United States General Accounting Office

GAO Report to the Honorable

Dianne Feinstein, U.S. Senate

April 1998 CUSTOMS SERVICE

Process for Estimating

and Allocating

Inspectional Personnel

GAO/GGD-98-107

GAO United States

General Accounting Office

Washington, D.C. 20548

General Government Division

B-278218 

April 30, 1998

The Honorable Dianne Feinstein

United States Senate

Dear Senator Feinstein:

You asked us to undertake a broad review of the drug enforcement

operations of the U.S. Customs Service along the Southwest border of the

United States. In September 1997, we provided you with information on

selected aspects of Customs’ drug enforcement operations.1

 In that letter,

we detailed, among other things, Customs’ emphasis on its drug

enforcement mission and its use of drug information. Our objectives for

this report were to determine (1) how Customs assesses its needs for

inspectional personnel (inspectors and canine enforcement officers) and

allocates such resources to commercial cargo ports of entry; (2) whether

Customs received all the additional inspectional personnel its assessments

indicated it needed and, if not, why it did not receive them; and

(3) whether there are any known implications of Customs’ not receiving all

of the personnel estimated to be needed and the impact of the additional

personnel that were appropriated on Customs’ drug enforcement

operations.

In developing the information in this report, we (1) obtained and reviewed

relevant budget, workload, personnel allocation, and drug smuggling

threat documents; (2) interviewed cognizant officials at Customs

headquarters, the Department of the Treasury, the Office of National Drug

Control Policy (ONDCP), and the Office of Management and Budget (OMB);

(3) telephonically interviewed Customs officials from the Arizona Customs

Management Center (CMC)2

 and the Nogales, Arizona, port; and (4) visited

two CMCs—Southern California and South Texas—and two ports—Otay

Mesa, California, and Laredo, Texas, where we interviewed cognizant

Customs officials. We did not assess the validity of Customs’ needs

assessments. Our objectives, scope, and methodology are discussed in

more detail in appendix I.

We requested comments on a draft of this report from the heads of OMB,

ONDCP, and the Department of the Treasury or their designees. On April 2,

April 6, and April 8, 1998, respectively, cognizant officials from these

1

See Customs Service: Information on Southwest Border Drug Enforcement Operations

(GAO/GGD-97-173R, Sept. 30, 1997).

2

On October 1, 1995, Customs closed its 7 regional and 42 district offices and replaced them with 20

CMCs.

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agencies provided us with their oral comments. These comments are

discussed near the end of this letter. We performed our work between

June 1997 and February 1998 in accordance with generally accepted

government auditing standards.

Results in Brief Customs does not have an agencywide process for annually determining

its need for inspectional personnel—such as inspectors and canine

enforcement officers—for all of its cargo operations and for allocating

these personnel to commercial ports of entry nationwide. While Customs

has moved in this direction by conducting three separate assessments

since 1995 to determine its need for additional inspectional personnel,

these assessments (1) focused exclusively on the need for additional

personnel to implement Operation Hard Line—Customs’ initiative to

address border violence and drug smuggling—and similar initiatives;

(2) were limited to land ports along the Southwest border and certain sea

and air ports considered to be at risk from drug smuggling; (3) were

conducted each year using generally different assessment factors; and

(4) were conducted with varying degrees of involvement by Customs

headquarters and field units.

Customs conducted the three assessments in preparation for its fiscal year

1997, 1998, and 1999 budget request submissions. To estimate the number

of additional inspectors and canine enforcement officers needed for fiscal

year 1997, Customs combined factors such as the need to (1) fully staff

inspectional facilities and (2) balance enforcement efforts against violators

with (3) the need to move legitimate cargo through the ports. For fiscal

years 1998 and 1999, Customs officials stated that they 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 additional personnel that were funded by

Congress in fiscal years 1997 and 1998 for Operation Hard Line and similar

initiatives, 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”).

Focusing on only 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

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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.

The President’s budgets did not request all of the additional inspectional

personnel Customs’ assessments indicated were needed. For example, the

assessment for fiscal year 1997 estimated that Customs, at a minimum,

needed an additional 1,036 inspectors, canine enforcement officers,

agents, and support staff for ports along the Southwest border to

adequately implement Operation Hard Line. As a result of an internal

review, Customs revised its estimate to 912 additional positions. Treasury

further revised this estimate to 657 additional positions. The President’s

fiscal year 1997 budget ultimately requested 657 additional inspectional

and other personnel (agents and support staff) for Customs. This

represented about 63 percent of Customs’ original 1,036-position estimate.

Congress appropriated $65 million for Operation Hard Line. The House

Appropriations Committee report accompanying the fiscal year 1997

appropriations bill agreed with the President’s request for $65 million for

Hard Line to be used for 657 additional positions and equipment (H.R. Rep.

No. 104-660, at 28 (1996)).

Customs and Treasury officials cited internal and external budget

constraints, drug enforcement policy considerations, and legislative

requirements as the primary factors affecting the number of additional

personnel that Customs could ultimately request and the manner in which

it could allocate or reallocate certain personnel. For example, as discussed

earlier, for fiscal year 1997, Treasury reduced Customs’ revised

912-position estimate for additional inspectional personnel to 657

positions. Treasury officials cited limited budgetary resources as the

reason behind this decision. Further, for fiscal year 1998, ONDCP directed

Customs to reallocate some of the additional 119 inspectors it requested

and was appropriated funds for to Southwest border ports in accordance

with the priorities in the National Drug Control Strategy. Customs had

originally planned to allocate all of these inspectors to air and sea ports

considered to be at risk from drug smuggling, none of which were located

along the Southwest border. Finally, Customs could not move certain

existing positions to the Southwest border because Congress had directed

Customs to use them for specific purposes at specific ports. Such

positions included about 1,200 inspectors funded by user fees.

It is too early to definitively determine (1) whether there are any

implications resulting from Customs not receiving all of the inspectional

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personnel that its needs assessments identified as needed and (2) the

impact of the additional inspectional personnel that were appropriated for

fiscal years 1997 and 1998 on Customs’ drug enforcement operations.

According to Customs officials, the additional inspectors that were hired

in fiscal year 1997 were still in the process of being deployed and trained

on-the-job; the fiscal year 1998 inspectors are in the process of being hired

and trained. According to these officials, Customs will not be able to

assess the full impact of the additional inspectors on its enforcement

operations until these inspectors gain experience, which may be up to 2

years from the time of their deployment. As part of its strategic plan,

Customs plans to assess, among other things, the success of its drug

enforcement operations by employing performance measures and

conducting internal evaluations of its drug strategy’s components.

To successfully implement the Government Performance and Results Act

of 1993 (the Results Act), P.L. 103-62—enacted to improve the efficiency

and effectiveness of federal programs—Customs has to determine its

needs for inspectional personnel for all of its cargo operations and ensure

that available personnel are allocated where they are needed most.

Accordingly, this report is making a recommendation to the Commissioner

of Customs to establish a process to accomplish these tasks.

Background 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. It 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 about 446 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. Of

these 301 ports, 24 are located along the Southwest border and—through

39 crossing points (such as bridges)—handle both passengers and

commercial cargo entering the United States. At the end of fiscal year

1997, Customs had deployed about 28 percent of its inspectors and about

62 percent of its canine enforcement officers at ports along the Southwest

border. This compared to about 24 percent of its inspectors and about

50 percent of its canine enforcement officers being deployed at the

Southwest border in fiscal year 1992, the earliest year that complete data

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were available. This deployment represented an increase of about

36 percent in the number of inspectors and about 67 percent in the number

of canine enforcement officers at the Southwest border over the fiscal

year 1992 level.

