Cargo Targeting and Examinations
 


Department of Homeland Security 

Office of Inspector General 

OIG-10-34 January 2010 
Office of Inspector General 

U.S. Department of Homeland Security

Washington, DC 20528 

 January 6, 2010 

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 U.S. Customs and Border Protection’s progress in improving the 

Automated Targeting System as a tool in the multilayered cargo security strategy. 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. We 

trust 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 Audit ...................................................................................................................2


 Documentation Is Needed to Support Mandatory Examinations and Waivers ..............2 
 

Recommendation ............................................................................................................4


 Management Comments and OIG Analysis ...................................................................5 


 Examinations Requirements Need to Be Updated and Improved ..................................5 
 

Recommendations...........................................................................................................6

 Management Comments and OIG Analysis ...................................................................6 


 Targeting Rule Development and Change Process Can Be Improved ...........................7 
 

Recommendation ............................................................................................................8


 Management Comments and OIG Analysis ...................................................................8 
 

Appendixes 

Appendix A: Purpose, Scope, and Methodology .......................................................9 
 

Appendix B: Management Comments to the Draft Report .....................................12 
 

Appendix C: CBP’s Layered Cargo Security Strategy ............................................17 
 

Appendix D: Related Automated Targeting System Reports ..................................20
 


Appendix E: Major Contributors to This Report.....................................................21 
 

Appendix F: Report Distribution.............................................................................22 
 

Abbreviations 

ATS Automated Targeting System
 


CBP U.S. Customs and Border Protection 
 

CERTS Customs Enforcement Reporting and Tracking System
 


DHS Department of Homeland Security 
 

OFO Office of Field Operations 
 

OIG Office of Inspector General 
 

Cargo Targeting and Examinations 
 

OIG
 


Department of Homeland Security 

Office of Inspector General 

Executive Summary 

Section 809(g) of the Coast Guard and Maritime Transportation 

Act of 2004 (Public Law 108-293) requires the Office of Inspector 

General to submit an annual report on its evaluation of the current 

targeting system for international intermodal cargo containers. 

The Customs and Border Protection is responsible for operation of 

the targeting system and conducting cargo examinations. This is 

our fifth audit on selected aspects of the Automated Targeting 

System. The purpose of this audit was to evaluate selected aspects 

of the Automated Targeting System, to determine their 

effectiveness in assisting the agency in detecting potential acts of 

terrorism, and to identify actions needed to improve the targeting 

of high-risk containers for inspection. 

U.S. Customs and Border Protection could improve its record 

retention processes to support decisions made to waive or inspect 

high-risk shipments. Of the 391 shipments identified as high-risk 

and selected for review, 57 did not have enough documentation to 

support the decisions that were made. Therefore, there was no 

means of substantiating that officers properly or consistently 

followed procedures in waiving or examining shipments to keep 

dangerous goods from entering U.S. commerce. 

Guidance on how to conduct and record physical examinations of 

high-risk cargo containers for biological, chemical, nuclear, and 

radiological threats is outdated. Because U.S. Customs and Border 

Protection officers use their own discretion and inconsistent 

processes to examine cargo, potentially dangerous goods and 

substances may go undetected. 

We are making four recommendations for U.S. Customs and 

Border Protection to improve its process for updating targeting 

rules used to identify high-risk shipments by enhancing the 

procedures used for defining terms, documenting rule change 

decisions, and documenting the testing and evaluation of rule 

changes. U.S. Customs and Border Protection concurred with our 

recommendations and outlined plans and actions to implement the 

needed improvements. We made technical revisions to the report 

as appropriate, based on the agency comments. 

Cargo Targeting and Examinations 

Page 1 
Background 

The U.S. Customs and Border Protection’s (CBP) mission includes 

preventing terrorists and terrorist weapons from entering the 

United States while also facilitating the flow of legitimate trade 

and travel. In 2008, approximately 11 million oceangoing cargo 

containers arrived at the Nation’s seaports. To manage the 

potential security threats presented by this large volume of 

maritime cargo, CBP employs a multilayered approach, including 

analyzing and reviewing shipment information and targeting and 

inspecting high-risk cargo. The Automated Targeting System 

(ATS) is a key component of this multilayered security strategy. 

(See appendix C for a more detailed description of CBP’s Layered 

Security Strategy.) 

ATS is an enforcement tool that uses sophisticated automated 

techniques and algorithms to perform risk-based analysis of 

anomalies and strategic intelligence to indicate which shipments 

are high risk and require additional scrutiny and mandatory 

security inspections. Additionally, CBP officers at ports of entry 

use their local knowledge and judgment to select unusual or 

irregular shipments for inspection. 

