United States Government Accountability Office

GAO Statement for the Record to the 

Permanent Subcommittee on 

Investigations, Committee on Homeland 

Security and Governmental Affairs, U.S. 

Senate

CARGO CONTAINER 

INSPECTIONS 

Preliminary Observations 

on the Status of Efforts to 

Improve the Automated 

Targeting System 

Statement for the Record by Richard M. Stana, Director 

Homeland Security and Justice Issues 

On April 19, 2007, references to GAO-04-352SU were revised in the 

footnotes on pages 1, 8, 9, 12, 13, and 14. The references did not 

identify the document as SU, which indicates a “sensitive but

unclassified” document not available to the public. That document was

not and is not available on the GAO Web site. 

For Release on Delivery

Expected at 9:30 a.m. EST 

Thursday, March 30, 2006

 

GAO-06-591T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

March 30, 2006

CARGO CONTAINER INSPECTIONS

Preliminary Observations on the Status of 

Efforts to Improve the Automated 

Targeting System 

Highlights of GAO-06-591T, a statement 

for the record to the Permanent 

Subcommittee on Investigations, 

Committee on Homeland Security and 

Governmental Affairs, United States 

Senate 

U.S. Customs and Border

Protection’s (CBP) Automated 

Targeting System (ATS)—a

computerized model that CBP 

officers use as a decision support 

tool to help them target oceangoing

cargo containers for inspection— is

part of CBP’s layered approach to 

securing oceangoing cargo. GAO 

reported in February 2004on 

challenges CBP faced in targeting 

oceangoing cargo containers for 

inspection and testified before this 

subcommittee in March 2004 about

the findings in that report. The 

report and testimony outlined 

recommendations aimed at (1) 

better incorporating recognized

modeling practices into CBP’s 

targeting strategy, (2) periodically 

adjusting the targeting strategy to

respond to findings that occur 

during the course of its operation, 

and (3) improving implementation 

of the targeting strategy. This

statement for the record discusses 

preliminary observations from 

GAO’s ongoing work related to ATS

and GAO’s 2004 recommendations 

addressing the following questions: 

• What controls does CBP have

in place to provide reasonable

assurance that ATS is effective 

at targeting oceangoing cargo 

containers with the highest 

risk of smuggled weapons of 

mass destruction? 

• How does CBP systematically

analyze security inspection

results and incorporate them 

into ATS? 

• What steps has CBP taken to 

better implement the rest of its 

targeting strategy at the 

seaports? 

CBP has not yet put key controls in place to provide reasonable assurance 

that ATS is effective at targeting oceangoing cargo containers with the 

highest risk of containing smuggled weapons of mass destruction. To 

provide assurance that ATS targets the highest-risk cargo containers as

intended, CBP is (1) working to develop and implement performance 

measures related to the targeting of cargo containers, (2) planning to 

compare the results of its random inspections with its ATS inspection 

results, (3) working to develop and implement a testing and simulation 

environment, and (4) addressing recommendations contained in a 2005 peer

review of ATS. CBP expects to begin using performance measures in June 

2006 and enter the final phase of software development for its testing and 

simulation environment at the same time. However, to date, none of these 

four initiatives has been fully implemented. Thus, CBP does not yet have key 

internal controls in place to be reasonably confident that ATS is providing 

the best information to allocate resources for targeting and inspecting 

containers that are the highest risk and not overlook inspecting containers 

that pose a threat to the nation. 

CBP does not yet have a comprehensive, integrated system in place to 

analyze security inspection results and incorporate them into ATS. CBP 

currently adjusts ATS based on intelligence information it receives and has 

initiated a process to track suggestions submitted by CBP targeting officers 

at the seaports for modifying ATS. However, CBP has not yet implemented 

plans to refine ATS based on findings from routine security inspections. 

Without a more comprehensive feedback system, CBP is limited in refining 

ATS, a fact that could hinder the overall effectiveness of the targeting 

strategy. 

CBP has taken steps to improve implementation of the targeting strategy at 

the seaports. It has implemented a testing and certification process for its 

officers who complete the Sea Cargo Targeting Course that should provide 

better assurance of effective targeting practices. CBP has also made a good 

faith effort to address longshoremen’s safety concerns regarding radiation 

emitted by nonintrusive inspection equipment by taking actions such as 

working with longshoremen’s unions and other maritime organization to 

develop public radiation tests on the nonintrusive inspection equipment. 

