Department of Homeland Security 

Office of Inspector General 

Improvements Needed in the Process to 
 

Certify Carriers for the Free and Secure 
 

Trade Program 
 

OIG-11-25 March 2011 
    

Office of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

MAR 14 2011

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 the strengths and weaknesses of the United States Customs and 

Border Protection’s ability to ensure that only low risk commercial carriers and drivers 

are allowed to participate in the Free and Secure Trade Program. 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. 

Anne L. Richards 

Assistant Inspector General for Audits 
Table of Contents/Abbreviations 

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


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

Results of Audit ...................................................................................................................4 
 

Carrier Certification Process Needs Improvement to Ensure Only Low Risk 
 

Participation ................................................................................................................4 
 

Initial Enrollment Process for FAST Drivers Generally Ensures Low Risk 

Participation ................................................................................................................9 
 

Recommendations........................................................................................................10 
 

Management Comments and OIG Analysis ................................................................10 
 

Appendices 

Appendix A: Purpose, Scope and Methodology........................................................12 
 

Appendix B: Management Comments to the Draft Report.......................................15 
 

Appendix C: Major Contributors to this Report........................................................19 
 

Appendix D: Report Distribution ..............................................................................20 
 

Abbreviations 

CBP United States Customs and Border Protection 
 

C-TPAT Custom-Trade Partnership Against Terrorism
 


FAST Free and Secure Trade 
 

GES Global Enrollment System
 


SAFE Port Act Security Accountability For Every Port Act of 2006 
 
 

OIG 
 Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The Free and Secure Trade program is a commercial clearance 

program for known low-risk shipments entering the United States from 

Canada and Mexico which allows for expedited processing of entities 

that have completed background checks and fulfill certain eligibility 

requirements. The purpose of our review was to determine whether 

Customs and Border Protection’s initial enrollment process ensures 

that only low risk carriers and drivers are allowed to participate in the 

Free and Secure Trade program. 

Improvements are needed in Customs and Border Protection’s initial 

enrollment process for carriers to ensure that only low risk carriers are 

allowed to participate in the Free and Secure Trade program. Highway 

carriers that did not meet all Custom-Trade Partnership Against 

Terrorism’s minimum security requirements have been certified to 

receive Free and Secure Trade program benefits. Supervisors did not 

review supply chain security specialists certification decisions to 

determine carrier eligibility. Also, the Customs and Border Protection 

Vetting Center and Customs-Trade Partnership Against Terrorism 

supply chain security specialists did not always follow established 

procedures when determining the initial eligibility of highway carriers. 

In some instances, the supply chain security specialist did not verify 

the accuracy of the law enforcement vetting information provided by 

the Vetting Center. In other instances, the supply chain security 

specialist did not receive law enforcement vetting information from 

the Vetting Center to verify. These instances occurred due to limited 

resources and interpretation of carrier vetting policy. As a result, the 

initial enrollment process for carriers is vulnerable to high risk carriers 

being certified and allowed to participate in the Free and Secure Trade 

program. However, Customs and Border Protection’s initial 

enrollment process for Free and Secure Trade drivers generally 

ensures that only low risk drivers participate in the Program. We are 

making two recommendations to improve Customs and Border 

Protection’s processing and oversight of the carrier initial enrollment 

certification process. Customs and Border Protection concurred with 

both recommendations and is in the process of implementing 

corrective actions. 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 
 

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Background 

Customs and Border Protection’s (CBP) priority mission is preventing 

terrorists and terrorist weapons from entering the United States, while 

also facilitating the flow of legitimate trade and travel. CBP uses 

multiple strategies and initiatives to accomplish its dual goals. One 

initiative is the Free and Secure Trade (FAST) program which was 

established after September 11, 2001 as a commercial clearance 

program for known low-risk shipments entering the United States from 

Canada and Mexico. This program is administered by CBP and allows 

for expedited processing for industry members (drivers, carriers, 

importers and manufacturers) that have fulfilled certain eligibility 

requirements and have qualified as low risk participants. Using FAST 

to help manage risk enables CBP to redirect security efforts on high or 

unknown risk commerce. Our review focused on the initial enrollment 

processes for FAST drivers and Customs and Trade Partnership 

Against Terrorism (C-TPAT) carriers and the policies and procedures 

CBP established to oversee these processes to ensure that only lowrisk drivers and carriers are eligible for FAST participation. 

