Department of Homeland Security 

Office of Inspector General 

CBP's Container Security Initiative Has 


Proactive Management and Oversight 


but Future Direction Is Uncertain 


(Letter Report)
 

OIG-10-52 February 2010 
 

 

Office of Inspector General 

U.S. Department of Homeland Security

Washington, DC 20528 

February 3, 2010 

MEMORANDUM FOR: 	 David V. Aguilar 

 Acting Commissioner 

United States Customs and Border Protection 

FROM: 	 Richard L. Skinner 

Inspector General 

SUBJECT:	 Final Letter Report: CBP’s Container Security Initiative 

Has Proactive Management and Oversight but Future 

Direction Is Uncertain (OIG-10-52) 

We initiated an audit to determine the efficacy of Customs and Border Protection’s 

(CBP) management and oversight of the Container Security Initiative (CSI) to achieve its 

mission to identify and inspect high-risk cargo at foreign ports. CBP established CSI in 

2002 as part of its layered security approach centered on advanced intelligence, effective 

inspections, a secure port environment, and international screening of cargo to manage 

the large volume of trade to the United States 

CBP uses proactive management and oversight processes through CSI to identify and 

inspect high-risk cargo at foreign ports. CBP conducts periodic evaluations of overseas 

CSI operations and has software tools to help managers monitor port activities. 

However, CBP could improve its local port standard operating procedures and the criteria 

used to evaluate these procedures. The CSI Strategic Plan does not address how the 

program integrates with other international maritime cargo security programs within 

CBP’s layered security strategy. The strategic plan also needs updated performance 

measures and does not include a vision for the future direction of the program. We are 

making three recommendations on actions that CBP can take in each of these areas to 

enhance its approach to ensuring international maritime cargo security. 

In its response to a draft of this report, CBP concurred with our recommendations and 

outlined plans and actions to implement the needed improvements. A copy of the 

comments in their entirety is included in Appendix B. Based on the comments, we 

addressed data sensitivity concerns and made technical revisions to the report as 

appropriate. We consider the recommendations resolved and open and will close them 

when implementation is complete. Please advise our office within 90 days of the date of 

this memorandum of CBP’s progress in implementing the recommendations. 
Consistent with our responsibility under the Inspector General Act, we are providing 

copies of this report to appropriate congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We will post the 

report on our website. 

Should you have any questions, please call me, or your staff may contact Anne L. 

Richards, Assistant Inspector General for Audits, at (202) 254-4100. 
Background 

United States Customs and Border Protection’s (CBP) mission includes protecting the 

American public against terrorists and the instruments of terror. One widely recognized 

area of vulnerability for entry of weapons of mass destruction is the Nation’s seaports. In 

2008, approximately 11 million maritime cargo containers arrived at the Nation’s 

seaports. To manage the large volume of cargo, CBP employs a layered security 

approach centered on advance intelligence, effective inspections, a secure port 

environment, and international screening of cargo. 

As part of its layered security approach, CBP established the Container Security Initiative 

(CSI) as a pilot program in 2002. The Security and Accountability for Every Port (SAFE 

Port) Act of 2006 made the program permanent. CSI uses risk-based analysis to screen 

maritime cargo for weapons of mass destruction before the cargo is laden on vessels 

destined for the United States. CBP officers work with foreign customs officials to 

identify and inspect maritime cargo that pose a security risk before the cargo is shipped to 

the United States. In 2009, CBP operated CSI in 53 seaports in the Americas, the 

Caribbean, Europe, Africa, the Middle East, and Asia. In 2007, there were 58 CSI 

seaports managing approximately 86 percent of container cargo that arrived in the U.S. 

The percentage of cargo arriving may have dropped because the number of CSI ports was 

reduced from 58 to 53 and due to the overall decrease in worldwide cargo due to the 

current economic situation. Approximately 150 CBP officers at CSI ports analyze 

shipping information and refer high-risk cargo to host country officials for inspection. 