A shipment selected by ATS or local CBP officers is held for a 

nonintrusive inspection. A nonintrusive inspection device takes xray images of the container’s contents, which CBP officers use to 

identify anomalies such as areas that appear unusual or 

inconsistent with the container contents listed on the shipping 

documents. If CBP Officers are unable to resolve the anomaly 

with a nonintrusive inspection, Officers may refer a shipment for 

physical examination, which may consist of a visual inspection of 

the container’s interior, limited inspection of selected contents, or 

complete unloading of the cargo. Officers also use physical 

examinations to determine whether a shipment contains undeclared 

or inadmissible cargo. 

Results of Audit 

Documentation Is Needed to Support Mandatory Examinations 

and Waivers 

CBP needs to ensure that documentation, either electronic or hard copy, is 

maintained to show that examinations of high-risk containers were 

Cargo Targeting and Examinations 

Page 2 
 

conducted or waived. According to CBP policy,1 at a minimum, all highrisk shipments must be scanned with nonintrusive inspection technology. 

If an anomaly is detected, the cargo must be examined and all examination 

activity recorded in ATS. CBP policy also requires that once a shipment 

is examined, CBP must maintain the nonintrusive inspection images for 30 

days, unless the examination resulted in a seizure or other event requiring 

longer retention. CBP allows CBP port directors to waive the mandatory 

physical examinations with proper justification if analysis of all 

information determined there was no security risk. 

Using the existing directives at the time of this review, we drew a sample 

of 391 high-risk shipments to determine whether CBP maintained 

adequate documentation to show that CBP officers conducted nonintrusive 

inspection examinations and physically examined or waived containers 

identified as high risk as specified by CBP’s policies. Our sample was 

selected from information gathered at seven ports of entry that handled 

269,813 high-risk shipments, representing nearly three-quarters of all 

high-risk shipments that entered the United States between October 1, 

2006, and March 31, 2008.2 

Testing Results 

CBP was unable to provide documentation to demonstrate that 

CBP officers conducted nonintrusive inspection examinations, 

physical examinations, or waived examinations for 17% (57 of 

391) of shipments identified as high risk. Specifically, CBP could 

not provide us with logs, nonintrusive inspection images, or other 

documentation (including electronic notes) substantiating that 

examinations were conducted or that waivers were granted based 

on a review of entry documentation. All but 9 of the 57 test 

failures occurred prior to CBP’s changes in policy in May 2007 to 

improve review of high risk shipments. 

While the results of our testing point to a positive change in CBP 

procedures to review and examine high risk shipments, further 

improvements are necessary. These results are not projectable 

because the samples were not designed to test for these 

improvements. 

1

 The National Maritime Targeting Policy, CBP Directive No. 3290-007B, issued December 28, 2007 and. 
 

Non-Intrusive Inspection Directive No. 3340-036, issued December 3, 2004. 


2

 Our sample was designed to assess the quality of CBP’s documentation of its mandatory examinations 
 

and waivers, not the quality of the inspections. We made no conclusions about whether the appropriate 
 

type of inspection took place. 
 

Cargo Targeting and Examinations 

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CBP officials acknowledge they are unable to prove beyond any 

doubt that all high risk shipments were examined and informed us 

that, among the possible reasons for missing non-intrusive image 

documentation, were software corruption, images that could not be 

retrieved due to proprietary systems and storage limitations, and 

failure on the part of CBP officers to properly record proof of 

examinations and waivers per current CBP policy. (See appendix 

A for more information about the scope of our testing.) 

Any high-risk shipment that is not examined or reviewed could 

cause catastrophic damage to the United States and its citizens if it 

happens to contain weapons of mass destruction. Without 

evidence documenting that high-risk containers were inspected and 

did not pose danger, CBP has no assurance that decisions to release 

these high-risk containers into U.S. commerce were appropriate. 

CBP needs to change its requirements for document retention to 

support examination decisions. This information should be used in 

conducting quality assurance efforts, such as validating release 

decisions, identifying trends or gaps in the conduct of high-risk 

examinations, or reviewing waiver decisions. Currently, DHS 

requires the retention of risk assessments for inbound and 

outbound cargo for up to 15 years. See 72 Fed. Reg. 43650, ATS 

System of Records Notice (Aug. 6, 2007). Also, with some 

exceptions, CBP requires importers to maintain their entry 

documentation for up to 5 years from date of entry. See 19 CFR 

163.4. To be consistent with regulatory requirements imposed on 

CBP for its risk assessments and on importers for their entry 

documents, CBP should consider requiring that its entry 

examination records (including those supporting waiver decisions) 

are maintained for an adequate period of time to allow for quality 

assurance and system reviews. 

Recommendation 

We recommend that the Commissioner of CBP: 

Recommendation #1: Require port directors to maintain either 

hard copy or electronic documentation produced when conducting 

examinations, or waiving examinations of containers determined to 

pose a high risk of containing weapons of mass destruction for a 

period long enough to allow for independent review. 

