DEPARTMENT OF HOMELAND SECURITY 

Office of Inspector General 

A Review of U.S. Customs and Border 

Protection’s Procurement of Untrained 

Canines 

OIG-08-46 April 2008 
 

 

 

 

Office of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

April 24, 2008 

Preface 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was established by 

the Homeland Security Act of 2002 (Public Law 107-296) by amendment to the Inspector General 

Act of 1978. This is one of a series of audit, inspection, and special reports prepared as part of our 

oversight responsibilities to promote economy, efficiency, and effectiveness within the department. 

This report addresses concerns raised by Chairman Bennie G. Thompson and Representative 

Kendrick B. Meek regarding the United States Customs and Border Protection’s procurement of 

untrained canines. It is based on interviews with employees and officials of relevant agencies and 

institutions, direct observations, and a review of applicable documents. 

The recommendations herein have been developed to the best knowledge available to our office, and 

have been discussed in draft with those responsible for implementation. It is our hope that this 

report will result in more effective, efficient, and economical operations. We express our 

appreciation to all of those who contributed to the preparation of this report. 

Richard L. Skinner 

Inspector General 
 

 

Table of Contents/Abbreviations 

Executive Summary...............................................................................................................................1 

Background............................................................................................................................................2 

Results of Review ..................................................................................................................................3 

CBP Paid a Competitive Average Price per Canine ........................................................................3 

CBP’s Solicitation and Award Processes Complied 

With Applicable Federal Acquisition Regulations ..........................................................................4 

Delivery Timeframe Should Coincide With Receipt of Purchase Order.........................................6 

Vendors Were Not Subject to USDA Licensing Requirements ......................................................7 

Eight Percent of Canines Did Not Pass Required Training Tests....................................................8 

CBP Needs to Donate or Sell Unfit Canines According to Applicable Federal Regulations..........9 

Training and Boarding Costs for Canine Teams Are Consistent...................................................10 

The Canine Program Serves as an Essential Tool in Securing U.S. Borders ................................11 

Improvements in Canine Performance Tracking Systems Are Needed.........................................14 

Additional Issue Regarding CBP Canine Teams.................................................................15 

Infrastructural Improvements at Land POEs and Permanent Checkpoints 

Could Enhance Canine Performance and Safety............................................................15 

Management Comments and OIG Analysis ........................................................................................17 

Appendices 

Appendix A: Purpose, Scope, and Methodology .......................................................................19 

Appendix B: Management Comments to the Draft Report.......................................... 21 

Appendix C: Congressional Letter.............................................................................................25 

Appendix D: Major Contributors to this Report ........................................................................29 

Appendix E: Report Distribution...............................................................................................30 
 

 

 

 

 

 

Abbreviations 

APHIS Animal and Plant Health Inspection Service 

ATCET Anti-Terrorism Contraband Enforcement Team 

CBP U.S. Customs and Border Protection 

DHS U.S. Department of Homeland Security 

DOD U.S. Department of Defense 

FAR Federal Acquisition Regulation 

FY Fiscal Year 

IDIQ Indefinite Delivery Indefinite Quantity 

JFK John F. Kennedy International Airport 

OBP Office of Border Patrol 

OFO Office of Field Operations 

OIG Office of Inspector General 

OTD Office of Training and Development 

POE Port of Entry 

SBI Secure Border Initiative 

USDA U.S. Department of Agriculture 
OIG
 Department of Homeland Security 

Office of Inspector General 

Executive Summary 

Chairman Bennie G. Thompson and Representative Kendrick B. Meek, U.S. 

House of Representatives Committee on Homeland Security, requested that 

we review a contract awarded by U.S. Customs and Border Protection to 

procure and deliver untrained canines to its canine training facilities. They 

expressed concerns that the contract costs may be outside of a reasonable 

price range for untrained dogs. We were also requested to review vendor 

licensing requirements, the percentage of canines unsuitable for service, and 

the role of dog deployment in the overall border protection strategy. 

From April 2006 through June 2007, U.S. Customs and Border Protection 

procured 322 untrained canines at a cost of $1.46 million, or an average price 

of $4,535 per canine. The costs incurred for the untrained canines were 

reasonable and were comparable to the costs incurred for untrained canines 

procured by organizations such as the United States Secret Service and the 

Department of Defense. Regarding the cost effectiveness of the program, 

while only 3.85% of the Office of Border Patrol’s 13,905 agents were canine 

handlers, they were credited with 60% of narcotic apprehensions and 40% of 

all other apprehensions in FY 2007. 

The solicitation and award of this contract were conducted according to 

applicable federal regulations. Also, U.S. Department of Agriculture officials 

said that the vendors were not required to possess a federally issued license to 

engage in the sale of animals. Through August 14, 2007, 26 or 8% of the 

procured canines did not complete the training. CBP donated six of these 

canines to private homes, which was inconsistent with federal regulations. 

We recommend that U.S. Customs and Border Protection adjust the delivery 

timeframes for vendors, properly transfer or sell unfit canines, and implement 

a unified system that accurately accounts for the performance of canine teams. 

U.S. Customs and Border Protection generally concurred with all 

recommendations. 

