Customs Service: Inspectional Personnel and Workloads (Letter Report,
08/14/98, GAO/GGD-98-170).

Pursuant to a congressional request, GAO reviewed certain aspects of the
Customs Service's inspectional personnel and its commercial cargo and
passenger workloads, focusing on: (1) the implications of any
differences between the cargo and passenger inspectional personnel
levels at selected airports and seaports around the United States and
those determined by Customs to be appropriate for these ports (assessed
levels); and (2) any differences among the cargo and passenger
processing workload-to-inspector ratios at the selected ports and the
rationales for any significant differences in these ratios.

GAO noted that: (1) it was not able to perform the requested analyses to
identify the implications of differences between assessed and actual
inspectional personnel levels because, as GAO reported in April 1998,
Customs had not assessed the appropriate inspectional personnel levels
for its ports; (2) in that report, GAO determined that Customs does not
have a systematic agencywide process for assessing the need for
inspectional personnel and allocating such personnel to commercial cargo
ports; (3) Customs also does not have such a process for assessing the
need for inspectional personnel to process land and sea passengers at
ports; (4) while Customs uses a quantitative model to determine the need
for additional inspectional personnel to process air passengers, the
model is not intended to establish the level at which airports should be
staffed, according to Customs officials; (5) Customs is in the early
stages of responding to a recommendation in GAO's April 1998 report that
it establish an inspectional personnel needs assessment and allocation
process; (6) Customs officials GAO interviewed at air and sea ports told
GAO that the current personnel levels, coupled with the use of overtime,
enabled the ports to process commercial cargo and passengers within
prescribed performance parameters; (7) the inspectional personnel data
that GAO obtained for the selected ports showed that at the end of
fiscal year 1997, the personnel levels at these ports were at or near
the levels for which funds were provided to the ports; (8) GAO was also
not able to perform the analyses to identify workload-to-inspector
ratios and rationales for any differences in these ratios because it did
not have a sufficient level of confidence in the quality of the workload
data; (9) GAO identified significant discrepancies in the workload data
it obtained from Customs headquarters, a Customs Management Center (CMC)
and two ports; (10) data from the New York CMC indicated that these
airports processed about 1.5 million formal entries alone, almost
100,000 entries more than the number headquarters had for all entries at
these ports; (11) workload was only one of several factors considered by
Customs in the few assessments--which focused on its drug smuggling
initiatives--completed since 1995 to determine its needs for additional
inspectional personnel and allocate such personnel to ports; and (12)
Customs also considered factors such as the threat of drug smuggling,
budgetary constraints, and legislative limitations.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GGD-98-170
     TITLE:  Customs Service: Inspectional Personnel and Workloads
      DATE:  08/14/98
   SUBJECT:  Customs administration
             Personnel management
             Agency evaluation
             Data integrity
             Human resources utilization
             Strategic planning
             Federal employees
             Inspection

             
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Cover
================================================================ COVER


Report to Congressional Committees

August 1998

CUSTOMS SERVICE - INSPECTIONAL
PERSONNEL AND WORKLOADS

GAO/GGD-98-170

Inspectional Personnel and Workloads

(264441)


Abbreviations
=============================================================== ABBREV

  CMC - Customs Management Center
  JFK - John F.  Kennedy International Airport
  LAX - Los Angeles International Airport

Letter
=============================================================== LETTER


B-259233

August 14, 1998

The Honorable Stephen Horn
Chairman, Subcommittee on
 Government Management,
 Information, and Technology
Committee on Government
Reform and Oversight
House of Representatives

The Honorable Phil Crane
Chairman, Subcommittee on Trade
Committee on Ways and Means
House of Representatives

On December 12, 1997, and January 29, 1998, respectively, you
requested that we review certain aspects of the U.S.  Customs
Service's (Customs) inspectional personnel and its commercial cargo
and passenger workloads.  Specifically, you requested that we analyze
(1) the implications of any differences between the cargo and
passenger inspectional personnel levels at selected airports and
seaports around the United States and those determined by Customs to
be appropriate for these ports (assessed levels) and (2) any
differences among the cargo and passenger processing
workload-to-inspector ratios at the selected ports and the rationales
for any significant differences in these ratios. 