Customs’ Anti-Drug

Smuggling Mission

A major goal of Customs is to prevent the smuggling of drugs into the

country by attempting to create an effective drug interdiction, intelligence,

and investigation capability that disrupts and dismantles smuggling

organizations. The Commissioner of Customs has designated this goal to

be the highest priority within Customs. Specifically, as 1 of more than 50

federal agencies involved in the national drug control effort, Customs is

responsible for stopping the flow of illegal drugs through the nation’s ports

of entry. In addition to routine inspections to search passengers, cargo,

and conveyances (these include cars, buses, trucks, aircraft, and marine

vessels) for illegal drugs moving through the ports, Customs’ drug

interdiction efforts include investigations and the use of contraband

enforcement teams3

 and canine enforcement officers.

In February 1995, Customs initiated Operation Hard Line along the

Southwest border to address drug smuggling, including port running (the

practice of racing drug-laden conveyances through a Customs inspection

point), and related border violence through increased and intensified

inspections, improved facilities, and the use of technology. According to

Customs officials, port running had increased in part as a result of

enforcement operations conducted by the Immigration and Naturalization

Service between the ports of entry along the Southwest border. Customs

has expanded its anti-smuggling initiative (called Operation “Gateway”)

beyond the Southwest border to the southern tier of the United States to

include the Caribbean and Puerto Rico.

According to Customs officials, in keeping with the need to perform a

multifaceted mission, Customs does not generally allocate inspectors to

ports of entry exclusively to perform drug enforcement. Accordingly,

while it is the highest priority, drug enforcement is only one of many

functions that inspectors are expected to perform when inspecting goods

and persons. However, in an effort to enhance its drug enforcement

operations, Customs has been using more specialized drug enforcement

units, such as contraband enforcement teams, and assigning inspectors to

such units on a rotational basis.

3

Contraband enforcement teams are specialized teams of inspectors dedicated to, among other things,

intensive examinations of cargo shipments to detect and interdict the movement of narcotics. Their

efforts focus on identifying, selecting, and examining the highest risk shipments.

Page 5 GAO/GGD-98-107 Customs Service
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The Results Act and

Strategic Planning

The Results Act was enacted to improve the efficiency and effectiveness of

federal programs by establishing a system to set goals for program

performance and to measure results. Under the Results Act, executive

agencies were to develop, by September 1997, strategic plans in which

they defined their missions, established results-oriented goals, and

identified the strategies they will use to achieve those goals for the period

covering at least fiscal years 1997 through 2002. These plans are to be

updated at least every 3 years. Beginning in fiscal year 1999, agencies are

also to develop annual performance plans. The Results Act requires that

these plans (1) identify annual performance goals and measures for each

of an agency’s program activities, (2) discuss the strategies and resources

needed to achieve the performance goals, and (3) explain the procedures

the agency will use to verify and validate its performance data.

Customs’ Strategic Plan for fiscal years 1997 through 2002 established a

goal and a number of objectives designed to continue Customs’

multipronged drug enforcement effort to increase the risk of being caught

for those smuggling illegal drugs into the country. The plan also included

measures, such as the number and amounts of narcotics seizures, to gauge

the success of the enforcement efforts and proposed conducting internal

evaluations of specific components of the strategy, such as narcotics

interdiction. Customs’ fiscal year 1999 Annual Performance Plan detailed

performance goals and measures for each of its operational activities. The

plan also discussed the strategies and proposed resources that would be

utilized to achieve the goals.

No Systematic

Approaches to

Determine Customs’

Inspectional

Personnel Needs and

Allocate Personnel

Customs does not have an agencywide process for annually determining

its need for inspectional personnel—such as inspectors and canine

enforcement officers—and for allocating these personnel to commercial

cargo ports of entry nationwide. Customs officials were not aware of any

such process to determine inspectional personnel needs prior to 1995.

While Customs has moved in this direction by conducting three

assessments to determine its need for additional inspectional personnel

since 1995, these assessments (1) focused exclusively on the need for

additional personnel to implement its anti-drug smuggling initiatives, such

as Operation Hard Line and similar initiatives; (2) were limited to land

ports along the Southwest border and certain sea and air ports at risk from

drug smuggling; (3) were conducted each year using different assessment

and allocation factors; and (4) were conducted with varying degrees of

involvement by Customs headquarters and field units. Focusing on only a

single aspect of its operations (i.e., countering drug smuggling); not

Page 6 GAO/GGD-98-107 Customs Service
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consistently including the key field components (i.e., CMCs and ports) in

the 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.

No Known Efforts Prior to

1995 to Determine

Inspectional Personnel

Needs

According to Customs officials, they were not aware of any agencywide

efforts prior to 1995 to determine the need for additional inspectional

personnel at commercial cargo ports of entry. Rather, CMCs (then called

districts) requested additional personnel primarily when new ports were

established. For example, when the new port at Otay Mesa, California, was

established, the Southern California CMC (then called the San Diego

District) requested from headquarters, and was allocated, some additional

personnel to staff the port. Separately, according to Customs officials, as

part of the annual budget request development process, CMCs can also

submit requests for inspectional personnel to fill vacancies in existing

positions created by attrition.

On a broader basis, according to officials at Customs’ Anti-Smuggling

Division (ASD),4

 beginning in the late 1980s, Customs redeployed some

existing inspectional personnel in response to the increasing workload and

drug smuggling threat along the Southwest border. For example, as shown

in figures 1 and 2 (see also app. II), prior to the Hard Line buildup, there

was an increase in inspectional personnel—inspectors and canine

enforcement officers —at Southwest border ports between fiscal years

1993 and 1994. According to ASD officials, this was done in preparation for

the implementation of the North American Free Trade Agreement and the

anticipated increase in related workload. According to these officials,

Customs accomplished the pre-Hard Line buildup by reallocating positions

that had become vacant through attrition from ports around the

country—such as those on the border with Canada—to the Southwest

border.

4

ASD is part of Customs’ Office of Field Operations (OFO). ASD, among other things, serves as the

focal point for assessing the need for inspectional personnel and then allocating them to ports in

support of Customs’ anti-drug initiatives. OFO is the organizational element within Customs

responsible for performing primary (initial) inspections of persons, cargo, and conveyances at air,

land, and sea ports of entry. Nationwide, OFO has over 7,000 inspectors and 500 canine enforcement

officers to perform inspections.

Page 7 GAO/GGD-98-107 Customs Service
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Figure 1: Customs Inspector Staffing

Levels, Fiscal Years 1992 to 1997 Number of inspectors

0

1000

2000

3000

4000

5000

6000

7000

8000

1992 1993 1994 1995 1996 1997

Fiscal year

6159

1488

6258

1592

6421

1673

6588

1664

6835

1654

7207

2023

All inspectors

Inspectors at S.W. border

Note: Fiscal year 1992 was the earliest year for which complete data were available.

Source: GAO analysis of Customs data.

Page 8 GAO/GGD-98-107 Customs Service
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Figure 2: Customs Canine

Enforcement Officer Staffing Levels,

Fiscal Years 1992 to 1997

Number of canine enforcement officers

0

50

100

150

200

250

300

350

400

450

500

550

600

1992 1993 1994 1995 1996 1997

Fiscal year

405

204

417

204

444

236

467

256

469

236

553

340

All canine enforcement officers

Canine enforcement officers at S.W. border

Note: Fiscal year 1992 was the earliest year for which complete data were available.

