Testimony Before the Permanent 

Subcommittee on Investigations, 

Committee on Homeland Security and 

Governmental Affairs, United States 

Senate

United States Government Accountability Office

GAO

For Release on Delivery 

Expected at 9:30 a.m. EDT 

Thursday, May 26, 2005 HOMELAND SECURITY

Key Cargo Security 

Programs Can Be Improved 

Statement of Richard M. Stana, Director, 

Homeland Security and Justice Issues 

GAO-05-466T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-466T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Rich Stana at 

(202) 512-8777or stanar@gao.gov. 

Highlights of GAO-05-466T, a testimony 

before the Permanent Subcommittee on 

Investigations, Committee on Homeland 

Security and Governmental Affairs, U. S. 

ted States Senate 

April 26

HOMELAND SECURITY

Key Cargo Security Programs Can Be 

Improved 

In return for committing to making improvements to the security of their 

shipments, C-TPAT members receive a range of benefits that may change the 

risk characterization of their shipments, thereby reducing the probability of 

extensive inspection. Before providing benefits, CBP reviews the selfreported information contained in applicants’ membership agreements and 

security profiles. Also, CBP assesses the compliance history of importers 

before granting them benefits. However, CBP grants benefits before 

members undergo the validation process, which is CBP’s method to verify 

that their security measures are reliable, accurate, and effective. Although 

CBP’s goal was to validate members within 3 years, to date it has validated 

11 percent of them. Further, the validation process is not rigorous, as the 

objectives, scope, and methodology of validations are jointly agreed upon 

with the member, and CBP has no written guidelines to indicate what scope 

of effort is adequate for the validation. Also, although CBP has recently 

moved to a risk-based approach to selecting members for validation, it has 

not determined the number and types of validations that are needed to 

manage security risks or the CBP staff required to complete them. Further, 

CBP has not developed a comprehensive set of performance measures for 

the program, and key program decisions are not always documented and 

programmatic information is not updated regularly or accurately. 

The CSI program is designed to target and inspect high-risk cargo containers 

at foreign ports before they leave for the United States. It has resulted in 

improved information sharing between U.S. and foreign customs operations 

and a heightened level of international awareness regarding securing the 

global shipping system. Yet, several factors limit CBP’s ability to successfully 

target containers to determine if they are high-risk. One factor is staffing 

imbalances, caused by political and practical considerations, which impede 

CBP’s targeting efforts at CSI ports. As a result, 35 percent of U.S.-bound 

shipments from CSI ports were not targeted and not subject to inspection 

overseas—the key goal of the CSI program. In addition, as of September 11, 

2004, 28 percent of the containers referred to host governments for 

inspection were not inspected overseas for various reasons such as 

operational limitations. One percent of these referrals were denied by host 

government officials, generally because they believed the referrals were 

based on factors not related to security threats. For the 72 percent of 

referred containers that were inspected overseas, CBP officials told us that 

no WMD were discovered. However, the nonintrusive inspection equipment 

used at CSI ports varies in detection capability, and there are no minimum 

technical requirements for equipment used as part of CSI. As a result, CBP 

has limited assurance that inspections conducted under CSI are effective at 

detecting and identifying terrorist WMD in containers. Finally, CBP 

continues to make refinements to the strategic plan and performance 

measures needed to help manage the program and achieve program goals. 

Until these refinements are completed, it will be difficult to assess progress 

made in CSI operations. 

U.S. Customs and Border 

Protection (CBP) has in place two 

programs to help address the threat 

posed by terrorists smuggling 

weapons of mass destruction 

(WMD) into the United States: the 

Customs-Trade Partnership Against 

Terrorism (C-TPAT) and the 

Container Security Initiative (CSI). 

In July 2003, GAO reported that 

these programs had management 

challenges that limited their 

effectiveness. Given plans to 

expand both programs, in two 

recently issued reports GAO 

examined selected aspects of both 

programs’ operations. This 

statement is a summary of those 

publicly available reports. 

What GAO Recommends

For the C-TPAT program, GAO 

recommended that CBP eliminate 

the weaknesses in its validation 

process, complete its human 

capital plan and performance 

measures, and put in place internal 

controls for the program. For the 

CSI program, GAO recommended 

that CBP refine its staffing model 

to help improve targeting of 

shipments at CSI ports, develop 

minimum technical requirements 

for the capabilities of inspection 

equipment, and complete 

development of program measures. 

CBP generally concurred with the 

recommendations and described 

corrective actions to respond to 

them. 
Page 1 GAO-05-466T 

Mr. Chairman and Members of the Subcommittee: 

I appreciate the opportunity to be here today to provide a summary of our 

recent reports for you on the Department of Homeland Security’s (DHS) 

programs to improve the security of the international supply chain, as well 

as target oceangoing cargo containers for inspection at foreign seaports 

before they arrive at destinations in the United States. 

In the aftermath of the terrorist attacks of September 11, 2001, there is 

heightened concern that terrorists may try to smuggle weapons of mass 

destruction (WMD) into the United States, specifically by using one of the 

millions of cargo containers that arrive at our nation’s seaports each year. 

If terrorists did so and detonated such a weapon (e.g., a radiological 

explosive device) at a seaport, the incident could cause widespread death 

and damage to the immediate area, perhaps shut down seaports 

nationwide, cost the U.S. economy billions of dollars, and seriously 

hamper international trade. 

DHS and its U.S. Customs and Border Protection (CBP) are responsible 

for addressing the threat posed by terrorists smuggling weapons into the 

United States. To carry out this responsibility, CBP has in place programs 

known as the Customs-Trade Partnership Against Terrorism (C-TPAT) and 

the Container Security Initiative (CSI). The C-TPAT program attempts to 

improve the security of the international supply chain (flow of goods from 

manufacturer to retailer). It is a cooperative program between CBP and 

members of the international trade community in which private companies 

agree to improve the security of their supply chains in return for a reduced 

likelihood that their containers will be inspected. C-TPAT membership is 

open to U.S.- and foreign-based companies whose goods are shipped to the 

United States via air, rail, ocean, and truck carriers. The CSI program 

specifically addresses the security of oceangoing cargo containers. Under 

the program, CBP places staff at foreign seaports to work with foreign 

counterparts to use risk assessment information to select, or target, those 

containers at risk of containing WMD and inspect them before they are 

shipped to the United States. 

This statement presents a summary of our latest efforts in a series of GAO 

reports that evaluate CBP’s response to the terrorist threat.1

 As requested, 

 1

A list of related GAO reports appears at the end of this statement. 
Page 2 GAO-05-466T 

my testimony will focus on our assessment of CBP’s efforts under both CTPAT and CSI. Regarding C-TPAT, I will address the following issues: 

• What benefits does CBP provide to C-TPAT members? 