We briefed your offices on the results of our work on May 19 and May
21, 1998, respectively.  This report documents the information that
we were able to obtain in response to your requests and that we
presented at the briefings.  Specifically, this report discusses the
reasons why we were not able to perform the analyses you requested on
the relationships between assessed and actual personnel levels and
workload-to-inspector ratios.  In addition, it presents information
on (1) the cargo and passenger inspectional personnel levels at
selected ports and (2) the cargo and passenger processing workloads
at selected ports. 

In developing the information in this report, we obtained and
reviewed relevant staffing, budget, and workload documents;
interviewed cognizant Customs officials at headquarters and nine
ports; and visited four major seaports and airports, where we
observed cargo and passenger processing operations.  We did not
assess the quality of Customs' inspectional personnel data.  However,
to obtain an indication of the overall quality of the cargo and
passenger workload data, we sought to identify whether Customs had
any procedures for verifying such data.  We also compared workload
data we obtained for each port from various sources and attempted to
reconcile any differences.  Our objectives, scope, and methodology
are discussed in more detail in appendix I. 

We performed our work between March and June 1998 in accordance with
generally accepted government auditing standards.  We requested
comments on a draft of this report from the Secretary of the Treasury
or his designees.  On August 4, 1998, Customs' Assistant Commissioner
for Field Operations provided us with Customs' comments.  These
comments are discussed near the end of this letter. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

We were not able to perform the requested analyses to identify the
implications of differences between assessed and actual inspectional
personnel levels because, as we reported in April 1998,\1 Customs had
not assessed the appropriate inspectional personnel levels for its
ports.  In that report, we determined that Customs does not have a
systematic, agencywide process for assessing the need for
inspectional personnel and allocating such personnel to commercial
cargo ports.  Customs also does not have such a process for assessing
the need for inspectional personnel to process land and sea
passengers at ports.  While Customs uses a quantitative model to
determine the need for additional inspectional personnel to process
air passengers (see table 1), the model is not intended to establish
the level at which airports should be staffed, according to Customs
officials. 

Customs is in the early stages of responding to a recommendation in
our April 1998 report that it establish an inspectional personnel
needs assessment and allocation process. 

Customs officials we interviewed at air and sea ports told us that
the current personnel levels, coupled with the use of overtime,
enabled the ports to process commercial cargo and passengers within
prescribed performance parameters, such as the inspection of
passengers within 5 minutes of their retrieving checked baggage.  The
inspectional personnel data that we obtained for the selected ports
showed that at the end of fiscal year 1997, the personnel levels at
these ports were at or near the levels for which funds were provided
to the ports.  For example, at the end of fiscal year 1997, while the
funded level for Los Angeles International Airport (LAX) was 336
inspectors, 320 inspectors were actually on board. 

We were also not able to perform the analyses to identify
workload-to-inspector ratios and rationales for any differences in
these ratios because we did not have a sufficient level of confidence
in the quality of the workload data.  We identified significant
discrepancies in the workload data we obtained from Customs
headquarters, a Customs Management Center (CMC),\2 and two ports. 
For example, for fiscal year 1997, data from Customs headquarters
indicated that John F.  Kennedy International Airport (JFK) and
Newark International Airport processed a total of about 1.4 million
cargo entries (shipments) of all types, including those with a value
of less than $1,250 (informal entries) and those with a value of over
$1,250 (formal entries).  However, data from the New York CMC
indicated that these airports processed about 1.5 million formal
entries alone, almost 100,000 entries more than the number
headquarters had for all entries at these ports.  We could not obtain
specific explanations for such discrepancies without Customs having
to conduct extensive additional work.  We also could not identify any
systematic controls over the quality of the data. 

In addition, workload was only one of several factors considered by
Customs in the few assessments--which focused on its drug-smuggling
initiatives--completed since 1995 to determine its needs for
additional inspectional personnel and allocate such personnel to
ports.  Customs also considered factors such as the threat of drug
smuggling, budgetary constraints, and legislative limitations. 


--------------------
\1 See Customs Service:  Process for Estimating and Allocating
Inspectional Personnel (GAO/GGD-98-107, Apr.  30, 1998). 

\2 On October 1, 1995, Customs closed its 7 regional and 42 district
offices and replaced them with 20 CMCs.  The CMCs have oversight
responsibilities over Customs' ports of entry. 


