives, and
3. the evaluations that CBP conducts to monitor CSI.^6
We noted that, given the importance of having an effective strategic plan
for the program, we would continue to monitor CBP's progress in refining
the plan. CBP has subsequently taken steps to address our concerns. In the
most recent version of the plan, released in August 2006, CBP included
information in three areas, as we had previously recommended. First, the
CSI strategic plan links each performance measure to the strategic goal it
supports. In addition, the plan describes how some performance measures
were designed to act as proxies for program objectives that can be
difficult to measure. Second, the CSI strategic plan also lists a variety
of external factors that have the potential to influence CSI operations,
including regional conflicts, organized crime, and changes in the
political administration of a foreign government participating in CSI.
Finally, the revised plan provides an explanation of the CSI team
evaluation process, thus addressing the third issue identified in our
April 2005 report. We discuss performance measure outcomes, other external
factors, and CBP's evaluation process in greater detail later in this
report.
CBP Met Performance Goals to Expand Number of CSI Seaports and to Increase
Proportion of Total U.S.-bound Containers Passing Through CSI Seaports
The August 2006 CSI strategic plan set specific goals for expanding the
number of seaports participating in CSI, and set targets for related
increases in the percentage of total U.S.-bound containers that pass
through CSI seaports. As of September 2007, CBP reported meeting its goals
in both of these areas. Specifically, the plan called for CBP to expand
CSI program operations from 40 to 50 seaports by the end of fiscal year
2006, and to 58 seaports by the end of fiscal year 2007 (see appendix III
for a complete list of participating seaports). Having reached its goal of
58 CSI seaports, CBP officials reported it currently does not have plans
to add other CSI seaports, as the costs associated with expanding the
program further would outweigh the potential benefits. In addition, the
plan set a performance target that by 2010, 86 percent of all U.S.-bound
container cargo was to pass through CSI seaports.^7 According to CBP, when
U.S.-bound containers pass through CSI seaports there is an opportunity
for high-risk cargo to be examined at the foreign seaport by the host
governments participating in CSI, rather than upon arriving at a U.S.
seaport. CBP reported that about 73 percent and about 80 percent of total
U.S.-bound container cargo passed through CSI seaports in fiscal years
2005 and 2006, respectively, and that it reached its 2010 goal early by
reaching approximately 86 percent by the end of fiscal year 2007. Figure 5
shows that as the number of operational CSI seaports expanded from 2002 to
2007, the proportion of total U.S.-bound container cargo passing through
CSI seaports also continued to increase.^8
^6 Pub. L. No. 103-62, 107 Stat. 285.
^7 According to CBP, the remaining 14 percent of U.S.-bound containers
that do not pass though CSI seaports are targeted by CBP officials at the
NTCC to identify high-risk container shipments, and containers would be
examined upon arrival at U.S. seaports if deemed necessary.
^8 The increase in the percentage of total U.S.-bound containers passing
through CSI seaports is not proportional to the number of CSI seaports in
the program because the volume of U.S.-bound containers varies from
seaport to seaport (and year to year). Appendix III provides details on
when specific foreign seaports began conducting CSI operations.
Figure 5: Number of Operational CSI Seaports and Percentage of Total
U.S-bound Containers Passing Through CSI Seaports, 2002-2007
In implementing the CSI program and reaching its goal of 58 operational
CSI seaports, CBP selected foreign seaports to participate in the program
in three phases. CBP officials reported using the following general
selection criteria for each phase as follows: ^9
o Most of the 23 phase I seaports were selected because they
shipped the highest volume of U.S.-bound container cargo.^10
o The 19 phase II seaports were selected based on factors such as
cargo volume, strategic threat factors and the foreign
government's level of interest in CSI.
o The 16 phase III seaports were selected using the phase II
criteria as well as diplomatic or political considerations, such
as the requests of foreign governments already participating in
CSI.
^9 According to CBP officials, due to logistics such as the time necessary
for negotiations with host governments and staffing CSI teams in foreign
countries, CSI seaports selected in phases one and two sometimes did not
begin operations until later selection phases were underway.
^10 According to CBP, phase I included three Canadian seaports at which
there was already a customs relationship with the United States.
As CBP expanded the number of CSI seaports and increased the proportion of
total U.S.-bound container cargo passing through CSI seaports, the agency
also achieved increases in security activities that occur at CSI
seaports--targeting (CBP screens container cargo with ATS to produce risk
scores and conducts additional review or research to ascertain risk
levels) and examining high-risk container cargo (host government officials
examine high-risk containers by scanning with nonintrusive inspection
equipment or by physically searching the container). As of September 2007
CBP reported fully targeting 100 percent of all U.S.-bound container cargo
to identify high-risk cargo as required by the SAFE Port Act.^11 In
addition, foreign governments participating in CSI have examined an
increasing amount of high-risk container cargo as a growing proportion of
total U.S.-bound containers pass through CSI seaports. In keeping with the
CSI program's risk-based approach, CBP currently does not request that the
host governments examine all U.S.-bound containers passing through the CSI
seaports, just those that CBP officers have determined to be high-risk. In
fiscal year 2006, the number of high-risk containers examined by host
government officials at CSI seaports increased by 77 percent from the
previous year to almost 71,000 containers. In fiscal year 2007,
examinations continued to increase, reaching almost 137,000 containers.
Moreover, in fiscal year 2007 CBP reported that host government officials
examined approximately 96 percent of the container cargo referred for
examination. CBP reported that about 4 percent of the referrals did not
lead to examinations (about 5,600 requests) because (1) logistical
difficulties arose, such as the container had already been loaded on the
shipping vessel (about 5,200 requests),or (2) the host government denied
the request (fewer than 400 requests).
^11 CBP reported that NTCC targeters assist the CSI teams at high-volume
seaports to help ensure all containers that pass through CSI seaports are
targeted.
To Strengthen CSI Operations, CBP Has Taken Steps to Address Human Capital
Challenges and Enhance Host Government Relations, but Operational Challenges
Remain
CBP has made various operational improvements to CSI, though challenges
remain. First, CBP has revised its human capital plan and added permanent
staff at CSI seaports, though it reports difficulties in hiring and
deploying qualified staff. Second, CBP's relations with CSI host
governments we spoke to that conduct cargo examinations have improved over
time, though access to key examination-related information and processes
is limited by host governments at some CSI seaports. And finally, CBP's
ability to conduct CSI program activities involves logistical challenges
that are inherent to many seaport environments, such as those that are
densely packed with equipment and personnel.
CBP Has Increased Permanent Staffing Levels at CSI Seaports, but Has Yet to
Determine Optimum Distribution of Staff to Ensure All Critical Operations Are
Performed
The ability of the CSI program to operate in accordance with its mission
and objectives depends, in part, on the success of its human capital
strategy--and CBP's ability to manage and deploy staff in a way that
ensures that critical security functions are performed. Our April 2005
report on CSI noted that although CBP's goal is to target all U.S.-bound
cargo shipped in containers at CSI seaports before they depart for the
United States, the agency had not been able to place enough officers at
some CSI seaports to do so. Specifically, CBP had developed a CSI staffing
allocation model to determine the staff needed to target container cargo.
However, at some CSI seaports CBP had been unable to staff the CSI teams
at the levels called for in the CSI staffing model.^12 We noted that CBP's
staffing model had not, at the time, considered whether some of the
targeting functions could be performed in the United States. We
recommended that CBP revise its staffing model to consider what functions
need to be performed at CSI seaports and what functions can be performed
in the United States, optimum levels of staff at CSI ports, and the cost
of locating CBP targeters overseas at CSI seaports instead of the United
States.
CBP has subsequently taken several steps to increase the number of CSI
officers and to implement our 2005 recommendations. For example, in
response to our concerns about staffing imbalances across seaports and
shortages at the highest-volume seaports, CBP has increased staffing
levels, bringing them closer to those called for in its staffing
model--resulting in a parallel increase in the volume of container cargo
that is targeted. Also, CBP has added 15 staff to CSI targeting duty at
the NTCC since 2005, composed of temporary and permanent officers. In
addition, in fiscal year 2007 CBP deployed an additional 125 permanent and
68 temporary officers to CSI seaports. Considering the officers at both
CSI seaports and the NTCC, as of November 2007, CBP had deployed 209 CSI
officers, which exceeds the 203 called for in the CSI staffing model. As a
result of these efforts, CBP officials told us that they had increased
their targeting of U.S.-bound container cargo from 65 percent in April
2005 to 100 percent in September 2007.
^12 CBP's staffing model calculates the number of officers required at a
CSI seaport as equal to the annual volume of containers shipped to the
United States divided by 64,350 (half the number of containers a CSI team
member should be able to target in a given year) plus or minus the level
of risk associated with that CSI seaport.
The agency also developed cost estimates for placing a mix of permanent
and temporary staff at CSI seaports (with permanent staff costing about
$330,000 per year and temporary staff about $275,000 per year) in response
to our recommendation. CBP reported that the advantages of placing
officers at CSI seaports on a permanent rather than a temporary basis
include greater opportunities for enhanced communication and coordination
with host governments, and less disruption due to fewer rotations into and
out of the country. At one CSI port that we visited, host government
customs officials told us that the presence of permanent staff facilitated
increased information sharing, which over time could lead to a decrease in
unnecessary examinations.
Despite the progress it has made, CBP continues to face staffing
challenges. CBP officials told us, for example, they continue to face
challenges in obtaining sufficient numbers of qualified officers to be
permanently deployed at CSI seaports. For example, CBP officials reported
that only 9 qualified applicants applied for 40 permanent positions at CSI
seaports. Officials told us that CSI must compete for staff with targeting
or seaport experience with other CBP programs or positions, such as C-TPAT
or other programs that operate at the NTCC. To fill open positions at CSI
seaports, CBP officials reported that in some instances officers have been
deployed who have not received all of the required training. In addition,
CBP evaluation data we reviewed showed examples of CBP officers at CSI
seaports lacking key skills, such as the ability to target proficiently or
communicate in the local language.