• Before providing benefits, what approach does CBP take to determine 

C-TPAT members’ eligibility for them? 

• After providing benefits, how does CBP verify that members have 

implemented their security measures? 

• To what extent has CBP developed strategies and related management 

tools for achieving the program’s goals? 

Regarding CSI, I will address the following issues: 

• What factors affect CBP’s ability to target shipments at overseas 

seaports? 

• Under CSI, to what extent have high-risk containers been inspected 

overseas prior to their arrival at U.S. destinations? 

• To what extent has CBP developed strategies and related management 

tools for achieving the program’s goals? 

My statement today represents a summary of two unrestricted reports we 

have provided to Congress on these programs—that is, our March 2005 

report on C-TPAT2

 and our April 2005 report on CSI.3

Our report on C-TPAT noted that C-TPAT members receive a range of 

benefits that reduce the level of scrutiny CBP provides to their shipments 

 2

GAO, Cargo Security: Partnership Program Grants Importers Reduced Scrutiny with 

Limited Assurance of Improved Security. GAO-05-404 (Washington, D. C.: March 11, 

2005). 

3

GAO, Container Security: A Flexible Staffing Model and Minimum Equipment 

Requirements Would Improve Overseas Targeting and Inspection Efforts. GAO-05-557

(Washington, D.C.: April 26, 2005). 

Summary 

C-TPAT Issues 
Page 3 GAO-05-466T 

bound for the United States. These benefits may change the risk 

characterization of their shipments, thereby reducing the probability of 

extensive documentary and physical inspection. Before providing benefits, 

CBP uses a two-pronged approach to assess C-TPAT members. First, CBP 

has a certification process to review the self-reported information 

contained in applicants’ membership agreements and security profiles. 

Second, CBP has in place a vetting process to try to assess the compliance 

with customs laws and regulations and violation history of and intelligence 

data on importers before granting them benefits. However, CBP grants 

benefits to members before they undergo the validation process, which is 

CBP’s method to verify that members’ characterization of their security 

measures are accurate and that the security measures have been 

implemented. 

Regarding the validation process, we found several weaknesses that 

compromise CBP’s ability to provide an actual verification that members’ 

supply chain security measures are accurate and are being followed. First, 

the validation process is not rigorous enough to ensure that the security 

procedures outlined in members’ security profiles are reliable, accurate, 

and effective. For example, CBP officials told us that validations are not 

considered independent audits, and the objectives, scope, and 

methodology of validations are jointly agreed upon with the member 

company. Related to this, CBP has no written guidelines to indicate what 

scope of effort is adequate for the validation to ensure that the member’s 

measures are reliable, accurate, and effective. Finally, CBP has not 

determined the extent to which validations are needed, abandoning its 

original goal to validate all members within 3 years because of rapid 

growth in membership and CBP staffing constraints. In 3 years of C-TPAT 

operation, CBP has validated about 11 percent of its certified members. 

We also found weaknesses in some of the tools CBP uses to manage the 

program that could hinder achieving the program’s goals. The new CBP 

strategic plan appears to provide the bureau with a general framework on 

which to base key decisions, including key strategic planning elements 

such as strategic goals, objectives, and strategies. CBP told us it has 

developed some initial performance measures to capture the program’s 

impact but has not developed a comprehensive set of performance 

measures and indicators to monitor the status of program goals. Finally, 

the C-TPAT program lacks an effective records management system. 

CBP’s record keeping for the program is incomplete, as key decisions are 

not always documented and programmatic information is not updated 

regularly or accurately. 
Page 4 GAO-05-466T 

Our report contained several recommendations to enhance the C-TPAT 

program. Specifically, we made recommendations to CBP to provide 

appropriate guidance to specialists conducting validations, determine the 

extent to which members should be validated in lieu of the original goal to 

validate all members within 3 years of certification, complete performance 

measures and a human capital plan, and implement a records management 

system for the program. CBP generally agreed with our recommendations 

and cited corrective actions the bureau either had taken or planned to take 

to implement them. 

Our report on CSI noted improved information sharing between U.S. and 

foreign customs operations and a heightened level of bilateral cooperation 

and international awareness regarding securing the whole global shipping 

system across governments. However, other, negative factors limit CBP’s 

ability to successfully target containers to determine if they are high-risk. 

One such factor is staffing imbalances, which impede CBP from targeting 

all containers shipped from some CSI ports before they leave for the 

United States. For example, political and practical considerations have 

limited the number of staff at some ports. As a result of these limitations, 

35 percent of U.S.-bound shipments from CSI ports were not targeted and 

were therefore not subject to inspection overseas—the key goal of the CSI 

program. We also noted that CBP’s reliance on placing staff at overseas 

ports without considering whether some targeting functions could be 

performed domestically limits the program’s operational efficiency and 

effectiveness. 

Our report also noted that as of September 2004, 28 percent of the 

containers referred to host governments for inspection had not been 

inspected overseas. These containers were not inspected for reasons such 

as operational limitations that prevented the containers from being 

inspected before they left the port. One percent of these referrals were 

denied by host government officials, generally because they believed the 

referrals were based on factors not related to security threats, such as 

drug smuggling. For the 72 percent of referred containers that were 

inspected overseas, CBP officials told us that no WMD were discovered, 

although they acknowledged that technologies to detect other WMDs have 

limitations. Also, considering that the nonintrusive inspection equipment 

used at CSI ports varies in detection capability and that there are no 

minimum technical requirements for equipment used as part of CSI, CBP 

has limited assurance that inspections conducted under CSI are effective 

at detecting and identifying terrorist WMD in containers. 

CSI Issues 
Page 5 GAO-05-466T 

The bureau continues to make refinements to management tools needed to 

help achieve program goals. Although CBP issued a strategic plan for CSI 

in February 2004, the bureau continues to develop three key elements: 

(1) describing how performance goals are related to general goals of the 

program, (2) identifying key external factors that could affect program 

goals, and (3) describing how programs are to be evaluated. Although CBP 

has made progress in the development of some outcome-oriented 

performance measures, it continues to face challenges in developing 

performance measures to assess the effectiveness of CSI targeting and 

inspection activities. Therefore, it is difficult to assess progress made in 

CSI operations over time, and it is difficult to compare CSI operations 

across ports. 

Our report made several recommendations to improve the CSI program. 

Specifically, we recommended that CBP revise its staffing model, develop 

minimum detection capability requirements for nonintrusive inspection 

equipment used in the program, and complete development of 

performance measures for all program objectives. CBP generally agreed 

with our recommendations and cited corrective actions the bureau either 

had taken or planned to take to implement them. 