A carrier desiring to participate in the FAST program must be certified 

through the C-TPAT process.1

 The carrier must provide sufficient 

information in the required security profile that demonstrates that its 

security processes and procedures satisfy the C-TPAT minimum 

security requirements. An entity interested in becoming a C-TPAT 

member first submits an application and a 29-part security profile via 

the C-TPAT Web Portal. Officers at the CBP Vetting Center vet 

carrier applicants by running queries in CBP’s law enforcement 

database know as TECS and the Automated Commercial Environment 

system (ACE). The vetting officer then enters a vetting summary into 

the C-TPAT Web Portal. The C-TPAT supply chain security 

specialist assigned to the applicant then conducts further vetting to 

verify the Vetting Center’s results. If the applicant successfully passes 

vetting, the specialist then reviews the security profile to determine if 

the applicant’s responses satisfy C-TPAT minimum security criteria. 

If so, the carrier is certified as a C-TPAT member and is then eligible 

to receive FAST benefits. FAST benefits include use of dedicated 

FAST lanes at land border ports for greater speed and efficiency, 

reduced Automated Targeting System score lessening the probability 

1 C-TPAT is a CBP initiative that seeks to achieve CBP’s twin goals of security and facilitation of trade by 

collaborating with willing trade community members to secure their supply chains. Through this initiative, 

CBP attempts to strengthen supply chain security by requesting businesses to ensure the integrity of their 

security practices, as well as their business partners’ security practices within the supply chain. 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 
 

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of inspection, and they are allowed to move to the front of the line 

when FAST shipments are selected for Non-Intrusive Inspection and 

secondary examinations at the port facility. During FY 2009, C-TPAT 

approved 195 highway carriers and denied 134 applicants. At the time 

of our review, there were approximately 2,625 C-TPAT carriers. 

While FAST shipments are considered known low risks, they are still 

subject to screening and examination based upon targeting scores, 

selectivity, and inspector-initiated enforcement actions commensurate 

with the threat. 

The Security Accountability For Every (SAFE) Port Act of 2006 

requires C-TPAT to complete the certification process within 90 days 

of receipt of an application. The Act also requires C-TPAT to conduct 

an on-site validation of the C-TPAT member’s supply chain security 

measures within one year of certification. The supply chain security 

specialist conducting the validation will make recommendations 

requiring corrective actions in areas where the member falls short of 

C-TPAT minimum security requirements. Carriers have 90 days to 

address these recommendations or face suspension from C-TPAT. 

The shipment’s driver must be a member of the FAST Commercial 

Driver Program. To become a member, a driver applies online via the 

Global Online Enrollment System. An Officer at the Vetting Center 

then vets the applicant by running queries in various law enforcement 

and operational databases such as TECS, the National Crime 

Information Center, the Central Index System, and the Automated 

Targeting System. The vetter notes any derogatory information on the 

risk assessment. If the applicant’s review indicates that agency 

standards are satisfied, the vetter grants the applicant conditional 

approval which is subject to final review and approval at the 

enrollment center. If agency standards are not met, the application is 

denied. However, the supervisory vetting officer has authority to 

override the denial recommendation and grant conditional approval. 

After conditional approval, CBP notifies the applicant and informs him 

to schedule an appointment at any of the 22 Enrollment Centers. At 

the Enrollment Center, a CBP officer verifies the applicants’ 

identifying information by reviewing physical documents such as 

drivers licenses, birth certificates, social security numbers and other 

identification documents. The officer also interviews the applicant, 

takes the applicant’s fingerprints and digital photograph, and attempts 

to resolve any issues identified by the Vetting Center. Fingerprint and 

digital photographs are queried using the Automated Biometric 

Identification System and the Integrated Automated Fingerprint 

Identification System. Based on the results, the officer can enroll the 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 
 

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applicant in the FAST Driver Program or recommend denial. A 

supervisory officer reviews recommended denials and has the 

authority to override them. More than 90,000 drivers are enrolled in 

the FAST program nationwide. During FY 2009, CBP approved 

20,391 and denied 1,578 driver applicant’s participation in the FAST 

driver program. 

Results of Audit 

Improvements are needed in CBP's initial enrollment process for 

FAST carriers to ensure that only low risk carriers are allowed to 

participate in the FAST program. Specifically, highway carriers that 

did not meet all C-TPAT's minimum security requirements have been 

certified to receive FAST program benefits. Supervisors did not 

review supply chain security specialist certification decisions to 

determine carrier eligibility. Also, the Vetting Center and C-TPAT 

supply chain security specialists did not always follow established 

procedures when determining the initial eligibility of highway carriers. 

In some instances, the supply chain security specialist did not verify 

the accuracy of the law enforcement vetting information provided by 

the CBP Vetting Center. In other instances, the supply chain security 

specialist did not receive law enforcement information from the 

Vetting Center to verify. CBP management explained that these 

instances occurred due to limited resources and interpretation of 

carrier vetting policy. As a result, the initial enrollment process for 

carriers is vulnerable to high risk carriers being certified and allowed 

to participate in the FAST program. The initial enrollment process for 

drivers generally ensures that only low risk drivers participate in the 

FAST program. CBP has improved its initial enrollment process for 

FAST drivers by reinforcing its policy at the Enrollment Centers that 

during the interview process the CBP officer must ask all the required 

questions to determine whether a driver is eligible to participate in the 

program. 