   BACKGROUND
------------------------------------------------------------ Letter :2

Created in 1789, Customs is one of the federal government's oldest
agencies.  Customs is responsible for collecting revenue from imports
and enforcing customs and related laws.  Customs also processes
persons, carriers, cargo, and mail into and out of the United States. 
In fiscal year 1997, Customs collected about $19 billion in revenues
and processed about 18 million import entries; about 128 million
vehicles and trucks; about 706,000 commercial aircraft; about 214,000
vessels; and about 442 million air, land, and sea passengers entering
the country.  Customs performs its mission with a workforce of about
19,500 personnel at its headquarters in Washington, D.C., and at 20
CMCs, 20 Special Agent-in-Charge offices, and 301 ports of entry
around the country.  At the end of fiscal year 1997, Customs had
deployed 7,207 inspectors at these ports.  This represented an
increase of 17 percent over the level in fiscal year 1992, the
earliest year for which complete data were available. 

The nine ports we visited or contacted--LAX Airport; Los Angeles/Long
Beach Seaport; JFK Airport; New York/Newark Seaport; Newark
International Airport; and the Houston and Detroit air and sea
ports--were among the busiest of their kind in the United States in
fiscal year 1997.  According to Customs workload data, these ports
accounted for about 31 percent of all air and sea passengers and
about 19 percent of all cargo entries processed by Customs in fiscal
year 1997.  The ports also accounted for about 21 percent of all
inspectors deployed by Customs at the end of fiscal year 1997. 


   IMPLICATIONS OF DIFFERENCES
   BETWEEN ASSESSED AND ACTUAL
   INSPECTIONAL PERSONNEL LEVELS
   COULD NOT BE DETERMINED
------------------------------------------------------------ Letter :3

We were not able to perform the requested analyses to identify the
implications of differences between assessed and actual inspectional
personnel levels because Customs had not assessed the appropriate
inspectional personnel levels for its ports.  Customs had not done so
because it does not have a systematic, agencywide process for
assessing the need for inspectional personnel and allocating such
personnel to process commercial cargo at air, sea, and land ports and
to process passengers at sea and land ports.  While Customs uses a
quantitative model to determine the need for additional inspectional
personnel to process air passengers, the model is not intended to
establish the level at which airports should be staffed.  Customs is
in the early stages of responding to a recommendation in our April
1998 report\3 that it establish an inspectional personnel needs
assessment and allocation process. 

Inspectional personnel levels at the selected ports at the end of
fiscal year 1997 were at or near the levels for which funds had been
provided to the ports.  According to Customs officials we interviewed
at air and sea ports, these personnel levels, coupled with the use of
overtime, enabled the ports to process commercial cargo and
passengers within prescribed performance parameters. 


--------------------
\3 GAO/GGD-98-107. 


      CUSTOMS HAS NOT DETERMINED
      APPROPRIATE INSPECTIONAL
      PERSONNEL LEVELS FOR ITS
      PORTS
---------------------------------------------------------- Letter :3.1

In our April 1998 report, we reported that Customs does not have a
systematic, agencywide process for determining its need for
inspectional personnel for processing commercial cargo and allocating
such personnel to ports of entry nationwide.  We also reported that,
accordingly, Customs had not determined the appropriate inspectional
personnel levels for each of its cargo ports and for its cargo
processing functions.  In addition, we reported that while Customs
had moved in this direction since 1995 by conducting three
assessments and two allocations, these assessements and allocations
were limited because they (1) focused on the need for additional
positions rather than first determining the feasibility of moving
existing positions, Customs' drug-smuggling initiatives rather than
its overall cargo processing operations, and Southwest border ports
and certain air and sea ports considered to be at risk from drug
smuggling rather than all 301 ports; (2) used different assessment
and allocation factors each year; and (3) were conducted with minimal
involvement from nonheadquarters Customs units, such as CMCs and
ports.  Accordingly, we pointed out that focusing only on a single
aspect of its operations (i.e., countering drug smuggling); not
consistently including the key field components (i.e., CMCs and
ports) in the personnel decisionmaking process; and using different
assessment and allocation factors from year to year could prevent
Customs from accurately estimating the need for inspectional
personnel and then allocating them to ports. 