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Background 

As the largest and most diverse law enforcement canine program in the 

country, U.S. Customs and Border Protection’s (CBP) Canine Enforcement 

Program has the mission to combat terrorism, and interdict narcotics and other 

contraband while helping to facilitate and process legitimate trade and travel. 

As such, CBP officers use specially-trained detector dogs to interdict illegal 

narcotic substances, smuggled humans, explosives, and agricultural products, 

and unreported currency at our Nation’s ports of entry (POE). 

CBP maintains two separate canine programs to meet the needs of the 

agency’s diverse responsibilities. The Office of Field Operations (OFO) 

canine program comprises 595 canine teams, each consisting of a canine and a 

handler, which are primarily stationed at our Nation’s land, sea, and air POEs. 

The Office of Border Patrol (OBP) canine program has 540 canine teams that 

maintain responsibility for border areas between the ports of entry. 

The Canine Center – Front Royal, formerly known as the Canine Enforcement 

Training Center in Virginia, trains canines for the OFO canine program. The 

Canine Center – El Paso, formerly known as the National Canine Facility in 

Texas, trains canines for OBP. The two training centers are managed by the 

Office of Training and Development. Although the Canine Center – Front 

Royal and the Canine Center – El Paso facilities have the capacity to train a 

maximum of 250 and 150 canine teams, respectively, in a 12-month period, 

the actual number of canine teams that require training in a fiscal year (FY) at 

each of the training centers is determined by its respective offices. 

The Front Royal facility trained 100 canine teams in fiscal year (FY) 2006, 

and expected to train 150 canine teams in FY 2007. This center trains canines 

to detect narcotics, explosives, concealed humans, and currency. The training 

for explosives is 15 weeks, while all other training is 13 weeks. The El Paso 

facility trained 127 canine teams in FY 2006, and expected to train 144 canine 

teams in FY 2007. This facility trains canines to detect both narcotics and 

concealed humans. 

In December 2005, CBP developed an acquisition plan to facilitate the 

centers’ procurement of untrained canines. An indefinite delivery indefinite 

quantity (IDIQ) multiple award contract was determined to be the most 

appropriate procurement vehicle to acquire canines on an as-needed basis, and 

to solicit and award as many qualified vendors as possible. The contract 

included one base year and four option years, for a total performance period of 

five years, if all option years are exercised. 

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Since its inception, both facilities followed their own procedures to sell or 

donate unfit canines. Included in this group are canines that retired, 

underperformed, or did not pass required training tests. 

Results of Review 

CBP Paid a Competitive Average Price per Canine 

Information maintained by the Office of Procurement showed that from April 

2006 to June 2007, CBP procured 322 untrained canines from seven vendors 

at a cost of $1.46 million. CBP pays the successful bidder up to $200 to ship 

each canine. Shipping costs for the 322 untrained canines totaled $33,788. 

Therefore, the average price per canine including shipping costs is $4,535, and 

the average price per canine excluding shipping costs is $4,430. 

We contacted the United States Secret Service and Transportation Security 

Administration to determine the average purchase price of canines used in 

their agencies’ programs. The United States Secret Service paid an average of 

$4,533 for 16 untrained canines as part of its current contract for FY 2006 to 

FY 2008. The Secret Service contract includes a provision that considers the 

fluctuating value of the U.S. dollar against the euro and authorizes up to $450 

above the cost per canine. 

Through an Interservice Support Agreement, the Transportation Security 

Administration receives untrained canines from the U.S. Department of 

Defense (DOD). DOD sends agency personnel to procure untrained canines 

directly from Europe. Due to the large quantity, the department uses a blanket 

purchase agreement to buy approximately 600 canines from European vendors 

annually at a reduced rate. DOD currently pays an average of $3,500, 

including shipping costs, for each untrained canine it purchases. 

Prior to the solicitation and award of this contract, CBP reviewed procurement 

prices in previous contracts, and determined that the cost per canine ranged 

between $3,300 and $3,800. The cost per canine was determined based on the 

Front Royal facility’s procurement of canines from three vendors via purchase 

orders, and the El Paso facility’s procurement of canines through an IDIQ 

multiple award contract, which expired at the end of FY 2005. Also, our 

review of CBP’s evaluation of bids received in response to its solicitation to 

procure untrained canines demonstrated that CBP followed applicable 

guidelines in assessing proposed costs. 

Due to the continued weakness of the U.S. dollar against the euro since April 

2006, canine vendors now require an increasing amount of U.S. dollars to buy 

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untrained canines from Europe, the primary source for canines that meet 

CBP’s standards. At an average cost of $4,435 per canine, we conclude that 

CBP has procured quality canines at a reasonable cost. 

CBP’s Solicitation and Award Processes Complied With Applicable 

Federal Acquisition Regulations 

Due to the unknown number of canines required throughout the period of 

performance, CBP’s Office of Procurement issued an Indefinite Delivery 

Indefinite Quantity (IDIQ) multiple award contract for vendors to provide 

untrained canines. On February 9, 2006, the solicitation was issued as a 

competitive commercial acquisition under the principles of Federal 

Acquisition Regulation (FAR) Part 12. As part of the solicitation and award 

process, CBP also followed applicable provisions of FAR Part 5, 6, 9, 11, and 

15. In April 2006, CBP announced and awarded the contract to seven 

vendors. The contract included one base year, April 6, 2006, to April 5, 2007, 

and four option years, which could extend the contract to April 5, 2011. 