Cargo Targeting and Examinations 

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Management Comments and OIG Analysis 

CBP concurred with our recommendation and stated that CBP’s 

Office of Field Operations (OFO) will create and implement a 

standard waiver form to be used for all waivers of high risk 

shipments. Once created, OFO will issue guidance to the field on a 

standardized method of maintaining hard copy waivers to include 

the original signature of the authorizing official as well as 

document retention requirements. The duration of document 

retention will be determined using established CBP retention 

mandates as a guideline. CBP plans to have these actions 

completed by February 26, 2010. 

We consider CBP’s action plans to be responsive to the 

recommendation. This recommendation will remain open until all 

plans are completed and implemented to meet the intent of the 

recommendation. 

Examination Requirements Need to Be Updated and Improved 

Prior to 9/11, the emphasis of cargo examinations was to target and 

identify illicit goods or narcotics. If unexplainable anomalies were 

detected during a nonintrusive inspection, CBP officers were required to 

identify the type of threat and perform a physical examination, as required 

by the U.S. Customs Narcotics Interdiction Guide issued in 1999. 

After 9/11, the emphasis of CBP examinations shifted from narcotic 

enforcement examinations to antiterrorism examinations. However, CBP 

continued to rely on the 1999 guide. Because CBP officers do not have 

updated national guidance on how to conduct physical examinations 

related to antiterrorism threats such as those involving biological, 

chemical, radiological, and nuclear agents, CBP officers must rely on their 

own judgment, experience, and training to determine the type and extent 

of physical examinations to perform. 

For example, owing to the lack of updated guidance, we observed that 

CBP officers used their own judgment to estimate and record the amount 

of cargo that needed to be examined and did not follow the guide’s 

minimum requirements for the percentage of cargo that needed to be 

examined when conducting physical examinations. Further, as noted in 

our recently issued draft report, CBP’s Ability to Detect Biological and 

Chemical Threats in Maritime Cargo Containers, CBP does not have 

updated guidance to address biological and chemical threats. Updated 

guidance to properly examine and document the results of examinations is 

Cargo Targeting and Examinations 

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critical because CBP uses prior examination results to update and refine 

ATS’ cargo targeting rules. 

CBP management advised us that they are aware that the August 1999 

narcotics interdiction handbook needs to be updated and that they planned 

to update the guidance for performing examinations. While the guidance 

remains out-of-date with the current threat environment, CBP officers will 

continue to rely on their own judgment and may not be thoroughly or 

appropriately examining potentially dangerous cargo before it is released 

into public commerce. 

During our review of information recorded in ATS, we noted 

inconsistencies and potential inaccuracies in the information being 

recorded by CBP officers. CBP should periodically review its 

examination processes to ensure that the information is being recorded 

accurately. 

Recommendations 

We recommend that the Commissioner of CBP: 

Recommendation #2: Update and implement examination 

guidelines to specifically address terrorism threats and outline 

minimum procedures for CBP officers to follow when performing 

antiterrorism examinations, including specific procedures for 

inspecting for chemical, biological, nuclear, and radiological 

threats. 

Recommendation #3: Periodically assess the examination 

process to ensure that CBP officers are properly performing and 

accurately recording examinations in ATS. 

Management Comments and OIG Analysis 

CBP concurred with both of our recommendations. The Office of 

Field Operations is updating the Anti-Terrorism Contraband 

Enforcement Team National Directive to specifically address 

terrorism threats and outline minimum procedures for CBP officers 

to follow when performing anti-terrorism examinations, including 

specific procedures for inspecting for chemical, biological, nuclear, 

and radioactive threats. CBP plans to have this directive finalized 

by April 30, 2010. CBP will also update the Cargo Examination 

Reporting and Tracking System (CERTS) port guidance to include 

issuance of specific requirements to the field for input of 

examination findings in CERTS to assist the field with their 

Cargo Targeting and Examinations 

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internal audit processes. CBP plans to have this guidance finalized 

by July 30, 2010. 

We consider the actions taken by CBP to be responsive to our 

recommendations. Both recommendations will remain open until 

the Anti-Terrorism Contraband Enforcement Team (A-TCET) 

National Directive and CERTS guidance are finalized and 

implemented. 

Targeting Rule Development and Change Process Can Be 

Improved 

CBP can improve its process for changing or deleting targeting rules used 

to identify high-risk shipments by better defining terms, documenting rule 

change decisions, and documenting the testing and evaluation of rule 

changes. During 2007, CBP made 22 ATS rule changes and inactivated 

several rules when updating the ATS Security targeting weight set. 