Figure 1 illustrates the cargo-screening process. 

CBP Officers 

analyze shipping 

information to 

identify high-risk 

cargo. 

Screening 

CBP Officers review 

the shipping 

information and 

select high-risk 

cargo to be 

presented to the 

host country for 

inspection 

If accepted for 

inspection, the cargo 

is scanned using 

large-scale NII 

equipment. 

CBP Officers or host 

country officials 

identify any 

anomalies in the xray image. 

Targeting Anomaly 

Detection 

CBP Officers or host 

country officials 

open containers to 

locate anomaly. 

Physical 

Examination 

Officials determine if 

the anomaly 

presents a threat. 

Anomaly 

Resolution 

The container is 

loaded onto the 

cargo ship. 

Lading 

(if anomaly is found) 

Resolution 

Officials take 

appropriate steps to 

resolve the threat. 

(if threat is not found) 

Inspection 

(if threat is not found) 

(if threat is found) 

Figure 1: Flowchart of CSI Cargo Screening Process 

Page 1 
Management and Oversight Process of CSI Port Operations 

CBP initiated several activities to manage and oversee the CSI program. In 2007, CBP 

established the Evaluations and Assessments Branch (EAB) to conduct periodic reviews 

of operational CSI ports, determine the effectiveness of the CSI program, and ensure 

effective coordination with foreign host governments. Evaluation teams review the 

targeting, case development, examination, and administrative activities at the ports at 

least every 2 years. In 2009, EAB evaluated CSI operations at 36 CSI ports. 

After the teams complete their CSI port evaluations, they submit a report with findings, 

recommendations, and an action plan for implementing recommendations. Annually, the 

EAB prepares a consolidated report for CSI management summarizing the teams’ findings 

and recommendations to improve the CSI program and its operations. EAB teams have 

recommended enhancements, such as improved targeting packages developed by CBP 

officers and used to refer high-risk cargo to the host nation, and increased assurance that 

CSI team members are familiar with applicable foreign guidance and procedures. 

CSI’s EAB created two managerial tools to oversee and evaluate its operations. The first 

tool is an information management system to collect and maintain statistics on high-risk 

cargo. This web-based system provides managers with information such as the number of 

examinations requested by the CBP officers at a specific port, allowing them to monitor 

CSI operations on a daily basis. The second tool provides evaluators with a standard 

method for conducting evaluations and reporting the results. EAB said that the use of these 

two tools helps to reduce human error in data reporting and enables CSI headquarters 

officials to identify and resolve potential problems. 

Prior Audits 

The United States Government Accountability Office (GAO) issued two audit reports on 

CSI in April 2005 and January 2008.1 GAO recommended that CBP (1) improve its 

staffing model to increase flexibility, (2) strengthen its process for evaluating CSI teams, 

(3) improve the quality of information gathered about host governments’ nonintrusive 

inspection systems, and (4) enhance CSI performance measurement metrics to better 

assess program performance. 

Results of Review 

Information in Local Standard Operating Procedures Is Not Consistent Across All 

53 CSI Ports 

Part of EAB’s port evaluation process confirms the existence of local standard operating 

procedures (SOPs) but does not ensure that minimum essential information about CSI 

1 Container Security: A Flexible Staffing Model and Minimum Equipment Requirements Would Improve 

Overseas Targeting and Inspection Efforts (GAO-05-557, April 2005), and Supply Chain Security: 

Examinations of High-Risk Cargo at Foreign Seaports Have Increased, but Improved Data Collection and 

Performance Measures Are Needed (GAO-08-187, January 2008). 

Page 2 
operations is included. We did not visit ports to determine whether CBP officers use or 

comply with local SOPs. We examined 46 local SOPs and determined that some did not 

contain minimum essential information and clear guidance. While some of this 

information is contained in the CSI master SOP, CBP could improve consistency. For 

example: 

�	 Thirty-one did not contain specific information on how to refer high-risk 


shipments for host country officials to review. 