CBP maintains two overarching goals: (1) increasing security and 

(2) facilitating legitimate trade and travel. Disruptions to the supply chain 

could have immediate and significant economic impacts. For example, in 

terms of containers, CBP data indicates that in 2003 about 90 percent of 

the world’s cargo moved by container. In the United States, almost half of 

all incoming trade (by value) arrived by containers on board ships. 

Additionally, containers arrive via truck and rail. Both admitting 

dangerous cargo into the country and delaying the movement of cargo 

containers through ports of entry could negatively affect the national 

economy. Therefore, CBP believes it is vital to try to strike a balance 

between its antiterrorism efforts and facilitating the flow of legitimate 

international trade and travel. 

The terrorist events of September 11, 2001, raised concerns about 

company supply chains, particularly oceangoing cargo containers, 

potentially being used to move WMD to the United States. An extensive 

body of work on this subject by the Federal Bureau of Investigation and 

academic, think tank, and business organizations concluded that while the 

likelihood of such use of containers is considered low, the movement of 

oceangoing containerized cargo is vulnerable to some form of terrorist 

Background 

Vulnerability of the 

Supply Chain 
Page 6 GAO-05-466T 

action. Such action, including attempts to smuggle either fully assembled 

WMD or their individual components, could lead to widespread death and 

damage. 

The supply chain is particularly vulnerable to potential terrorists because 

of the number of individual companies handling and moving cargo through 

it. To move a container from production facilities overseas to distribution 

points in the United States, an importer has multiple options regarding the 

logistical process, such as routes and the selection of freight carriers. For 

example, some importers might own and operate key aspects of the 

overseas supply chain process, such as warehousing and trucking 

operations. Alternatively, importers might contract with logistical service 

providers, including freight consolidators and nonvessel-operating 

common carriers. In addition, importers must choose among various 

modes of transportation to use, such as rail, truck, or barge, to move 

containers from the manufacturer’s warehouse to the port of lading. 

CBP has implemented a layered enforcement strategy to prevent terrorists 

and WMD from entering the United States through the supply chain. One 

key element of this strategy is the C-TPAT program. Initiated in November 

2001, C-TPAT is a voluntary program designed to improve the security of 

the international supply chain while maintaining an efficient flow of goods. 

Under C-TPAT, CBP officials work in partnership with private companies 

to review their supply chain security plans to improve members’ overall 

security. In return for committing to making improvements to the security 

of their shipments by joining the program, C-TPAT members may receive 

benefits that result in reduced scrutiny of their shipments (e.g., reduced 

number of inspections or shorter border wait times for their shipments). 

C-TPAT membership is open to U.S.-based companies in the trade 

community, including (1) air/rail/sea carriers, (2) border highway carriers, 

(3) importers, (4) licensed customs brokers, (5) air freight consolidators 

and ocean transportation intermediaries and nonvessel-operating common 

carriers, and (6) port authorities or terminal operators. Of these 

companies, CBP grants importers key program benefits. According to 

CBP, program membership has grown rapidly, and continued growth is 

expected, especially as member importers are requiring their suppliers to 

become C-TPAT members. For example, as of January 2003 approximately 

1,700 companies had become C-TPAT members. By May 2003, the number 

had nearly doubled to 3,355. According to CBP officials, as of April 2005, 

the C-TPAT program had over 9,000 members. For fiscal year 2005, the CTPAT budget request was about $38 million, with a requested budget for 

fiscal year 2006 of about $54 million for program expansion efforts. As of 

C-TPAT Is Part of CBP’s 

Layered Enforcement 

Strategy 
Page 7 GAO-05-466T 

August 2004, CBP had hired 40 supply chain specialists, who are dedicated 

to serve as the principal advisers and primary points of contact for C-TPAT 

members.4

 The specialists are located in Washington, D.C., Miami, Florida, 

Los Angeles, California, and New York, New York. 

CBP has a multistep review process for the C-TPAT program. Applicants 

first submit signed C-TPAT agreements affirming their desire to participate 

in the voluntary program. Applicants must also submit security profiles—

executive summaries of their company’s existing supply chain security 

procedures—that follow guidelines jointly developed by CBP and the trade 

community. These security profiles are to summarize the applicant’s 

current security procedures in areas such as physical security, personnel 

security, and education and training awareness. Next, CBP established a 

certification process in which it reviews the applications and profiles by 

comparing their contents with the security guidelines jointly developed by 

CBP and the industry, looking for any weaknesses or gaps in the 

descriptions of security procedures. Once any issues are resolved to CBP’s 

satisfaction, CBP signs the agreement and the company is considered to be 

certified C-TPAT member, eligible for program benefits. However, 

members that are importers must first complete another review, as 

described below, before benefits can begin. CBP encourages all members 

to conduct self-assessments of their security profiles each year to 

determine any significant changes and to notify CBP. For example, 

members may be using new suppliers or new trucking companies and 

would need to update their security profiles to reflect these changes. 

For certified importers, CBP has an additional review called the vetting 

process in which CBP reviews information about an importer’s 

compliance with customs laws and regulations and violation history. 

Conducted concurrently with the certification process, CBP requires the 

vetting process for certified importers as a condition of granting them key 

program benefits. As part of the vetting process, CBP obtains trade 

compliance and intelligence information on certified importers from 

several data sources. If CBP gives the importer a favorable review under 

both the vetting process and the certification process, benefits are to begin 

 4

For fiscal year 2004, CBP had authorization for 157 positions for supply chain specialists 

and support staff, but as of August 2004 had hired only 40 specialists. CBP officials noted 

that the bureau recognizes the need for additional permanent positions, and CBP planned 

to hire, train, and have in place an additional 30 to 50 supply chain specialists by the end of 

calendar year 2004. 
Page 8 GAO-05-466T 

within a few weeks. If not, benefits are not to be granted until successful 

completion of the validation process, as described below. 

The final step in the review process is validation. CBP’s stated purpose for 

validations is to ensure that the security measures outlined in certified 

members’ security profiles and periodic self-assessments are reliable, 

accurate, and effective. In the validation process, CBP staff meet with 

company representatives to verify the supply chain security measures 

contained in the company’s security profile. The validation process is 

designed to include visits to the company’s domestic and, potentially, 

foreign sites. The member and CBP jointly determine which elements of 

the member’s supply chain measures will be validated, as well as which 

locations will be visited. Upon completion of the validation process, CBP 

prepares a final validation report it presents to the company that identifies 

any areas that need improvement and suggested corrective actions, as well 

as a determination if program benefits are still warranted for the member. 