As a part of the rule revision process, CBP extracts and analyzes 

examination results from cargo shipments in ATS. During the analysis of 

these results, CBP officers and analysts categorize the examined cargo by 

risk level. The process can be improved by providing more specific 

definitions for its risk categories. Another component of the rule update 

process involves the review of the proposed rule changes by subject matter 

experts. CBP can improve the process by ensuring the rationale for 

changes implemented or not implemented are documented and recorded 

for future use. 

The testing and evaluation of new rules can also be improved. CBP tests 

new rules using actual data to determine how well the new rules are 

working. However, the process for testing and evaluating the rules, and 

subsequent modifications of the new rules, are not formally documented. 

To improve this process, CBP could more clearly document the steps used 

to ensure that rule testing is consistent and test results are thoroughly 

analyzed. 

During our review, CBP began the process of improving rule process 

procedures to improve the controls over the targeting rules and testing 

processes. CBP’s Office of Intelligence and Operations Coordination, 

Automation and Targeting Division oversees the management of ATS 

rules development process and procedures. 

Cargo Targeting and Examinations 

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Recommendation 

We recommend that the Commissioner of CBP: 

Recommendation #4: Enhance current documentation efforts to 

ensure that each stage of the process for analyzing and developing 

ATS rules, including the rationale for making changes, specific 

definitions of terms used, and details on tools used to improve 

application consistency and rule change standardization, is 

documented. 

Management Comments and OIG Analysis 

CBP concurred with our recommendation and recognizes the 

critical need to document each stage of the process utilized for 

analyzing and developing ATS rules. To this end, CBP developed 

a documentation process to capture and record information that 

includes the rationale for rule changes, definitions of terminology, 

and the utilization of tools. The Office of Intelligence and 

Operations Coordination has introduced more formality into the 

rules process by implementing a structure to guide national 

conferences, rule evaluation, targeting development, and process 

management. In addition, a structure has been added to the 

existing processes for rules development and management 

oversight. We consider the actions taken by CBP to be responsive 

to the recommendation. This recommendation is now resolved and 

closed. 

Cargo Targeting and Examinations 


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Appendix A 

Purpose, Scope, and Methodology 

The purpose of this audit was to evaluate selected aspects of the 

Automated Targeting System, to determine their effectiveness in 

assisting CBP in detecting potential acts of terrorism, and to 

identify actions needed to improve the targeting of high-risk 

containers for inspection. We also observed the performance of 

physical cargo examinations to determine how accurately the 

examination results were entered into the Cargo Enforcement 

Reporting and Tracking System. We reviewed internal controls 

pertinent to our overall objective. 

During our audit, we met with CBP’s Office of Intelligence and 

Operations Coordination, Automation and Targeting Division at 

the National Targeting Center and CBP Headquarters in 

Washington DC, as well as various seaports nationwide. 

Using a statistically valid random sample of 391 targeted high-risk 

shipments arriving in the United States between October 1, 2006, 

and March 31, 2008, we tested two key control attributes: 

(1) whether documentation exists to show that the high-risk 

shipments were subject to nonintrusive inspections, and 

(2) whether additional examinations were conducted if the 

nonintrusive inspection examinations resulted in referrals for 

further inspection. 

At the National Targeting Center, we obtained an understanding of 

the process for developing and maintaining ATS Rules and 

Weight-Sets. We also obtained a database of 20,973,589 

shipments that entered the United States during FY 2007 and the 

first two quarters of FY 2008. To systematically analyze the 

nearly 21 million shipments mentioned above, we used threshold 

score for identifying high-risk shipments at ports of entry. Based 

on this information, we identified 362,179 high-risk shipments as a 

possible sample universe. We selected seven ports for review. 

This represents a statistical sample of 269,813 targeted high-risk 

shipments, or 74.5% of all high-risk shipments for the period. 

Our sample plan was developed to provide a 95% confidence level 

with a precision of +/-5 percentage points, or less, on all attributes 

that apply to the entire population of transactions. A statistical 

sample of 391 high-risk shipments was selected and used for each 

test. To allow for the replacement of transactions, we selected a 

total of 400 transactions for which we requested supporting 

documentation. We replaced a shipment if that shipment was not 

in an oceangoing vessel container. We did not replace a shipment 

if the transaction did not have the necessary support to show that 

Cargo Targeting and Examinations 

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Appendix A 

Purpose, Scope, and Methodology 

an exam was performed. Given the results of our work, we are 

95% confident that the examination results of between 11% and 

18% of high-risk containers are not correctly documented. 

We requested supporting documentation for each selected 

shipment and evaluated the effectiveness of internal controls over 

two key attributes: (1) documentation exists that the high-risk 

container received a nonintrusive examination, and 

(2) documentation exists that a secondary examination was 

conducted if the nonintrusive exam results in a referral. 

Results of our statistical tests of the examinations of high-risk 

shipments were projected only to the seven ports included in the 

statistical sample, not to the population as a whole. We designed 

our sample to assess the quality of CBP’s documentation of its 

mandatory examinations and waivers. Our sample was not 

designed to test the quality of inspections, and we offered no 

conclusion as to whether the appropriate type of inspection took 

place. 