Source: GAO analysis of Customs data.

Recent Needs Assessments

Focused on

Anti-Smuggling Initiatives

Customs’ personnel needs assessment process for fiscal years 1997

through 1999 focused exclusively on its anti-drug smuggling initiatives,

namely Operations Hard Line and Gateway. In focusing on only one aspect

of its cargo and passenger operations (i.e., countering drug smuggling),

Customs is not identifying the need for inspectional personnel for its

overall cargo processing operations.

According to Customs and Treasury officials, the impetus for the focus of

the needs assessements on the anti-smuggling initiatives, beginning with

Hard Line, was provided by a June 1995 visit by the Deputy Secretary of

the Treasury to ports within the Southern California CMC to observe how

Hard Line was being implemented. According to these officials, the Deputy

Secretary expressed concern about Hard Line’s implementation, especially

about the extensive use of overtime and the apparent lack of results in

terms of drug seizures. According to the officials, the Deputy Secretary

Page 9 GAO/GGD-98-107 Customs Service
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concluded that the Southwest border ports did not have a sufficient

number of inspectors and other personnel to adequately implement Hard

Line. As a result, the Deputy Secretary asked Customs officials to review

the staffing situation at the Southwest border ports and prepare a proposal

for additional staffing and other measures to enhance Hard Line’s

implementation.

In response to the Deputy Treasury Secretary’s concerns about Operation

Hard Line, Customs conducted a needs assessment in 1995 for its fiscal

year 1997 budget submission. Specifically, in June 1995, ASD asked the four

Customs districts (now called CMCs) along the Southwest border to

develop estimates of their inspectional personnel needs. The four districts

were San Diego, California (now the Southern California CMC); El Paso,

Texas (now the West Texas CMC); Laredo, Texas (now the South Texas

CMC); and Nogales, Arizona (now the Arizona CMC). The factors used in this

assessment and its results are discussed later in this report.

Recent Inspectional

Personnel Needs

Assessments Limited to

Certain Ports

Because they focused on Customs’ anti-smuggling initiatives, the

inspectional personnel needs assessments that began in 1995 were

accordingly limited to ports along the Southwest border and the southern

tier of the United States, and to sea and air ports determined to be at risk

from drug smuggling. Also, these assessments focused only on the need

for additional personnel at these ports. Specifically, Customs did not

conduct a review of its 301 ports to determine (1) the appropriate staffing

levels at each one of these ports and (2) whether it was feasible to

permanently reallocate inspectors to the Southwest border ports and other

high-risk ports from other ports around the country that potentially had, at

that time, higher levels of inspectors than justified by workload and other

factors, before assessing the need for additional personnel.

In addition, Customs’ strategic plan and the fiscal year 1999 Annual

Performance Plan did not provide the detail necessary to determine the

level of personnel needed and how Customs planned to align, or allocate,

these personnel to meet its plans’ goals and objectives. The strategic plan,

however, recognized the need to assess the allocation of resources,

including personnel, and their effectiveness and to address any necessary

redeployments, while Customs’ fiscal year 1998 Annual Plan identified the

linkage of its goals with available and anticipated resources as an area that

needed attention.

Page 10 GAO/GGD-98-107 Customs Service
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Customs officials said that they did not conduct broad-based assessments

because the results of these assessments would likely indicate the need to

move inspectional personnel. These officials stated that moving personnel

would be difficult for four primary reasons. First, about 1,200 current

inspectional positions 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. These positions are funded for

specific purposes at specific locations, such as processing arriving

passengers at air and sea ports, in proportion to the revenues contributed

by each user fee category. For example, according to Customs officials,

since air passenger fees contributed about 85 percent of all user fee

revenues, air ports would receive 85 percent of all inspectors funded by

the fee revenues. Consequently, Customs cannot redeploy such positions

to other locations for other purposes, such as inspecting cargo at

commercial cargo ports.

Second, under the terms of its union contract, to permanently move

inspectors from one CMC to another, Customs needed to ask for volunteers

before directing the reassignment of any inspectors. However, when

Customs asked for 200 volunteers—a number far short of what was

ultimately estimated as being needed—to be detailed to the Southwest

border to help implement Operation Hard Line, very few volunteers

emerged. Consequently, Customs abandoned its call for volunteers and

decided to implement Hard Line with existing personnel by relying on the

use of overtime. In other instances that would require inspectors to move,

according to Customs officials, if volunteers did not emerge, Customs

would need to select the most junior inspectors to move. However, for

operational reasons having to do primarily with inspector experience, this

was not an option preferred by Customs.

Third, funding historically was not requested in the President’s budgets or

appropriated by Congress for permanent changes of station (i.e.,

permanent moves) because of the high cost involved. Customs officials

estimated that it cost between $50,000 and $70,000 to move an inspector,

thus making any substantial number of moves prohibitively expensive.

However, more recently, the President’s budgets have requested funding

for redeploying Customs agents, and Congress has appropriated such

funding. For example, in the fiscal year 1998 budget, $4 million was

requested for agent redeployments, and Congress appropriated the

requested amount.

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Fourth, by 1995, Customs had already reallocated positions to the

Southwest border from other ports as the positions became vacant

through attrition. However, according to ASD officials, Customs could no

longer reallocate positions in this manner because some non-Southwest

border ports were experiencing staffing shortages due to attrition and

growing workloads and needed to fill their vacancies.

Customs Used Different

Factors in Its Needs

Assessments

Customs’ three needs assessments utilized different factors from year to

year to determine the need for additional inspectional personnel.

However, Customs’ decision not to consider factors critical to

accomplishing its overall mission every year—such as the configuration of

the ports that was used in the fiscal year 1997 assessment—could have

prevented Customs from estimating the appropriate level of personnel at

each port.

Factors Used in Fiscal Year

1997

For the fiscal year 1997 assessment, ASD provided the Southwest border

districts with a number of factors to use in determining the need for

additional inspectors and canine enforcement officers for their cargo and

passenger operations. The factors were based primarily on the

configuration of ports, which, in addition to its drug enforcement

functions, is a reflection of Customs’ mission critical functions. The

factors were (1) the need to fully staff all primary passenger lanes, taking

into account agreements with the Immigration and Naturalization Service

(INS),5

 including inspectors to conduct preprimary roving;6 (2) the need to

fully staff cargo facilities (primary booths and examination docks), while

taking into account the balance between Customs’ enforcement mission

and the need to facilitate the movement of legitimate conveyances and

their cargo; and (3) the need for canine enforcement officers to support all

cargo and passenger processing operations. The districts were also asked

to (1) assume that they were going to at least maintain the examination

rates being achieved at the time of the assessment, based on the national

standard to examine a minimum of 20 percent of a selected conveyance’s

cargo, and (2) consider the overall drug smuggling threat at ports.

Factors Used in Fiscal Years

1998 and 1999

Unlike the fiscal year 1997 needs assessment process that was based on

the configuration of ports, ASD officials said they used the threat of drug

smuggling at commercial cargo land ports along the Southwest border and

5

Both Customs and INS inspect incoming passengers at ports of entry.

6

Preprimary roving is the process through which Customs inspectors target passengers for intensive

inspections. Rovers are teams of inspectors who, along with canine enforcement officers, attempt to

identify potential smugglers through behavioral analysis, prior intelligence, or canine alert.