The Solicitation Process 

As required by FAR Subpart 11.1, Selecting and Developing Requirements 

Documents, the Contracting Officer’s Technical Representatives provided the 

technical requirements in the Statement of Work that identified the canine 

needs for Front Royal and El Paso, the description of the canines, the selection 

criteria, and required documentation. 

To obtain information on potential vendors in the canine marketplace, the 

Office of Procurement contacted certification groups such as the North 

American Police Dog Association, the National Narcotic Detector Dog 

Association, and the National Police Canine Association. The Office of 

Procurement requested additional guidance from the El Paso facility since it 

had purchased canines under a similar contracting arrangement prior to its 

merger with the U.S. Department of Homeland Security (DHS). El Paso 

facility officials said that the CBP canine contract was well known throughout 

the canine industry since it was publicized and announced at national 

conferences and other events during the preceding year. 

In the solicitation’s Pricing Schedule attachment, the vendors were required to 

bid a fixed amount to include the price of one canine plus shipping costs to 

Front Royal, El Paso, and any other DHS location for components that may 

wish to use this contract to procure untrained canines in the future. 

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CBP posted the announcement of the solicitation order on the FedBizopps.gov 

website, in accordance with the FAR 6.102, Use of Competitive Procedures, 

to ensure full and open competition. As specified in FAR 5.203(a)(1), the 

solicitation for the acquisition of commercial items can be published for less 

than 15 days. CBP’s solicitation for untrained canines was open from 

February 9 to February 24, 2006, for a total of 16 days. 

The Award Process 

Nine vendors responded to CBP’s solicitation for untrained canines. 

Prospective vendors were evaluated on the basis of past performance and 

price bids, according to the evaluation criteria outlined in FAR 15.305. 

To evaluate past performance, a Source Selection Evaluation Team, headed by 

a canine training center director: 

•	 Reviewed orders filled by prospective vendors for a minimum of five 

untrained canines in the past three years; 

•	 Contacted the prospective vendors’ references; and 

•	 Assessed their responses to the Reference Questionnaire they were 

required to complete regarding their past experiences in delivering 

untrained canines. 

All nine vendors were canine trainers. CBP officials and vendors said that 

based on past experience, canines from trainers are more likely to satisfy the 

statement of work requirements than breeders. Also, they are more likely to 

pass pre-selection tests because the canines have completed prior training. 

Based on past performance, the Source Selection Evaluation Team assigned 

an adjectival rating to all vendors who responded to the solicitation. Vendors 

could be rated outstanding, good, neutral, acceptable, marginal, or 

unacceptable. Four of the winning bidders were rated outstanding, two were 

rated good, and the other received a neutral rating. 

CBP evaluated the vendors’ prices for fairness and reasonableness based on 

the price analysis technique specified in FAR 15.404 –1(b), which requires 

that the price determined for the award be fair and reasonable. CBP compared 

the proposed prices from the base year to the fourth option year, and 

determined the price per canine among the vendors to be similar throughout 

all of the proposed contract years. Vendors who proposed to deliver canines 

to two locations were compared separately from those who proposed to 

deliver canines to three locations. Bids from vendors ranged from $3,500 to 

$6,000 in the base year, and from $4,000 to $8,000 in the fourth option year of 

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the contract. The total estimated price reflects differences in delivery charges 

for the vendors’ proposed pricing over the entire five-year contract and the 

price per canine. 

Based on past performance and price proposals, seven of the nine vendors met 

the general standards of responsible prospective contractors as outlined in 

FAR 9.104, and were subsequently awarded the contract. One vendor 

received a neutral rating, but was still considered for the award because as a 

small and new business, strong technical standing outweighed its limited past 

performance, which is a trade-off permissible under FAR 15.101-1. Two 

vendors were excluded from consideration due to a marginal rating for past 

performance, and submitting a bid that only included base year prices when 

the solicitation required vendors to bid prices for all five years. 

A determination of the vendors’ ability to board and care for the canines was 

not included as part of the review process. According to FAR 12.208, 

“Contracts for commercial items shall rely on contractors’ existing quality 

assurance systems as a substitute for Government inspection and testing...” 

Although nine vendors had to bid price per canine to fulfill the solicitation 

requirements, the price CBP actually pays its seven vendors is the winning bid 

amount for each subsequent delivery order. 

Delivery Timeframe Should Coincide With Receipt of Purchase Order 

According to CBP officials, when a specific delivery order for canines is 

awarded to a vendor selected under this contract, the vendor is allowed 30 to 

45 days from the award date to deliver canines to the training centers. 

Vendors expressed concern about the short timeframe between official 

confirmation from the Office of Procurement that they have been awarded a 

specific order for canines, and the required delivery date to the training center. 

After vendors have submitted bids for a specific canine order, the Office of 

Procurement notifies the successful vendor(s) that they have been tentatively 

awarded an order to deliver canines by a specific date. The Office of 

Procurement’s interpretation of the tentative award notification to successful 

vendors means that the vendor has been awarded the specific delivery order. 