In its assessment for fiscal year 1997 (conducted in 1995), to
estimate the number of inspectional personnel needed, Customs
combined factors such as the need to (1) fully staff inspectional
facilities and (2) balance enforcement efforts against violators with
the need to move legitimate cargo and passengers through the ports. 
In its assessments for fiscal years 1998 and 1999 (conducted in 1996
and 1997, respectively), Customs used factors such as the number and
location of drug seizures and the perceived threat of drug smuggling,
including the use of rail cars to smuggle drugs.  To allocate to the
ports the inspectional personnel that were funded by Congress,
Customs used factors such as (1) commercial cargo workloads and (2)
specific aspects of the drug smuggling threat, such as attempts by
private sector employees at sea and air ports to assist drug
smuggling organizations in their efforts to smuggle drugs (described
by Customs as "internal conspiracies"). 

Customs also does not have a systematic inspectional personnel
assessment and allocation process for processing land passengers.  In
1995, Customs assessed the need for additional inspectional personnel
to process incoming land passengers but since then has not done such
an assessment.  As with the assessments for cargo processing, this
assessment was limited to Southwest border ports to address drug
smuggling and related border violence.  The primary factor considered
in this assessment was the physical configuration, i.e., the number
of primary passenger lanes, of the ports involved. 

Customs has not assessed the need for inspectional personnel to
process sea passengers.  According to Customs officials at the Newark
seaport, because of the cyclical nature of the sea passenger workload
(in terms of the time of week and year), they did not assign
inspectional personnel to process sea passengers on a full-time
basis.  The port assigned inspectional personnel from other
functions, such as cargo processing, on an "as needed" basis to
process sea passengers.  Conversely, a Customs official at the Los
Angeles/Long Beach seaport indicated that it would be operationally
desirable to have dedicated inspectional personnel to process sea
passengers that arrive on board cruise ships three days a week.  This
port also assigned inspectors to process sea passengers on an as
needed basis. 


      QUANTITATIVE MODEL USED TO
      ESTIMATE NEED FOR
      INSPECTIONAL PERSONNEL FOR
      AIR PASSENGER PROCESSING
---------------------------------------------------------- Letter :3.2

Unlike its cargo and other passenger processing functions, Customs
has employed a quantitative model since 1993 to determine the need
for additional inspectional personnel to process air passengers at
the 16 largest international airports in the United States, including
the 5 airports we visited or contacted.\4 In developing its
recommendations for inspectional personnel, the model utilized the
following factors in its formula:  (1) the number of arriving
international passengers and the activities required to clear them
for entry, (2) workforce productivity, (3) growth in workload, (4)
the number of passenger terminals at each port, (5) enforcement risk
(threat), and (6) the number of positions equivalent to the amount of
overtime spent to operate a particular port.  Table 1 shows the
model's recommendations for inspectional positions and Customs'
allocations of such positions to the five airports we visited or
contacted for fiscal year 1998 and the recommendations for fiscal
year 1999. 



                                Table 1
                
                   Results of Customs' Air Passenger
                 Staffing Allocation Model for Selected
                  Airports, Fiscal Years 1998 and 1999

                         Number of         Number of         Number of
                        additional        additional        additional
                      inspectional      inspectional      inspectional
                         positions         positions         positions
                   recommended for  allocated for FY   recommended for
Airport                    FY 1998              1998           FY 1999
----------------  ----------------  ----------------  ----------------
JFK                            108                12                88
LAX                             20                16               (8)
Newark                           9                 2                14
Houston                        (9)                 0               (6)
Detroit                         18                10                 8
----------------------------------------------------------------------
Note 1:  Numbers in parentheses indicate that the model considered
these ports to be overstaffed for that fiscal year. 

Note 2:  The allocation of inspectional positions for fiscal year
1999 is pending the results of congressional appropriations. 

Source:  U.S.  Customs Service. 

Customs officials considered the model to be an analytical tool in
their decisionmaking.  As such, the model is not intended to
establish the level at which airports should be staffed.  Rather, the
model's results and recommendations are considered to be an indicator
of the additional inspectional positions needed by each of the 16
ports, given the six factors discussed earlier that the model
considers. 