Carrier Certification Process Needs Improvement to Ensure Only 

Low Risk Participation 

The initial enrollment process for carriers does not always ensure that 

only low risk carriers are eligible to participate in the FAST program. 

Highway carriers that did not meet all C-TPAT minimum security 

requirements have been certified to receive FAST program benefits. 

Furthermore, the Vetting Center and C-TPAT supply chain security 

specialists do not always follow established procedures when vetting 

carriers for certification. As a result, the initial enrollment process for 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 
 

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carriers is vulnerable to high risk carriers being certified and allowed 

to participate in the FAST program. 

Highway Carriers were Certified that Did Not Meet Minimum 

Security Standards 

CBP certified highway carriers to receive FAST program benefits that 

did not demonstrate adherence to all of the C-TPAT minimum security 

requirements in the information provided in their application for 

certification. Supervisors did not review of the supply chain security 

specialist’s certification decision to determine program eligibility. 

Also, supply chain security specialists’ use of discretion when 

reviewing security profiles has added to the inconsistent application of 

C-TPAT minimum security requirements. 

The standard operating procedure requires supply chain security 

specialists to review the applicant’s security profile to establish that 

the company satisfies C-TPAT’s minimum security requirements. The 

standard operating procedure requires the company’s security profile 

responses to delineate in detail the security processes the company has 

implemented throughout its international supply chain. If the security 

profile is approved, the supply chain security specialist changes the 

company’s C-TPAT status from “Applicant” to ‘Certified.” Supply 

chain security specialists use their experience and discretion when 

reviewing the security profile and deciding whether to approve or 

reject security profile responses. 

The SAFE Port Act of 2006 requires CBP to establish sufficient 

internal quality controls in support of C-TPAT program management. 

Specifically, CBP must ensure that C-TPAT has a standardized work 

program to be used by agency personnel to carry out the certifications. 

Additionally, OMB Circular No. A-123 states that Management is 

responsible for establishing and maintaining internal control to achieve 

the objectives of effective and efficient operations and compliance 

with applicable laws and regulations. In the security profile review 

process, C-TPAT Field Office supervisors review cases in which a 

supply chain security specialist recommends that a carrier be denied CTPAT certification. However, supervisors do not review the supply 

chain security specialist’s certification decision when the specialist 

grants C-TPAT certification. 

We reviewed 19 carriers certified by CBP during fiscal year (FY) 2009 

at the Buffalo, New York and Houston, Texas C-TPAT Field Offices 

to assess the C-TPAT’s vetting process for carrier applicants. Of the 

19 carriers, 11 had subsequently undergone validation examinations 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 
 

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after receiving certification. C-TPAT determined that 5 of these 11 

did not meet minimum security criteria at the time of on-site 

validation. 

For example, the supply chain security specialist certified one of the 

carriers even though it failed to respond to 3 of the 29 critical security 

areas in its application: (1) Conveyance Security - no documented 

procedures to prevent unauthorized entry in storage areas; (2) Physical 

Access Controls - no documented procedures to ensure employees are 

only given access to secure areas needed for performance of their 

duties; and (3) - Physical Security -no documented procedures for 

issuance, removal, and changing of access devices. The supply chain 

security specialists assigned to review the security profile for this 

carrier used officer discretion by certifying the carrier without 

indication of adherence with these security requirements. During onsite validation, the supply chain security specialist determined that the 

carrier did not have effective security measures in place and failed to 

satisfy the same three requirements. CBP issued a 90 day compliance 

letter requiring the carrier to implement and document procedures for 

preventing unauthorized entry in storage areas; limit employee access 

to those secure areas needed for the performance of their duties; and 

implement and document procedures for the issuance, removal, and 

changing of access devices. 

In another example the supply chain security specialist certified a 

carrier to participate in the FAST program despite failing to respond to 

another 3 critical security requirements in its application: (1) Business 

Partner Security Procedures - no documented process for screening 

business partners beyond financial soundness issues; (2) Physical 

Security - Alarm Systems and Surveillance - did not use video 

surveillance cameras to monitor premises and prevent unauthorized 

access; and (3) Security Training and Threat Awareness - no specific 

employee training to recognize internal conspiracies and no continuous 

security training to maintain currency of threat issues. During the onsite validation the supply chain security specialist determined that this 

carrier did not meet the minimum security requirements in these same 

three areas. CBP issued a 90 day compliance letter requiring the 

carrier to develop written and verifiable processes for screening 

business partners beyond financial soundness issues to include security 

indicators; use video surveillance cameras to monitor premises in 

order to prevent unauthorized access to conveyances, trailers, cargo 

handling and storage areas; and provide specific training to employees 

to help them to recognize internal conspiracies and provide continuous 

security training to keep up-to-date on security related issues. CBP 

will suspend or revoke the carriers C-TPAT certification when the 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 

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corrective action taken by the carrier does not satisfy the compliance 

requirements. 