However, vendors do not interpret the tentative notification as the official 

award notification, and do not initiate actions to procure canines until receipt 

of a purchase order from CBP, officially confirming the order. As a result, the 

available time for vendors to purchase the canines from Europe and deliver 

them to the training centers is reduced by the length of time between CBP’s 

tentative award notification and their receipt of a purchase order. This results 

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in vendors not always having sufficient time to meet the 30- to 45-day 

delivery timeframe. 

Recommendation 

We recommend that the Commissioner of U.S. Customs and Border 

Protection: 

Recommendation 1: Start the 30- to 45-day delivery requirement on the date 

that coincides with the vendors’ acknowledgement of receipt of the purchase 

order. 

Vendors Were Not Subject to USDA Licensing Requirements 

Based on our review of regulatory guidelines and discussions with officials 

from the U.S. Department of Agriculture’s (USDA) Animal and Plant Health 

Inspection Service (APHIS), we conclude that the licensing requirements for 

the Animal Welfare Act do not apply to vendors supplying canines to CBP. 

The Animal Welfare Act provides guidance regarding the need to possess a 

valid USDA license to sell or breed canines.1 Under the Act, APHIS issues 

three types of licenses to animal dealers falling under either: Class A, which 

includes commercial breeders; Class B, which includes brokers and auction 

operators; or Class C, which includes animal breeders. Other business 

categories are entirely excluded from this requirement, including retail pet 

stores, retail chain stores, hobby breeders, animal shelters, and boarding 

kennels. 

According to APHIS officials, vendors selling canines to CBP are not required 

to possess a USDA license because they are engaged in retail sales, with 

“retail” being defined as a sale to an end user. This exemption extends to the 

direct sale of security canines to a final user since this constitutes a retail sale. 

APHIS officials also said that the seller who originally sold the canines to the 

vendors for resale to CBP would be subject to licensing by USDA. However, 

since all of the vendors purchase canines for CBP’s training programs from 

European suppliers, the licensing requirement does not apply. 

Vendors are subject to applicable state and local laws, which vary 

dramatically by state. For example, one vendor selected by CBP under this 

contract is located in Rhode Island, and licensed by both the state and county 

to sell and kennel canines. To remain in good standing with his licenses, his 

1

 7 U.S.C. § 2133 

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facility is inspected annually at a minimum, as well as at random. In 2004, 

seven canines died while kenneled at this vendor’s facility. The canines had 

been left in a room overnight when the air conditioning unit malfunctioned, 

which resulted in the dogs dying of heatstroke. The state veterinarian’s office 

immediately suspended the vendor’s license pending the outcome of a full 

investigation, after which the license was reinstated, and the vendor has had 

no other incidents since that time. 

Eight Percent of Canines Did Not Pass Required Training Tests 

The training centers select only those canines that successfully pass their 

required tests. Even if a dog is selected initially, there is a 20-day period 

before a final selection is made. During the 20-day period, the canines are 

observed to confirm that they are disease-free, medically fit, and acceptable 

for the program. If the training centers determine that a dog is unfit for 

training, the vendor must replace it at its own cost. 

A demonstration of the pre-selection test at the El Paso Facility 

A training center official said that a very small percentage of canines fail the 

training program. One vendor explained that a major incentive to provide 

quality canines is reputation within the industry. According to the vendor, this 

is a small community where word spreads quickly if a vendor is not providing 

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quality canines to meet customer demands. Another control on vendors’ 

practices is that they use their own money to purchase these canines without a 

guarantee that the dogs will be repurchased by CBP or any other customer. 

According to information provided by the Office of Training and 

Development, as of August 14, 2007, 26 or 8% of the procured canines did 

not successfully complete the required training course. Lack of success was 

due to failure to detect an odor for which the canine was trained to recognize, 

or insufficient genetic drive, which is an inherent trait required for detection 

training candidates. 

CBP Needs to Donate or Sell Unfit Canines According to Applicable 

Federal Regulations 

According to 40 U.S.C. § 555 and 41 C.F.R. § 102-36.365, when a canine is 

no longer needed for law enforcement duties, the agency may donate the 

canine to an individual who has experience handling canines in the 

performance of those official duties. However, these laws do not permit the 

sale or donation of canines to private homes. 

Of the 23 canines at the Front Royal facility that were not certified, 15 were 

donated to other federal, state, and local law enforcement agencies, two were 

sold, and six were provided to private homes. All three of the canines that 

failed certification at the El Paso facility were given to federal handlers for 

adoption. 

CBP officials said that they believe that the General Services Administration 

exempted the agency from this federal regulation because canines are live 

animals. However, they were unable to provide documentation to support an 

exemption. In the absence of a valid exemption, CBP must provide the 

canines to the General Services Administration for appropriate removal from 

the Canine Enforcement Program. 

Recommendation 

We recommend that the Commissioner of U.S. Customs and Border 

Protection: 

Recommendation 2: Donate or sell unfit canines according to applicable 

federal regulations. 

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Training and Boarding Costs for Canine Teams Are Consistent 

According to information provided by the Office of Training and 

Development, the Front Royal and El Paso facilities have the capacity to train 

a maximum of 250 and 150 canine teams, respectively, in a 12-month period. 