�	 Eighteen did not contain information on how to conduct further research with host 

country counterparts at that port. 

�	 Five contained information on how the host country detains, seizes, or releases a 

high-risk shipment; however, CSI has no authority with respect to how the host 

country detains, seizes or releases a high-risk shipment. 

Local SOPs guide new officers arriving at the port by identifying preferred procedures at 

the port and providing information on available equipment and host nation counterparts. 

Local SOPs also should include up-to-date information, such as port-specific points of 

contact, operational procedures, vehicle procedures, and how best to research shipments. 

EAB could improve its process to evaluate CSI operations by developing standard 

minimum criteria necessary for developing local SOPs. Once criteria are established, 

EAB should develop a consistent process for evaluating the content of local port SOPs. 

Recommendations 

We recommend that the Commissioner, U.S. Customs and Border Protection: 

Recommendation #1: Identify minimum essential elements for inclusion in every local 

port standard operating procedure, and include these elements in the CSI program-level 

SOP. 

Recommendation #2: Establish a process for EAB to ensure that all local port SOPs 

include the minimum essential elements as stated in the CSI program-level SOP. 

Management Comments and OIG Analysis 

CBP concurred with our recommendations and will standardize the requirements for all 

local SOPs. CBP plans to outline these elements in the CSI SOP and all CSI ports will be 

required to update their local SOPs with these requirements by March 1, 2010. CBP also 

plans to establish questions in its CSI Team evaluation database to ensure that the local 

SOPs contain the standardized criteria outlined in the CSI SOP, and will begin examining 

local SOPs to make sure they include the necessary elements. We consider the 

recommendations resolved and open and will close them when implementation is 

complete. 

Page 3 
CSI’s Strategic Plan 

CSI’s strategic plan, dated August 2006, includes outdated performance measures and 

does not describe how CSI integrates with other CBP international maritime cargo 

security programs initiated after the plan was published. 

Some Performance Metrics in CSI’s Strategic Plan Are No Longer Relevant 

When CBP designed the 2006–2011 CSI Strategic Plan, CSI was operational in 44 ports 

and envisioned expansion to 58 ports by FY 2008. CSI achieved the expansion outlined 

in the CSI Strategic Plan in 2007. CBP does not plan to expand CSI to additional ports. 

However, the strategic plan includes the following performance metrics, which are 

contingent on further expansion: 

� Number of operational CSI ports 

� Percentage of worldwide U.S.-destined containers processed through CSI ports 

� Average cost per CSI port to achieve operational status 

Accurate and relevant performance metrics help inform CBP, the Department of 

Homeland Security (DHS), Congress, and the public of CSI’s progress and achievements. 

If metrics are out of date and do not reflect current strategic planning efforts, program 

decision makers could be misinformed about the program’s future and its ability to meet 

its goals and objectives. 

CBP managers recently completed the 2009–2014 CBP Strategic Plan and are working 

with CBP programs such as CSI to revise program-level strategic plans to ensure that the 

plans have parallel goals. CSI officials said that they plan to update or replace strategic 

program performance metrics during this planning process. 

CSI’s Strategic Plan Does Not Address the Influence of Other CBP International 

Maritime Security Programs 

The 2006–2011 CSI Strategic Plan does not reflect the influence of other CBP 

international maritime security initiatives on CSI’s mission and goals. In response to the 

Implementing Recommendations of the 9/11 Commission Act of 2007, CBP established 

another maritime cargo security program, the Secure Freight Initiative (SFI), to test the 

feasibility of moving from a risk-based approach to 100% scanning of all cargo 

containers bound for U.S. ports. According to the Implementing Recommendations of the 

9/11 Commission Act of 2007, by 2012, all maritime cargo coming into the United States 

must be scanned prior to reaching a domestic port. 