In addition, CBP has taken action to enhance its human capital planning
process for CSI, but has not yet included important factors in its
staffing allocation model. As we reported in 2005, one of the features of
the CSI staffing model that may contribute to staffing imbalances was its
reliance on placing officers overseas at CSI seaports. It did not consider
what functions could be done in the United States. In May 2006, in
response to our recommendations, CBP issued a human capital plan that did
not specify that CSI targeting positions be located at CSI seaports, thus
recognizing that officers could support CSI seaports from the NTCC in the
United States. CBP officers assigned to the NTCC perform many of the same
roles as officers at CSI seaports, including reviewing bills of lading.^13
CBP officers at the NTCC review bills of lading for high-volume seaports
where the placement of the number of CSI officers required to review all
bills of lading is unfeasible.^14 In addition, according to CBP officials,
CBP officers at the NTCC review bills of lading for U.S.-bound cargo from
CSI seaports where no CBP officers are stationed. Though CBP's 2006 human
capital plan generally recognizes that some CSI functions can be performed
at either a CSI seaport or at the NTCC, the staffing allocation model used
to calculate the number of targeters necessary to review bills of lading
for each CSI port does not include factors that specify where these
positions should be located.
In addition, CBP's staffing allocation model does not take into account
activities other than targeting--such as witnessing host government
examinations--that CSI officers perform at CSI seaports. According to CBP,
the agency stations as many of the total officers needed as possible at
the CSI seaports, but if the number of officers needed is higher than the
number of officers allowed by the host government or available to be
stationed in the seaport, then the remainder of the officers target from
the NTCC.^15 However, we found that CBP has still not systematically
determined the optimal number of officers that need to be physically
located on-site at CSI seaports to carry out duties that require an
overseas presence (such as coordinating with host government officials or
witnessing the examinations they conduct) as opposed to other duties that
could be performed off-site in the United States (such as reviewing bills
of lading and databases). Also, CBP's revised CSI human capital plan does
not include costs related to placing temporary staff at the NTCC and thus
does not have the data needed to conduct a cost-benefit analysis for
determining the optimal location for its CSI officers.^16 As we noted in
our 2002 report on a staffing framework for use at U.S. embassies, federal
agencies should consider factors such as cost and physical security of
foreign operations and consider options such as relocating staff to the
United States, as part of their framework for determining the right number
of staff to be placed overseas.^17 Determining optimal staffing levels is
particularly important in light of ongoing challenges CBP reports facing
to identify sufficient numbers of qualified individuals to hire for the
program, and in light of the program's recent expansion to additional
seaports around the world.
^13 Bills of lading are documents issued by carriers describing cargo in a
shipment, details of the intended voyage, and the conditions of
transportation.
^14 Host nations may limit the number of CSI personnel to less than
optimum per the CSI staffing model. According to CBP officials, since
2005, CBP has reported it is unable to staff the CSI teams at the levels
called for in the CSI staffing model because of diplomatic and practical
considerations. For example, the host government or the U.S. Department of
State can restrict the size of the CSI teams located at foreign seaports.
^15 Permanent recruitment for all overseas positions requires DHS and
State Department approval through the National Security Decision Directive
38 (NSDD38) process. The NSDD38 provides Chiefs of Mission the authority
to determine the size, composition, and mandate of personnel operating
under their authority. The NSDD38 process is required whenever a
requesting agency is establishing or abolishing an activity, and changing
the size, composition, or mandate of full-time permanent direct-hire
positions.
While CBP has taken steps to implement the recommendations from our April
2005 report, further action is needed regarding the staffing allocation
model. Specifically, as we recommended in 2005, the model should be
revised to consider (1) what functions need to be performed at CSI
seaports and what functions can be performed in the United States, (2) the
optimum levels of staff needed at CSI seaports to maximize the benefits of
targeting and examination activities in conjunction with host nation
customs officials, and (3) the cost of locating targeting positions
overseas at CSI seaports instead of in the United States.
Level of Collaboration between U.S. and Host Customs Officials Has Improved, but
Challenges Remain at Some CSI Seaports
CSI's strategic plan emphasizes the importance of CBP's continued efforts
to foster partnerships with foreign customs officials at CSI seaports to
improve CSI operations. Specifically, according to CBP headquarters
officials, when CSI teams stationed at foreign seaports develop strong
interpersonal relations with foreign government officials, it leads to
increased trust and information sharing and thus improved targeting and
examination of high-risk cargo. While the extent of cooperation across all
of the 58 CSI seaports now operating is difficult to quantify, our
observations at 6 CSI seaports and our review of select CSI team
evaluations provide examples of how collaboration can benefit the CSI
program, and conversely, how the lack thereof can hinder progress.^18
^16 The CSI human capital plan states that CBP has relied on CBP officers
on temporary duty at the NTCC for CSI duties.
^17 GAO, Overseas Presence: Framework for Assessing Embassy Staff Levels
Can Support Rightsizing Initiatives, [40]GAO-02-780 (Washington, D.C.:
July 2002).
At all 6 CSI seaports we visited, CBP officers or host government
officials told us that the relationship between the CSI team and the host
government has been positive or has improved over time. CBP and host
government officials we spoke with at all of the seaports we visited
reported that establishing trust and collegiality has led to increased
information sharing, resulting in more effective targeting and examination
of high-risk container cargo. For example, CBP officers noted instances in
which host customs officials would occasionally notify them of container
cargo they thought could be high-risk, so that CBP could take a closer
look at the information available in ATS related to the container cargo.
In addition, a few CBP officers or host government officials stated that
the presence of CSI teams at foreign seaports has in many instances helped
to prevent unnecessary examinations because information provided by host
government customs officials has led to lower risk profiles for certain
container cargo.
Moreover, CBP officials reported that strengthened relationships with host
government officials and the trade community have led host governments to
bolster their customs and port security practices. CBP officials we spoke
to emphasized that, like the United States, most foreign customs
administrations have traditionally focused on revenue collection and the
seizure of contraband, rather than security concerns. During our visits to
CSI seaports, the CBP and host government officials we spoke with reported
several examples of how the presence of CSI teams at seaports has helped
to expand the focus of the efforts of these foreign customs
administrations and the trade community to include enhanced security
practices. For example, one country developed databases with trade
information to achieve its customs goals and to assist CSI after seeing
how gathering historical data benefited CBP. Furthermore, at a couple of
the CSI seaports we visited, the CSI team or host government officials
arranged outreach meetings with the trade community to raise companies'
awareness of security practices and the benefits of providing correct and
complete data about their cargo.
^18 The methods we used to evaluate CBP information in CSI team
evaluations and to observe operations at CSI seaports we visited are
described in appendix I.
During our visits to CSI seaports and our review of data CBP collected
during its evaluations of CSI teams, we also identified instances where
cooperation between CSI teams and their counterparts in the host
government could be improved--though, as CBP officials noted, some of the
factors involved are beyond CBP's ability to control directly. For
example, in some locations, CBP officials reported that a country may have
laws that hinder the collaboration of host government officials with CSI
teams. We identified the following issues during our observations at 6 CSI
seaports as well as from our review of CBP data collected in fiscal year
2007 at an additional 12 CSI seaports (for a total of 18 CSI seaports):
o At 9 CSI seaports, the CSI teams there reported that they only
interacted infrequently with their host government counterparts or
the host government officials did not readily share information
that would benefit CSI, such as knowledge about potentially
suspicious container cargo. In one instance the lack of
interaction was attributed to the host government's competing
priorities.
o At 6 CSI seaports, host governments restricted CSI teams from
viewing nonintrusive inspection equipment examinations conducted
by host customs authorities or the resulting images of the
container's contents, which is one of the key purposes for
staffing CBP officers at CSI seaports.
o At 4 CSI seaports, host governments prohibited the use of
hand-held radiation detection devices by CBP officials, which is
considered by CBP to be an important way to identify a potential
anomaly in a high-risk container. According to CBP officials, a
few of the countries prohibit the equipment due to safety and
health concerns about the use of the equipment.
o At 3 of the CSI seaports, host customs officials lacked access
to technical equipment, such as computers or nonintrusive
inspection equipment that worked properly, which CBP believes
could limit their ability to share customs-related information
with CSI team members or efficiently conduct examinations.
According to CBP officials, sometimes host governments lack
resources to meet these technological needs.
o At 6 CSI seaports in 2 countries, CBP officers at the seaport
reported that host customs administrations did not provide a
sufficient number of staff to assist CSI teams or the host
government officials were often unavailable, which, according to
CSI teams, can sometimes lead to delays in examining high-risk
containers.
o At 3 CSI seaports, there was evidence of challenges to effective
communication, such as some CSI teams having limited proficiency
in the local language.^19
These examples are not intended to represent the CSI program as a whole,
but are included to illustrate the types of challenges that CSI teams at
the seaports and CBP program managers face. CBP officials responsible for
managing the CSI program have reported that overall there has been a high
level of cooperation at CSI seaports, though they acknowledged that the
degree of involvement and participation that CBP officers have with
foreign customs officials during the examination of high-risk cargo varies
by country. It is also important to note that while CBP negotiates a
written, nonbinding arrangement stating expectations for inclusion in the
CSI program with the participating foreign governments, the agency cannot
compel foreign governments to offer information for the purposes of CSI or
to examine high-risk containers. Later in this report, we describe the
processes CBP has in place to address difficulties that may be identified
at the CSI seaports as part of its program oversight and monitoring
efforts.
Seaport Environment and Logistics Present Challenges to CSI Operations
Another factor that can affect CBP's ability to conduct CSI program
operations involves logistical challenges that are inherent to many
seaport environments. For example, as illustrated in figure 6, foreign
government officials we spoke with at CSI seaports reported that many
seaports are densely packed with equipment and personnel, which can make
it difficult for host government customs officials to examine container
cargo.
^19 According to CBP, all permanent CSI staff deployed at CSI seaports
receive some foreign language training. However, a minimum proficiency in
the language is not required.
Figure 6: View of the Physical Layout of a Congested CSI Seaport
According to CBP, open space to place scanning equipment or to conduct
physical searches of containers can be scarce at some CSI seaports. For
example, in two of the CSI locations we visited, scanning equipment and
examination sites were placed several miles from where container cargo is
unloaded, loaded, or stored. According to the CBP officials we spoke with,
this adds to the costs and time required for examination and may result in
logistical difficulties in having high-risk U.S.-bound containers examined
before being loaded onto the shipping vessel. In addition, at one port we
visited, the host government limited the number of containers it would
examine, in part to limit the cost of examination and the amount of delay
caused by moving these containers, according to the CSI team we spoke
with. CBP officials reported that despite this limit to examine no more
than 250 containers (out of the over 115,000 container cargo shipments to
the United States from this seaport in fiscal year 2007), the country has
not denied many examination requests--only two in fiscal year 2007.