We determined that the training centers’ costs associated with training and 

boarding canine teams do not fluctuate based on the method used to procure 

the canines. Also, dog handlers receive the necessary training along with their 

canines regardless of the procurement method. The total costs to board and 

train canine teams for specific classes at the training centers are shown in 

Tables 1 and 2. 

Table 1: Training and Boarding Costs of Canine Teams at Front Royal 

Fiscal 

Year Training Class Number of CBP Handlers Total Costs 

2006 Narcotics 66 $938,850 

Explosives 19 $350,550 

2007 Narcotics 133 $2,195,165 

Table 2: Training and Boarding Costs of Canine Teams at El Paso 

Fiscal 

Year Training Class Number of CBP Handlers 

Total 

Costs 

Handler Class 87 $607,995 

2006 Returning Handler Class 22 $131,670 

Search & Rescue Handler Class 6 $78,120 

Tracking & Training Class 12 $76,800 

Handler Class 101 $705,485 

Returning Handler Class 20 $119,700 

2007 Search & Rescue Handler Class 6 $78,120 

Tracking &Training Class 3 $18,000 

Human Remains Class 2 $21,860 

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The Canine Program Serves as an Essential Tool in Securing U.S. Borders 

To observe the work of canine teams, we conducted site visits to POEs in El 

Paso and Laredo, Texas, and John F. Kennedy International (JFK) and 

Newark Liberty International Airports. We also visited Border Patrol 

checkpoints in Las Cruces, New Mexico, and Laredo, Texas. At all locations, 

we learned that OFO officers and OBP agents valued the canines for their 

ability to efficiently clear people and vehicles with minimum wait times at 

POEs and checkpoints, as well as locate migrants and smugglers crossing 

through the desert. 

Canine Teams at Ports of Entry 

OFO maintains canine teams trained to detect a variety of odors to fit its broad 

mission of interdicting illegal narcotic substances, smuggled humans and 

agricultural products, and unreported currency at our Nation’s POEs. At the 

Front Royal facility, canines are trained for the following forms of detection: 

•	 Narcotics – to detect and interdict narcotics; 

•	 Concealed Human/Narcotics – to detect concealed narcotics, and 

people attempting to enter the United States illegally; 

•	 Currency – to detect the odor of undeclared U.S. currency before it is 

smuggled out of the country to circumvent monetary reporting 

requirements; and 

•	 Explosives – to detect explosive odors concealed in cargo, vehicles, 

aircraft, luggage, and on passengers. 

CBP also maintains agriculture detector dogs to detect prohibited fruits, 

vegetables, or meats that may carry pests, or animal and plant diseases 

harmful to U.S. agricultural resources. Those canine teams are trained 

separately at a USDA academy in Orlando, Florida, and were not included as 

part of this contract. 

Most of the OFO canines working at the land POEs are trained to detect 

narcotics and concealed humans, and are capable of screening a vehicle in 

seconds. Depending on their availability at a POE, explosive detection 

canines also screen vehicles. Knowing that a vehicle has been searched by a 

detector dog for drugs, people, or possible bomb-making materials, the 

officers working in the primary inspection booths can focus their attention on 

the occupants’ behavior or their possible connection to other criminal 

activities. Primary inspection officers have the discretion to refer vehicles to 

the secondary inspection area for a full inspection using a canine team that can 

complete the inspection in about five minutes. An equivalent inspection 

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without the use of a canine would require an officer at least 20 minutes. With 

port directors under pressure to minimize wait times, the canines serve a 

unique role in maintaining traffic flow through the lanes without 

compromising security. 

Many of the canine teams stationed at airport POEs operate with more public 

interaction. Occasionally, explosive detection canine teams will check 

individual passengers in the baggage claim areas, which are regularly 

inspected by agricultural canine teams. OFO officials at JFK and Newark 

Airports explained that the canine teams operate in conjunction with their 

Anti-Terrorism Contraband Enforcement Teams (ATCET), which use 

intelligence and threat information to conduct local targeting operations. 

Since there are not enough canine teams to search every arriving international 

flight, OFO must determine which flights to search through the ATCETs. 

OFO determined that this method is more effective in yielding larger finds of 

contraband and breaking up smuggling rings than searching each passenger 

individually as they disembark the plane. The narcotics or explosives 

detection dogs may also inspect the cargo and luggage of selected flights, if 

the search will not prolong the movement of these items. OFO randomizes 

targeted flights and the types of searches conducted to prevent evasion by 

potential smugglers. 

OFO also maintains currency detection canines to check outbound vehicles, 

passengers, and cargo for large currency loads before they are taken out of the 

country. However, for the sites we visited, the presence of currency detection 

teams was minimal. JFK and Newark airports have been without currency 

canines for the past year because CBP’s focus was to fill its backlog of other 

canine vacancies. 

At the seaports, canine teams are an essential part of OFO’s efforts to clear 

shipments and containers that must be inspected because of the country of 

origin, the product being shipped, the shipping company, or other factors that 

inform targeting decisions. The canines are flexible and can be easily moved 

from shipment to shipment, climbing on top of and around items in ways that 

would physically challenge officers. 