The model's results and recommendations are reviewed by Customs
officials and are modified in two primary ways.  First, Customs does
not allocate all of the positions recommended for particular ports. 
According to Customs officials, because additional inspectional
positions have generally not been available from regular ("Salaries
and Expenses") appropriations, Customs has provided additional
positions to airports mainly by funding them through user-fee
revenues.\5 However, according to these officials, user-fee revenues
each fiscal year were not sufficient to fund all of the positions the
model estimated were needed.  For example, for fiscal year 1998, a
total of 142 additional positions were actually funded by user-fee
revenues, while the model estimated that 288 additional positions
were needed.  The model recommended that out of the 288 estimated
additional positions, JFK Airport needed 108 additional positions and
LAX Airport needed 20 additional positions.  As a result of internal
reviews by Customs officials, JFK Airport was allocated 12 positions
and LAX Airport was allocated 16 positions.  For fiscal year 1999,
the model recommended that out of the 175 total additional positions
it estimated as needed, JFK Airport needed 88 additional positions. 
As discussed below, the model indicated that LAX Airport was
overstaffed.  As of August 1998, the allocation of inspectional
personnel was pending the outcome of congressional appropriations for
fiscal year 1999.  The appropriations would determine the actual
number of additional positions that could be funded. 

Second, Customs did not move existing positions from airports that
the model indicated were overstaffed.  For example, for fiscal year
1998, the model indicated that 4 airports were overstaffed by a total
of 37 positions.  For fiscal year 1999, the model indicated that LAX
Airport was overstaffed by 8 positions and that 4 other airports were
overstaffed by a total of 42 positions.  In our April 1998 report,\6
Customs officials stated that they generally did not reallocate
existing inspectional personnel for several reasons, including
legislative limitations placed on the movement of certain positions,
such as those funded by user-fee revenues for specific purposes at
specific locations.  In addition, according to the Customs official
who administers the model, primarily because the model did not take
into account certain factors, such as sudden changes in airline
markets, Customs did not plan to move positions from the ports that
the model indicated were overstaffed. 


--------------------
\4 The 16 airports each handle more than 700,000 international
passengers.  The additional personnel are funded through revenues
from user fees established by the Consolidated Omnibus Budget
Reconciliation Act of 1985 as amended, codified at 19 U.S.C.  58c. 

\5 In our April 1998 report, we indicated that the President's
budgets for fiscal years 1997 to 1999 did not request all of the
additional inspectional positions that Customs estimated it needed
for its commercial cargo processing operations.  Congress funded the
number of positions that were requested for fiscal years 1997 and
1998.  As of August 1998, fiscal year 1999 appropriations were
pending. 

\6 GAO/GGD-98-107. 


      CUSTOMS' RESPONSE TO OUR
      RECOMMENDATION ON NEED FOR
      INSPECTIONAL PERSONNEL
      ASSESSMENT AND ALLOCATION
      PROCESS
---------------------------------------------------------- Letter :3.3

In our April 1998 report, we concluded that in order to successfully
implement the Government Performance and Results Act of 1993 (the
Results Act) (P.L.  103-62),\7

Customs had to determine its needs for inspectional personnel for all
of its operations and ensure that available personnel were allocated
where they were needed most.  Accordingly, we recommended that, as a
sound strategic planning practice, Customs establish a systematic
process that would properly align its inspectional personnel with its
operational activity goals, objectives, and strategies. 

Customs' Assistant Commissioner for Field Operations told us that, in
part, as a result of reviewing the April 1998 report and its
recommendation, Customs recognizes that staffing imbalances may exist
at certain ports.  In a June 1998 written response to our
recommendation, Customs detailed the steps it was taking to implement
it.  Specifically, Customs indicated that it had awarded a contract
for the development of a resource allocation model that would define
the work of Customs' core occupations and prioritize workload.  The
model also is to process data using performance measurement
methodologies, be compatible with cost accounting and other
management controls, and establish linkages between core occupations
and support positions.  Upon delivery of the model, Customs indicated
it would customize a process for using it to meet changing personnel
needs and new initiatives.  The model is scheduled to be ready for
implementation by fiscal year 1999. 

In conjunction with the development of the resource allocation model,
Customs indicated that it was undertaking an initiative to assess and
improve the quality of the data to be used in the model. 
Specifically, the initiative is to review and confirm data
definitions and sources and assess the quality of the data. 


--------------------
\7 The Results Act was enacted to improve the efficiency and
effectiveness of federal programs.  The Results Act required that
executive agencies develop strategic plans in which, among other
things, they defined their missions and established performance goals
and measures for each of their program activities.  Customs'
Strategic Plan for fiscal years 1997 through 2002 established
performance goals and measures for its program activities.  The
Results Act also required that strategic plans describe, among other
things, (1) the human and other resources needed and (2) how agencies
proposed to align these resources with their activities to support
mission-related goals and objectives. 