The DHS Secretary and CBP’s Acting Commissioner have expressed concerns regarding 

CBP’s ability under SFI to scan 100% of the 11.3 million containers that enter the United 

States each year by the 2012 deadline. GAO is reviewing the SFI program and plans to 

provide recommendations to address concerns regarding the agency’s ability to meet the 

2012 deadline. 

Page 4 
The current CSI Strategic Plan predates the creation of SFI by several months. CSI and 

SFI have a common mission: to identify weapons of mass destruction in containerized 

maritime cargo before the cargo reaches the United States. The two programs also have a 

common history, staff, equipment, and budget. It is essential that CBP take steps to 

evaluate the impact of other CBP initiatives, such as SFI, on CSI, and that these steps be 

considered in updating CSI’s strategic plan and performance metrics to guide the future 

direction of the program. 

Recommendations 

We recommend that the Commissioner, U.S. Customs and Border Protection: 

Recommendation #3: Revise the CSI Strategic Plan to include (a) the current strategic 

outlook of the CSI program, (b) refined relevant goals and performance metrics to help 

guide and inform CSI’s future direction, and (c) the impact of other CBP programs and 

factors that may affect CSI’s goals and objectives. 

Management Comments and OIG Analysis 

CBP concurred and plans to incorporate mission objectives into Office of Field 

Operations’ overall strategic plan (2011-2016) to ensure that they align with the strategic 

plan’s mission and goals. These objectives will be supported by strategies to include the 

impact of other CBP programs, and will have performance measures to ensure that the 

objectives are being met. We consider this recommendation resolved and open and will 

close it when implementation is complete. 

Page 5 
 

Appendix A 

Purpose, Scope and Methodology 

The purpose of this audit was to determine the efficacy of CBP’s 

management and oversight of the CSI program to achieve its 

mission of identifying and inspecting high-risk cargo at foreign 

ports. We reviewed internal controls pertinent to our overall 

objective. 

We interviewed government officials at CBP headquarters and the 

National Targeting Center in the Washington, DC, area, as well as 

a domestic port to gain an understanding of CBP’s cargo 

inspection process. We also interviewed officials at the 

Department of State and the Department of Energy. We analyzed 

the planning, policies, and procedures of CSI’s management and 

oversight systems. We did not visit ports to determine whether 

CBP officers use or comply with CSI procedures. We issued a 

web-based survey to the 159 CBP officers deployed at all CSI 

ports to gain a field perspective on the management and oversight 

of the CSI program. We analyzed the data systems CBP has in 

place to track CSI performance and observed CSI’s remote port 

operations and CSI’s domestic targeting operations at the National 

Targeting Center. We also analyzed CSI program changes based 

on recommendations from GAO’s audit of the CSI program 

conducted in January 2008. 

We conducted this performance audit between May and September 

2009 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a 

reasonable basis for our findings and conclusions based on our 

audit objectives. We believe that the evidence obtained provides a 

reasonable basis for our findings and conclusions based on our 

audit objective. 

We would like to thank CBP for its cooperation in the performance 

of this audit. 

Page 6 
Appendix B 

Management Comments to the Draft Letter Report 

Page 7
 
Appendix B 

Management Comments to the Draft Letter Report 

Page 8
 
Appendix C 

Major Contributors to this Report 

Paul Wood, Director 

Shelley Howes, Audit Manager 

Tricia Benson, Auditor 

Keith Nackerud, Program Analyst 

Holly Snow, Auditor 

Tristan Weir, Program Analyst 

Jim Bess, Independent Referencer 

Page 9 
Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff for Operations 

Chief of Staff for Policy 

General Counsel 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Policy 

Assistant Secretary for Public Affairs 

Assistant Secretary for Legislative Affairs 

Under Secretary for Management 

Chief Procurement Officer 

Acting Commissioner, U.S. Customs and Border Protection 

Executive Director, Cargo Security and Conveyance 

OIG Liaison, CBP 

DHS Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

Page 10 
ADDITIONAL INFORMATION AND COPIES 

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fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

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