Announced in January 2002, the CSI program was implemented to allow 

CBP officials to target containers at foreign seaports so that any high-risk 

containers may be inspected prior to their departure for U.S. destinations. 

Strategic objectives for the CSI program include (1) pushing the United 

States’ zone of security beyond its physical borders to deter and combat 

the threat of terrorism; (2) targeting shipments for potential terrorists and 

terrorist weapons, through advanced and enhanced information and 

intelligence collection and analysis, and preventing those shipments from 

entering the United States; (3) enhancing homeland and border security 

while facilitating growth and economic development within the 

international trade community; and (4) utilizing available technologies to 

leverage resources and to conduct examinations of all containers posing a 

high risk for terrorist-related activity. 

To participate in the CSI program, a host nation must utilize (1) a seaport 

that has regular, direct, and substantial container traffic to ports in the 

United States; (2) customs staff with the authority and capability to 

inspect cargo originating in or transiting through its country; and (3) 

nonintrusive inspection equipment. In addition, a host nation must meet 

several operational criteria, including a commitment to establishing an 

automated risk management system. To implement the CSI program, CBP 

negotiates and enters into bilateral arrangements with foreign 

governments, specifying the placement of CBP officials at foreign ports 

and the exchange of information between CBP and foreign customs 

administrations. CBP first solicited the participation of the 20 foreign ports 

CSI Is Another Layer of 

CBP’s Enforcement 

Strategy 
Page 9 GAO-05-466T 

that shipped the highest volume of ocean containers to the United States. 

These top 20 ports are located in 14 countries and regions and shipped a 

total of 66 percent of all containers that arrived in U.S. seaports in 2001. 

CBP has since expanded CSI to strategic ports, which may ship lesser 

amounts of cargo to the United States but may also have terrorism or 

geographical concerns. As shown in table 1, as of February 2005, CSI was 

operational at 34 ports, located in 17 countries or regions. For fiscal year 

2005, the CSI budget was about $126 million, with a budget of about $139 

million requested in fiscal year 2006. 
Page 10 GAO-05-466T 

Table 1: CSI Operational Seaports, as of February 2005 

Country/region CSI port Date CSI operations began at port

Canada Halifax March 2002

 Montreal March 2002

 Vancouver February 2002

The Netherlands Rotterdam September 2002

France Le Havre December 2002

 Marseilles January 2005

Germany Bremerhaven February 2003

 Hamburg February 2003

Belgium Antwerp February 2003

 Zeebrugge October 2004

Republic of Singapore Singapore March 2003

Japan Yokohama March 2003

 Tokyo May 2004

 Nagoya August 2004

 Kobe August 2004

Hong Kong Special Administrative Region 

of China 

Hong Kong 

May 2003

Sweden Gothenburg May 2003

United Kingdom Felixstowe May 2003

 Liverpool October 2004

 Southampton October 2004

 Thamesport October 2004

 Tilbury October 2004

Italy Genoa June 2003

 La Spezia June 2003

 Livorno December 2004

 Naples September 2004

 Gioia Tauro October 2004

South Korea Busan August 2003

South Africa Durban December 2003

Malaysia Port Klang March 2004

 Tanjung Pelepas August 2004

Greece Piraeus July 2004

Spain Algeciras July 2004

Thailand Laem Chabang August 2004

Source: CBP. 
Page 11 GAO-05-466T 

CBP then deploys a CSI team, which generally consists of three types of 

officials—targeters, intelligence analysts, and special agents. These 

officials come from either CBP or U.S. Immigration and Customs 

Enforcement (ICE). The team leader is a CBP officer or targeter who is 

assigned to serve as the immediate supervisor for all CSI team members 

and is responsible for coordinating with host government counterparts in 

the day-to-day operations. The targeters are team members responsible for 

targeting shipments and referring those shipments they determine are 

high-risk to host government officials for inspection. The targeter may also 

observe inspections of containers. The intelligence analyst is responsible 

for gathering information to support targeters in their efforts to target 

containers. In addition, the special agents are to coordinate all 

investigative activity resulting from CSI-related actions, as well as act as 

liaison with all appropriate U.S. embassy attachés. Under the CSI program, 

the targeting of cargo is largely dependent on CBP targeters’ review of 

information contained within CBP’s Automated Targeting System (ATS) in 

conjunction with other sources to determine the risk characterization of a 

container.5

CSI teams refer any containers they characterize as high-risk to host 

government officials for concurrence to inspect. If host government 

officials, on the basis of their review, agree that the shipment is high-risk, 

they will proceed with an inspection using nonintrusive inspection 

equipment (that is, X-ray) and physical examinations, if warranted. If the 

host government officials determine, on the basis of their review, that a 

shipment is not high-risk, they will deny inspection of the shipment. For 

any high-risk shipment for which an inspection is not conducted, CSI 

teams are to place a domestic hold on the shipment, so that it will be 

inspected upon arrival at its U.S. destination. 

We have conducted previous reviews of the C-TPAT and CSI programs and 

CBP’s targeting and inspection strategy. In July 2003, we reported that 

CBP’s management of C-TPAT and CSI had not evolved from a short-term 

focus to a long-term strategic approach.6

 We recommended that the 

 5

For all cargo containers arriving in the United States, CBP uses a targeting strategy that 

employs its computerized targeting model, the Automated Targeting System. CBP uses ATS 

to review container documentation and help characterize the risk level of shipments to 

determine the need for additional documentary review or physical inspection. 

6

GAO, Container Security: Expansion of Key Customs Programs Will Require Greater 

Attention to Critical Success Factors, GAO-03-770 (Washington, D.C.: July 25, 2003). 

Prior GAO Work 

Disclosed Challenges 
Page 12 GAO-05-466T 

Secretary of Homeland Security work with the CBP Commissioner to 

develop for both programs (1) strategic plans that clearly lay out the 

program’s goals, objectives, and detailed implementation strategies; (2) 

performance measures that include outcome-oriented indicators; and (3) 

human capital plans that clearly describe how the programs will recruit, 

train, and retain new staff to meet the program’s growing demands as CBP 

implements new program elements. In March 2004, we testified that CBP’s 

targeting system does not incorporate all key elements of a risk 

management framework and recognized modeling practices in assessing 

the risks posed by oceangoing cargo containers.7

My statement will now focus on the results of our work on the C-TPAT 

program. 

In our C-TPAT report we noted that the C-TPAT program offers numerous 

benefits to C-TPAT members. As table 2 shows, these benefits may reduce 

the scrutiny of members’ shipments. These benefits are emphasized to the 

trade community through direct marketing in presentations and via CBP’s 

Web site. Although these benefits potentially reduce the likelihood of 

inspection of members’ shipments, CBP officials noted that all shipments 

entering the United States are subject to random inspections by CBP 

officials or inspections by other agencies. 