A shipment above the ATS examination high-risk threshold score 

was considered failing an attribute if there was no documentation 

such as a nonintrusive inspection image, a log showing that a 

required nonintrusive inspection examination was performed, or 

notations in the ATS system. If a shipment was referred for further 

examination, usually because an anomaly was discovered during a 

nonintrusive inspection examination, the shipment was considered 

failing an attribute if there was no supporting documentation, such 

as examination documents or itemized notes in the ATS System. 

Because CBP policies related to cargo examinations and 

documentation changed during the time of our audit, we tested our 

statistical sample items in accordance with the policy in effect at 

the time the shipments entered the United States. 

Freight Remaining Onboard 

Of the 391 shipments selected for review, we identified 36 highrisk freight remaining onboard shipments that did not have 

documents to support that reviews occurred before waivers were 

granted. CBP policy prior to December 2007 required CBP 

personnel to review high-risk freight remaining onboard shipments 

before waiving them from examination. This policy, however, did 

not specifically instruct CBP personnel to document their review 

as support for waivers. Even though the support was inadequate, 

these shipments passed internal control tests if CBP policy did not 

Cargo Targeting and Examinations 

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Appendix A 

Purpose, Scope, and Methodology 

specifically require the documentation. CBP informed us that 

these freight remaining onboard shipments did not enter U.S. 

commerce, alleviating concerns that potentially dangerous cargo 

could be released into the country. 

Additionally, using data collection sheets, we documented our 

observations of CBP officers performing physical examinations of 

cargo. We counted alongside CBP officers who were opening and 

inspecting boxes and bags of cargo at the Centralized Examination 

Stations. After the physical counts were complete, we watched 

CBP officers record their examination results in the Cargo 

Enforcement Reporting and Tracking System. We interviewed 

CBP officers regarding their examination procedures and obtained 

the Cargo Enforcement Reporting and Tracking System screen 

prints on the examination results. 

We conducted this performance audit between April 2008 and May 

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 objectives. 

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

of this audit. 

Cargo Targeting and Examinations 


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Appendix B 

Management Comments to the Draft Report 

U.S. Department of Homeland Security

Washington. DC 20229

u.s. Customs and

Border Protection

November 17,2009

MEMORANDUM FOR: ANNE L. RICHARDS

ASSISTANT INSPECTOR GENERAL FOR AUDITS

FROM: ASSISTANT COMMISSIONER \\"',,11' ~1117/(}1 OFFICE OF INTERNAL AFFAIRS (J''''''''- -(

U.S. CUSTOMS AND BORDER PROTECTION

SUBJECT: U.S. Customs and Border Protection's Comments on Office of

Inspector General Draft Report Entitled "Automated Targeting

Systern Progress Report 2009: Cargo Targeting and Examinations"

- For Official Use Only version

Thank you for providing us with a copy ofthe draft report entitled "Automated Targeting System

Progress Report 2009: Cargo Targeting and Examinations" - For Official Use Only version.

Attached are U.S. Customs and Border Protection (CBP) formal responses to the

recommendations and technical corrections to the draft report.

With regard to the classification ofthe draft report, CBP has identified information that requires

restricted public access based on a designation of "For Official Use Only." As a result, also

attached are recommended redactions. Please consider CSP's concerns prior to finalizing the

report.

Thank you for your assistance. Should you have any questions, please have a member of your

staff contact Ms. Arlene Lugo, Audit Liaison, Office of Internal Affairs, at (202) 344-1218.

Attachment

Cargo Targeting and Examinations 
 

Page 12 
 
Appendix B 

Management Comments to the Draft Report 

2

DRS Office oflnspector General's (OIG) Draft Report Entitled "Automated Targetin2

System Progress Report 2009: Cargo Targeting and Examinations"

For Official Use Only

CBP Corrective Action Plans

Recommendation 1: Require port directors to maintain either hard copy or electronic

documentation produced when conducting examinations or waiving examinations of containers

determined to have a high risk of containing weapons of mass destruction for a period long

enough to allow for independent review.

CBP Response: Concur. U.S. Customs and Border Protection's (CBP's) Office ofField

Operations (OFO) will create and implement a standard waiver form to be used for documentation

of all waivers of high risk shipments. Once created, OFO will issue guidance to the field on a

standardized method ofmaintaining hard copy waivers to include the original signature ofthe

authorizing official as well as document retention requirements. The duration ofdocument

retention will be determined using established CBP retention mandates as a guideline. This hard

copy will provide justification and recordation of authorized approval.