However, this ceiling was not based on risk factors, and an increase in
denied requests could lead to additional containers with high-risk cargo
departing for the United States without being examined.
Finally, CBP officials stated that containers at seaports are generally
stored in a container yard before they are loaded onto the shipping
vessel. These container yards may be very large, and containers in these
yards are often stacked to minimize the time required to load container
vessels. As shown in figure 7, containers on a vessel may be stacked
several layers deep. Accordingly, CBP and host government officials we
spoke to at a few CSI seaports reported it can sometimes be challenging to
access a container for examination. CBP officials noted that any
examinations requested but not conducted in the CSI seaport would occur at
a U.S. seaport upon arrival.
Figure 7: Stacked Containers on a Shipping Vessel at a CSI Seaport
CBP Has Enhanced Its CSI Evaluations at CSI Seaports and Performance Measures
but Still Does Not Capture Critical Information about Host Government
Examination Systems
CBP has enhanced how it collects CSI data by strengthening its approach to
conducting periodic evaluations of CSI officers at CSI seaports through
on-site evaluations of performance. However, weaknesses remain in how CBP
conducts evaluations, the information collected regarding host government
examination systems, and performance measurement of the program as a
whole.^20 For example, CBP does not systematically collect information on
the equipment, people, and processes that are part of the host
government's overall examination system. Also, while CBP has refined and
updated its performance measures, we identified remaining limitations,
such as the omission of measures for all core program elements and several
performance targets.
CBP Significantly Improved Its CSI Evaluations to Assess Program Operations at
CSI Seaports, but Weaknesses Remain
CBP conducts evaluations at CSI seaports to determine the effectiveness of
the program. Specifically, CBP uses these on-site evaluations to assess
CSI team operations and capabilities, such as how well CSI team members
use ATS to determine the risk levels associated with U.S.-bound containers
passing through CSI seaports. CBP's CSI strategic plan states that these
periodic reviews are intended both to ensure that deployed CSI teams are
adhering to standard operating procedures as well as to evaluate the
relationships between the teams and the host customs administrations. In
fiscal years 2006 and 2007, CBP reported conducting 42 and 45 evaluations,
respectively. Since the program's inception in 2002, the agency reported
conducting a total of 202 evaluations.
In November 2006, CBP significantly changed the way it conducts CSI team
evaluations. Prior to that time, CBP officials reported that its
evaluators relied on self-reported information from CSI team members on
how proficiently they performed CSI program activities. CBP's current
approach to conducting CSI team evaluations seeks to provide a more
thorough review of CSI team performance. According to CBP officials, the
agency now requires the CSI team members under review to demonstrate their
targeting competence to an evaluator, such as by physically showing the
evaluator how they review information about container cargo to determine
its risk level. To better assess the deployed CSI team's performance, CBP
augmented its evaluation teams with officers who have expertise in areas
such as targeting and intelligence gathering.
^20 We use the term "examination system" to refer to the overall
equipment, people, and processes used by any country to assess goods
leaving or entering their seaports. In the context of CSI, U.S. and host
government officials share the role of assessing goods leaving the
seaports of countries participating in CSI. CSI teams at CSI seaports are
responsible for targeting high-risk containers and other tasks, whereas
host government customs officials examine containers by scanning a
container with nonintrusive inspection equipment, a physical search of the
container's contents, or both.
Also, CBP has developed a new software tool that enables evaluators to
record evaluation data electronically, using laptop computers to conduct
the on-site evaluations. This tool, CSI Team Evaluation (CSITE), consists
of a series of yes or no questions that cover the various areas of CSI
team performance, including whether all of the container cargo that the
CSI team designated high-risk were examined and whether these actions were
properly documented. The CSITE tool also provides guidance on each
question and prompts evaluators as they conduct their review by, for
example, directing them to ensure that the CSI team is using the correct
settings in ATS. In addition, employing CSITE, CBP reported it can now
aggregate the results of some or all of its evaluations, a capability it
previously lacked, and can conduct statistical analyses of the results of
the evaluations. The agency can determine, for example, what percentage of
CSI team members successfully demonstrated proficiency in targeting
high-risk containers. According to CBP officials, CSITE will eventually
allow the agency to make comparisons of CSI performance across seaports.
Moreover, CBP now retains the information it collects at CSI seaports and
the resultant evaluation reports in a more systematic fashion. CBP
officials acknowledged that the agency did not always store this data
effectively prior to the implementation of the new evaluation system and
could not provide us with documentation of all of the evaluations it had
conducted since the program's inception.
While these efforts should help to strengthen the CSI team evaluation
process, CBP is still not consistently collecting all available data to
aid in its analysis of CSI team performance, and we identified instances
in which the agency did not reconcile contradictory information it had
collected. Based on our review of CBP's documentation associated with 34
evaluations to assess the information the agency collected and its methods
for doing so, we found that evaluators do not always answer all of the
questions contained in CSITE. ^21 For example, the software tool instructs
the CBP evaluation team to collect information on whether recommendations
made in prior evaluations have been implemented. This information could
allow CBP to determine whether past problems have been addressed, but it
is not always provided by the evaluation team. We also identified
discrepancies between (a) the CSITE checklist of questions that the
evaluation team completes during the onsite evaluation, and (b) the
resulting evaluation report produced by CBP headquarters officials for 2
of the 14 locations for which we had both documents to compare. At one
seaport, for example, the CBP evaluation team indicated in the CSITE
checklist that the CSI team did not have all of the data systems it needed
to effectively target outbound shipments, whereas the evaluation report
stated the team had access to all of the appropriate targeting tools and
databases. With more complete information, collected in a consistent
manner, CBP may be better able to determine how well CSI teams are
performing, what corrective actions may be needed to improve the program,
or whether the CSI program is achieving its security goals.
CBP Lacks a Process for Systematically Gathering Information on Host Government
Examination Systems, Which Include Equipment, People, and Processes
Host Government Examination Systems--Equipment
In April 2005, we recommended that CBP establish minimum technical
criteria required for the capabilities of nonintrusive inspection
equipment at CSI seaports, while considering sovereignty issues with
participating countries. CBP agreed to evaluate the feasibility of
establishing such criteria. In 2006, section 205(e) of the SAFE Port Act
required DHS to establish minimum technical capability criteria for the
use of nonintrusive inspection equipment and nuclear and radiological
detection systems in conjunction with CSI, but noted that these criteria
should not be designed to conflict with the sovereignty of host countries.
In 2007, the 9/11 Act also required the Secretary of DHS to develop
technological standards for scanning systems that will be used to conduct
100 percent scanning at foreign seaports in the future and to ensure that
these and other actions implementing the act's 100 percent scanning
provisions do not violate international trade obligations and are
consistent with the World Customs Organization framework or other
international obligations of the United States.^22 CSI host governments,
which are responsible for conducting examinations of container cargo,
purchase and operate nonintrusive inspection equipment, though as of
November 2007, 13 CSI seaports use equipment on loan from the United
States. The capabilities of this inspection equipment vary by manufacturer
and model. The equipment may differ, for example, in its ability to
penetrate steel shielding in order to generate an image of container
contents, or may scan containers at different rates. Appendix IV describes
the capabilities of this equipment in greater detail. As of November 2007,
CBP had not yet implemented our prior recommendation or taken actions to
meet the SAFE Port and 9/11 Acts requirements for setting minimum
technical criteria. CBP officials stated that the reason for this is that
they do not consider the agency to be a standard-setting organization.
While CBP refers host governments to the World Customs Organization' SAFE
Framework regarding the procurement of inspection equipment, this document
does not include specific technical criteria or standards. Moreover, they
added that it is important to acknowledge the inherent challenges involved
in efforts to ascertain the capabilities of nonintrusive inspection
equipment that is owned and operated by CSI host governments.
^21 This sample was composed of all of the evaluations that had been
conducted using the CSITE tool at the time of our review, the evaluations
that directly preceded them chronologically (where available), and one
evaluation from each additional seaport for which we had documentation.
See appendix I for more details about our selection methodology.
In May 2005, however, CBP put forth minimum technical criteria to evaluate
the quality and performance of nonintrusive imaging inspection equipment
being considered for use at U.S. seaports.^23 These domestic standards set
baseline performance requirements for penetration, contrast sensitivity,
throughput, image quality, and scan size. To determine whether certain
types of nonintrusive inspection equipment were acceptable for use at
domestic seaports--and could meet the criteria that had been set--CBP
conducted tests comparing the capabilities of nonintrusive imaging
inspection equipment provided by seven manufacturers with its technical
operating standards. On the basis of the test results, CBP recommended the
inspection equipment from five of the seven manufacturers for use at
domestic seaports, while equipment from two manufacturers was not
recommended. CBP officials stated that there are no plans to
systematically compare the capabilities of inspection equipment at CSI
seaports against these criteria for domestic equipment due to sovereignty
concerns.
^22 This provision appears to refer to the Framework of Standards to
Secure and Facilitate Global Trade, commonly referred to as the SAFE
Framework, which was adopted by the member countries of the World Customs
Organization, including the United States, in June 2005. As of September
11, 2007, 148 member countries had signed letters of intent to implement
the SAFE Framework.
^23 There are two types of nonintrusive inspection equipment currently
used at CSI seaports: (1) radiation detection equipment and (2) imaging
inspection equipment, which may use X-rays or gamma rays. Radiation
detection equipment, such as a radiation portal monitor, detects
radioactive emissions that may originate from a container, indicating the
presence of radiological material.
CBP collects limited information on certain characteristics of the
inspection equipment installed at CSI seaports, such as manufacturer;
however, information related to capabilities and performance is not
generally obtained. Officials in CBP's Office of Technology stated that
they have information on the capabilities of equipment that the United
States loans to other countries for 16 CSI seaports, and that only this
equipment can be assured of meeting the CBP domestic requirements.
However, these CBP officials said that they had neither determined which
other CSI seaports use the inspection equipment that was assessed as part
of CBP's test and recommended for use at domestic seaports, nor
systematically determined the specific capabilities of the equipment used
at those CSI seaports. Host government officials in the countries we
visited stated that they followed their country's acquisition procedures,
which included reviewing equipment capabilities and performance, among
other things, for the purchase of nonintrusive imaging inspection
equipment. However, CBP does not have documentation on the testing used by
the host countries or the manufacturers to determine the basis for the
equipment's stated performance or whether this stated performance is less
than, meets, or exceeds the criteria CBP established for equipment used at
domestic seaports.