 7

GAO, Homeland Security: Summary of Challenges Faced in Targeting of Oceangoing 

Cargo Containers for Inspection, GAO-04-557T (Washington, D.C.: March 2004). 

C-TPAT Grants 

Importers Reduced 

Scrutiny with Limited 

Assurance of 

Improved Security 

C-TPAT Benefits Reduce 

Scrutiny of Shipments 
Page 13 GAO-05-466T 

Table 2: Benefits for C-TPAT Members 

Benefit 

Reduces amount of 

scrutiny provided for 

members?

A reduced number of inspections and reduced border wait 

times Yes

Reduced selection rate for trade-related compliance 

examinations Yes

Self-policing and self-monitoring of security activities Yes

Access to the expedited cargo processing at designated 

FAST lanes (for certified highway carriers and certified 

importers along the Canadian and Mexican borders, as well 

as for certified Mexican manufacturers) Yes

Eligible for the Importer Self-Assessment Program and has 

priority access to participate in other selected customs 

programs (for certified importers only) Yes

A C-TPAT supply chain specialist to serve as the CBP 

liaison for validations No

Access to the C-TPAT members list No

Eligible to attend CBP-sponsored antiterrorism training 

seminars No

Source: CBP’s C-TPAT Strategic Plan, January 2005. 

We also reported that CBP does not grant program benefits until it has 

reviewed and certified applicants’ security profiles and, for importers, 

completed an additional review called the vetting process. According to 

CBP, approximately 23 percent of the security profiles it received 

contained shortcomings that prevented the companies from being certified 

and eligible for program benefits. However, CBP has stated that a 

company will not be rejected from participating in C-TPAT if there are 

problems with its security profile. Instead, CBP says it will work with 

companies to try to resolve and overcome any deficiencies with the profile 

itself. Regarding the vetting process, we reported that according to CBP, to 

date most members who have been vetted have proven to have favorable 

or neutral importing histories. CBP officials told us that not many 

members have been denied benefits as a result of the vetting process. 

Although CBP does not grant program benefits until it has certified and 

vetted members, we reported that neither the certification nor the vetting 

process provides an actual verification that the supply chain security 

measures contained in the C-TPAT member’s security profile are accurate 

and are being followed before CBP grants the member benefits. A direct 

CBP Grants Benefits 

before Verification of 

Security Procedures 
Page 14 GAO-05-466T 

examination of selected members’ security procedures is conducted later 

as part of CBP’s validation process, as discussed below. 

As we reported, we found weaknesses in the validation process that limit 

CBP’s ability to ensure that the C-TPAT program supports the prevention 

of terrorists and terrorist weapons from entering the United States. First, 

we reported that CBP’s validation process is not rigorous enough to 

achieve its stated purpose, which is to ensure that the security procedures 

outlined in members’ security profiles are reliable, accurate, and effective. 

CBP officials told us that validations are not considered independent 

audits, and the objectives, scope, and methodology of validations are 

jointly agreed upon with the member representatives. In addition, CBP has 

indicated that it does not intend for the validation process to be an 

exhaustive review of every security measure at each originating location; 

rather, it selects specific facets of the members’ security profiles to review 

for their reliability, accuracy, and effectiveness. For example, the guidance 

to ocean carriers for preparing a security profile directs the carriers to 

address, at a minimum, three broad areas (security program, personnel 

security, and service provider requirements), which contain several more 

specific security measures, such as facilities security and pre-employment 

screening. According to CBP officials, as well as our review of selected 

case files, validations examine only a few facets of members’ security 

profiles. CBP supply chain specialists, who are responsible for conducting 

most of the validations, are supposed to individually determine which 

segments of a company’s supply chain security will be suggested to the 

member for validation. To assist in this decision, supply chain specialists 

are supposed to compare a company’s security profile, as well as any selfassessments or other company materials or information retrievable in 

national databases, against the C-TPAT security guidelines to determine 

which elements of the profile will be validated. Once the supply chain 

specialist determines the level and focus of the validation, the specialist is 

supposed to contact the member company with a potential agenda for the 

validation. The two parties then jointly reach agreement on which security 

elements will be reviewed and which locations will be visited. 

Moreover, as we reported, CBP has no written guidelines for its supply 

chain specialist to indicate what scope of effort is adequate for the 

validation to ensure that the member’s security measures are reliable, 

accurate, and effective, in part because it seeks to emphasize the 

partnership nature of the program. Importantly, CBP has no baseline 

standard for what minimally constitutes a validation. CBP discourages 

supply chain specialists from developing a set checklist of items to 

Weaknesses Exist in 

Process for Verifying 

Security Procedures 
Page 15 GAO-05-466T 

address during the validation, as CBP does not want to give the 

appearance of conducting an audit. In addition, as discussed below, the 

validation reports we reviewed did not consistently document how the 

elements of members’ security profiles were selected for validation. 

Second, we also reported that CBP has not determined the extent to which 

it must conduct validations of members’ security profiles to ensure that 

the operation of C-TPAT is consistent with its overall approach to 

managing risk. In 3 years of C-TPAT operation, CBP has validated about 

11 percent of its certified members. CBP’s original goal was to validate all 

certified members within 3 years of certification. However, CBP officials 

told us that because of rapid growth in program membership and its 

staffing constraints, it would not be possible to meet this goal. In February 

2004, CBP indicated that approximately 5,700 companies had submitted 

signed agreements to participate in the program. As shown in figure 2, by 

April 2005, the number of members had grown to over 9,000, about 4,800 

of which had been certified and were thus eligible for validation. 

According to CBP, as of April 2005, CBP staff had completed validations of 

550 companies, including 174 importers. 

Figure 2: Status of Validating C-TPAT Members, as of April 1, 2005 

In our C-TPAT report we noted that CBP has made efforts to hire 

additional supply chain specialists to handle validations for the growing 

membership. As of August 2004, CBP had hired a total of 40 supply chain 
Page 16 GAO-05-466T 

specialists to conduct validations, with 24 field office managers also 

available to conduct validations. CBP officials told us the bureau is 

currently conducting as many validations as its resources allow. However, 

CBP has not determined the number of supply chain specialists it needs or 

the extent to which validations are needed to provide reasonable 

assurance that the program is consistent with a sound risk management 

approach to securing U.S.-bound goods. 