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at air and sea ports on the southern tier of the United States and other

locations to estimate the number of additional inspectors needed in fiscal

years 1998 and 1999. However, in not considering land border port

configurations, Customs did not take into account changes in the

configurations that could have implications for the number of inspectional

personnel needed.

For fiscal year 1998, ASD officials said they focused on three aspects of the

drug smuggling threat: (1) the number and location of drug seizures, since

they were evidence of the threat; (2) the use of rail cars by drug smugglers

to smuggle drugs; and (3) the existence of internal conspiracies by

individuals, such as dock workers at ports, to smuggle drugs. According to

the ASD officials, the latter two factors represented the evolving nature of

the drug smuggling threat and needed to be addressed.

For fiscal year 1999, in addition to the latter two factors used in fiscal year

1998, ASD said it also considered the need to address the continued

evolution of the drug smuggling threat, namely (1) an increase in drug

smuggling using waterways bordering the United States and (2) an

expansion in the number of drug smuggling organizations operating in U.S.

cities. According to an ASD official, the factors used in fiscal years 1998 and

1999 were meant to balance Customs’ continued emphasis on the drug

smuggling threat along the Southwest border and the need to address new

threats in other areas, such as Miami and Los Angeles.

Fiscal Year 1997 and 1998

Inspectional Personnel

Allocations Utilized

Different Needs

Assessment Factors

The processes to allocate the inspectional personnel funded by Congress

in fiscal years 1997 and 1998 generally used different needs assessments

factors.7

 For fiscal year 1997, ASD used commercial truck volume to

allocate the new cargo inspectors to the Southwest border ports.8

According to ASD officials, they used the workload data because they

believed that the drug smuggling threat ultimately manifested itself in

terms of conveyance and passenger traffic—commercial trucks, passenger

vehicles, and pedestrians at land ports; aircraft and passengers at air ports;

and vessels, cargo, and passengers at sea ports—and the likelihood that

any one of these conveyances or passengers could carry drugs through any

port at any time.

7

As discussed later in this report, the President’s fiscal year 1999 budget did not request any additional

inspectional resources specifically for cargo processing. Consequently, Customs has not developed an

inspectional resource allocation proposal.

8

Customs considered INS’ passenger allocation model to allocate inspectors to its passenger

processing operations. Since this report focuses on cargo operations, we do not discuss the allocation

of passenger inspectors.

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ASD used an estimated ratio of 10 inspectors for every 100,000 laden (full)

trucks and 5 inspectors for every 100,000 empty trucks to allocate the

additional personnel to the Southwest border ports. An ASD official said

that the ratio was based on ASD’s experience with the number of inspectors

and the length of time needed to inspect laden and empty trucks. In

addition, according to this official, ASD used the ratio because it was

relatively easy to understand and implement and was generally supported

by the CMCs and ports receiving the resources, such as the Otay Mesa port.

For fiscal year 1998, ASD officials stated that they used the same aspects of

the drug smuggling threat used for that year’s needs assessment to allocate

the inspectional personnel that were funded. Accordingly, to address the

use of commercial rail cars to smuggle drugs, for example, ASD estimated

that a team of between four to eight inspectors was needed to inspect a

commercial cargo train, depending on the number of rail cars. Using this

estimate, ASD allocated inspectors to ports with rail car inspection

operations that were facing a drug smuggling threat, such as Laredo and

Brownsville, Texas. However, because Customs did not consider its entire

workload, it did not take into account the anticipated growth in trade

volume and the potential resulting need for additional inspectional

personnel to handle this growth. Further, considering that Customs has

identified workload as an indicator of the drug smuggling threat, it could

not respond to the escalation of the threat as represented by the growth in

its entire workload. Customs officials commented that, since a limited

number of additional inspectors were available for allocation to rail

operations, they allocated a minimum number of inspectors to each port

with such operations, without considering the workload.

In fiscal year 1997, ASD officials stated that, working with Customs’ Canine

Branch,9

 they used workload and the extent of the drug smuggling threat

to allocate the additional canine enforcement officers to ports. No canine

enforcement officers were requested or appropriated for fiscal year 1998.

Needs Assessments and

Allocations Conducted

With Varying Degrees of

Involvement by Customs

Units

Customs’ needs assessments and allocations were conducted with varying

degrees of involvement by headquarters and field units. ASD had the lead

role in the assessments and allocations, while other units—CMCs and

ports—had more limited roles. Specifically, while Southwest border CMCs

and ports conducted the fiscal year 1997 assessment, they were not

involved in the subsequent allocation of the personnel that were funded. In

9

The Canine Branch is a unit within OFO that is responsible for the training and operational oversight

of Customs’ canine enforcement units.

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its role, ASD compiled the results of the needs assessment. Customs’ Office

of Investigations10 estimated the number of investigative agents and other

staff needed to support the inspectors and canine enforcement officers.

The Canine Branch estimated the number of canine enforcement officers

needed to provide operational support to inspectors. As described earlier,

ASD also allocated the inspectors and, working with the Canine Branch, the

canine enforcement officers that were funded by Congress. The Office of

Investigations allocated the agents and support staff.

ASD conducted the fiscal year 1998 needs assessment and allocation

processes and the fiscal year 1999 needs assessment. CMCs and ports

affected by ASD’s proposed fiscal year 1998 allocations were asked to

comment on them. Five CMCs and two ports submitted written comments.

Three CMCs indicated that they were satisfied with the number of

additional inspectors to be allocated to them. Two CMCs and two ports

indicated that additional inspectors were needed. ASD officials said that

they took these comments into consideration when finalizing the

allocation.

According to ASD officials, they assumed a leading role because the needs

assessments and subsequent allocations were being conducted exclusively

in support of Customs’ anti-drug smuggling initiatives, such as Operation

Hard Line. These initiatives are conducted under ASD’s oversight. In

addition, an ASD official explained that ASD was fully cognizant of the

threat, workload, and other factors relevant to the needs assessment and

allocation processes at the CMCs and ports; thus, it was able to conduct

them without the need to consult extensively with the CMCs and ports.

However, because it did not fully involve the two key field components

responsible for day-to-day operations (i.e., the CMCs and ports) throughout

the needs assessment and allocation processes, Customs received no input

from those who, by virtue of their operational roles, are in the best

position to know the levels of inspectional personnel they need.

10The Office of Investigations has about 2,500 special agents and about 1,100 other personnel in its

aviation, marine, and intelligence units. Among other things, special agents investigate drug seizures at

ports and develop cases that implicate smuggling organizations.

Page 15 GAO/GGD-98-107 Customs Service
B-278218 

Effective Implementation

of the Results Act Requires

the Establishment of a

Link Between the

Deployment of Resources

and the Achievement of

Performance Goals

The Results Act specifies that all agencies’ strategic plans should have six

critical components. Among these is the establishment of approaches or

strategies to achieve general goals and objectives. In addition, the Results

Act requires that, beginning in fiscal year 1999, agencies must develop

annual performance plans to establish a link between their budget

requests and performance planning efforts. The Act also envisioned that

the strategic and annual performance planning cycles would be iterative,

mutually reinforcing processes.

We have previously reported11 that under strategic planning envisioned by

the Results Act, as part of establishing strategies to achieve goals, strategic

plans and annual performance plans need to describe, among other things,

(1) the human and other resources needed and (2) how agencies propose

to align these resources with their activities to support mission-related

outcomes. We have accordingly pointed out that in order to effectively

implement the Results Act, and as part of the annual performance

planning process, agencies will need to consider how they can best deploy

their resources to create a synergy that effectively and efficiently achieves

performance goals.