According to CBP officials, the capabilities of nonintrusive inspection
equipment are vetted during an assessment phase of the CSI program, when
CBP is determining whether a seaport is prepared to operate within CSI.
While, as part of the assessment phase, CSI officials stated that they
collect descriptive technical information about the type of nonintrusive
inspection equipment to be used at seaports, we did not find--in our
review of CBP's checklist used to guide its assessment teams as they
examine prospective CSI seaports--questions covering inspection equipment
other than general direction to ascertain whether some type of this
equipment was in place. Also, through our review of CBP's assessments of
10 CSI seaports--through which approximately 55 percent of all U.S.-bound
containers passed in fiscal year 2007--we did not find any assessments
that described the performance capabilities of the equipment or judgments
about the proficiency of host government officials in operating these
systems. CBP officials stated that the agency has never prohibited a
seaport from participating in CSI on the basis of its inspection
equipment, and CBP documents show that participation in the program
requires only that some type of nonintrusive inspection equipment be
available at or near the potential CSI port.
Host Government Examination Systems--People and Processes
The SAFE Port Act also directed DHS to (1) establish standard operating
procedures for the use of nonintrusive inspection equipment at CSI
seaports and (2) require CSI seaports to operate the equipment in
accordance with the criteria and operating procedures established by
DHS.^24 Also, the 9/11 Act required DHS to develop operational standards
for scanning systems that will be used to conduct 100 percent scanning at
foreign seaports in the future. CBP officials stated that they recognize
that the capabilities of nonintrusive inspection equipment are only one
element for determining the effectiveness of examinations that take place
at CSI seaports. It is better, in their view, to make assessments of the
whole examination system, which includes nonintrusive inspection
equipment, personnel, and processes. However, CBP acknowledged it does
not systematically collect information on host governments' use of
examination systems and has not developed general guidelines or criteria
that could provide CBP with the means to determine the quality of
examinations of high-risk container cargo bound for the United States. CBP
officials stated that they rely on CSI teams to notify headquarters if
they have concerns about the host government customs or examination
practices. Specifically, each CSI team leader is to meet weekly--usually
via teleconference--with a CSI manager located at CBP headquarters to
discuss ongoing CSI operations. However, CBP officials acknowledged that
equipment, capabilities, and examinations practices of host government
customs personnel are not routinely discussed.
CBP officials also reported that CSI team members witness most
examinations of high-risk U.S.-bound containers, and their presence at the
examinations would allow them to make judgments about aspects of the host
government's examination system. However some host governments
specifically prohibit CSI team members from witnessing examinations. Also
we found that CBP officials did not routinely observe inspections at one
CSI seaport we visited, and were not always able to be present for
inspections at two other CSI seaports because those inspections were
scheduled and conducted when CBP officials were not available.
^24 The act stated that the technical criteria and operating procedures
should not be designed to conflict with the sovereignty of host countries,
but it did not address host government sovereignty related to requirements
for CSI seaports to operate the equipment in accordance with the criteria
and procedures.
CBP officials told us that their CSI team evaluations are also a means of
capturing some information on various aspects of the host government's
examination system. In order to participate in CSI, CBP requires that,
among other things, host governments have customs staff capable of
examining cargo originating in or transiting through its country and
maintain a program to prevent breaches in employee integrity. However, the
15 CSI team evaluations we reviewed, which CBP had conducted since the
agency revised its evaluation process in November 2006, showed limited
coverage of whether host government customs personnel have been trained to
use nonintrusive inspection equipment or are using it properly, the
sufficiency of host staffing levels, and host government efforts to ensure
the integrity of their customs administration. Specifically, 6 of the 15
CSI team evaluations discussed whether equipment was used properly, 1
discussed host staffing levels, and none discussed host integrity
programs.
CBP's Lack of Information on Host Government Examination Systems Potentially
Limits Assurance That Examinations of High-Risk Container Cargo are Effective
CBP's lack of a systematic way to collect information on host governments'
examination systems--including their equipment, people, and
processes--potentially limits CBP's ability to ensure that examinations of
high-risk container cargo at CSI seaports can detect and identify WMD.
Without information on host governments' examination systems, CBP
management may not be able to determine the reliability of the host
government's inspections of high-risk U.S.-bound container cargo. This is
of particular concern since, according to CBP officials, most high-risk
cargo that has already been examined at a CSI seaport, is generally not
reexamined once it arrives at a U.S. seaport.^25 CBP officials stated that
if problems are found in the examination process at a CSI seaport, then
high-risk container cargo would be reexamined upon arrival in the United
States.
^25 According to CBP, containers are generally not reexamined in the
United States unless new information is provided about risks or threats
associated with the cargo, such as information related to its point of
origin or some similar factor.
As already noted, CBP must respect participating countries' sovereignty.
CBP cannot require that a country use specific equipment. However, if a
high-risk container was examined using an examination system found by CBP
to be less capable than established criteria, the agency could require
that the container be reexamined upon arrival at a U.S. seaport. CBP
officials stated that they believe that in general the equipment used by
participating governments meets or exceeds the capabilities of the
nonintrusive inspection equipment used at U.S. seaports. However, because
CBP has not set minimum technical criteria for nonintrusive inspection
equipment at CSI seaports, and the agency does not systematically review
the operations of the host government examination systems at CSI seaports,
CBP potentially has limited assurance that their inspection equipment is
capable of detecting and identifying potential WMDs. In light of the new
9/11 Act requirement that 100 percent of U.S.-bound container cargo be
scanned in the future with nonintrusive inspection equipment at foreign
seaports before leaving for the United States, it is important that CBP
have processes in place to gather the information necessary to ensure that
cargo container examinations--and the equipment used as part of the
examination process--are reliable, regardless of the point of origin.
CBP Made Efforts to Refine CSI Performance Measures, but Did Not Fully Address
our Previous Recommendation
While CBP has taken steps to strengthen performance measures for the CSI
program, we identified areas that did not fully address our April 2005
recommendation to develop outcome-based performance measures or proxy
measures of program functions--if program outcomes could not be
captured--and performance targets to track the program's progress in
meeting its objectives. Whereas CBP's CSI team evaluations and program
monitoring activities help to evaluate CSI operations at the seaport
level, CBP uses performance measures to gauge the effectiveness of the
overall program in meeting its broader strategic objectives for CSI across
seaports. By definition, performance measures are a particular value or
characteristic used to quantify a program's outputs--which describe the
products and services delivered over a period of time--or outcomes--which
describe the intended result of carrying out the program. A performance
target is a quantifiable characteristic that establishes a goal for each
measure; agencies can determine the program's progress, in part, by
comparing the program's measures against the targets. For example, the
target of one of CBP's performance measures--the "number of operational
CSI seaports"--was to have 58 CSI seaports operating in fiscal year 2007,
which the agency achieved as described previously in this report. The
Government Performance and Results Act of 1993 incorporated performance
measurement as one of its most important features, and the establishment
and review of performance measures are a key element of the standards for
internal control within the federal government.^26 As discussed in the
Government Performance and Results Act of 1993 and as we reported in 1996,
measuring performance allows organizations to track progress being made
toward specific goals and provides managers crucial information upon which
to base their organizational and management decisions.^27 In addition,
leading organizations recognize that performance measures can create
powerful incentives to influence organizational and individual behavior.
In the past 2 years, CBP has made efforts to refine and modify its
performance measures as the CSI program has matured. Since 2005, for
example, CBP has eliminated five performance measures that it had used to
track the implementation of seaports participating in CSI, measures that
CBP determined were no longer needed because CSI operations were under way
at the majority of planned CSI seaports. Also, in our April 2005 review of
CSI, we identified a CSI performance measure that was calculated
inappropriately, and in response, CBP modified how the measure was
calculated to address our concerns. Specifically, for the CSI measure that
tracks the number of container examinations waived because they are
determined to be unnecessary, CBP began excluding inappropriate data that
made the results of the performance measure misleading.^28 This was an
important modification because, as we reported in November 2002, measures
that are defined inconsistently with how they are calculated can be
confusing and create the impression that performance is better or worse
than it actually is.^29
^26 GAO, Internal Control: Standards for Internal Control in the Federal
Government. [41]GAO/AIMD-00-21 .3.1. Washington, D.C.: November1999.
^27 GAO, Executive Guide: Effectively Implementing the Government
Performance and Results Act. [42]GAO/GGD-96-118 . Washington, D.C.: June
1996.
^28 Specifically, CBP stopped including the number of container
examinations that were not conducted because the host government denied
the request or because logistical challenges prevented it. As we reported
in 2005, these are not necessarily indicators of unnecessary examinations
that were prevented.
^29 GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing
Season Performance Measures. [43]GAO-03-143 . Washington, D.C.: November
2002.
CBP has made efforts to enhance CSI performance measures, but we
identified limitations in the information available for CSI program
managers to assess the program. In the past, we and the Office of
Management and Budget have encouraged federal departments and agencies to
measure whether programs are achieving their intended outcomes, such as
CSI's purpose of protecting global trade from being exploited by
international terrorists. However, we and the Office of Management and
Budget have acknowledged the difficulty in developing outcome measures for
programs that aim to deter or prevent specific behaviors. In such an
instance, we have reported that proxy measures should be designed to
assess the effectiveness of program functions. CBP officials reported the
agency has not been able to develop a way to measure the deterrence effect
of the program, as CSI is designed to support the CBP mission to prevent
and deter terrorists and terrorist weapons from entering the United
States. Examples of CSI program functions include targeting and examining
high-risk container shipments before they are loaded on vessels bound for
the United States, and in our 2005 review of CSI we provided guidance on
an alternative method of developing proxy measures to evaluate program
performance. Further, according to the Office of Management and Budget,
proxy measures should be closely tied to the intended program outcome, and
it may be necessary to have a number of proxy measures to help ensure
sufficient safeguards are in place to account for performance results.
According to CBP officials the following three of its existing performance
measures were proxies for program outcomes.^30
(1) The percentage of worldwide U.S.-bound containers passing
through CSI seaports--since these containers are to be targeted
and, if determined high-risk, may be examined by host government
officials, this is a measure of the program goal to detect and
prevent WMDs headed to U.S. seaports from leaving foreign
seaports.