We brought these concerns to the attention of C-TPAT management to 

obtain any additional insight that may have existed which impacted the 

supply chain security specialist’s decision to grant certification despite 

the obvious failure of these members to meet established minimum 

security requirements. CBP management said that “a one size fits all” 

approach cannot be used when determining compliance with the 

security requirements and that each case must be handled on an 

individual basis. CBP management added that the supply chain 

security specialist often must rely on his experience and discretion 

when determining certification eligibility. 

Certifying C-TPAT members whose security profile responses that do 

not satisfy minimum security requirements could compromise the goal 

of the FAST program, which is to offer expedited processing to known 

low-risk carriers. Moreover, because supply chain specialists have up 

to a year to conduct an onsite validation, high-risk carriers that were 

certified could have up to a year to participate in FAST. In these two 

examples the carriers were ineligible to receive FAST benefits, but 

were allowed to participate in the FAST program and receive benefits 

for approximately 3 months until the validation determined their 

ineligibility. C-TPAT should enhance management oversight to 

ensure that supply chain security specialists certify carriers only if they 

meet all of C-TPAT’s minimum security criteria. 

Effective May 1, 2010, CBP established a new procedure for 

withholding FAST lane benefits from newly certified Mexican 

Highway Carriers until they have been validated. This process 

requires that all validation site visits be completed within 120 days 

from the date of certification unless extenuating circumstances exist 

which must be approved by C-TPAT Headquarters. Further, FAST 

benefits will only be administered once the highway carrier has 

responded to all actions required that are listed within the initial 

validation report and has satisfied C-TPAT program officials that 

proper compliance has been established. Once the carrier is approved 

to receive FAST benefits the Field managers will notify CBP 

Headquarter’s enforcement team to apply benefits for the highway 

carrier. 

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CBP Vetting Center and C-TPAT Supply Chain Security 

Specialist Do Not Always Follow Established Procedures When 

Vetting Carriers For Certification. 

Vetting Center officers and C-TPAT supply chain security specialists 

do not always vet carrier applicants using the two-tiered approach 

required by CBP operating procedures. In some instances, the supply 

chain security specialist did not verify the accuracy of law 

enforcement vetting information provided by the Vetting Center. In 

other instances, the Vetting Center did not provide law enforcement 

information to the supply chain security specialist to verify. 

CBP’s standard operating procedures for C-TPAT supply chain 

security specialists establish a two-tiered process for vetting highway 

carrier applicants. First, the Vetting Center reviews the TECS law 

enforcement database and the ACE system to determine whether the 

applicant has any derogatory information which would preclude FAST 

participation. The Vetting Center then provides the vetting results to 

the C-TPAT supply chain security specialist who must subsequently 

re-vet the applicant to ensure that the Vetting Center’s results were 

accurate. Also, the CBP FAST Manual states that highway carrier 

applications are forwarded to C-TPAT for further review after risk 

assessments are conducted by the Vetting Center. 

We reviewed a sample of 19 carriers that were certified during FY 

2009 at the Buffalo, New York and Houston, Texas C-TPAT Field 

Offices. We determined that only 3 of the 19 carriers sampled were 

vetted by both the Vetting Center officer and the supply chain security 

specialists as required. Of the remaining 16 applicants, 5 were vetted 

by the Vetting Center only, while 11 carriers were vetted by a supply 

chain security specialist only. In one example, the Vetting Center 

surfaced concerns regarding a carrier’s application whose company 

name was identified in the TECS database query as having transported 

an illegal commodity. However, because of differences in the TECS 

database regarding the identity of the suspect company and the 

applicant, the Vetting Center was unable to link the law enforcement 

database results to the applicant. The Vetting Center recommended 

approval contingent upon subsequent vetting, which could 

conclusively determine that no association existed between the 

applicant and the suspect company. CBP maintained no evidence that 

the supply chain security specialist performed subsequent vetting. 

CBP management explained that the Vetting Center did not always 

follow the layered vetting process due to limited resources, which 

often results in a vetting backlog. When this backlog occurs, the 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 

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vetting officer does not have sufficient time to conduct the required 

vetting and provide the results to the supply chain security specialist. 