Consequently, to effectively implement the Results Act, Customs will need

to consider the relationship or link between the personnel it will have

available and the results it expects these personnel to produce. However,

its most recent estimates of the need for inspectional personnel and

allocations of such personnel to ports were too narrowly focused on

certain aspects of its operations and limited to certain ports to clearly

achieve such a link for all of its operations.

As discussed earlier, in its strategic plan, Customs has already recognized

the need to review the deployment of its resources, including personnel;

evaluate their effectiveness; and address any necessary redeployments. In

addition, in its fiscal year 1998 Annual Plan, Customs has identified the

linkage of available and anticipated resources with achieving performance

goals as an area that needs attention.

11See Executive Guide: Effectively Implementing the Government Performance and Results Act

(GAO/GGD-96-118, June 1996), Government Reform: Goal Setting and Performance

(GAO/AIMD/GGD-95-130R, Mar. 27, 1995), and Agencies’ Annual Performance Plans Under the Results

Act: An Assessment Guide to Facilitate Congressional Decisionmaking (GAO/GGD/AIMD-10.1.18,

Feb. 1998).

Page 16 GAO/GGD-98-107 Customs Service
B-278218 

Not All of the

Inspectional

Personnel Customs

Estimated It Needed

Were Requested

The President’s budgets did not request all of the additional personnel

Customs’ assessments indicated it needed. According to Customs and

Treasury officials, budget constraints, drug enforcement policy

considerations, and legislative requirements affected the number of

personnel Customs could request and how it could allocate those it

received.

Fiscal Year 1997 Additional

Personnel Estimates and

Requests

For its fiscal year 1997 personnel needs assessment, Customs’ four

districts (now CMCs) along the Southwest border estimated that they

needed 931 additional inspectors and canine enforcement officers to

adequately implement Operation Hard Line. While reviewing this

assessment, the Office of Investigations determined that an additional 75

agents and 30 support staff for the agents were needed to complement the

districts’ request. This raised the estimate to a total of 1,036 additional

positions. According to ASD, CMC, and port officials, this estimate

represented the minimum number of additional positions needed to

adequately implement Hard Line.

The President’s fiscal year 1997 budget ultimately requested 657—or about

63 percent of Customs’ original estimate—additional inspectors, canine

enforcement officers, agents, and support staff. Congress appropriated

funds for the 657 positions. In terms of inspectional personnel specifically

for commercial cargo, Customs received funding for about 80 percent (260

of 325) of the additional inspectors, 63 percent (157 of 249) of the

additional canine enforcement officers, and about 96 percent (101 of

105) of the additional agent and support positions originally estimated as

being needed. Figure 3 provides a position-by-position comparison of what

Customs estimated it needed for fiscal year 1997 and what was actually

requested and appropriated.

Page 17 GAO/GGD-98-107 Customs Service
B-278218 

Figure 3: Comparison of Customs’

Original Estimated Inspectional

Personnel Needs With Its Actual

Appropriation, Fiscal Year 1997.

Number of personnel

0

150

300

450

600

750

900

1050

All resources Cargo

inspectors

Canine

enforcement

officers

Passenger

inspectors

Agents and

support

Resource category

1036

657

325

260 249

157

357

139 105 101

Resources estimated to be needed

Resources appropriated

Source: GAO analysis of Customs data.

Tables 1 and 2 show how the funded inspector and canine enforcement

officer positions in fiscal year 1997 were allocated to CMCs and how these

allocations compared with the original Customs estimates.

Page 18 GAO/GGD-98-107 Customs Service
B-278218 

Table 1: Fiscal Year 1997 Estimates

and Allocations of Additional

Inspectors

Location

Original

Customs

estimate Allocation

Allocation as

percentage of

original

estimate

Overall 325 260 80%

Southern California CMC 83 53 64%

Arizona CMC 30 24 80%

West Texas CMC 131 47 36%

South Texas CMC 81 128 158%

South Florida CMC 0 8 N/A

Source: GAO analysis of Customs data.

Table 2: Fiscal Year 1997 Estimates

and Allocations of Additional Canine

Enforcement Officers

Location

Original

Customs

estimate Allocation

Allocation as

percentage of

original

estimate

Overall 249 157 63%

Southern California CMC 37 37 100%

Arizona CMC 32 32 100%

West Texas CMC 33 32 97%

South Texas CMC 147 55 37%

South Florida CMC 0 1 N/A

Source: GAO analysis of Customs data.

Fiscal Year 1998 Additional

Personnel Estimates and

Requests

Fewer inspectional positions were requested for Customs than it originally

determined were needed in fiscal year 1998. For that year, Customs

initially estimated that it needed 200 additional cargo inspectional

positions. However, the President’s fiscal year 1998 budget requested

119—or about 60 percent of Customs’ original estimate—additional cargo

inspectional positions. Congress appropriated funding for the 119

positions. Table 3 shows how funded inspector positions were allocated

and how these allocations compared with the original Customs estimates.

Page 19 GAO/GGD-98-107 Customs Service
B-278218 

Table 3: Fiscal Year 1998 Estimates

and Allocations of Additional

Inspectors

Location

Original

Customs

estimate Allocations

Allocation as

percentage of

original

estimate

Overall 200 119 60%

High-risk air and sea ports 200 72 36%

Southwest border ports 0 47 N/A

Source: GAO analysis of Customs data.

Fiscal Year 1999 Additional

Personnel Estimates

For fiscal year 1999, Customs estimated that it needed an additional 479

inspectors, 85 canine enforcement officers, 211 agents, 33 intelligence

analysts, and 68 marine enforcement officers, for a total of 876 additional

positions. However, the President’s fiscal year 1999 budget requested 27

agents as part of a separate initiative called the “Narcotics and Drug

Smuggling Initiative” to counter drug smuggling. This request represented

3 percent of Customs’ total estimate and about 13 percent of the estimate

for agents.

Budget Constraints, Policy

Considerations, and

Legislative Requirements

Cited as Reasons Affecting

Personnel Request and

Allocation Decisions

Customs and Treasury officials cited internal and external budget

constraints, drug enforcement policy considerations, and legislative

requirements as the primary factors affecting the number of additional

personnel that Customs requested and the manner in which it allocated

appropriated personnel or reallocated existing personnel.

Budget Constraints Affected

Personnel Requests

Budget constraints affected the number of additional inspectional

personnel that Customs requested for fiscal years 1997, 1998, and 1999.

Specifically, according to Customs officials, internal budget constraints

resulted in their reducing the original fiscal year 1997 1,036-position

request to 912 positions. Customs subsequently submitted its request for

912 additional positions to Treasury. Treasury officials, also citing budget

constraints, including their decision to maintain budget requests within

OMB’s overall targets for Treasury, further reduced Customs’ request to 657

additional positions.

Customs’ fiscal year 1997 request was transmitted by Treasury as part of

its departmental request to OMB for an initial review. According to Customs

Page 20 GAO/GGD-98-107 Customs Service
B-278218 

and Treasury officials, upon review, OMB denied the request.12 Instead, OMB

recommended that Customs move 240 existing inspectional positions to

the Southwest border to help implement Operation Hard Line. OMB’s

decision was appealed by Treasury and ONDCP, which had already certified

Customs’ request for 657 additional positions as adequate to meet the

National Drug Control Strategy’s goals.13 In its appeal, Treasury cited the

detrimental effect OMB’s denial would have on Customs’ drug enforcement

operations, including its inability to increase the number of cargo

examinations. In its own appeal, ONDCP identified the level of personnel for

Customs as a critical issue and argued that the requested inspectional

personnel were needed to strengthen the Southwest border against drug

smuggling.