(2) The number of foreign mitigated examinations (that is,
examinations determined to be unnecessary due to information
provided by host government officials and thus waived) by
category--developed to quantify whether collocating CBP officials
at CSI seaports increases information sharing and collaboration.
(3) The number of intelligence reports based on CSI foreign
sources--intended to measure whether having CBP officials located
at foreign seaports leads to increased collaboration with foreign
customs officials.
^30 Appendix V provides more detail on the CSI performance measures
(including the three proxies for program outcomes), the associated CSI
goals, performance targets, and measured results.
The Office of Management and Budget has stated that performance measures
should capture the most important aspects of a program's mission and
priorities. However, CBP does not have a measure that tracks the extent to
which U.S.-bound containers carrying high-risk cargo are examined at CSI
seaports, despite the fact that this activity is a core element of the CSI
program.
CBP has taken other actions to address our April 2005 recommendation that
includes ways to improve CSI performance measures, but we found additional
weaknesses as well. The strategic plan demonstrated how each performance
measure corresponds to the three strategic goals of CSI, which include (1)
securing U.S. borders, (2) building a robust CSI cargo security system,
and (3) protecting and facilitating trade. This marked an improvement, as
this linkage had not been made previously. In addition, CBP addressed an
additional aspect of our prior recommendation by establishing performance
targets for four of the six CSI performance measures currently used.
However, only one measure had a target for multiple years. In addition,
since issuing the CSI strategic plan the agency has not updated its
performance targets for fiscal year 2008 or beyond for any of its
measures. Without this information about the performance targets, it may
be difficult for CBP to determine whether the results were more positive
or negative than expected.
Also, we identified a weakness in how some CSI performance measures are
calculated. As we noted earlier in this report, as the number of CSI
seaports has increased in recent years, program activities have increased
as well. However, CBP does not appropriately control for this program
growth in how it calculates three of its six performance measures. For
example, since the "number of foreign mitigated examinations by
category"--the number of container examinations determined to be
unnecessary due to information provided by host government officials--is
not calculated on a per-container basis (i.e., per 10,000 containers), it
may be difficult to determine whether fluctuation in the numbers across
years is due to (1) increased collaboration with foreign government
officials or (2) simply an increase in the number of containers reviewed
and considered for examination at the increasing number of CSI seaports.
Similarly, the number of intelligence reports and the number of
investigative cases initiated may be due to an increase in the number of
operational CSI seaports, not increased collaboration with host government
officials. Without controlling for program growth, CBP's calculation of
results for its performance measures may be misleading or confusing to CBP
and DHS program managers or the Congress, who provide program oversight.
Conclusions
Since we began reporting on the CSI program in 2003, CBP has made
significant progress in expanding and developing the program. However, CBP
continues to face several management and operational challenges, which may
limit CBP's ability to ensure that the CSI program provides the intended
level of security for U.S.-bound container cargo moving through the
international supply chain. Also, balancing security concerns with the
need to facilitate the free flow of commerce remains an ongoing challenge
for CBP.
Recognizing that program evaluation data are important for program
managers to understand why results occur and what value a program adds,
CBP has taken actions to enhance its evaluation of CSI team activities.
The revised evaluation program has increased the information available to
make policy and programmatic decisions regarding the operations at the CSI
seaports. However, limitations that remain in CBP's evaluation process
affect the accuracy and completeness of the program information available
for making sound management decisions about the CSI program as a whole.
Specifically, when CBP's evaluation teams do not complete the evaluation
tools or resolve contradictory information, program managers may receive
limited or inaccurate information. Further, when the data collected using
the CSI evaluation tool during the evaluations are not reliable and
readily available for assessment, CBP's planned programwide trend analyses
of the CSI program may be misleading.
In assessing CSI performance, CBP lacks information about a very important
aspect of the program--the overall examination systems used by the host
governments to examine high-risk cargo shipped in containers as requested
by CBP. CBP's efforts have led to the successful participation of a wide
array of foreign governments in the CSI program, and CBP has established
many cooperative relationships with its foreign partners. While we
acknowledge the agency cannot force security requirements upon foreign
governments, the lack of information systematically gathered about the
examination systems used by participating governments is problematic. Data
about the equipment, people and processes involved in the examination
system are vital for determining whether high-risk U.S.-bound containers
have been properly examined or should be examined or reexamined upon
arrival at a U.S. seaport. CBP lacks guidelines and criteria for most of
the equipment and the people and processes used by host government
examination systems--as required, in some instances, by the SAFE Port and
9/11 Acts--for evaluating CSI seaport operations and determining overall
program effectiveness. In light of the new 9/11 Act requirement that 100
percent of U.S.-bound container cargo be scanned in the future at foreign
seaports before leaving for the United States, it is important that that
CBP have programs in place to gather the information necessary to ensure
that cargo container examinations--and the equipment used as part of the
examination process--are reliable, regardless of the point of origin.
Program evaluations are just one source of information that managers need
to make decisions, and evaluation data must often be coupled with
performance measurement to assess overall program results. Measuring the
overall impact of the CSI program remains difficult due to the challenges
involved in creating effective performance measures, and because of great
difficulty in measuring the deterrent effect of the program. As we and the
Office of Management and Budget have reported, performance measurement can
be very valuable to program managers, as the process can indicate what a
program is accomplishing and whether intended results are being achieved.
Measuring program performance encourages managers to focus on the key
goals of a program and helps them by providing information on how
resources and efforts are best allocated to ensure effectiveness. Though
CBP identified performance measures it considers proxies for program
outcomes (given the difficulty in assessing the deterrent effect of CSI),
these measures do not cover a key core program function, for example a
performance measure for the number of high-risk U.S.-bound containers
examined at CSI seaports. Finally, without clearly developed performance
targets for each of its measures, program managers, Congress, and the
public lack information needed to determine the extent to which the CSI
program is performing as intended. Taken as a whole, the lack of clearly
articulated performance measures and accurate and reliable evaluative data
may hinder CBP's ability to ensure that the resources it expends for CSI
effectively achieve its goal of helping to secure U.S. borders against
terrorists and terrorist weapons.
Recommendations for Executive Action
To help ensure that CBP has the information needed to assess its
achievement of CSI program goals to help enhance supply chain
security--while at the same time balancing security concerns with the need
to facilitate the free flow of commerce--we recommend that the Secretary
of Homeland Security direct the Commissioner of U. S. Customs and Border
Protection to take the following actions in three areas:
o Strengthen CBP's process for evaluating CSI teams at overseas
ports by (a) systematically capturing and maintaining all relevant
evaluation data and documentation so that it can be used by CBP
management to guide operating decisions, monitor program
performance, and inform resource allocation decisions; (b)
ensuring that CSI evaluation teams follow established evaluation
procedures; and (c) monitoring the completion, within established
time frames, of recommendations made in previous evaluations.
o In collaboration with host government officials, improve the
information gathered about the host governments' examination
systems--which includes people, processes, and equipment--at each
CSI port by (a) establishing general guidelines and technical
criteria regarding the minimal capability and operating procedures
for an examination system that can provide CBP with a basis for
determining the reliability of examinations and related CSI
activities; (b) systematically collecting data for that purpose;
and (c) analyzing the data against the guidelines and technical
criteria to determine what, if any, mitigating actions or
incentives CBP should take to help ensure the desired level of
security.
o Enhance CSI performance measures to better assess CSI
performance overall by (a) developing measures for all core CSI
program functions designed to have a deterrent effect, (b)
establishing annual performance targets--based on explicit
assumptions--for all performance measures, and (c) revising how
performance measures are calculated to take into account CSI
program growth.
Agency Comments and Our Evaluation
We provided a draft of this report to the Department of State and the
Department of Homeland Security for their review and comment. The
Department of State did not provide written comments but provided
technical comments, which have been incorporated into the report as
appropriate. DHS provided written comments--incorporating comments from
CBP--on December 20, 2007, which are presented in Appendix II. In
commenting on a draft of this report, DHS noted that it concurred with one
recommendation and partially concurred with the remaining two
recommendations.
In its written comments, DHS and CBP concurred with our recommendation on
strengthening its process for evaluating CSI teams at overseas locations.
Specifically, CBP noted that by June 2008, it planned to establish a
database that would contain all recommendations and action plans as a
result of CSI port evaluations as well as due dates for implementing
recommendations and actions taken. To ensure that CSI evaluation teams
follow procedures, CBP indicated that it would make it mandatory that the
teams complete all database fields. Furthermore, CBP reported that it
would assign values to questions in its evaluation tool on the basis of
the criticality of the activity evaluated in each question to CSI's
mission as a whole.
DHS commented that CBP partially concurred with our second recommendation
to improve information gathered about host governments' examination
systems by (a) establishing general guidelines and technical criteria
regarding the minimal capability and operating procedures; (b)
systematically collecting data for that purpose; and (c) analyzing the
data against the guidelines and technical criteria. CBP agreed on the
importance of an accepted examination process and noted it continues to
take steps in addressing improvements in the information gathered about
host government's examination systems at CSI seaports by working directly
with host government counterparts, through the World Customs Organization,
and providing capacity building training and technical assistance. While
CBP does engage in capacity building, it does so with only 5 of the 33
countries with CSI ports. CBP also stated that it will continue to use the
WCO through its SAFE Framework of Standards to address a uniform customs
process and technical standards for equipment. However, the SAFE Framework
mentions no specific technical capability criteria for inspection
equipment. Additionally, CBP does not systematically collect or assess
information on the people, processes, or technology used by these host
governments to examine high-risk U.S.-bound containers. CBP also noted in
its comments to this report, that equipment used for inspection of
containers in foreign countries is equal to or better than the equipment
used by CBP at its domestic ports. While CBP has performance information
for the 16 seaports that have inspection equipment on loan from CBP, it is
not in a position to assess the performance of equipment used at the
remaining 42 CSI seaports. Although we repeatedly requested systematic
information regarding the equipment technical capabilities in these other
ports, CBP officials were unable to provide it to us. In response to our
2005 report, CBP stated that it would evaluate the feasibility of
technical requirements for nonintrusive inspection equipment, but a legal
issue may exist regarding CBP's ability to impose such requirements. While
we understand CBP's position, it could still gather information on such
equipment's technical capabilities. Because the CSI inspection might be
the only inspection of a container before it enters the United States, it
is important that information on the people, processes, and equipment used
as part of CSI be obtained and assessed to provide some level of assurance
of the likelihood that the examination system could detect the presence of
WMD. If a port's examination system were determined to be insufficient,
CBP could take mitigating actions, such as re-examining container cargo
upon its arrival at a domestic seaport.