Canine Teams Along U.S. Borders 

OBP’s challenge lies in the thousands of miles of border that must be covered 

by its agents. There are a limited number of technological tools to help agents 

during their patrols, with sensors and cameras being the most prominent. 

However, as canines rely on their sense of smell instead of sight, they 

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represent an important tool in tracking people who have illegally crossed the 

border. 

In addition, the canines enhance OBP’s interior enforcement efforts at 

strategically placed checkpoints located miles from the borders by quickly 

inspecting approaching vehicles along the roadway and providing a deterrent 

effect. For example, agents at one checkpoint told us they regularly find 

abandoned narcotic loads left along the highway leading to the checkpoint 

after the smugglers’ spotters informed them that a canine was on duty. 

While only 3.85% of the Office of Border Patrol’s approximately 13,905 

agents are canine handlers, they were credited with 60% of narcotic 

apprehensions and 40% of all other apprehensions in FY 2007. Unlike OFO, 

which has jurisdictional authority to search anyone at a POE, OBP officials 

told us that its agents must have probable cause to search passenger vehicles. 

Therefore, the canine teams are not only helpful for finding narcotics and 

smuggled humans, but serve as a useful tool in providing probable cause for 

agents to search suspicious vehicles or people. 

The Canine Program and the Secure Border Initiative 

According to CBP officials, the planning and deployment of canine teams is 

conducted every fiscal year by OFO and OBP.2

 Regarding the Secure Border 

Initiative (SBI) and SBInet, canine teams are part of a layered enforcement 

strategy. The Canine Enforcement Program augments existing technology by 

deploying detector dog teams that enhance border security by efficiently 

screening conveyances at ports of entry. 

To date, CBP’s Canine Enforcement Program has not been integrated into the 

Security Border Initiative (SBI) and SBInet. When it is integrated, OBP 

officials said they will adjust the deployment of their canine resources, which 

is expected to increase. Both OFO and OBP officials said that the Canine 

Enforcement Program is so essential to their mission that the canines will not 

be replaced by technology, but will complement it. 

2 SBInet is a program to develop and deploy the optimum mix of personnel, technology, and tactical infrastructure to 

gain control of the border. SBInet chose to focus the first comprehensive border security solution along 28 miles 

contiguous to the Sasabe, Arizona, port of entry. 

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Improvements in Canine Performance Tracking Systems Are Needed 

Within the Canine Enforcement Program, OFO and OBP canine teams are 

tracked separately within each office’s computer systems. We requested 

information from OFO and OBP regarding the number of total canine-initiated 

interdictions. While OBP provided updated performance information on its 

canine teams, we determined that OFO is limited in its reporting capabilities 

due to its reliance on an outdated system. Without such information, OFO 

cannot make objective judgments about the value of its canine teams in 

relation to overall interdictions each fiscal year or determine the optimal 

number for each type of team. 

OFO’s “Detector Dog System” tracks canine interdictions and is used to 

produce an annual cost-effectiveness ratio for its teams. However, the ratio’s 

computations are based on 1994-1995 costs, which was the last time the 20-

year-old system was updated. An OFO official said that updating the system 

with current cost information would require several hundred thousand dollars 

because it was created using a computer code that is no longer in use, and 

funding has not been made available for this effort. 

Because of the costs required for this update, an OFO official said that they 

are considering replacing the current Detector Dog System with a system that 

will incorporate the needs of CBP including the canine program statistics used 

by OFO, OBP, and the OTD training centers. This will provide CBP with a 

unified system of generating, maintaining, and reporting canine seizure 

statistics. 

Without updated cost information, the Detector Dog System is generating 

inaccurate cost-effectiveness ratios, and data that do not accurately reflect the 

performances of OFO canine teams. The ratios provided from this system, 

suggest that OFO’s canines have returned at least $100 for every $1 of 

deployment costs for handler salaries, ongoing training, and kenneling costs 

during four of the past five fiscal years. Because this information is not based 

on current costs, these figures are of limited value in OFO’s decision-making 

process regarding the canine program. 

The only other system currently available to OFO is its main interdiction 

tracking system, which relies on officer entries at POEs. However, an OFO 

official said that this is not as reliable as the Detector Dog System for tracking 

canine performances because officers at POEs do not always enter canineinitiated interdictions into this system. OBP’s system, by contrast, requires 

agents to indicate which interdictions were canine-initiated, enabling OBP to 

count canine interdictions as a percentage of total interdictions, which are 

A Review of U.S. Customs and Border Protection’s Procurement of Untrained Canines 

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stratified by type. Such a measurement allows OBP to view the canine teams’ 

performances in relation to its overall interdictions, as shown in Chart 1. 

Chart 1: OBP - Percent of Total Seizures Assisted By 

Canines 

0 

10 

20 

30 

40 

50 

60 

70 

Narcotics Currency 

In Percentage 

FY05 FY06 FY07 

Recommendation 

We recommend that the Commissioner of U.S. Customs and Border 

Protection: 

Recommendation 3: Implement plans for a unified system within CBP to 

accurately track the performance of its canine teams. 