According to Customs officials, through subsequent negotiations following

Treasury’s appeal involving, among others, the Treasury Secretary and the

OMB Director, OMB approved the 657-position request. The 657

positions—and $65 million to fund them—were ultimately funded when

Treasury received an additional $500 million from Congress as part of its

budget appropriation, according to Treasury officials.

As discussed earlier, for fiscal year 1998, Customs originally estimated that

200 additional cargo inspectors were needed for air and sea ports

determined to be at risk from drug smuggling. None of the ports were

located along the Southwest border. Treasury initially denied Customs’

request for 200 positions and later approved for submission to OMB a

request for 119 additional positions. Customs and Treasury officials again

cited budget constraints as the reason for the reduction. As part of its role

(see footnote 12), ONDCP certified the submission as adequate. According

to Customs budget documents, the 119 positions were funded for 1 year

with appropriations from the Violent Crime Reduction Trust Fund.14 For

fiscal year 1999, the President’s budget is proposing that these positions be

funded from Customs’ Salaries and Expenses account.

12OMB officials would not discuss the details of their decisionmaking process or provide relevant

documents related to Customs’ request for inspectional personnel. The OMB officials stated that they

could neither provide nor discuss such information because it involved internal administration budget

deliberations.

13By law (21 U.S.C. 1502(c)), all departments, bureaus, and independent agencies with responsibilities

under the National Drug Control Strategy are required to submit their drug budget requests to ONDCP.

ONDCP is to review the drug budgets to determine if they are adequate to implement the goals of the

strategy. ONDCP then is to send a letter to the cognizant entity advising it either that its budget is

adequate or that changes are needed prior to its submission to OMB.

14The Violent Crime Reduction Trust Fund was established by the Violent Crime Control and Law

Enforcement Act of 1994 (P.L. 103-322). Among other things, the Trust Fund provides funding for

drug-related programs.

Page 21 GAO/GGD-98-107 Customs Service
B-278218 

For fiscal year 1999, Customs estimated that it needed an additional 876

inspectional and related positions for its anti-drug smuggling initiatives at

the Southwest border and at air and sea ports believed to be at risk from

drug smuggling. According to an ASD official, Treasury supported and

ONDCP certified this estimate, which was then transmitted to OMB for

review. OMB denied the request. Instead, the President’s fiscal year 1999

budget included a separate 27-agent anti-narcotics initiative.

Personnel Allocation Affected

by Policy Considerations and

Legislative Requirements

The resource allocation process was affected by policy considerations

related to the drug smuggling threat. Specifically, for fiscal year 1997, ASD

changed its initial allocation of inspectional personnel to include a port

not located at the Southwest border. ASD had originally planned to allocate

all of the additional inspectional and canine enforcement officers

exclusively to Southwest border ports. According to an ASD official, ASD

modified the allocation because the South Florida CMC appealed to the

Commissioner of Customs for additional inspectional personnel, citing a

significant drug smuggling threat as indicated by the number of cocaine

seizures—totaling about 10,000 pounds—at Port Everglades port. The

Commissioner agreed with the appeal. Consequently, ASD adjusted its

allocation to provide nine inspectors and canine enforcement officers to

this port.

For fiscal year 1998, during the course of its review of Customs’ request

for the additional resources and its plans to allocate them, ONDCP directed

Customs to change its allocation to include cargo ports along the

Southwest border. According to Customs and ONDCP officials, this was

done to maintain the National Drug Control Strategy’s emphasis on the

Southwest border. Subsequently, Customs reallocated 47 of the 119

positions to Southwest border ports.

According to Customs officials, the potential reallocation of existing

inspectional personnel has also been affected by legislative requirements.

As discussed earlier, positions funded with the user fees established in the

Consolidated Omnibus Budget Reconciliation Act of 1985 as amended,

cannot be redeployed because these positions are funded for specific

purposes at specific ports. In addition, according to the officials, the

positions funded in the fiscal year 1997 appropriation for Operation Hard

Line were to be used exclusively at Southwest border ports.

Page 22 GAO/GGD-98-107 Customs Service
B-278218 

Too Early to

Determine Personnel

Assessment and

Allocation

Implications

It is too early to definitively determine (1) any implications of Customs not

receiving all of the inspectional personnel it originally estimated to be

needed and (2) the effect of the additional personnel that were

appropriated on Customs’ drug enforcement operations. According to

Customs officials, the new inspectors need to gain experience before they

are fully effective. Further, while many of the fiscal year 1998 inspectors

have been hired, few, if any, have finished basic training. Customs plans to

assess the effectiveness of drug enforcement operations by establishing

performance measures and conducting internal evaluations.

New Inspectors Need to

Gain Experience

One reason that it is too early to determine the impact of the additional

inspectional personnel on Customs’ drug enforcement operations is that

new inspectors need to gain experience. For example, according to a

Southern California CMC official, the CMC’s policy is to provide extensive

on-the-job training lasting up to 1 year to new inspectors at its passenger

processing port before deploying them to cargo processing. New

inspectors are effective in interdicting drugs in the passenger processing

environment, but must receive commercial operations training to be

proficient at drug interdiction in the truck and rail environments on the

Southwest border. As a result, according to this official, it may take up to 2

years to fully train new inspectors in the skills needed in all areas of this

CMC’s operations. Also, the South Texas CMC Director said that, once the

new inspectors were hired and trained, they were sent to this CMC for an

additional 10 weeks of specialized training, of which 2 weeks were for

cargo inspections. The Director estimated that it then takes about 6

months before new inspectors are fully productive on their own.

Additional Inspectors

Funded in Fiscal Year 1998

Have Not Been Deployed

A second reason why it is too soon to determine the full impact of the

additional resources is that, while many of the 119 inspector positions

funded for fiscal year 1998 have been filled, few, if any of these inspectors

have completed basic training. An ASD official said that, as of early

April 1998, about 60 percent of the inspectors had been hired and were in

basic training, and thus had not been deployed in the field.

Customs Plans to Evaluate

Effectiveness of

Enforcement Initiatives

Customs plans to evaluate the effectiveness of its anti-drug smuggling

initiatives. To this end, in its fiscal year 1997 to 2002 Strategic Plan,

Customs established seven measures or improvement targets, including

the number and amount of drug seizures and the ratio of seizures to the

number of cargo examinations conducted. Three other measures or

Page 23 GAO/GGD-98-107 Customs Service
B-278218 

targets—including the number of internal conspiracies disrupted—were

being reviewed at the time of the Strategic Plan’s introduction by Customs

management for possible permanent inclusion in the Plan. Customs also

proposed to conduct internal evaluations of its strategies, including the

narcotics strategy. For example, it plans to evaluate the interdiction

component of that strategy in fiscal year 1999.

We have previously reported15 that, while Customs’ goals and objectives

appear to be results-oriented and measurable, it still faces challenges in

evaluating its drug interdiction mission. For example, according to several

Customs officials, it is unclear whether an increase in drug seizures

indicates that Customs has become more effective or that the extent of

drug smuggling has increased significantly.