Finally, DHS commented that CBP partially concurred with our third
recommendation to enhance CSI performance measures to better assess CSI
performance overall. CBP stated that it believes its current measures
address core program functions of targeting and collaboration with host
governments to mitigate or substantiate the risk of a maritime container
destined for the United States. We disagree. As discussed earlier in this
report, a core element of the CSI program, specifically the extent to
which U.S.-bound containers carrying high-risk cargo are examined at CSI
seaports, is not addressed through CBP's performance measures. In its
comments, CBP stated that its outcome performance indicator captures the
number of foreign mitigated examinations by category, however CBP did not
respond to our requests for more information regarding these categories,
including whether risk was a category. Although it considers action on
this recommendation completed, CBP noted its intention to continue to
refine, evaluate, and implement measures to track progress toward meeting
CSI objectives. As previously stated, since issuing the CSI strategic
plan, CBP has not updated its performance targets for fiscal year 2008 or
beyond for any of its measures. Thus, we believe additional action is
warranted. Establishing annual targets for performance measures is
important, as agencies can determine the program's progress, in part, by
comparing the performance measures against the targets. In addition, CBP
did not address whether it plans to reconsider how it calculates some of
its performance measures to control for CSI program growth. Without doing
so, CBP's calculation of results for its performance measures may be
misleading or confusing to CBP and DHS program managers, or the Congress,
who provide program oversight.
DHS and CBP also provided technical comments, which have been incorporated
into the report as appropriate.
If you or your staff have any questions about this report, please contact
me at (202) 512-9610 or at [44][email protected] . Key contributors to
this report are listed in appendix VI. This report will also be available
at no charge on the GAO Web site at [45]http://www.gao.gov .
Stephen L. Caldwell
Director, Homeland Security and Justice Issues
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):
o How has CBP contributed to strategic planning for supply chain
security efforts and the CSI program in particular, and what
progress has been made in achieving CSI performance goals?
o How has CBP strengthened CSI operations in response to our 2005
review, and what challenges, if any, remain?
o How does CBP evaluate CSI port operations and assess program
performance overall, and how has this process changed over time?
Scope and Methodology
To address our first objective, we reviewed the strategic plans of the
Department of Homeland Security (DHS), CBP, and CSI as well as national
strategies like the National Maritime Security Strategy and the Strategy
to Enhance International Supply Chain Security. We also analyzed the CSI
strategic plan to determine whether it includes all of the key elements
included in the Government Performance and Results Act. In addition, to
measure CSI's progress in meeting its performance goals, we reviewed and
analyzed CBP data related to the number of CSI seaports, the cargo CBP
targeted and referred to the host government to examine, and the number of
cargo containers that were (and were not) examined by host government
officials at the CSI seaports. We also met with CBP officials responsible
for managing the CSI program, from the CSI Strategic Planning and
Evaluation Branch, and from CBP's Office of Field Operations and Office of
International Affairs and Trade Relations, not only to gather information
about CSI strategic planning and performance goals, but to discuss all of
the issues within the scope of this review.
To examine CBP's efforts to enhance CSI operations and the operational
challenges that remain at CSI seaports, we reviewed GAO's previous
assessments of the CSI program and examined CBP's efforts to implement our
three prior recommendations. We also reviewed the CSI human capital plan
and spoke to CBP officials about actions the agency has taken to ensure
that CSI human resources are appropriately allocated. As part of that
process, we met with officials at CBP headquarters and at the National
Targeting Center - Cargo (NTCC) in Virginia to discuss the agency's
decision to conduct some targeting of high-risk containers from the NTCC
rather than at CSI seaports.^1 In addition, we spoke to CBP officials at
three domestic seaports, selected according to geographical location and
container volume. We also visited six CSI seaports located overseas, and
selected the locations based on geographic and strategic significance,
container volume to the United States from the seaports, when the seaports
began conducting CSI operations, and whether the seaport was involved in
CBP's Secure Freight Initiative. At the CSI seaports, we also interviewed
host government officials and CSI teams to discuss the frequency and level
of collaboration involved in their interactions with each other,
circumstances at seaport facilities that affect CSI operations, and
financial cost issues associated with examinations. The results from our
visits to seaports provided examples of CBP and host government operations
but cannot be generalized beyond the seaports visited because we did not
use statistical sampling techniques in selecting the seaports.
To determine what progress CBP has made in strengthening its tools for
monitoring and measuring the progress of the CSI program, we reviewed the
performance measures presented in the CSI strategic plan against criteria
developed by the Office of Management and Budget and GAO. In addition, to
appraise CBP's efforts to strengthen its methods to evaluate CSI teams and
to learn about operations at CSI seaports, we analyzed a sample of
evaluation documents. Our nonrepresentative sample consisted of
evaluations for all 40 seaports for which we had documentation at the time
of our review, including (1) the 15 evaluations conducted between November
2006 (when CBP revised its evaluation process and began using the
Container Security Initiative Team Evaluation software tool) and May 2007
(when we conducted our analysis), (2) the 7 available evaluations that
directly preceded them chronologically and were conducted using CBP's
previous evaluation methodology (for the purpose of comparison), and (3)
the most recent evaluations conducted at each of the additional locations
for which documentation had been provided by CBP. Thus, we reviewed a
total of 34 evaluations (covering 40 CSI seaports) out of the 114
evaluations that GAO had obtained from CBP as of May 2007. For each of the
evaluations reviewed, we assessed any available materials, which could
include a narrative report and/or a checklist of yes or no responses.
While our sample covered various aspects of CBP's evaluations, our sample
was not selected using statistical sampling techniques. Thus, the results
from our review of CBP evaluation data provide illustrative examples about
CSI team evaluation methods and program operations at CSI seaports--and
generally corroborated our seaport site visit observations--but cannot be
generalized to the all 58 seaports conducting CSI operations.
^1 In October of 2001, the U.S. Customs Service established the Office of
Border Security (OBS). In October of 2002, OBS was renamed the National
Targeting Center (NTC) and in January of 2003, was relocated to Virginia.
The NTC was established in response to the need for proactive targeting
aimed to prevent acts of terror and to seize, deter, and disrupt
terrorists and/or implements of terror. The NTC originally combined both
passenger and cargo targeting in one facility. As the NTC targeting
mission and staff expanded, it became obvious that additional facilities
were necessary. On March 26, 2007, NTC Passenger and Cargo operations were
divided. The existing NTC facility became known as the NTC - Passenger
(NTCP). The National Targeting Center - Cargo (NTCC) began operations
within the existing facility until the NTCC facility construction was
completed. On May 14, 2007, staff moved to the new NTCC facility located
approximately a mile from NTCP. The mission of the NTCC is to coordinate
and support CBP cargo targeting operations. NTCC developed enhanced
operations to proactively target and coordinate examinations of high-risk
cargo in all modes; provide high quality research and support to the
Secure freight Initiative (SFI), Container Security Initiative (CSI),
domestic CBP units, and other government agencies; implement new proactive
methodologies and expand information sharing and partnerships. Liaisons
stationed at NTCP include U.S. Coast Guard, Federal Air Marshals, Federal
Bureau of Investigation, Department of State, Transportation Security
Administration, Immigration and Customs Enforcement, and Financial Crimes
Enforcement Network. Liaisons stationed at NTCC include the Food and Drug
Administration, Department of Agriculture, and the Department of Commerce.
The liaisons provide support to both facilities as needed but are
physically located in one facility.
We also met with CBP officials managing the CSI program to assess the
agency's efforts to collect information about the equipment, people, and
processes involved in the host governments' examinations of U.S.-bound
container cargo, including the capabilities of examination equipment
operating at CSI seaports and the proficiency of host customs
administrations using the equipment. In addition, we selected and analyzed
a nonrepresentative sample of 10 port assessments among those that CBP
conducted at each port prior to its admission into the CSI program--the
sample was composed of the 6 seaports we visited plus the 4 highest-volume
locations as of January 2007. As of that date, approximately 55 percent of
containers bound for the United States passed through these 10 seaports.
Thus, our findings from our review of the assessments provide examples
about the type of information collected as part of the process, but cannot
be generalized to all 58 seaports in the program.
We conducted this performance audit from May 2006 through January 2008 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives.
Data Reliability
We met with CBP officials to discuss the agency's efforts to ensure CSI
data on the number of cargo shipments and containers subject to targeting
and examination are reliable. In our 2005 review of the program, we found
the data to be sufficiently reliable to support our findings. Since that
time, CBP has further enhanced the way in which it collects and aggregates
information about CSI program activities at foreign seaports, including
the targeting and examination of high-risk container cargo. Specifically,
CSI teams now utilize improved technology, eliminating the need for
transmitting data to CBP headquarters via e-mail and thereby reducing the
opportunity for human error in manually entering and aggregating data for
the program. CBP officials at headquarters can now directly access the
data entered at each CSI port as soon as they are entered into the shared
system and can monitor the data on a daily basis to identify errors in or
mischaracterization of the data. While we did not directly test the
reliability of 2006 data, the recent CBP initiatives to improve
reliability, combined with GAO's previous assessment of the 2005 data,
gave us confidence in using CSI targeting and examination data to provide
descriptive, background information regarding the extent to which
high-risk container cargo is targeted by CBP and examined by foreign
governments participating in CSI.
Appendix II: Comments from the Department of Homeland Security
Appendix III: Container Security Initiative Seaports
This appendix provides information on the 58 foreign seaports
participating in CBP's Container Security Initiative (CSI). According to
CBP, CSI was operating in 58 foreign seaports by the end of September
2007. Table 2 lists the CSI seaports according to the date when the
seaports began conducting CSI operations, shows the phase (I, II, or III)
in which specific seaports were selected for participation in CSI, the
volume of U.S.-bound shipments passing through the seaport in fiscal year
2007, and specifies which seaports are participating in the Department of
Energy's (DOE) Megaports Initiative and in CBP's Secure Freight
Initiative.