Additionally, as Cargo Enforcement Reporting and Tracking System (CERTS) is the requisite

system of electronic documentation of examination results and waivers, OFO will deploy

automated reports in CERTS intended to help CBP personnel, including CBP field managers and

headquarters, determine if all high risk shipments have been appropriately held, examined or

waived. The "Maritime Cargo Mandatory Exam Report" is designed to identify high risk

shipments that require additional enforcement action from CBP. Also within the report "Maritime

Cargo Mandatory Exam Report" is a column indicating the number ofhigh risk shipments waived.

The data has a hyperlink to a list of corresponding Shipment ID numbers (SID) to facilitate further

research. A draft version ofthis report is currently functional in CERTS.

Due Date: February 26,2010

Recommendation 2: Update and implement examination guidelines to specifically address

terrorism threats and outline minimum procedures for CBP officers to follow when performing

anti-terrorism examinations, including specific procedures for inspecting for chemical, biological,

nuclear, and radioactive threats.

CBP Response: Concur. CBP's OFO is updating the Anti-Terrorism Contraband Enforcement

Team (A-TCET) National Directive to specifically address terrorism threats and outline minimum

procedures for CBP officers to follow when performing anti-terrorism examinations, including

specific procedures for inspecting for chemical, biological, nuclear, and radioactive threats.

Due Date: April 30, 2010

Recommendation 3: Periodically assess the examination process to ensure CBP Officers are

properly performing and accurately recording examinations in Automated Targeting System

(ATS).

Cargo Targeting and Examinations 
 

Page 13 
 
Appendix B 

Management Comments to the Draft Report 

3

CBP Response: Concur. CBP's OFO will update CERTS port guidance to include issuance of

specific requirements to the field for input of examination findings in CERTS. As CERTS is the

requisite system of electronic documentation of examination results, OFO will deploy automated

reports in CERTS to assist the field with their internal audit processes. Within the report

"Maritime Cargo Mandatory Exam Report" is a column that indicates which high risk shipments

were held and released, but have no exam results posted in CERTS. The data has a hyperlink to a

list of corresponding shipment ID numbers (SID) to facilitate further research. A draft version of

this report is currently functional in CERTS.

Due Date: July 30, 2010

Recommendation 4: CBP can improve its process for changing or deleting targeting rules used

to identify high-risk shipments by better defining terms, documenting rule change decisions, and

documenting the testing and evaluation ofrule changes.

CBP Response: Concur. CBP uses a risk-based approach to cargo targeting. This approach

utilizes advance information, emphasizes automated systems, and is enhanced by intelligence and

analysis. ATS is used to collect and analyze cargo shipping data, to distinguish and select highrisk shipments for further review and examination. ATS targeting concepts are based on the

following risk factors: familiarity indicators, geographic routing and addresses, violation history,

intelligence, and high-risk commodities. CBP relies upon ATS to assist in identifying high-risk

shipments by providing the targeting officer with critical shipment information as well as

historical transaction data on the parties involved, their enforcement history with CBP, and any

pertinent intelligence available on the operating entities at the time ofreviewing the shipment

transaction data.

CBP does recognize the critical need to document each stage ofthe process utilized for analyzing

and developing ATS rules. In pursuing this objective, CBP developed a documentation process to

capture and record information that includes rationale for rule changes, definitions ofterminology,

and identifies the utilization oftools. The Office of Intelligence and Operations Coordination

(OIOe) has introduced more formality into rules evolution by implementing a structure to guide

national conferences, rule evaluation, targeting development and process management. Additional

structure has been added to the existing processes for rules development and management

oversight. OIOC has established a consistent approach to targeting evolution and rules

development, determining measures ofthe effectiveness ofrules, and ensuring accountability for

all activities pertaining to cargo and passenger targeting rules.

OIOC has described its process in the document, "Rule Development Group CONOPS" that was

given to OIG. OIOC implementation has been evolving and includes the use of information

sharing technology such as SharePoint. This relevant data includes information from rules

conference and associated documentation and includes, but is not necessarily limited to:

•

•

•

Agenda

Subject Matter Expert (SME) input and presentation material prepared for the conference

Reference material used at the conference (e.g., glossary ofterms, statistical information

on mode-specific shipments, rule firing counts and likelihood ratios, ROC analyses,

spreadsheets with proxy positive data, etc)

Cargo Targeting and Examinations 
 

Page 14 
 
Appendix B 

Management Comments to the Draft Report 

4

•

•

Presentation material prepared during and presented at the end ofthe conference

Conference Summary

Subsequently, additional information relative to the weight set and associated current and new

rules, changes, and significant correspondence are added to the SharePoint site. For a given

national weight set, the SharePoint site can be viewed as a "binder" -living documentation that

contains (or possibly references) material and decisions that have guided the evaluation, targeting

development and process management associated with the transition ofthe weight set and rules.