Conclusions Customs does not have an agencywide process for annually determining

its need for inspectional personnel—such as inspectors and canine

enforcement officers—for all of its cargo operations and for allocating

these personnel to commercial ports of entry. Customs has moved in this

direction since 1995 by conducting three assessments to determine its

need for additional inspectional personnel. However, these assessments

(1) focused exclusively on the need for additional resources to implement

Operation Hard Line and other anti-smuggling initiatives, (2) were limited

to land ports along the Southwest border and certain sea and air ports at

risk from drug smuggling, (3) were conducted each year using different

assessment factors, and (4) were conducted with varying degrees of

involvement from Customs units.

Focusing on only 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 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 conducting its strategic planning under the Results Act, Customs will

need an annual approach that considers all of its commercial ports, its

mission-related functions, and the impact of technology and related

equipment so that it can determine the inspectional personnel it would

need to achieve the desired mission outcomes it details in its strategic and

15See Customs Service: Drug Interdiction Efforts (GAO/GGD-96-189BR, Sept. 26, 1996) and Customs

Service: Comments on Strategic Plan and Resource Allocation Process (GAO/T-GGD-98-15, Oct. 16,

1997).

Page 24 GAO/GGD-98-107 Customs Service
B-278218 

annual performance plans. Customs, in its strategic planning documents,

has already recognized the need to review its personnel deployments,

evaluate their effectiveness, and address any necessary changes and to

address the link between performance goals and existing and anticipated

resources, including personnel.

We recognize that Customs’ requests for inspectional personnel will

continue to be influenced by budget, policy, and legislative constraints.

However, we believe that by developing a process that, in addition to

considering drug enforcement activities, also considers mission-critical

functions related to processing cargo at commercial ports, Customs would

be able to provide Treasury, OMB, ONDCP, and Congress with more

systematically developed personnel needs estimates and rationales for

these estimates.

Recommendation We recommend that, as a sound strategic planning practice, and taking

into account budget and other constraints, the Commissioner of Customs

establish a systematic process to ensure, to the extent possible, that

Customs’ inspectional personnel are properly aligned with its goals,

objectives, and strategies, including those for drug enforcement. Such a

process should include conducting annual assessments to determine the

appropriate staffing levels for its operational activities related to

processing cargo at commercial ports.

Agency Comments

and Our Evaluation

We requested comments on a draft of this report from the Director of OMB,

the Director of ONDCP, and the Secretary of the Treasury, or their

designees. On April 2, April 6, and April 8, 1998, respectively, the Chief of

OMB’s Treasury Branch; the Director of ONDCP’s Office of Programs, Budget,

Research, and Evaluation; and the Assistant Commissioner of Customs’

Office of Field Operations provided us with their agencies’ oral comments

on the draft. These officials generally agreed with our conclusions and

recommendation. The officials also provided technical comments and

clarifications, which we have incorporated in this report where

appropriate. The Assistant Commissioner indicated that Customs had

already undertaken steps to begin implementing the recommendation.

We are sending copies of this report to the Secretary of the Treasury, the

Commissioner of Customs, and to the Chairmen and Ranking Minority

Members of the congressional committees that have responsibilities

Page 25 GAO/GGD-98-107 Customs Service
B-278218 

related to these issues. Copies also will be made available to others upon

request.

The major contributors to this report are listed in appendix III. If you or

your staff have any questions about the information in this report, please

contact me on (202) 512-8777 or Darryl Dutton, Assistant Director, on

(213) 830-1000.

Sincerely yours,

Norman J. Rabkin

Director, Administration

 of Justice Issues

Page 26 GAO/GGD-98-107 Customs Service
Page 27 GAO/GGD-98-107 Customs Service
Contents

Letter 1

Appendix I 

Objectives, Scope,

and Methodology

30

Appendix II 

Customs’ Inspectional

Personnel Levels

33

Appendix III 

Major Contributors to

This Report

36

Tables Table 1: Fiscal Year 1997 Estimates and Allocations of Additional

Inspectors

19

Table 2: Fiscal Year 1997 Estimates and Allocations of Additional

Canine Enforcement Officers

19

 Table 3: Fiscal Year 1998 Estimates and Allocations of Additional

Inspectors

20

 Table II.1: Number of Customs Inspectors Deployed Overall and

at the Southwest Border, Fiscal Years 1992 to 1997

34

Table II.2: Number of Customs Canine Enforcement Officers

Deployed Overall and at the Southwest Border, Fiscal Years 1992

to 1997

35

Figures Figure 1: Customs Inspector Staffing Levels, Fiscal Years 1992 to

1997

8

Figure 2: Customs Canine Enforcement Officer Staffing Levels,

Fiscal Years 1992 to 1997

9

Figure 3: Comparison of Customs’ Original Estimated

Inspectional Personnel Needs With Its Actual Appropriation,

Fiscal Year 1997.

18

Page 28 GAO/GGD-98-107 Customs Service
Contents

Abbreviations

ASD Anti-Smuggling Division

CMC Customs Management Center

OFO Office of Field Operations

OMB Office of Management and Budget

ONDCP Office of National Drug Control Policy

Page 29 GAO/GGD-98-107 Customs Service
Appendix I 

Objectives, Scope, and Methodology

Our objectives in this review were to determine (1) how Customs assesses

its needs for inspectional personnel and allocates these personnel to

commercial ports of entry, (2) whether Customs received all the

inspectional personnel its assessments indicated it needed, and

(3) whether there are any known implications of Customs’ not receiving all

of the personnel estimated to be needed and the impact of the additional

personnel that were appropriated on Customs’ drug enforcement

operations.

To determine how Customs assesses its needs for inspectional personnel

and allocates these personnel to commercial ports of entry, we obtained

and reviewed relevant documentation. The documentation included (1) a

headquarters directive to the then districts—now Customs Management

Centers (CMC)—and ports initiating an assessment of the needs for

inspectional personnel, (2) CMCs’ detailed responses to this directive,

(3) budget proposals and requests, and (4) matrices developed by Customs

headquarters that are used to allocate the inspectional personnel

appropriated by Congress to ports of entry. The documentation also

included summaries of current and historical workloads and staffing levels

and assessments of the drug smuggling threat. We discussed these

documents and related issues with cognizant officials from Customs’

Anti-Smuggling Division within the Office of Field Operations, the Budget

Division within the Office of Finance, and the CMCs and ports we visited or

contacted.

We also held discussions with officials from the Department of the

Treasury’s Office of Finance and Administration and Office of Budget, the

Office of Management and Budget’s (OMB) Treasury Branch, and the Office

of National Drug Control Policy (ONDCP).

To determine whether Customs received all the inspectional personnel it

estimated were needed, we obtained and reviewed relevant budget

documents, such as internal Customs and Treasury memorandums,

reports, and budget request reviews, and congressional appropriations

legislation. We compared the appropriated levels with those that were

estimated as needed and discussed discrepancies with cognizant Customs,

Treasury, and OMB officials.

To determine the known implications, if any, of Customs’ not receiving all

of the personnel it estimated were needed, we obtained and reviewed

relevant documents, such as summaries of Operation Hard Line and

Customs’ Strategic Plan. We also interviewed cognizant Customs officials

Page 30 GAO/GGD-98-107 Customs Service
Appendix I 

Objectives, Scope, and Methodology

at headquarters and at CMCs and ports of entry. During these interviews,

we focused on the effect, if any, of Customs’ not receiving the level of

personnel it originally estimated were needed on its enforcement activities

at ports of entry. We also used this information to determine if the

potential contributions of the additional personnel that were provided to

Customs could be identified.