Nevertheless, CBP has not been able to persuade one longshoremen’s union 

to permit changes in the procedure for staging containers to increase

inspection efficiency at some West Coast seaports where the union’s 

members work. 

www.gao.gov/cgi-bin/getrpt?GAO-06-591T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Richard Stana 

at (202) 512-8777 or stanar@gao.gov. 
Mr. Chairman and Members of the Subcommittee: 

I appreciate the opportunity to comment on our ongoing work on the U.S. 

Customs and Border Protection’s (CBP) Automated Targeting System 

(ATS)—a computerized model that CBP officers use as a decision support 

tool to help them target oceangoing cargo containers for inspection.1

In the aftermath of the terrorist attacks of September 11, 2001, there is 

heightened concern that terrorists will attempt to smuggle a weapon of 

mass destruction (e.g., a nuclear, biological, or radiological explosive 

device) into the United States using one of the 11 million cargo containers

that arrive at our nation’s seaports. Because of the large volume of 

imported containers, CBP maintains that it is unable to physically inspect

all oceangoing containers without disrupting the flow of commerce. Thus, 

CBP uses a multilayered strategy for addressing the threat posed by the 

movement of oceangoing containers, of which ATS is a key component.2

CBP uses ATS to review documentation and assign a risk score for all 

containers destined for U.S. ports. CBP officers located at domestic ports 

or at 1 of the 40 foreign ports that participate in the Container Security 

Initiative (CSI) then use these scores to help them make decisions on the 

extent of additional documentary review and possible physical inspection 

that will be conducted at the seaport.

We previously reported in February 2004 on the challenges CBP faced in 

targeting oceangoing cargo containers for inspection3

 and testified before 

this Subcommittee in March 2004 about the findings in that report. 4 The 

 1

A model is a physical, mathematical, or otherwise logical representation of a system, 

entity, phenomenon, or process.

2

In addition to ATS, CBP’s multilayered strategy includes the (1) Compliance Measurement 

Program, which randomly selects additional containers to be physically examined; (2) the

Container Security Initiative, whereby CBP places staff at foreign seaports to work with 

foreign counterparts to inspect high-risk containers before they are shipped to the United

States; and (3) the Customs-Trade Partnership Against Terrorism which is a cooperative 

program between CBP and members of the international trade community in which private 

companies agree to improve the security of their supply chains. A supply chain consists of 

all stages involved in fulfilling a customer request, including stages conducted by

manufacturers, suppliers, transporters, retailers, and customers. 

3

GAO, Homeland Security: Challenges Remain in the Targeting of Oceangoing Cargo 

Containers for Inspection, GAO-04-352SU (Washington, D.C.: Feb. 20, 2004). 

4

GAO, Homeland Security: Summary of Challenges Faced in Targeting Oceangoing 

Cargo Containers for Inspection, GAO-04-557T, (Washington, D.C.: Mar. 31, 2004). 

Page 1 GAO-06-591T 
report and testimony outlined recommendations aimed at (1) 

incorporating recognized modeling practices into its targeting strategy, 

such as conducting simulated events and initiating an external peer 

review,5

 (2) periodically adjusting the targeting strategy to respond to 

findings that occur during the course of its operation, and (3) improving 

implementation of the targeting strategy at domestic seaports. This 

subcommittee and other congressional requesters asked that we ascertain

whether CBP had implemented the recommendations we made to improve 

the targeting strategy. Our work, in response to this request, has been 

under way since last October, and we expect to complete the work and 

provide this subcommittee and our other requesters with a report on the 

final results later this year. In this statement, I will discuss our preliminary 

observations on the status of these recommendations as part of the 

following questions: 

• What controls does CBP have in place to provide reasonable assurance 

that ATS is effective at targeting oceangoing cargo containers with the 

highest risk of smuggled weapons of mass destruction? 

• How does CBP systematically analyze security inspection results and 

incorporate them into ATS? 

• What steps has CBP taken to better implement the rest of its targeting 

strategy at the seaports? 

To address these questions, we interviewed CBP officials in headquarters 

and visited six seaports: Baltimore, Charleston, Los Angeles-Long Beach, 

Miami, New York-New Jersey, and Savannah. Because we did not select a 

random sample of ports to visit, the results from these visits cannot be 

generalized to ports nationwide. We also met with CBP’s contractor 

responsible for conducting CBP’s peer review of ATS and longshoremen’s 

union representatives. We reviewed CBP’s policies and procedures for 

targeting and inspecting shipments, and its documentation on intelligence

gathering and dissemination, targeting strategies, random inspections, 

training, and radiation safety as well as its peer review report. We also 

examined information on officers trained and certified in CBP’s Sea Cargo 

Targeting Training course. We did not independently validate the 

reliability of CBP’s targeting results or test the effectiveness of ATS. We 

conducted our work in response to this request from October 2005 

through March 2006 in accordance with generally accepted government 

 5

External peer review is a process that includes an assessment of the model by 

independent and qualified external peers.