Table 2: 58 CSI seaports as of September 2007
Seaports
Volume of Seaports participating
U.S.-bound participating in CBP's
CBP Date port containers, in DOE's Secure
selection beganCSI fiscal year MegaPorts Freight
Seaport Country phase^a operations 2006 Initiative^c Initiative^d
1 Vancouver Canada I 2/20/2002 102,363
2 Halifax Canada I 3/25/2002 26,228
3 Montreal Canada I 3/25/2002 140,912
4 Rotterdam Netherlands I 9/2/2002 205,461 X
5 Le Havre France I 12/2/2002 84,634
6 Bremerhaven Germany I 2/2/2003 350,353
7 Hamburg Germany I 2/9/2003 74,776
8 Antwerp Belgium I 2/23/2003 189,466 X
9 Singapore Singapore I 3/10/2003 376,846 X X
10 Yokohama Japan I 3/24/2003 65,686
11 Hong Kong I 5/5/2003 1,333,812 X X
12 Gothenburg Sweden II 5/23/2003 16,256
13 Felixstowe United I 5/24/2003 75,544
Kingdom
14 Genoa Italy I 6/16/2003 104,332
15 La Spezia Italy I 6/23/2003 130,515
16 Pusan South Korea I 8/4/2003 610,061 X X
17 Durban South II 12/1/2003 18,060
Africa
18 Port Klang Malaysia II 3/8/2004 18,068
19 Tokyo Japan I 5/21/2004 166,560
20 Piraeus Greece II 7/27/2004 6,306 X
21 Algeciras Spain I 7/30/2004 38,266 X
22 Kobe Japan I 8/6/2004 87,688
23 Nagoya Japan I 8/6/2004 75,290
24 Laem Thailand I 8/13/2004 72,477 X
Chabang
25 Tanjung Malaysia II 8/16/2004 24,538
Pelepas
26 Naples Italy II 9/30/2004 20,281
27 Liverpool United II 10/19/2004 38,062
Kingdom
28 Thamesport United II 10/19/2004 20,182
Kingdom
29 Southampton United II 10/19/2004 31,780 X X
Kingdom
30 Tilbury United II 10/19/2004 5,018
Kingdom
31 Gioia Tauro Italy II 10/29/2004 51,664
32 Zeebrugge Belgium II 10/29/2004 13,202 X
33 Livorno Italy II 12/16/2004 90,073
34 Marseille France II 1/7/2005 21,142
35 Dubai United Arab II 3/26/2005 11,316 X
Emirates
36 Shanghai China I 4/12/2005 1,041,707
37 Shenzhen China I 6/24/2005 1,099,137
38 Kao-hsiung Taiwan I 7/25/2005 780,598
39 Santos Brazil II 9/21/2005 80,146
40 Colombo Sri Lanka II 9/29/2005 97,058 X
41 Buenos Argentina II 11/17/2005 27,830
Aires
42 Lisbon Portugal II 12/14/2005 12,178
43 Salalah Oman III 3/8/2006 81,333 X X
44 Puerto Honduras III 3/25/2006 77,707 X X
Cortes
45 Chi-lung Taiwan III 9/25/2006 78,150
46 Valencia Spain III 9/25/2006 64,453
47 Caucedo Dominican III 9/26/2006 24,495
Republic
48 Barcelona Spain III 9/27/2006 46,521
49 Kingston Jamaica III 9/28/2006 54,244 X
50 Freeport Bahamas III 9/29/2006 91,159 X
51 Qasim Pakistan III 4/30/2007 2,058 X X
52 Balboa Panama III 8/27/2007 26,543 X
53 Cartagena Colombia III 9/13/2007 22,081 X
54 Ashod Israel III 9/17/2007 1996 X
55 Haifa Israel III 9/25/2007 36,594 X
56 Colon Panama III 9/28/2007 56,098 X
57 Manzanillo Panama III 9/28/2007 61,767 X
58 Alexandria Egypt III 9/28/2007 4,397 X
Source: GAO presentation of CBP data.
^aCBP selected the foreign seaports in three phases, using the following
general selection criteria for each phase: Phase I included the seaports
with the highest volume of shipments to the United States, and in phases
II and III additional factors were considered, such as strategic threat
factors and diplomatic considerations.
^bAs of December 2007, these seaports are in various stages of
implementation of the Megaports Initiative, and the Department of Energy
has signed agreements to begin work and is in various stages of
implementation at seaports in additional countries as well.
^cThree CSI seaports (Puerto Cortes, Honduras; Southampton, United
Kingdom; and Qasim, Pakistan) participating in the Secure Freight
Initiative will receive integrated technology that includes existing
container scanning technology--such as X-ray and gamma ray scanners used
by host nations at CSI ports--and radiation detection equipment. The
remaining four seaports will receive more limited deployment of these
technologies as part of the pilot program.
Appendix IV: CSI Activities and Equipment
Targeting and Examining High-risk Containers
This appendix provides a detailed description of activities and equipment
used at CSI seaports to target and examine container cargo. CBP targets
all of the U.S.-bound containers that pass through CSI seaports to
identify and, where feasible, examine high-risk container cargo. The
container targeting and examination activities conducted at the foreign
seaports for U.S.-bound cargo (exports) are very similar to activities CBP
conducts at domestic seaports for arriving containers (imports). Figure 8
illustrates the various steps and decision points involved in targeting
and examining high-risk U.S.-bound containers at CSI seaports.
Figure 8: CSI Process for Targeting and Examining High-risk Containers
Overseas
Under CSI, the targeting of cargo can include the targeters' review of the
Automated Targeting System (ATS) score and the information on which it is
based, the bills of lading--which include data about the cargo--and
additional information provided by host government officials.^1 CBP
targeters at CSI seaports are to access bills of lading through ATS, a
system that automatically uses its hundreds of rules to check available
data for every container arriving in the United States and assigns a risk
score to each cargo shipment.^2 Targeters review the bill of lading,
making a cursory check for discrepancies and anomalies in the name and
address of the importer, the commodity, the cargo description and other
data elements. On the basis of the initial review of the bill of lading,
CBP officials are to either (1) categorize the cargo as low risk, in which
case, the container holding the cargo is loaded onto the departing vessel
without being examined, or (2) conduct further research in order to
properly characterize the risk level of the cargo. Further research
entails targeters using automated resources, such as the Treasury
Enforcement Communication System or AutoTrack, as well as nonautomated
resources, such as information provided by host government officials, to
obtain applicable information to determine the validity of the shipment.
Further research may also be conducted by the team's intelligence research
specialist. After further research is completed, CBP officials are to
characterize the cargo as either (1) low risk, in which case it is loaded
onto the departing vessel without being examined, or (2) high-risk, in
which case it is referred to host government officials for concurrence to
examine. Since CBP officials do not have the legal authority to examine
U.S.-bound containers in foreign seaports, the host government customs
officials conduct the examinations.
Host government officials can respond to the referrals for examination in
one of three ways--cargo is examined or the request is either waived or
denied. After receiving a referral from CSI teams, host customs officials
are to review the bill of lading and the reasons for the referrals to
determine whether or not to examine the container cargo. Some host
governments collect intelligence information on U.S.-bound cargo
independent of CSI, which host officials also consider in decisions of
whether to examine the referred cargo. If host government officials agree
that the cargo is high-risk, they will proceed with an examination.
According to CBP, in general, CSI team members are to observe the
examinations and review and document the results. On the basis of the
results of a nonintrusive examination, such as if an anomaly is apparent
in the image of the container, the host government and CBP officials must
decide whether the host government will conduct a physical examination of
the a container.
^1 Bills of lading are documents issued by a carrier describing the goods,
the details of the intended voyage, and the conditions of transportation.
^2 A risk score is derived from applicable rules that assess the level of
risk for the shipment.
Alternatively, the CSI team may waive an examination referral if (1) host
government officials provide the CSI team with additional information that
lowers the risk level of the cargo or (2) logistics prohibit an
examination, such as if the cargo container were already loaded on the
departing vessel. Finally, if the host government officials determine, on
the basis of their review, that the cargo is not high-risk, they will deny
examination of the cargo. For any high-risk cargo for which an examination
is waived or denied, CSI teams are to place a domestic hold on the cargo,
so that an examination will be conducted upon arriving in the United
States. However, if CSI team members are adamant that a cargo container
poses an imminent risk to the carrier or U.S. seaport of arrival but
cannot otherwise convince the host officials to examine the container, CSI
team members are to contact and coordinate with the NTCC 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 for national security has been implemented
six times since the inception of CSI.
Equipment Used to Conduct Examinations of Cargo Containers
There are generally two types of CSI cargo container
examinations--scanning with nonintrusive inspection equipment and physical
searches. For scanning cargo containers, there are two basic types of
nonintrusive inspection equipment currently used at CSI seaports: (1)
radiation detection equipment and (2) imaging inspection equipment, which
may use X-rays or gamma rays. Radiation detection equipment, such as a
radiation portal monitor (RPM) and radiation isotope identifier devices
(RIID) detects the presence of radioactive material that may originate
from a container. However, only the RIID can determine whether the type of
radiation emitted by the material actually poses a threat or is a normal
emission of radiation, such as that found in ceramic tile. We observed at
a domestic and a foreign seaport that generally if radioactive emissions
are detected from a cargo container, customs officials will use a RIID
(shown in fig. 9), to determine whether the radiation being emitted poses
a threat.
Figure 9: CBP Official Using Radiation Isotope Identifier Device to
Examine Container at CSI Seaport
The second type of equipment, referred to as imaging equipment, uses X-ray
or gamma ray technology to scan a container and create images of the
container's contents without opening the container. CBP officials, along
with host government officials, may review the images produced with the
X-ray or gamma ray equipment to detect anomalies that may indicate the
presence of WMD. Figure 10 shows a sample image produced by this type of
equipment.
Figure 10: Commercial Sample Image Produced by Nonintrusive Imaging X-ray
Equipment of a Container Loaded on a Truck Trailer
The capabilities of nonintrusive imaging inspection equipment vary by
manufacturer and model. In May 2005, CBP defined minimum performance
capabilities to evaluate the quality and performance of the nonintrusive
imaging inspection equipment being considered for use at domestic
seaports. The domestic standards set baseline performance requirements for
such things as the ability of nonintrusive inspection equipment to
identify images through steel shielding (referred to as penetration) or
the ability to scan an amount of containers in a given time (referred to
as throughput).