We visited the Southern California and South Texas CMCs and contacted

the Arizona CMC by telephone because they represented three of the four

CMCs along the Southwest border of the United States. We visited the Otay

Mesa, California, and Laredo, Texas, ports of entry and contacted the

Nogales, Arizona, port of entry by telephone because they each were

among the busiest ports within their respective CMCs in terms of the

number of vehicles and commodities entering the United States each day.

The ports also processed a diverse mix of imports, including produce,

television sets, and liquor.

Laredo consists of two separate cargo facilities: the downtown Laredo

facility and the Colombia Bridge facility; combined, they form the busiest

commercial cargo port along the Southwest border. For the purposes of

this review, we focused only on the operations of the Laredo facility, the

busier of the two facilities. During fiscal year 1996, the Laredo facility

handled about 732,000 vehicles, which was an average of 2,007 vehicles

per day.1

 The Laredo facility had 13 dock spaces to examine trucks and

cargo and, as of July 1997, had a staff of 49 inspectors, canine enforcement

officers, and supervisors. The Laredo facility is located 154 miles south of

San Antonio, Texas.

Otay Mesa was the third busiest commercial cargo port on the Southwest

border. In fiscal year 1996, Otay Mesa handled over 516,000 vehicles,

which was an average of 1,422 vehicles per day. The port had over 100

dock spaces available for inspections and, as of July 1997, had 110

inspectors, canine enforcement officers, and supervisors. Otay Mesa is

located about 15 miles south of San Diego.

Nogales, Arizona, was the fifth busiest commercial cargo port on the

Southwest border, handling about 208,000 vehicles during fiscal year 1996,

which was an average of 572 vehicles per day. Nogales had 92 dock spaces

dedicated to Customs inspections and, as of April 1997, had a staff of 27

1

The average number of vehicles per day reflects the traffic average over a 1-year period, which

includes both weekdays, when the traffic volume is much higher, and weekends, when the traffic

volume is much lower.

Page 31 GAO/GGD-98-107 Customs Service
Appendix I 

Objectives, Scope, and Methodology

inspectors, canine enforcement officers, and supervisors. The port is

located 67 miles south of Tucson, Arizona.

Since it was not material for the purposes of this review, we did not

independently verify the accuracy and validity of Customs’ workload and

personnel data. However, to obtain some indication about the overall

quality of the data and Customs’ own confidence in their accuracy and

validity, we held discussions with a cognizant Customs official. According

to this official, the personnel data resided in Customs’ Office of Human

Resources database. The workload data resided in its Port Tracking

System database. The Customs official expressed general confidence in

the accuracy and validity of the data. He said his confidence was based on

the fact that the data were compiled using standardized definitions and

entry formats.

Page 32 GAO/GGD-98-107 Customs Service
Appendix II 

Customs’ Inspectional Personnel Levels

The number of Customs inspectional personnel—inspectors and canine

enforcement officers—increased overall between fiscal year 1992, the

earliest year for which complete data were available, and fiscal year 1997.

During the same period, the number and percentage of inspectional

personnel deployed at the Southwest border, while increasing overall,

fluctuated from year to year.

According to Customs officials, year-to-year fluctuations in personnel

levels could be attributed in part to the effects of attrition. For example,

while additional positions may have been funded for a particular year or

purpose (for example, in fiscal year 1997, for Operation Hard Line), others

may have become vacant through retirement.

In addition, according to Customs and Treasury officials, other positions

could be lost because of the effects of reductions in Customs’ baseline

funding. For example, in fiscal year 1997, Customs had to absorb a

reduction of $38 million in its baseline funding to address unfunded

mandates. As a result, 733 positions were removed through a

comparability adjustment by OMB because they could not be funded.

According to OMB officials, a comparability adjustment brings an agency’s

authorized staffing levels more into line with actual funded levels. The loss

of the 733 positions more than offset the 657 additional positions

appropriated for Operation Hard Line, according to Customs officials.

The Customs officials also cautioned that end-of-year data represented

only a point-in-time snapshot of personnel levels. Accordingly, funded

personnel levels throughout a particular year could have been lower or

higher than the end-of-year number.

Customs’ Inspector

Personnel Levels (Fiscal

Years 1992 Through 1997)

Table II.1 shows that the number of Customs inspectors overall grew by

about 17 percent between fiscal years 1992 and 1997. During the same

period, while fluctuating from year to year, the number of inspectors

deployed at the Southwest border grew by about 36 percent. The number

of inspectors deployed at the Southwest border as a percentage of all

Customs inspectors also fluctuated from year to year, but grew from about

24 percent of the total in fiscal year 1992 to about 28 percent in fiscal year

1997.

Page 33 GAO/GGD-98-107 Customs Service
Appendix II 

Customs’ Inspectional Personnel Levels

Table II.1: Number of Customs

Inspectors Deployed Overall and at the

Southwest Border, Fiscal Years 1992

to 1997

Fiscal year Overall

Southwest

border

Percentage

deployed at

Southwest

border

1992 6,159 1,488 24.2%

1993 6,258 1,592 25.4

1994 6,421 1,673 26.1

1995 6,588 1,664 25.3

1996 6,835 1,654 24.2

1997 7,207 2,023 28.1

Percentage change, fiscal years 1992-1997 17.0% 35.9%

Note 1: Fiscal year 1992 was the earliest year that complete data were available.

Note 2: Inspector numbers could not be separated by passenger and cargo processing

functions. According to Customs, ports shift inspectors between functions, depending on

workload.

Source: GAO analysis of Customs data.

Customs’ Canine

Enforcement Officer

Personnel Levels (Fiscal

Years 1992 Through 1997)

Table II.2 shows that the number of Customs canine enforcement officers

overall increased between fiscal years 1992 and 1997 by about 37 percent.

The number of canine enforcement officers deployed at the Southwest

border fluctuated during the same period, while growing by about

67 percent. The number of canine enforcement officers deployed at the

Southwest border as a percentage of the total, while also fluctuating from

year to year, increased from about 50 percent in fiscal year 1992 to about

62 percent in fiscal year 1997.

Page 34 GAO/GGD-98-107 Customs Service
Appendix II 

Customs’ Inspectional Personnel Levels

Table II.2: Number of Customs Canine

Enforcement Officers Deployed Overall

and at the Southwest Border, Fiscal

Years 1992 to 1997

Fiscal year Overall

Southwest

border

Percentage

deployed at

Southwest

border

1992 405 204 50.4%

1993 417 204 48.9

1994 444 236 53.1

1995 467 256 54.8

1996 469 236 50.3

1997 553 340 61.5

Percentage change, fiscal years 1992-1997 36.5% 66.7%

Note 1: Fiscal year 1992 was the earliest year that complete data were available.

Note 2: Canine enforcement officer numbers could not be separated by passenger and cargo

processing functions. According to Customs, ports shift canine enforcement officers between

functions, depending on workload.

Source: GAO analysis of Customs data.

Page 35 GAO/GGD-98-107 Customs Service
Appendix III 

Major Contributors to This Report

General Government

Division, Washington,

D.C.

Darryl W. Dutton, Assistant Director

Seto J. Bagdoyan, Evaluator-in-Charge

Wendy C. Graves, Evaluator

Office of the General

Counsel, Washington,

D.C.

Ann H. Finley, Senior Attorney

Los Angeles Field

Office

Kathleen H. Ebert, Senior Evaluator

(264439) Page 36 GAO/GGD-98-107 Customs Service
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