      INSPECTIONAL PERSONNEL
      LEVELS AT SELECTED PORTS
      WERE AT OR NEAR FUNDED
      LEVELS
---------------------------------------------------------- Letter :3.4

Table 2 shows the combined (cargo and passenger processing) onboard
inspectional personnel levels at the end of fiscal year 1997 at the
ports we visited or contacted.  According to Customs officials at the
ports, inspectors who are not funded by user-fee revenues often shift
between cargo and passenger processing functions, depending on
workload demands and the need to work overtime.  Consequently, it
could be difficult to establish the exact number of inspectors
dedicated to each function at any given time.  Accordingly, we did
not separate the staffing levels by function. 

Table 2 also shows that the onboard personnel levels for each port
were very near the levels funded from appropriations.  According to
Customs officials, under its current "staff-to-budget"\8 procedures,
rather than "authorized" levels, Customs tracks its personnel levels
at ports through "tables-of-organization"--which reflect the number
of positions that are funded at a particular port--and the number of
personnel onboard. 



                                Table 2
                
                   Table-of-Organization (Funded) and
                 Onboard Inspectional Personnel Levels
                for Selected Ports, as of September 30,
                                  1997

                                        Inspectional      Inspectional
                                    Personnel Levels  Personnel Levels
Port                                        (Funded)         (Onboard)
----------------------------------  ----------------  ----------------
LAX Airport                                      336               320
Los Angeles/Long Beach Seaport                   156               145
JFK Airport                                      563               531
Newark Airport                                   100                95
New York/Newark Seaport                          307               292
Houston Airport                                   62                58
Houston/Galveston Seaport                         93                89
Detroit Airport                                   43                43
Detroit Seaport                                    2                 2
----------------------------------------------------------------------
Source:  U.S.  Customs Service. 

According to Customs officials at the ports we visited or contacted,
the existing inspectional personnel above and the use of overtime
funds enabled the ports to process arriving international passengers
and cargo within the performance measures established by Customs for
these functions in its strategic plan.  The performance measure for
processing air passengers requires that 95 percent of such passengers
be cleared within 5 minutes from the time they retrieve their checked
luggage, while the measure for air cargo (formal entries) requires
that 99.6 percent of such entries be released in 1 day.\9


--------------------
\8 According to Customs officials, under the "staff-to-budget"
concept, rather than attempting to fill "authorized" positions, which
was unrealistic given funding levels, Customs seeks to fill the
number of positions that its appropriated funding actually allows. 

\9 Customs' fiscal year 1997 performance plan included a performance
measure for examining incoming cargo.  The plan called for 3.1
percent of such cargo to be examined.  In its fiscal year 1999 budget
request submission, Customs reported that, overall, 2.6 percent of
cargo had been examined in fiscal year 1997.  It also reported that
the cargo examination performance measure was being discontinued as
part of Customs' ongoing efforts to improve and refine its
performance measures.  The ports we visited or contacted reported
that they examined an average of 2.2 percent of incoming cargo in
fiscal year 1997. 


   WORKLOAD-TO-INSPECTOR RATIOS
   AND RATIONALES FOR DIFFERENCES
   COULD NOT BE DETERMINED
------------------------------------------------------------ Letter :4

We were not able to develop reliable workload-to-inspector ratios
because we could not establish a sufficient level of assurance
regarding the overall quality of the workload data to conduct further
analyses.  Specifically, we identified significant discrepancies in
the workload data as reported from Customs headquarters and a CMC and
ports for two ports.  For example, headquarters workload
data--considered by Customs to be the official data--showed that the
Newark Seaport processed 154,206 sea passengers in fiscal year 1997. 
However, the port itself reported that it processed 186,957
passengers that same year.  The data discrepancies for JFK Airport
are discussed earlier in this report.  We could not obtain specific
reasons for these discrepancies without Customs having to conduct
additional work.  In addition, we could not identify any systematic
internal controls over the accuracy and reliability of such data,
either at Customs headquarters or at the CMCs and ports we visited or
contacted. 

Workload is one of several factors that Customs considered in the
assessments and allocations done over the past 3 years.  According to
Customs officials, the drug-smuggling threat--such as the use of rail
cars to smuggle drugs--was the primary factor considered in these
assessments and allocations.  As discussed earlier, Customs also
considered budgetary constraints and legislative limitations in its
personnel assessment and allocation decisionmaking. 