The SharePoint site is updated as ATS operational data becomes available subsequent to

deployment ofthe new or revised weight set and rules. As targeting and rule effectiveness metrics

are generated on a continuing basis, record keeping processes and oversight will be performed,

and results will be included in the SharePoint site.

Revisions to a weight set are identified as an Evolutionary Improvement as defined in the

CONOPS. An evolutionary improvement responds to an operational need that can be done over a

time frame longer than a few days. The process takes advantage ofthe timing requirements for the

change and provides the opportunity for assessment and evaluation ofthe capabilities before

implementation occurs. In contrast to a revolutionary improvement, an evolutionary improvement

does not include significant new targeting concepts such as extensive algorithmic changes to rulesbased targeting nor does the decision process used for an evolutionary improvement necessitate

full understanding ofthe cost, benefit, or full impact ofthe intended change before and during its

consideration and development.

In the CONOPS, the Evolutionary Improvement Process Flow identifies the activities and

decisions related to responding to a desired targeting change that is characterized as a relatively

smal1 or moderate-size modification to existing operational ATS capabilities. Key activities

associated with the transition are documented and the associated documentation is included in the

SharePoint site. Such activities include:

•

•

•

•

•

Evolutionary Improvement - Improvement Request

Evaluate Impact on Targeting Scores (performance Analysis)

DefinelUpdate Potential Change

Evaluate Potential Performance and Impact

Record Change and Metrics

During analysis and evaluation ofthe potential performance and impact (for weight set and rules),

OIOC tools are used to improve consistency of application and standardization ofrule changes.

Two such tools that CBP uses are:

• Targeting Assessment Toolkit (TAT) that automates and standardizes the Receiver

Operating Characteristic (ROC)-based performance evaluation analysis ofthe ATS used by

CBP to identify shipments requiring closer scrutiny in order to reduce risks to our nation's

supply chain.

Cargo Targeting and Examinations 
 

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5

• Semi-automated methodology for identifying "proxy positive" shipments from the set of

all examined shipments, based on a consistent process of data analysis ofthe examination

results that are reported in up to six CBP data repositories.

The TAT provides the capability to generate and display ROC curves and related performance

data in a variety offormats to support many different types of analyses. The I56-page document

User Manual for the Targeting Assessment Toolkit describes the integrated set ofsoftware

applications that automate and (automatically) document the generation of ATS performance

metrics based on user-defined parameters.

The document Proxy Positive Identification Process describes the enhanced methodology for

identifying "proxy positive" shipments. These "proxy positive" shipments are the basis for all

ROC-based performance evaluation analysis oftargeting performance and other data analyses

supporting CBP operations. The methodology is repeatable and comprehensive, as it includes all

modes oftransportation and is able to integrate data from a wide variety of highly complex and

inconsistent databases.

In addition to electronically capturing information related the analysis and development ofATS

rules, CBP has documented the formal methodology for developing the National Security Country

Threat Tier Model and monitors daily automated reports on ATS utilization.

Due Date: CBP believes that by initiating the above steps, it has implemented the 010

recommendation for an improved process for changing or deleting targeting rules used to identify

high-risk shipments by better defining terms, documenting rule change decisions, and

documenting the testing and evaluation ofrule changes.

Appendix B 

Management Comments to the Draft Report 

Cargo Targeting and Examinations 
 

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Appendix C 

CBP’s Layered Cargo Security Strategy 

CBP has implemented a layered approach to prevent cargo linked 

to terrorism from entering the country. The use of a layered 

approach implementing multiple diverse strategies and initiatives, 

such as Customs-Trade Partnership Against Terrorism and the 

Container Security Initiative, is essential to accomplish this goal. 

The wide range of possible terrorist threat scenarios requires the 

use of tiered and varied strategies. No single approach to cargo 

security can sufficiently protect against the terrorist risk. CBP’s 

layered security is initiated by requiring that ocean carriers submit 

manifest information 24 hours before the cargo containers are 

loaded and shipped at a foreign seaport and requiring importers to 

provide entry documentation declaring items within 15 calendar 

days after arrival. 

ATS currently has the capability to electronically compare 

manifest and other available data to detect any significant 

anomalies and facilitate their resolution. Using ATS, CBP officers 

review all cargo shipment information (manifest, entry and 

Importer Security Filing data) to determine the risk posed by 

shipments. CBP officers use the ATS information along with other 

information to help determine which shipments are high-risk and 

the type of examination that should be conducted, if any. 

To further improve ATS’ ability to target high-risk cargo, CBP 

recently published an interim final rule on importer security filing 

and additional carrier requirements. This new rule requires 

importers to submit additional data, generally no later than 24 

hours prior to the container being loaded onto a U.S.-bound vessel. 