Finally, we reported that it would not be possible for CBP to meet its goal 

of validating every member within 3 years of certification. Instead, CBP 

told us it is using a risk-based approach, which considers a variety of 

factors to prioritize which members should be validated as resources 

allow. CBP has an internal selection process it is supposed to apply to all 

certified members. Under this process CBP officials are supposed to 

prioritize members for validation based on established criteria but may 

also consider other factors. For example, recent seizures involving CTPAT members can affect validation priorities. If a member is involved in 

a seizure, CBP officials noted that the member is supposed to lose 

program benefits and be given top priority for a validation. In addition, 

CBP officials told us that an importer that failed CBP’s vetting process 

would also be given top priority for a validation. CBP officials have taken 

this approach because any importer that fails the vetting process is not 

supposed to receive program benefits until after successful completion of 

the validation process. 

As we reported, CBP continues to expand the C-TPAT program without 

addressing management weaknesses that could hinder the bureau from 

achieving the program’s dual goals of securing the flow of goods bound for 

the United States and facilitating the flow of trade. First, we reported that 

CBP is still developing an implementation plan to address the strategies 

for carrying out the program’s goals and those elements required in a 

human capital plan. For example, CBP said it has developed new 

positions, training programs and materials, and a staffing plan. Further, 

CBP said it will continue to refine all aspects of the C-TPAT human capital 

plan to include headquarters personnel, additional training requirements, 

budget, and future personnel profiles. 

Second, we reported that CBP continues developing a comprehensive set 

of performance measures and indicators for C-TPAT. According to CBP, 

developing these measures for C-TPAT, as well as other programs in the 

bureau, has been difficult because CBP lacks data necessary to exhibit 

whether a program has prevented or deterred terrorist activity. For 

Incomplete Progress 

Made in Addressing 

Management Weaknesses 
Page 17 GAO-05-466T 

example, as noted in the C-TPAT strategic plan, it is difficult to measure 

program effectiveness in terms of deterrence because generally the direct 

impact on unlawful activity is unknown. The plan also notes that while 

traditional workload measures are a valuable indicator, they do not 

necessarily reflect the success or failure of the bureau’s efforts. CBP is 

working to collect more substantive information—related to C-TPAT 

activities (i.e., current workflow process)—to develop its performance 

measures. In commenting on a draft of our report, CBP indicated it has 

developed initial measures for the program but will continue to develop 

and refine these measures to ensure program success. 

Third, we reported that CBP’s record keeping for the program is 

incomplete, as key decisions are not always documented and 

programmatic information is not updated regularly or accurately. Federal 

regulations require that bureau record-keeping procedures provide 

documentation to facilitate review by Congress and other authorized 

agencies of government. Further, standards for internal control in the 

federal government require that all transactions be clearly documented in 

a manner that is complete, accurate, and useful to managers and others 

involved in evaluating operations. During our review of six company files 

for which validations had been completed, it was not always clear what 

facet of the security profile was being validated and why a particular site 

was selected at which to conduct the validation because there was not 

always documentation of the decision-making process. The aspects of the 

security profiles covered and sites visited did not always appear to be the 

most relevant. For example, one validation report we reviewed for a major 

retailer—one that imports the vast majority of its goods from Asia—

indicated that the validation team reviewed facilities in Central America. 

CBP officials noted that it recently revised its validation report format to 

better capture any justification for report recommendations and best 

practices identified. After reviewing eight of the more recent validation 

reports, we noted that there appeared to be a greater discussion related to 

the rationale for validating specific aspects of the security profiles. 

However, the related company files did not consistently contain other 

documentation of members’ application, certification, vetting, receipt of 

benefits, or validation. While files contained some of these elements, they 

were generally not complete. In fact, most files did not usually contain 

anything other than copies of the member’s C-TPAT agreement, security 

profiles, and validation report. 

Further, we reported that CBP does not update programmatic information 

regularly or accurately. In particular, the reliability of CBP’s database to 

track member status using key dates in the application through validation 
Page 18 GAO-05-466T 

processes is questionable. The database, which is primarily used for 

documentation management and workflow tracking, is not updated on a 

regular basis. In addition, C-TPAT management told us that earlier data 

entered into the database may not be accurate, and CBP has taken no 

systematic look at the reliability of the database. CBP officials also told us 

that there are no written guidelines for who should enter information into 

the database or how frequently the database should be updated. We made 

several requests over a period of weeks to review the contents of the 

database to analyze workload factors, including the amount of time that 

each step in the C-TPAT application and review process was taking. The 

database information that CBP ultimately provided to us was incomplete, 

as many of the data fields were missing or inaccurate. For example, more 

than 33 percent of the entries for validation date were incomplete. In 

addition, data on the status of companies undergoing the validation 

process was provided in hard copy only and included no date information. 

CBP officials told us that they are currently exploring other data 

management systems, working to develop a new, single database that 

would capture pertinent data, as well as developing a paperless 

environment for the program. 

Our C-TPAT report recommended that the Secretary of Homeland Security 

direct the Commissioner of U.S. Customs and Border Protection to take 

the following five actions: 

• strengthen the validation process by providing appropriate guidance to 

specialists conducting validations, including what level of review is 

adequate to determine whether member security practices are reliable, 

accurate, and effective; 

• determine the extent (in terms of numbers or percentage) to which 

members should be validated in lieu of the original goal to validate all 

members within 3 years of certification; 

• complete the development of performance measures, to include 

outcome-based measures and performance targets, to track the 

program’s status in meeting its strategic goals; 

• complete a human capital plan that clearly describes how the C-TPAT 

program will recruit, train, and retain sufficient staff to successfully 

conduct the work of the program, including reviewing security profiles, 

vetting, and conducting validations to mitigate program risk; and 

GAO Recommendations 

and CBP Response 
Page 19 GAO-05-466T 

• implement a records management system that accurately and timely 

documents key decisions and significant operational events, including 

a reliable system for (1) documenting and maintaining records of all 

decisions in the application through validation processes, including but 

not limited to documentation of the objectives, scope, methodologies, 

and limitations of validations, and (2) tracking member status. 

In commenting on a draft of the report, CBP generally agreed with our 

recommendations and outlined actions it either had taken or was planning 

to take to implement them. 

After our work was completed, CBP issued new security criteria for CTPAT importers. Although we have not assessed the new criteria in detail, 

the new criteria appear to better define the minimum security 

expectations of importers participating in the C-TPAT program than the 

prior security guidelines. For example, under the prior security guidelines, 

all importers were to secure containers’ internal and external 

compartments and panels. Under the new security criteria, importers are 

to explicitly require all containers bound for the United States to have 

high-security seals affixed to them. In addition, the new criteria appear to 

place a greater emphasis on security procedures throughout importers’ 

supply chains than the prior guidelines. Specifically, the new criteria state 

that importers must have written and verifiable processes for the selection 

of business partners, as well as documentation of whether these business 

partners are either C-TPAT certified or meet the C-TPAT security 

criteria—requirements not found in the prior security guidelines. 