      CARGO AND PASSENGER
      PROCESSING WORKLOADS AT
      SELECTED PORTS
---------------------------------------------------------- Letter :4.1

Table 3 shows the cargo and passenger processing workloads for fiscal
year 1997 at the selected ports we visited or contacted as reported
by Customs headquarters.  The cargo workload data are presented as
totals of all types of entries, including formal entries, for each
port. 



                                Table 3
                
                Cargo and Passenger Processing Workloads
                  for Selected Ports, Fiscal Year 1997

                                                            Cargo (all
Port                                      Passengers          entries)
----------------------------------  ----------------  ----------------
LAX Airport                                7,317,123           604,038
LA/Long Beach Seaport                        804,418           800,511
JFK Airport                                9,710,193           786,617
Newark Airport                             2,613,760           660,159
Newark Seaport                               154,206           660,159
Houston Airport                            1,881,970            59,575
Houston/Galveston Seaport                     17,424            97,125
Detroit Airport                            1,460,469            45,250
Detroit Seaport                               12,557            18,747
----------------------------------------------------------------------
Note 1:  Customs uses the same code to track cargo entries at the
Newark sea and air ports. 

Source:  U.S.  Customs Service headquarters database. 


   CONCLUSIONS
------------------------------------------------------------ Letter :5

We could not perform the staffing and workload analyses requested by
the Subcommittees because (1) Customs had not assessed the level of
appropriate staffing at its ports and (2) of concerns about the
quality of Customs' workload data.  In addition, Customs considered
factors other than workload--such as budget constraints and
legislative limitations--in determining its need for inspectional
personnel and allocating such personnel to ports.  According to
Customs officials, these factors must be considered in their
decisionmaking in order to maximize the effectiveness of deployed
resources. 

Based on statements to us by senior Customs officials and their
response to the recommendation in our April 1998 report, we believe
that Customs has recognized that staffing imbalances may exist at
certain ports and that it needs to improve the manner in which it
assesses the need for and allocates inspectional personnel to ports
of entry.  Customs' actions--the award of a contract to develop a
resource allocation model and an initiative to improve the quality of
data in its management database--are steps in the right direction to
address the personnel assessment and allocation issues we identified
during our work.  Given these steps by Customs, we are not making any
recommendations in this report. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :6

We requested comments on a draft of this report from the Secretary of
the Treasury or his designees.  On August 4, 1998, Customs' Assistant
Commissioner for Field Operations provided us with Customs' comments
on the draft.  The Assistant Commissioner generally agreed with the
information presented in the report and its conclusions and provided
technical comments and clarifications, which we have incorporated in
this report where appropriate. 


---------------------------------------------------------- Letter :6.1

We are sending copies of this report to the Chairmen and Ranking
Minority Members of the congressional committees that have
responsibilities related to Customs, the Secretary of the Treasury,
and the Acting Commissioner of Customs.  Copies will also be made
available to others on request.  Major contributors to this report
are listed in appendix II.  If you have any questions or wish to
discuss the information in this report, please contact Brenda J. 
Bridges, Assistant Director, on (202) 512-5081 or me on (202)
512-8777. 

Norman J.  Rabkin
Director, Administration
 of Justice Issues


OBJECTIVES, SCOPE, AND METHODOLOGY
=========================================================== Appendix I

Our objectives in this review were to analyze (1) the cargo and
passenger inspectional personnel levels at selected airports and
seaports around the United States and the implications of any
differences between these levels and those determined by Customs to
be appropriate for these ports (assessed levels) and (2) the cargo
and passenger processing workloads and related workload-to-inspector
ratios at the selected ports and the rationales for any significant
differences in these ratios. 