Also, in addition to what was required under the 24 hour rule, 

carriers must now submit vessel stow plans and container status 

messages in certain situations. CBP stated that this additional 

information will help stabilize ATS scoring as shipments move 

through the supply chain, allowing for more effective targeting and 

examination of high-risk level shipments. 

CBP has also initiated the Secure Freight Initiative pilot as part of 

the overall layered security approach. This DHS and Department 

of Energy program is intended to strengthen maritime cargo 

security and global nuclear nonproliferation efforts by providing 

real-time radiographic and spectrographic scanning of maritime 

shipping containers. The pilot is currently underway at five 

foreign seaports. 

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Appendix C 

CBP’s Layered Cargo Security Strategy 

Programs and Initiatives in the Layered Security Improving ATS' Effectiveness 

Cargo Origination 

Empty Container 

Shipment Consolidation 

Port of Origin 

Transshipment Port Port of 

Entry 

Storage 

Shipment Deconsolidation Destination 

Packaging Origination 

Storage 

SECURITY LAYERS CBP Officers 

Customs-Trade Partnership Against Terrorism 

Intelligence Community 

CBP's Automated Targeting System Risk Assessment of Cargo 

100% Cargo Screening 

 Advance Security Filing 

24-Hr. Rule 

SFI 

CSI 

International Ship and Port Facility Security Code 

USCG Advance Notice of Arrival 

Radiation Portal Monitors 

Nonintrusive Inspections 

Physical Inspections 

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Appendix C 

CBP’s Layered Cargo Security Strategy 

U.S. Customs and Border Protection Officers CBP Officers are the first line of defense in the security of the supply chain and the last to release the cargo. Customs-Trade Partnership Against Terrorism (C-TPAT) Voluntary government-business initiative to strengthen supply chain security. C-TPAT offers participating importers, carriers, consolidators, and brokers an incentive in having less frequent and expedited cargo inspections. Intelligence Community Shares critical information as needed, which ATS uses to assess cargo shipment risk. Automated Targeting System CBP’s risk model system that uses information from multiple sources to screen 100% of the cargo shipped into the United States against a set of rules to determine each shipment’s risk level. 100% Cargo Screening CBP’s goal is to screen 100% of U.S.-bound cargo before it leaves the port of origin. Importer Security Filing Provides additional advanced cargo information intended to enhance CBP’s ability to identify and stop dangerous cargo from entering the United States through ATS risk-based assessments. 24-Hour Rule Requires the submission of complete and accurate manifest information 24 hours before a container destined for the United States is loaded onto a vessel in a foreign port. 

Initiative to improve the ability to scan containers for nuclear and radiological materials overseas to better assess the risk of inbound containers. This is a joint partnership between DHS and the Department of Energy for radiological equipment acquisition. Container Security Initiative (CSI) A reciprocal program enabling bilateral arrangements between CBP and foreign authorities to help identify high-risk containers before they are loaded onto U.S.-destined vessels. International Ship and Port Facility Security (ISPS) Code A 2002 amendment to the International Maritime Organization (IMO), International Convention for the Safety of Life At Sea (SOLAS). According to the IMO, the ISPS Code establishes “a comprehensive set of measures to enhance the security of ships and port facilities” that were developed in the wake of the September 11, 2001, attacks against the United States. USCG Advance Notice of Arrival U.S. Maritime Domain Awareness safeguards our systems of transportation by integrating legacy information and intelligence systems with current and emerging intelligence capabilities. This includes detailed crew and passenger information and cargo details, as well as voyage history from shipping companies, intelligence and law enforcement community and others 96 hours before arrival at a U.S. port. 

Secure Freight Initiative (SFI) 

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Appendix D 

Related Automated Targeting System Reports 

Report Title Date Issued 

Audit of Targeting Oceangoing Cargo Containers, OIG-05-26 July 31, 2005 

Audit of Targeting Oceangoing Cargo Containers, OIG-07-09 November 21, 2006 

Targeting Oceangoing Cargo Containers, OIG-07-72 August 28, 2007 

Targeting of Cargo Containers 2008: Review of CBP’s Cargo 

Enforcement Reporting and Tracking System, OIG-08-65 June 11, 2008 

CBP’s Ability to Detect Biological and Chemical Threats in 

Maritime Cargo Containers, OIG-10-01 October 7, 2009 

To obtain copies of these reports, visit the OIG website at www.dhs.gov/oig. 

Cargo Targeting and Examinations 


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Appendix E 

Major Contributors to This Report 

Paul Wood, Director for Trade Operations 

 Carlos Berrios, Audit Manager 

 Robert Edwards, Auditor 

 James Barnett, Auditor 

 Yesenia Starinsky, Desk Officer 

 Jim Bess, Referencer 

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Appendix F 

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 Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Acting Commissioner of Customs and Border Protection 

DHS Component Liaison 

DHS Audit 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 

Cargo Targeting and Examinations 
 

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ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, 

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 us 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.