However, the new security criteria do not address our recommendations 

for improving the program and may place an even greater emphasis on the 

need to strengthen the validation process. According to the new criteria, 

importers wishing to join the C-TPAT program must submit security 

profiles that address the new criteria as part of the certification process. 

But importers who are already C-TPAT members are not required to 

provide any written certification that they meet the new security criteria 

and will not have to resubmit their security profiles. Instead, CBP will use 

validations to gauge whether or not these members have adopted the new 

security criteria. This places a greater emphasis on the need for CBP to 

establish guidelines for what constitutes a validation and the extent to 

which it must conduct validations to ensure that the C-TPAT program is 

consistent with its overall approach to managing risk. 
Page 20 GAO-05-466T 

My statement will now focus on the results of our work on the CSI 

program. 

In our CSI report, we noted that CBP officials told us the CSI program has 

produced factors that contribute to CBP’s ability to target shipments at 

overseas seaports, including improved information sharing between the 

CSI teams and host government officials regarding U.S.-bound shipments 

and a heightened level of bilateral cooperation on and international 

awareness of the need for securing the global shipping system. However, 

we found factors that may limit the program’s effectiveness at some ports, 

including (1) staffing imbalances at CSI ports and (2) weaknesses in one 

source of data CBP relies upon to target shipments. 

As we reported, one factor negatively affecting CBP’s ability to target 

containers is staffing imbalances across ports. Although CBP’s goal is to 

target all U.S.-bound containers at CSI ports before they depart for the 

United States, it has not been able to place enough staff at some CSI ports 

to do so. As a result of these imbalances, 35 percent of U.S.-bound 

shipments from CSI ports were not targeted and were therefore not 

subject to inspection overseas—the key goal of the CSI program. CBP has 

been unable to staff the CSI teams at the levels called for in the CSI 

staffing model because of diplomatic and practical considerations. 

However, CBP’s staffing model for CSI does not consider whether some of 

the targeting functions could be performed in the United States. For 

example, the model does not consider what minimum number of targeters 

need to be physically located at CSI ports to carry out duties that require 

an overseas presence (such as coordinating with host government 

officials) as opposed to other duties that could be performed in the United 

States (such as reviewing manifests and databases). CBP has placed 

targeters at its National Targeting Center to assist CSI teams in targeting 

containers for inspection, which demonstrates that CBP does not have to 

rely exclusively on overseas targeters as called for in its staffing model. 

Further, we reported the existence of limitations in one data source CSI 

teams use for targeting high-risk containers. For CSI, CBP uses manifest 

information as one data source to help characterize the risk level of U.S.-

Improvements 

Needed in CSI 

Targeting, Inspection 

and Management 

Efforts 

Limitations Exist in Ability 

to Target Containers 

Overseas 
Page 21 GAO-05-466T 

bound shipments, information that may be unreliable and incomplete. 

Although CBP officials told us that the quality of the manifest data has 

improved, there is no method to routinely verify whether the manifest data 

accurately reflect the contents within the cargo container. 

As we reported, since the implementation of CSI through September 11, 

2004, 28 percent (4,013) of containers referred to host government officials 

for inspection were not inspected for a variety of reasons including 

operational limitations that prevented the containers from being inspected 

before they left the port. In 1 percent of these cases, host government 

officials denied inspections, generally because inspection requests were 

based on factors not related to security threats, such as drug smuggling. 

Containers referred to host governments for inspection by CSI teams that 

are not inspected overseas are supposed to be referred for inspection 

upon arrival at the U.S. destination port. CBP officials noted that between 

July 2004 and September 2004, about 93 percent of shipments referred for 

domestic inspection were inspected at a U.S. port. CBP officials explained 

that some of these shipments were not inspected domestically because 

inspectors at U.S. ports received additional information or entry 

information that lowered the risk characterization of the shipments or 

because the shipments remained aboard the carrier and were never 

offloaded at a U.S. port. 

Further, we reported that for the 72 percent (10,343) of containers that 

were inspected overseas, CBP officials told us there were some anomalies 

that led to law enforcement actions but that no WMD were discovered. 

There are two types of radiation detection devices used at CSI ports to 

inspect cargo containers—radiation isotope identifier devices and 

radiation portal monitors—as well as various types of X-ray and gammaray imaging machines used at CSI ports to inspect cargo containers, each 

with different detection and identification capabilities. However, the 

inspection equipment used at CSI ports varies in detection capability, and 

there are no minimum requirements for the detection capability of 

equipment used for CSI. In addition, technologies to detect other WMD 

have limitations. As a result, CBP has no absolute assurance that 

inspections conducted under CSI are effective at detecting and identifying 

WMD. According to CBP officials, the bureau has not established 

minimum technical requirements for the nonintrusive inspection 

equipment or radiation detection equipment that can be used as part of 

CSI because of sovereignty issues, as well as restrictions that prevent CBP 

from endorsing a particular brand of equipment. Although CBP cannot 

endorse a particular brand of equipment, the bureau could still establish 

Some Containers Were Not 

Inspected for a Variety of 

Reasons 
Page 22 GAO-05-466T 

general technical capability requirements for any equipment used under 

CSI similar to other general requirements CBP has for the program, such 

as the country committing to establishing an automated risk management 

system. Because the CSI inspection could be the only inspection of a 

container before it enters the interior of the United States, it is important 

that the nonintrusive inspection and radiation detection equipment used as 

part of CSI provides some level of assurance of the likelihood that the 

equipment could detect the presence of WMD. 

As we reported, CBP has made some improvements in the management of 

CSI, but further refinements to the bureau’s management tools are needed 

to help achieve program goals. Regarding a strategic plan for CSI, CBP 

developed a strategic plan in February 2004 that contained three of the six 

key elements the Government Performance and Results Act (GPRA) 

required for executive agency strategic plans but lacked (1) a description 

of how performance goals and measures are related to the general goals 

and objectives of the program, (2) an identification of key factors external 

to the agency and beyond its control that could affect the achievement of 

general goals and objectives, and (3) a description of program evaluations. 

We also reported that CBP told us it was revising the CSI strategic plan to 

address the elements we raised in the report. We noted that it appeared 

that the bureau’s initial efforts in this area met the intent of our prior 

recommendation to develop a strategic plan for CSI, but we could not 

determine the effectiveness of further revisions to the plan without first 

reviewing and evaluating them. 