Also, CBP management does not interpret its policy to require layered 

vetting for all carriers—only for carriers with negative law 

enforcement information. In addition, CBP explained that these 

instances occurred because of insufficient communication between 

C-TPAT and the Vetting Center regarding coordination of resources 

and requirements. 

Inconsistent use of the established vetting process could increase the 

risk of granting FAST benefits to ineligible applicants and could 

compromise border security. The carrier vetting process combines the 

supply chain security specialists’ expertise with C-TPAT requirements 

and the Vetting Center’s enhanced vetting capabilities to create a 

layered vetting approach aimed at preventing C-TPAT certification of 

high-risk carrier applicants. CBP should enhance oversight to ensure 

that staff at the Vetting Center and C-TPAT complete all required 

vetting. 

CBP officials subsequently informed us that the Vetting Center has 

made the following changes to ensure better compliance with 

operating procedures: 

• Two additional officers were assigned to carrier vetting duties to 

address the workload issues. 

• A weekly report is generated to identify carriers that require 

vetting. 

• A supervisory officer is the direct contact with the C-TPAT office 

and receives all e-mail traffic. 

• Backlogs are closely monitored and assignments are made at a 

weekly meeting to ensure that carrier vetting is completed in a 

timely fashion. 

Initial Enrollment Process for FAST Drivers Generally Ensures Low 

Risk Participation 

We reviewed a statistical sample of 366 FAST drivers approved at 

CBP Enrollment Centers located across the Untied States. Our audit 

determined that CBP management established and consistently 

implemented controls to ensure the eligibility of low-risk participation 

in the FAST driver program with the exception of interview questions. 

However, CBP made improvements to the FAST driver approval 

interview question process during the course of our audit. 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 
 

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The Consolidated Trusted Traveler Handbook provides a list of 

general questions that, at a minimum, must be answered to determine 

whether the applicant is low risk. We initially determined that CBP 

Officers did not always ask driver applicants the minimum eligibility 

questions required during Enrollment Center interviews. We 

discussed this issue with CBP Headquarters. Subsequently, on 

December 3, 2009, Headquarters released a memorandum reiterating 

that Enrollment Centers must ask all the required questions to 

determine whether an applicant is low risk, and can be approved for 

program participation. We obtained and reviewed documentation and 

conducted observations at the Buffalo, New York and Laredo, Texas 

Enrollment Centers and have since determined that CBP Officers are 

currently asking driver applicants the required minimum eligibility 

questions during Enrollment Center interviews. 

Recommendations 

We recommend that the Assistant Commissioner, Office of Field 

Operations: 

Recommendation #1: Require C-TPAT to establish and implement a 

process for supervisors to review decisions made by supply chain 

security specialists during the certification process to ensure that 

security profiles are thoroughly assessed and highway carriers meet all 

of the C-TPAT’s minimum security requirements. 

Recommendation #2: Clarify the FAST manual and supply chain 

security specialist standard operating procedures to ensure that layered 

carrier vetting process is conducted, and continue current staffing and 

oversight efforts to address vetting backlog and communication 

challenges between the CBP Vetting Center and C-TPAT supply chain 

security specialists. 

Management Comments and OIG Analysis 

CBP concurs with both recommendations. Our summary and analysis of 

CBP’s official response follows. 

Management Response on Recommendation # 1 

CBP concurred: CBP management proposed several strategies in 

response to the recommendation. CBP stated that it will conduct 

refresher training for certifying all C-TPAT applicants and review 50 

percent of all new highway carrier certifications over the next 6 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 

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months to provide data to determine the extent of supervisory approval 

necessary during the certification process. Also, CBP stated that it 

issued new policy effective May 1, 2010, requiring FAST benefits to 

be withheld from Mexican highway carriers until they have been 

validated and all actions required resolved. 

OIG Analysis: We consider the proposed action to be responsive to 

the recommendation. However, this recommendation will remain 

open and unresolved until the refresher training has been completed 

and CBP has completed their analysis of the extent of supervisory 

approval necessary during the certification process. Also the 

recommendation will remain open until the OIG has evaluated CBP’s 

analysis and conclusion. 

Management Response on Recommendation # 2 

CBP concurred: CBP stated that its Vetting Center has trained 

additional officers to conduct the carrier vetting of applicants which 

has expanded the pool of officers who are available to conduct vetting 

and enabled CBP to apply resources to address the volume of 

applications. CBP also stated that the Assistant Director of the Vetting 

Center has been given oversight authority for all processes and 

communications linked to the C-TPAT program. CBP added that 

weekly meetings are now held to assess workload requirements and 

backlogs are closely monitored. Also, CBP said that the vetting 

process has been automated and now requires the Assistant Director to 

review the process to ensure a layered approach and timely processing 

of applicants for the C-TPAT program. Along with this CBP added 

that both the C-TPAT and Vetting Center directors will meet 

periodically to discuss operational issues. 