Additional Issue Concerning CBP Canine Teams 

Infrastructural Improvements at Land POEs and Permanent Checkpoints 

Could Enhance Canine Performance and Safety 

During our site visits along the Southern border in El Paso, Laredo, and Las 

Cruces, we observed infrastructural deficiencies that affect the performance 

and safety of the canine teams. Officials from the Office of Finance-Asset 

Management stated that the process to improve the physical infrastructure at 

ports of entry and permanent border checkpoints is complex, lengthy, and 

budget-constrained. They also said that modernization is a challenge across 

the board, where funding must be aligned against operational priorities. 

While we are not making any recommendations based on our observations at 

three locations, we believe these issues warrant management’s attention. 

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At POEs in El Paso and Laredo, officials told us that while the canines are 

very effective in detecting their trained odors, they also tire easily in the heat. 

The preprimary inspection areas in both areas are largely uncovered, while a 

canopy covers the primary inspection booths. Canine officers constantly 

monitor their dogs for signs of heat exhaustion and must take care that the 

dogs’ paws do not get burned by extended periods on the asphalt. These 

conditions limit the amount of time that each team can work, resulting in 

frequent breaks during the eight-hour shift. 

OBP officials at the Las Cruces station said their canines experience similar 

issues at Border Patrol checkpoints, such as the one along Interstate-10 

highway. In addition to problems with excessive heat, the checkpoint has 

only a single lane that does not allow for the continuous movement of traffic 

when a driver is stopped for extended questioning. Therefore, agents stop 

100% of trucks and buses for questioning, and only stop passenger vehicles 

randomly to avoid traffic congestion. Also, since traffic is constantly moving, 

canines are unable to screen vehicles before they reach the inspection area. 

There are no medians or other infrastructure to separate vehicles from the 

agents and canines, which was a factor in the recent death of one canine hit by 

a truck. 

OBP officials in Las Cruces said the Interstate-10 facility is now undergoing a 

$5 million expansion, which is scheduled for completion in March 2008. The 

improvements will separate commercial traffic from passenger vehicles about 

a mile before the actual checkpoint, which should reduce traffic volume by 

45%. The checkpoint will also have telecommunications systems in the 

inspection booths and a canopy over the inspection area to provide dogs, the 

handlers, and other agents shelter from the heat. The separate commercial 

area will have two lanes and a separate area to accommodate equipment 

capable of detecting hidden compartments in vehicles undergoing full 

inspections. 

We visited another OBP checkpoint located approximately 30 miles north of 

Laredo along Interstate-35. Opened in April 2006 at a cost of $15.5 million, 

the checkpoint features six lanes separated by medians. Depending on traffic 

volume, OBP can staff each open lane with an agent to process more vehicles 

simultaneously and minimize traffic congestion. With the vehicles lined up 

similar to a land POE, the canine teams have sufficient time and space to 

safely screen each vehicle. The facility is also covered in order to protect the 

canines, their handlers, and other agents from the intense heat. According to 

OBP agents, this facility is considered to be a model for OBP; however, the 

medians between each lane are too narrow for the canine teams to walk on. 

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Handlers have their canines step off the median to get closer to the vehicles, 

increasing the level of risk for the canine teams. 

Management Comments and OIG Analysis 

We evaluated technical and written comments prepared by CBP regarding our 

draft report, and where appropriate, made changes to ensure the accuracy of 

information. CBP management agreed with the report findings and 

recommendations, and provided an alternative corrective action for 

Recommendation 1. A copy of CBP’s written comments, in its entirety, is 

included as Appendix B. 

Recommendation 1: Start the 30- to 45-day delivery requirement on the date 

that coincides with the vendors’ acknowledgement of receipt of the purchase 

order. 

CBP Response: CBP agreed, in part, with our recommendation, and 

provided an alternative corrective action. CBP said that the Government has 

no control over when a vendor acknowledges receipt of a purchase order, and 

that acknowledgement of new orders can take time. CBP has begun to e-mail 

purchase orders directly to selected vendors on the date of award. The 

delivery period starts from the date of order identified in Block 1 of Office of 

Finance Form 347, and end on the delivery date identified in Block 15. The 

delivery period is for at least 30 days. 

OIG Analysis: We consider CBP’s alternative corrective action responsive to 

the recommendation. The recommendation is resolved and open pending 

verification that CBP has implemented this notification process as part of their 

standard operating procedures. 

Recommendation 2: Donate or sell unfit canines according to applicable 

federal regulations. 

CBP Response: CBP concurred with our recommendation, and noted that 

Federal Management Regulations do not address the unique requirements of 

live animals, such as their care and feeding, and do not distinguish them from 

other forms of government personal property. CBP has been working with the 

General Services Administration to bring the agency’s practices into full 

compliance with Federal Management Regulations. 

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OIG Analysis 

We consider CBP’s comment responsive to the recommendation, which is 

resolved and open. This recommendation will remain resolved and open 

pending our receipt of (1) the results of on-going efforts with General Services 

Administration to bring the agency’s practices into full compliance with 

Federal Management Regulations, and (2) verification that CBP has 

developed and implemented a process to donate or sell unfit canines according 

to applicable federal regulations. 

Recommendation 3: Implement plans for a unified system within CBP to 

accurately track the performance of its canine teams. 