To identify the cargo and passenger inspectional personnel levels at
the selected ports and the implications of any differences between
the assessed and actual personnel levels, we reviewed budget
documents and summaries, staffing statistics, cargo and passenger
processing performance data, and Customs' strategic plan for fiscal
years 1997 to 2002.  We also interviewed Customs officials at
headquarters, Customs Management Centers (CMC), and ports where we
also observed cargo and passenger processing operations.  In
addition, we sought to determine how Customs assesses the need for
inspectional personnel and allocates such personnel to ports of entry
to process cargo and passengers.  Accordingly, we reviewed documents
related to Customs' three assessments since 1995 focusing on its drug
smuggling initiatives and documents related to Customs' air passenger
processing model, including a September 1992 report about the model
done for Customs by two consulting firms.  We did not independently
assess the validity and reliability of the air passenger processing
model or its results.  However, we conducted a limited review of the
consultants' report and discussed its findings and
recommendations--and Customs' responses to them--with cognizant
Customs officials.  Because of the similarities in the subject
matter, we relied extensively on information in our April 1998
report\10 that focused on Customs' inspectional personnel assessment
and allocation processes for commercial cargo ports. 

To identify the cargo and passenger processing workloads and any
related workload-to-inspector ratios at the selected ports and the
rationales for any significant differences in these ratios, we
obtained and reviewed workload data from Customs headquarters, CMCs,
and ports.  Given time constraints, we did not independently verify
the accuracy and reliability of Customs' workload data.  However, to
obtain some indication of the overall quality of these data, we
sought to identify whether Customs had in place any procedures for
verifying data.  Customs officials could not identify any formal,
systematic procedures to verify data quality.  Some port officials
told us that they informally monitored data in management reports to
detect potential errors.  In addition, we compared workload data
obtained from headquarters, CMCs, and ports and identified several
discrepancies, such as those in the number of cargo entries at John
F.  Kennedy International (JFK) Airport.  While Customs officials
said they could not explain specific discrepancies in the data
without conducting lengthy additional work, they provided some
general reasons that could potentially explain the discrepancies. 
These reasons included the possibility that some ports tracked
workload data differently from Customs headquarters. 

We visited the CMCs in Los Angeles and New York and the Los Angeles
International Airport (LAX), Los Angeles/Long Beach Seaport, JFK
Airport, New York/Newark Seaport, and Newark International Airport,
which, although not part of our original scope, we visited due to its
proximity to the seaport--at the request of the Subcommittees.  We
subjectively selected both the airports and seaports each in Houston
and Detroit and telephonically interviewed cognizant officials from
these ports in response to the Trade Subcommittee's request following
our May 21, 1998, briefing that we expand the geographic scope of our
work to include ports along the Northern and Southern borders of the
United States. 

As discussed earlier, the nine ports we visited or contacted were
among the busiest of their kind in the United States in fiscal year
1997.  JFK Airport was the busiest in terms of passenger workload and
the second busiest in terms of cargo workload and had flights
arriving from all over the world.  The Newark Airport, while seventh
in terms of passenger workload, has been experiencing rapid growth. 
Specifically, the number of passengers arriving at the airport had
grown by 67 percent between fiscal years 1992 and 1997, while the
number of arriving flights had grown by 30 percent during the same
period.  The New York/Newark Seaport was the second busiest in terms
of cargo workload, which was expected to grow by over 10 percent
annually for the next 4 years.  The Los Angeles/Long Beach Seaport
was the busiest in terms of cargo workload, collecting 18
percent--about $4 billion--of the duties, fees, and taxes collected
by Customs nationwide in fiscal year 1997.  LAX Airport was the third
busiest in terms of passenger workload and fifth busiest in terms of
cargo workload.  For example, over 7 million passengers and 41,000
flights were cleared through LAX Airport in fiscal year 1997.  The
Houston/Galveston Seaport was the eighth busiest in terms of cargo
processing, while the Houston Airport was the eighth busiest in terms
of passenger processing.  The airport's workload had grown by between
12 to 15 percent annually over the past 2 to 3 years.  The Detroit
Airport was the 13th busiest in terms of passenger processing, while
the seaport processed a relatively small number of cargo entries and
vessel crew. 

The results related to inspectional staffing levels and cargo and
passenger workloads apply only to the five ports we visited and the
four ports we telephonically contacted and cannot be generalized to
all Customs ports. 


--------------------
\10 GAO/GGD-98-107. 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II

GENERAL GOVERNMENT DIVISION,
WASHINGTON, D.C. 

Brenda J.  Bridges, Assistant Director
Barry J.  Seltser, Assistant Director, Design, Methodology, and
Technical
 Assistance
Seto J.  Bagdoyan, Evaluator-in-Charge
Sidney H.  Schwartz, Senior Statistician, Design, Methodology, and
 Technical Assistance
Donald E.  Jack, Evaluator
Wendy C.  Simkalo, Evaluator


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