OIG Analysis: We consider the proposed action to be responsive to 

the recommendation. However, this recommendation will remain 

open and unresolved until we receive a corrective action plan 

reflecting corrective action target dates. 

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Appendix A 

Purpose, Scope, and Methodology 

The purpose of our audit was to determine whether CBP’s initial 

enrollment process ensures that only low-risk drivers and carriers 

are allowed to participate in the FAST program. To accomplish 

this objective, we conducted site visits and interviewed Officials 

and key personnel at CBP Headquarters, the CBP Vetting Center, 

and C-TPAT. During survey, we also conducted site visits at the 

Champlain, NY and El Paso, Texas Enrollment Centers and Ports 

of Entry. We conducted fieldwork site visits at the CBP Buffalo, 

New York Field Office (Enrollment Center, Port of Entry, and CTPAT Field Office), the Laredo, Texas Field Office (Port of Entry 

and Enrollment Center), and the C-TPAT Field Office located in 

Houston, Texas. To achieve our objective, we: 

•	 Obtained and reviewed applicable laws, regulations, policy, 

and internal directives used by CBP to authorize low-risk 

participants, to identify, report, and track violations, and to 

revoke FAST participants who compromise border 

security. 

•	 Reviewed CBP organizational structure and workforce mix, 

including a review of plans, actual staffing, and prior 

studies and reviews regarding CBP workforce. 

•	 Evaluated the application approval processing for FAST 

participants, including a review of support documentation 

to justify approvals. 

•	 Conducted a review of violations against FAST participants 

and measures to revoke those FAST participants who 

compromise border security. 

•	 Interviewed CBP officials to obtain their views and 

opinions on the effectiveness of the program and additional 

measures to ensure that border security was not 

compromised (best practices, lessons learned, and areas of 

concern). 

•	 Conducted observations of the Vetting Center process and 

driver and carriers. 

•	 Conducted observations of the C-TPAT supply chain 

security specialist vetting process for determining carrier 

low-risk eligibility. 

•	 Conducted observations of the Enrollment Center interview 

process for drivers and FAST processing at the Ports of 

Entry. 

•	 Submitted Data Collection Instruments to key officials and 

personnel at CBP Headquarters, the Vetting Center, CTPAT, Enrollment Centers, and Ports of Entry. 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 
 

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Appendix A 

Purpose, Scope, and Methodology 

Coverage included program and participant information and 

statistics for fiscal year 2008 and 2009. 

During the survey, we did not use statistical sampling 

methodologies for testing sample selections. Accordingly, the 

results of our testing represented the characteristics of a 

judgmental sample and were not projected to the population from 

which it was selected. We utilized statistical sampling 

methodologies for testing a nationwide sample of FAST drivers for 

audit field work. 

We selected a national sample which included all enrollment 

centers in the U.S. DHS-OIG obtained a general list of approved 

drivers for fiscal year 2009 for all enrollment centers, which 

totaled 20,391. From that list we requested a breakdown of the 

data by month for each enrollment center. There were 5,883 

northern border FAST drivers and 1,358 southern border FAST 

drivers, for a total of 7,241 drivers. We then selected a statistical 

sample using Interactive Data Extraction and Analysis software 

with a 95 % confidence interval and a 5% error rate, which 

resulted in a sample of 366 FAST drivers for testing. We requested 

the Risk Assessment Worksheet for each of the 366 drivers from 

CBP Headquarters. The risk assessment worksheet was used to 

determine if the vetting standards were consistently applied 

nationwide for all FAST drivers. We reviewed the risk assessment 

worksheets for all 366 FAST drivers and documented all the 

drivers with derogatory information on their risk assessments, 

which resulted in 48 case files. 

For our carrier analysis, we began with the 203 carriers that the 

Houston and Buffalo C-TPAT Field Offices certified in fiscal year 

2009. We conducted a 10% judgmental sample of the 203 carriers 

certified in fiscal year 2009, giving us 20 carriers. We 

subsequently removed one carrier after discovering it had failed 

vetting, giving us a final number of 19. For each of these 19 

carriers, we reviewed documentation of Vetting Center vetting, 

documentation of C-TPAT vetting, the carrier’s security profile 

responses, and the validation report, if available. 

We conducted fieldwork from October 2009 to April 2010. Our 

review was conducted under the authority of the Inspector General 

Act of 1978, as amended. We conducted this performance audit in 

accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 
 

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Appendix A 

Purpose, Scope, and Methodology 

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. However, we relied on CBP law enforcement data 

from various databases. CBP relies on databases such as TECS, 

the National Crime Information Center, the Central Index System, 

the Automated Commercial System, and ACE to determine driver 

and carrier eligibility; therefore, we did not verify the accuracy 

database information obtained. 