CBP Response: CBP agreed with our recommendation. The Office of Field 

Operations, Office of Border Patrol, Office of Training and Development, and 

Office of Information Technology within CBP have held initial meetings to 

detail the requirements of a unified system within CBP. Unfunded requests 

have been filed to support this endeavor. Once the unfunded requests are 

approved, the project will advance to the development stage where individual 

offices can determine which information can be unified to facilitate the 

reporting and tracking of specific performance related measures. CBP expects 

this system to be implemented by April 1, 2009. 

OIG Analysis: We consider CBP’s comments responsive to the 

recommendation, which is resolved and open. This recommendation will 

remain resolved and open pending our receipt of documentation verifying 

actions taken by CBP to accurately track performance related measures. 

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Appendix A 

Purpose, Scope, and Methodology 

At the joint requests of Representatives Bennie Thompson and Kendrick 

Meek, U.S. House of Representatives Committee on Homeland Security, we 

reviewed a U.S. Customs and Border Protection (CBP) contract awarded to 

seven vendors to procure and deliver untrained canines to its canine training 

centers. The congressmen expressed concern that the contract costs may be 

outside of a reasonable price range even for fully trained dogs. 

The purpose of our review was to determine: (1) the reasonableness of CBP’s 

contracts with seven vendors regarding the procurement of untrained canines; 

(2) whether specific aspects of CBP’s award process complied with applicable 

federal regulations and other guidelines; (3) the licensing requirements of 

vendors; (4) any additional expenses associated with training and boarding of 

canines and their handlers under this contract; (5) the adequacy of CBP’s plan 

for handling procured canines that are unsuitable for service; and (6) the role 

of canine deployment in CBP’s overall protection strategy. 

We reviewed the Federal Acquisition Regulations, and CBP’s internal 

procurement policies and guidelines. We examined documents related to the 

solicitation and award process, methods used to determine the costs for 

procuring, training, and boarding the canine teams. We interviewed U.S. 

Department of Agriculture officials regarding licensing requirements for 

vendors engaged in the sale of animals, and contacted the United States Secret 

Service, Transportation Security Administration, and U.S. Department of 

Defense to determine their average price paid for untrained canines, as well as 

the General Services Administration regarding the disposition of canines from 

the training programs or through retirement. 

During our fieldwork, we interviewed CBP officials from the Office of 

Procurement, Office of Border Patrol, Office of Field Operations, Office of 

Training and Development, and the Office of Finance-Asset Management. 

We visited the Canine Center – Front Royal in Virginia and the Canine Center 

– El Paso in Texas to observe a demonstration of pre-selection tests for 

canines, and tour the training and kennel facilities. We also observed canine 

deployment operations in El Paso and Laredo, Texas; Las Cruces, New 

Mexico; John F. Kennedy International Airport in New York; Newark Liberty 

International Airport in New Jersey, and, the New York-New Jersey Seaport 

in Elizabeth, New Jersey. We visited two of the seven vendors selected for 

this procurement, and held teleconferences with the remaining five vendors. 

We also held a teleconference with the Rhode Island state veterinarian to 

obtain information regarding the July 2004 deaths of seven dogs while in the 

care of the International Canine Exchange, one of the seven vendors selected 

under this contract. 

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Appendix A 

Purpose, Scope, and Methodology 

We conducted our fieldwork from May 2007 through August 2007. This 

review was scheduled as part of our annual work plan. Our review was 

conducted under the authority of the Inspector General Act of 1978, as 

amended, and according to the Quality Standards for Inspections issued by the 

President’s Council on Integrity and Efficiency. 

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Appendix B 

Management Comments to the Draft Report 

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Appendix B 

Management Comments to the Draft Report 

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Appendix B 

Management Comments to the Draft Report 

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Appendix B 

Management Comments to the Draft Report 

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Appendix C 

Congressional Letter 

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Appendix C 

Congressional Letter 

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Appendix C 

Congressional Letter 

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Appendix C 

Congressional Letter 

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Appendix D 

Major Contributors to this Report 

Deborah Outten-Mills, Chief Inspector, Department of Homeland Security, 

Office of Inspections 

M. Faizul Islam, Senior Inspector, Department of Homeland Security, Office 

of Inspections 

Jessica Barnes, Inspector, Department of Homeland Security, Office of 

Inspections 

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Appendix E 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Policy 

Assistant Secretary for Public Affairs 

Assistant Secretary for Legislative Affairs 

Commissioner of Customs and Border Protection 

DHS OIG Liaison 

CBP Audit Liaison 

Office of Management and Budget

 Chief, Homeland Security Branch 

 DHS OIG Budget Examiner 

Congress

 Congressional Oversight and Appropriations Committees, as appropriate 

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Additional Information and Copies 

To obtain additional copies of this report, call the Office of Inspector General (OIG) at 

(202) 254-4199, fax your request to (202) 254-4305, or visit the OIG web site at 

www.dhs.gov/oig. 

OIG Hotline 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal 

or noncriminal misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

•	 Write to use at: 

DHS Office of Inspector General/MAIL STOP 2600, Attention: 

Office of Investigations - Hotline, 245 Murray Drive, SW, Building 410, 

Washington, DC 20528, 

The OIG seeks to protect the identity of each writer and caller.