Appendix V: CSI Performance Measures
This appendix provides information on the CSI performance measures used by
CBP. Table 3 describes the performance measures CBP is currently using to
report the overall performance of the CSI program, the linkage between
performance measures and CSI goals, the performance targets established,
and the recent results collected for each measure. In addition, since our
2005 report, CBP has identified performance measures one, two and three
below as its proxy measures used in place of a measure for program
outcomes, given the difficulty in measuring the deterrent effect of the
program.
Table 3: CSI Performance Measures
Performance
CSI goals targets and
associated actual
with results of
Performance Description of specific measures, by
measure Performance performance performance fiscal year
number^a measures measures measures Targets Results
1^c Percentage of Percentage of Goal 1: 2010: 86% 2007:86%
worldwide total U.S.-bound securing
United States containers that U.S. borders
destined pass through CSI
containers seaports, where
processed actions are
through CSI taken to detect
seaports^b and prevent WMDs
from leaving the
foreign
seaports.
2^c Number of Number of Goal 1: 2006: 2006:47,630
foreign container securing
mitigated examinations U.S. borders 24,000
examinations determined to be
by category unnecessary, and Goal 2:
thus waived, due building a
to information robust CSI
provided by cargo
foreign customs security
administrations. system
Developed to No target 2007:
quantify whether established.
co-locating CBP 18,404
officials at CSI
seaports
increases
information
sharing and
collaboration.
3^c Number of Number of Goal 1: No target 2007:
intelligence intelligence securing established.
reports based reports that CSI U.S. borders 138
on CSI teams
foreign disseminate to Goal 2:
sources other CSI and building a
CBP offices robust CSI
after cargo
researching security
information system
provided by CSI
foreign sources. Goal 3:
Intended to protecting
measure whether and
having CBP facilitating
officials trade
located at
foreign seaports
leads to
increased
collaboration
with foreign
customs
officials.
4 Number of Total number of Goal 2: 2006: 2006:
operational seaports where building a
CSI seaports CSI has been robust CSI 50 50
implemented and cargo
is operating. security
system
2007: 2007:
Goal 3:
protecting 58 58
and
facilitating
trade
5 Number of Number of Goal 1: 2006: 2006:
investigative investigative securing
cases cases opened U.S. borders 48 155
initiated due either in the
to CSI United States or Goal 3:
intelligence at a foreign protecting 2007: 2007:
location due to and
intelligence facilitating No target 135
gathered by CSI trade established.
staff at foreign
port locations.
6 Number of Number of Goal 1: No target 2007:
positive foreign and securing established.
findings by domestic U.S. borders 0
category positive
findings in Goal 3:
U.S.-bound protecting
containers in and
which there was facilitating
participation trade
from CSI teams.
Source: GAO presentation of data reported by CBP.
^aThe CSI strategic plan includes seven performance measures, but according
to CBP officials, the agency is no longer using its cost efficiency
measure, which tracked the expense involved in integrating a new foreign
seaport into the CSI program. CBP officials stated that they did not plan
to establish a cost efficiency measure for ongoing CSI seaport operations
because the seaports differed greatly in their costs.
^bCBP defines `processing' to include any of the following CSI activities:
screening U.S. destined cargo using ATS; conducting further research;
collaborating with host government officials; or examining the container.
^cThese three performance measures are those CBP identified as proxies
for program outcomes.
Appendix VI: GAO Contact and Staff Acknowledgments
GAO Contact
Stephen L. Caldwell, Director, Homeland Security and Justice Issues, (202)
512-9610, [email protected].
Staff Acknowledgments
This report was prepared under the direction of Christine A. Fossett,
Assistant Director, Homeland Security and Justice Issues. Key
contributions to this report also included Amy Bernstein, Fredrick Berry,
Yecenia Camarillo, Frances Cook, Christopher Conrad, Wendy Dye, Kathryn
Godfrey, Valerie Kasindi, Stanley Kostyla, Matthew Lee, Frederick Lyles,
Robert Rivas, and Leslie Sarapu.
Related GAO Products
Maritime Security: The SAFE Port Act: Status and Implementation One Year
Later. [46]GAO-08-126T . Washington, D.C.: October 30, 2007.
Maritime Security: One Year Later: A Progress Report on the SAFE Port Act.
[47]GAO-08-171T . Washington, D.C.: October 16, 2007.
Maritime Security: The SAFE Port Act and Efforts to Secure Our Nation's
Seaports. [48]GAO-08-86T . Washington, D.C.: October 4, 2007.
Combating Nuclear Smuggling: Additional Actions Needed to Ensure Adequate
Testing of Next Generation Radiation Detection Equipment. [49]GAO-07-1247T
. Washington, D.C.: September 18, 2007.
Maritime Security: Observations on Selected Aspects of the SAFE Port Act.
[50]GAO-07-754T . April 26, 2007.
Customs Revenue: Customs and Border Protection Needs to Improve Workforce
Planning and Accountability. [51]GAO-07-529 . Washington, D.C.: April 12,
2007.
Cargo Container Inspections: Preliminary Observations on the Status of
Efforts to Improve the Automated Targeting System. [52]GAO-06-591T .
Washington, D.C.: March 30, 2006.
Combating Nuclear Smuggling: Efforts to Deploy Radiation Detection
Equipment in the United States and in Other Countries. [53]GAO-05-840T .
Washington, D.C.: June 21, 2005.
Container Security: A Flexible Staffing Model and Minimum Equipment
Requirements Would Improve Overseas Targeting and Inspection Efforts.
[54]GAO-05-557 . Washington, D.C.: April 26, 2005.
Homeland Security: Key Cargo Security Programs Can Be Improved.
[55]GAO-05-466T . Washington, D.C.: May 26, 2005.
Maritime Security: Enhancements Made, but Implementation and
Sustainability Remain Key Challenges. [56]GAO-05-448T . Washington, D.C.:
May 17, 2005.
Cargo Security: Partnership Program Grants Importers Reduced Scrutiny with
Limited Assurance of Improved Security. [57]GAO-05-404 . Washington, D.C.:
March 11, 2005.
Preventing Nuclear Smuggling: DOE Has Made Limited Progress in Installing
Radiation Detection Equipment at Highest Priority Foreign Seaports.
[58]GAO-05-375 . Washington, D.C.: March 31, 2005.
Homeland Security: Process for Reporting Lessons Learned from Seaport
Exercises Needs Further Attention. [59]GAO-05-170 . Washington, D.C.:
January 14, 2005.
Port Security: Better Planning Needed to Develop and Operate Maritime
Worker Identification Card Program. [60]GAO-05-106 . Washington, D.C.:
December 10, 2004.
Maritime Security: Substantial Work Remains to Translate New Planning
Requirements into Effective Port Security. [61]GAO-04-838 . Washington,
D.C.: June 30, 2004.
Homeland Security: Summary of Challenges Faced in Targeting Oceangoing
Cargo Containers for Inspection. [62]GAO-04-557T . Washington, D.C.: March
31, 2004.
Container Security: Expansion of Key Customs Programs Will Require Greater
Attention to Critical Success Factors. [63]GAO-03-770 . Washington, D.C.:
July 25, 2003.
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Highlights of [71]GAO-08-187 , a report to congressional requesters
January 2008
SUPPLY CHAIN SECURITY
Examinations of High-Risk Cargo at Foreign Seaports Have Increased, but
Improved Data Collection and Performance Measures Are Needed
Customs and Border Protection's (CBP) Container Security Initiative (CSI)
aims to identify and examine high-risk U.S.-bound cargo at foreign
seaports. GAO reported in 2003 and 2005 that CSI helped to enhance
homeland security, and recommended actions to strengthen the program. This
report updates information and assesses how CBP has (1) contributed to
strategic planning for supply chain security, (2) strengthened CSI
operations, and (3) evaluated CSI operations. To address these issues, GAO
interviewed CBP officials and reviewed CSI evaluations and performance
measures. GAO also visited selected U.S. and CSI seaports, and met with
U.S. and foreign government officials.
[72]What GAO Recommends
GAO recommends that CBP enhance data collected on CSI team performance,
host government examinations, and related performance measures. CBP
concurred with the recom-mendation to enhance data on team performance. It
partially concurred with the need to enhance data on host examin-ations,
stating that it already conducts actions to improve such data. However,
these actions do not systematically collect data on people, processes, or
technology used by host governments to examine U.S.-bound containers. CBP
partially concurred with the need to enhance performance measures, but
stated it already captures core program functions. We still see room for
improvement.
By collaborating on the development of the Department of Homeland
Security's Strategy to Enhance International Supply Chain Security, and by
revising the CSI strategic plan as GAO recommended, CBP has contributed to
the overall U.S. strategic planning efforts related to enhancing the
security for the overseas supply chain. Also, CBP reached its targets of
operating CSI in 58 foreign seaports, and thereby having 86 percent of all
U.S.-bound cargo containers pass through CSI seaports in fiscal year
2007--representing a steady increase in these measures of CSI performance.
To strengthen CSI operations, CBP has sought to address human capital
challenges and previous GAO recommendations by increasing CSI staffing
levels closer to those called for in its staffing model and revising its
human capital plan. However, challenges remain because CBP continues to
rely, in part, on a temporary workforce; has not determined how to
optimize its staffing resources; and reports difficulties in identifying
sufficient numbers of qualified staff. In addition, CBP has enhanced
relationships with host governments participating in CSI. However, hurdles
to cooperation remain at some seaports, such as restrictions on CSI teams
witnessing examinations.
CBP improved its evaluation of CSI team performance at seaports, but
limitations remain in the evaluation process that affect the accuracy and
completeness of data collected. CBP has not set minimum technical criteria
for equipment or systematically collected information on the equipment,
people, and processes involved in CSI host government examinations of
high-risk, U.S-bound container cargo. Also, CBP has not developed general
guidelines to use in assessing the reliability of these examinations.
Thus, CBP potentially lacks information to ensure that host government
examinations can detect and identify weapons of mass destruction, which is
important because containers are typically not reexamined in the United
States if already examined at a CSI seaport. CBP refined overall CSI
performance measures, but has not fully developed performance measures and
annual targets for core CSI functions, such as the examination of
high-risk containers before they are placed on vessels bound for the
United States. These weaknesses in CBP's data collection and performance
measures potentially limit the information available on overall CSI
effectiveness.
Containers Stacked on a Vessel at a CSI Port
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