We appreciate the cooperation and courtesies extended to our audit 

team by CBP officials. Major contributors to this report are 

identified in Appendix D. 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 
 

Page 14
 

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Border Protection

i'lonDlber 3, 1010

MEMORANDUM FOR: ANNE L. RICHARDS

ASSISTANT INSPECTOR GENERAL FOR AUDITS

FROM: ASSISTANTCOMMlSSIONER ~-_(\_cL

US.

OFFICE

CUSTOMS

OF INTERNAL

AND BORDER

AFFAIRS

PRO cnON

(~

SUBJECT: U.S. Custon'lS and Border Protection's Comments on Ibe Offig:

oflnspector 0eneraI Drafi Repon Letter Entitled

~lmprovemenlS Needed in Ibe Process to Certify Carriers for

!be Free and Secure Trade Program~ (OIG 09·169·AlJD.CBP)

Thank: you for providing us with a copy ofthe Department of Homeland Sc<::urity Office of

Inspector GcncraI (OIG) draft report letter entitled "/mprrwcments Herded in 1M Procus 10

Cerrify Carriersfor 1M Frer ond$«uTe Trade Progrom.

Atlachcd is U.S. CustOl1l$ and Border Proteclion's (CBP's) formal rcsponx to the draft report

that includes com:dive action plans to m:ommcndations made by OIG and technical

comments. CBP is concurring with both recommendations issued.

In an effort to provide balance and context 10 the report. CBP would like to offer that the Free

and Scc:ure Trade (FAS1) program is an initiative between the United Stales, Canada and

Mexico designed to ensure 5e(:urity and safety while enhancing the economic prosperity ofthc

countries. The FAST program promotes free and secure trade by using common riskmWlagemenl principles, supply chain security, induslry partnership, and advanced technology

to improve the efficienty ofscreening and clearing commercialtrtlffic at our shared borders.

FAST is aimed at improving and ensuring the inlegrily oflhe supply chain ofthesc

panicipanlS lhat range from manufacturing to tmnsponatioll aoo importation. U.S. Ports of

Entry on lhe northern and southern border have dedicated FAST lanes. Any conveyance

using FAST lane processing must be a CBP approved carrier, CIUT)' qualifying goods from a

C8P approved importer, and. the driver must have a valid FAST-COmmercial Driver Card.

To be CBP approvM, the carrier and importer must be participants in the CBP Customs-Trade

Partnership Against Terrorism (C-TPAT) proi"&m. In addition to these requirement.s,

Appendix B 

Management Comments to the Draft Report 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 

Page 15 
Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 
 

Page 16
 


2

manufacturers in Mexico must be a C·ll'ATparlidpant, and aU FAST shipments must have.

high-security seal property placed in the approved manner when crossing the bol"dc".

csP employs I layered en{on::ement strategy for FAST and C·11'AT participants 10 ensure

the InISt given to the participants is verified at regular inlervaa. The layered mforcancnl

bqins with the vetting aDd approval ofalllppLieanlS through the FAST and e-TPAT

cmullmmt programs. CBP ba!l furtba iniplemenled I slBlegy iocorpotllting Auaomated

Taraeting System rule-sets established at the Headquarters level and combining them with !he

effotu of!he NatioMi Targeting Cenrer-<:argo (NTCC) and por1 Manifest Review Units

(MRU). In Mlditioll, FASTIC·ll'AT shipmenlure subject to regular Non·lntrusive

Inspection (NIl) I«hnologyexaminations, 100% Radiation POlUI Monitor (RPM) 5CnaIing,

CIIlline sweeps. and physical examinations. Also. CSP uses Random and Stmtified

Compliance Examinations (SCM) along ..ith high-security seals to measure compliance with

progJWl\ partieipanlS.

With regard to the classification oftbc draft report, cep has identified information within the

repof1 requiring restricted public access based onl designation or"For Offtcial Use Only".,

il exposes vulnerabilities in the FAST program which could be exploited by persons seeking

to do hanD. Therefore, cap abo includes sensitivity comments.

Please consider CBP's COIl(:eI'fIS prior to issuing the: final report. ThInk you foc your

assistance.

If you have any questions, please have. member of yourstaff contact~. Arlene LugQ. CSP

Audit Liaison, al (202) 344-1218.

Attachments

Appendix B 

Management Comments to the Draft Report 
3

OIG Brafl Report Entitled "'mpnwcmcnls Needed in the Proceu to Certify

Carricl'$ for the Free and Secure Trade Program"

COP Corredil'c Action Plan

Recommendation 1; Require C·TPAT to establisb and implement a process for supervisors

10 review decisions made by Supply Chain Se<:urity Specialists during Ihe certification

process to ensure that security profiles were thoroughly assessed and (highway) carriers met

all ofthe e-TPAT minimum Stturity requirements.