Further, we recommended in our July 2003 report that CBP expand efforts 

already initiated to develop performance measures for CSI that include 

outcome-oriented indicators. Until recently, CBP based the performance 

of CSI on program outputs such as (1) the number and percentage of bills 

of lading reviewed, further researched, referred for inspection, and 

actually inspected, and (2) the number of countries and ports participating 

in CSI. CBP has developed 11 performance indicators for CSI, 2 of which it 

identified as outcome-oriented: (1) the number of foreign mitigated 

examinations and (2) the percentage of worldwide U.S.-destined 

containers processed through CSI ports. However, CSI lacks performance 

goals and measures for other program objectives. In commenting on a 

draft of our April 2005 report, DHS noted that CBP is continuing to refine 

existing performance measures and develop new performance measures 

for its program goals. For example, CBP was developing a cost efficiency 

measure to measure the cost of work at a port and to contribute to staffing 

decisions. 

CBP Has Made Progress 

Developing a Strategic 

Plan and Performance 

Measures for CSI, but 

Further Refinements Are 

Needed 
Page 23 GAO-05-466T 

Our CSI report recommended that the Secretary of Homeland Security 

direct the Commissioner of U.S. Customs and Border Protection to take 

the following three actions: 

• revise the CSI staffing model to consider (1) what functions need to be 

performed at CSI ports and what functions can be performed in the 

United States, (2) the optimum levels of staff needed at CSI ports to 

maximize the benefits of targeting and inspection activities in 

conjunction with host nation customs officials, and (3) the cost of 

locating targeters overseas at CSI ports instead of in the United States; 

• establish minimum technical requirements for the capabilities of 

nonintrusive inspection equipment at CSI ports, to include imaging and 

radiation detection devices, that help ensure that all equipment used 

can detect WMD, while considering the need not to endorse certain 

companies and sovereignty issues with participating countries; and 

• develop performance measures that include outcome-based measures 

and performance targets (or proxies as appropriate) to track the 

program’s progress in meeting all of its objectives. 

In commenting on a draft of the report, DHS generally agreed with our 

recommendations and outlined actions CBP either had taken or was 

planning to take to implement them. 

This concludes my statement. I would now be happy to answer any 

questions for the subcommittee. 

For further information about this testimony, please contact me at (202) 

512-8816. Stephen L. Caldwell, Deena D. Richart, and Kathryn E. Godfrey 

also made key contributions to this statement. 

GAO Recommendations 

and CBP Response 

GAO Contacts and 

Staff 

Acknowledgments 
Page 24 GAO-05-466T 

Maritime Security: Enhancements Made, But Implementation and 

Sustainability Remain Key Challenges. GAO-05-448T (Washington, D.C.: 

May 17, 2005). 

Container Security: A Flexible Staffing Model and Minimum Equipment 

Requirements Would Improve Overseas Targeting and Inspection

Efforts. GAO-05-557 (Washington, D.C.: April 26, 2005). 

Maritime Security: New Structures Have Improved Information 

Sharing, but Security Clearance Processing Requires Further Attention. 

GAO-05-394 (Washington, D.C.: April 15, 2005). 

Preventing Nuclear Smuggling: DOE Has Made Limited Progress in 

Installing Radiation Detection Equipment at Highest Priority Foreign 

Seaports. GAO-05-375 (Washington, D.C.: March 31, 2005). 

Cargo Security: Partnership Program Grants Importers Reduced 

Scrutiny with Limited Assurance of Improved Security. GAO-05-404

(Washington, D.C.: March 11, 2005). 

Homeland Security: Process for Reporting Lessons Learned from Seaport 

Exercises Needs Further Attention. GAO-05-170 (Washington, D.C.: 

January 14, 2005). 

Port Security: Planning Needed to Develop and Operate Maritime Worker 

Identification Card Program. GAO-05-106 (Washington, D.C.: December 

10, 2004). 

Maritime Security: Better Planning Needed to Help Ensure an Effective 

Port Security Assessment Program. GAO-04-1062 (Washington, D.C.: 

September 30, 2004). 

Maritime Security: Substantial Work Remains to Translate New 

Planning Requirements into Effective Port Security. GAO-04-838

(Washington, D.C.: June 30, 2004). 

Border Security: Agencies Need to Better Coordinate Their Strategies 

and Operations on Federal Lands. GAO-04-590 (Washington, D.C.: June 

16, 2004). 

Homeland Security: Summary of Challenges Faced in Targeting 

Oceangoing Cargo Containers for Inspection. GAO-04-557T (Washington, 

D.C.: March 31, 2004). 

Related GAO Products 
Page 25 GAO-05-466T 

Rail Security: Some Actions Taken to Enhance Passenger and Freight 

Rail Security, but Significant Challenges Remain. GAO-04-598T

(Washington, D.C.: March 23, 2004). 

Department of Homeland Security, Bureau of Customs and Border 

Protection: Required Advance Electronic Presentation of Cargo 

Information. GAO-04-319R (Washington, D.C.: December 18, 2003). 

Homeland Security: Preliminary Observations on Efforts to Target 

Security Inspections of Cargo Containers. GAO-04-325T (Washington, 

D.C.: December 16, 2003). 

Posthearing Questions Related to Aviation and Port Security. 

GAO-04-315R (Washington, D.C.: December 12, 2003). 

Homeland Security: Risks Facing Key Border and Transportation 

Security Program Need to Be Addressed. GAO-03-1083 (Washington, D.C.: 

September 19, 2003). 

Maritime Security: Progress Made in Implementing Maritime 

Transportation Security Act, but Concerns Remain. GAO-03-1155T

(Washington, D.C.: September 9, 2003). 

Container Security: Expansion of Key Customs Programs Will Require 

Greater Attention to Critical Success Factors. GAO-03-770 (Washington, 

D.C.: July 25, 2003). 

Homeland Security: Challenges Facing the Department of Homeland 

Security in Balancing Its Border Security and Trade Facilitation 

Missions. GAO-03-902T (Washington, D.C.: June 16, 2003). 

Transportation Security: Federal Action Needed to Help Address 

Security Challenges. GAO-03-843 (Washington, D.C.: June 30, 2003). 

Transportation Security: Post-September 11th Initiatives and LongTerm Challenges. GAO-03-616T (Washington, D.C.: April 1, 2003). 

Border Security: Challenges in Implementing Border Technology. 

GAO-03-546T (Washington, D.C.: March 12, 2003). 

Customs Service: Acquisition and Deployment of Radiation Detection 

Equipment. GAO-03-235T (Washington, D.C.: October 17, 2002). 
Page 26 GAO-05-466T 

Port Security: Nation Faces Formidable Challenges in Making New 

Initiatives Successful. GAO-02-993T (Washington, D.C.: August 5, 2002). 

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