Response: COP concurs with this recommendation and has developed the following strategies

10 address this issue.

o Strategy I. C-TPAT will conduct Supply Chain Security Specialists (SCSS)

refresher training for certifying all applicants. The Webinar will focus on lhe 29

sections ofthe security profile and will establish a threshold for appropriate

responses to clarify approvaVdisapproval of eaeh section by the SCSS. The

training will inelude a matrix which crosswalks the minimum security

requirements to the 29 sections ofthe security profile.

Due date: December 15, 2010.

o Strategy 2. The C-TPAT Evaluation and Assessment Branch will review 50

percent of all new highway carrier certifications over the next 6 months to

determine the thoroughness, completeness and timeliness ofthe security profile

review before deciding ifany further policy change is required. This option will

provide data with which C-TPAT can thoughtfully address OIG's concerns and

determine the extent ofsupervisory approval necessary during the certification

process. Due date: July 31, 2011.

o Strategy 3. C-TPAT issued new policy effective May I, 2010 establishing a new

procedure for withholding FAST benefits from newly certified Mexican highway

carriers L!ntil they have been validated and nil actions required resolved. This

policy ensures that the security profile is physically confirmed by the SCSS and

validation report approved by the Supervisor before granting FAST benefits to

Mexico Highway Carriers. Due Date: Completed. (See policy memo at!ached)

RecommendaHon 2: Clarify the FAST manual and supply chain security specialist standard

operating procedures to ensure that layered carrier vetting process is conducted, and continue

current staffing and oversight efforts to address backlog and communication challenges

between the CBP Vetting Center and C-TPAT supply chain security specialists.

Response: CBP concurs with this recommendation and has developed the following

strategies 10 address this issue.

o Strategy I. The CBP Vetting Center has trained additional officers to conduclthe

carrier velling ofapplicants. This has expanded our pool of officers who are

Appendix B 

Management Comments to the Draft Report 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 
 

Page 17
 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 
 

Page 18
 


4

available to oonduet this activity and enabled us to apply where needed

in orner to address the volwne ofapplicalions. This will CIlSlIl'e lhat the layered

approach with the Vetting Center officel1' and C·TPAT Supply Chain Security

Specialisu is consistently followed..

o Strategy 2. The Assistant DireclOroftbc Vetting Center has been given o'Va'Sighl

authority for all processes and communieations linked to the C·TPAT program. A

e-TPAT beadquarteB offlCa sends • spreadsheet listing pending carner

applications and pending benefits to the Assistant Director ofthc Vdting Centu.

Weekly meetings with the assistant dirtttor or designated 1Upa'Vi$Ol" are DOW held

10 assess the wortload and distribute assignmmu. Backlop ate closely monitored

and asignmmts are made al tbe:$e weekly meetings. The carriers in pending

$l8.UU as indicaled in the potU! ate oompared 10 the pending spreadshcel provided

by e-TPAT headquarters officers.

o Sltategy 3. The vetting process itselfhu been automated using seripu and we

have built in a required review by the Auiswu DireclOf or his designee 10 enstI1e a

layered approach and timely enhanced Vetting Center processing of applicants for

the C-TPAT program.

o Strategy 4. The Vening Center DirectoT attended the C-TPAT conference in

Buffalo, NY in August 2010. The purJICllZ was to meet with senior management

officials involved with the C-TPAT program to improve and strengthen the

communication between the Vetting Center and headquarters Ind get a better

understanding ofthe overall C-TPAT process. The C·TPAT and Vetting Center

Directors will meet periodically to discuss operational issues. A meeting at the

CBP Vetting Center is pllll1lled during the I" quarter Fiscal Year 2011 wilh senior

management representatives from the: C-TPAT office. This will serve to futther

strengthen communication alld coordination.

Due Date: CBP believes lhese actions address this recommendation and considers it

closed.

Appendix B 

Management Comments to the Draft Report 
Appendix C 

Major Contributors to this Report 

Alexander Best, Director 

Inez Jordan, Desk Officer 

LaTrina McCowin, Project Lead 

Jeffrey Wilson, Senior Program Analyst 

Carolyn Floyd, Auditor 

Melissa Motley, Program Analyst 

Victor Leung, Program Analyst 

Andre Marseille, Referencer 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 

Page 19 
Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

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 

Under Secretary for Management 

Commissioner, Customs and Border Protection 

OIG Liaison, CBP 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

Improvements Needed in the Process to Certify Carriers for the Free and Secure Trade Program 

Page 20 
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.