Page 2 GAO-06-591T 
auditing standards. Appendix I contains more detailed information on our 

scope and methodology.

CBP has not yet put key controls in place to provide reasonable assurance

that ATS is effective at targeting oceangoing cargo containers with the 

highest risk of containing smuggled weapons of mass destruction.6

 To 

provide assurance that ATS targets the highest-risk cargo containers as 

intended, CBP is (1) working to develop and implement performance 

measures related to the targeting of cargo containers, (2) planning to 

compare the results of its random inspections with its ATS inspection 

results, (3) working to develop and implement a testing and simulation 

environment, and (4) addressing recommendations contained in a 2005 

peer review of ATS. CBP expects to begin using performance measures in 

June 2006 and enter the final phase of software development for its testing 

and simulation environment at the same time. However, to date, none of

these four initiatives has been fully implemented. Thus, CBP does not yet

have key internal controls in place to be reasonably confident that ATS is 

providing the best information to allocate resources for targeting and 

inspecting containers that are the highest risk and not overlook inspecting 

containers that pose a threat to the nation. 7

Summary 

CBP does not yet have a comprehensive, integrated system in place to 

analyze security inspection results and incorporate them into ATS. An 

integrated system would allow any of the various systems that CBP uses to 

manage cargo inspection data to communicate with one another for the 

purpose of analyzing combined data. CBP currently adjusts ATS based on

intelligence information it receives and has initiated a process to track 

suggestions submitted by CBP targeting officers at the seaports for 

modifying ATS. However, CBP has not yet implemented plans to refine 

ATS based on findings from routine security inspections. Without a more 

comprehensive feedback system, CBP is limited in refining ATS, a fact that 

could hinder the overall effectiveness of the targeting strategy. 

 6

For purposes of this statement, when we state that CBP uses ATS to target oceangoing 

cargo containers to identify weapons of mass destruction, we are also including the

different components that could be used to create a weapon of mass destruction. 

7

Internal control is an integral component of an organization’s management that provides 

reasonable assurance that the following objectives are achieved: (1) effectiveness and 

efficiency of operations, (2) reliability of financial reporting, and (3) compliance with 

applicable laws and regulations.

Page 3 GAO-06-591T 
CBP has taken steps to improve implementation of the targeting strategy 

at the seaports. It has implemented a testing and certification process for 

its officers who complete the Sea Cargo Targeting Course that should 

provide better assurance of effective targeting practices. CBP has also 

made a good faith effort to address longshoremen’s safety concerns 

regarding radiation emitted by nonintrusive inspection equipment by 

taking actions such as working with longshoremen’s unions and other 

maritime organization to develop public radiation tests on the nonintrusive 

inspection equipment. 8 Nevertheless, CBP has not been able to persuade 

one longshoremen’s union to permit changes in the procedure for staging 

containers to increase inspection efficiency at some West Coast seaports 

where the union’s members work. 

Oceangoing cargo containers have an important role in the movement of 

cargo between global trading partners. Approximately 90 percent of the 

world’s trade is transported in cargo containers. In the United States 

almost half of incoming trade (by value) arrives by containers aboard 

ships. If terrorists smuggled a weapon of mass destruction into the nation 

using a cargo container and detonated such a weapon at a seaport, the 

incident could cause widespread death and damage to the immediate area, 

perhaps shut down seaports nationwide, cost the U.S. economy billions of 

dollars, and seriously hamper international trade. 

Background 

The Department of Homeland Security and CBP are responsible for 

addressing the threat posed by terrorist smuggling of weapons in 

oceangoing containers. To carry out this responsibility, CBP uses a layered 

security strategy. One key element of this strategy is ATS. CBP uses ATS 

to review documentation, including electronic manifest information 

submitted by the ocean carriers on all arriving shipments, to help identify 

containers for additional inspection.9

 CBP requires the carriers to submit 

manifest information 24 hours prior to a United States-bound sea 

container being loaded onto a vessel in a foreign port. ATS is a complex 

mathematical model that uses weighted rules that assign a risk score to 

each arriving shipment in a container based on manifest information. As 

previously discussed, CBP officers use these scores to help them make 

 8

Nonintrusive inspection equipment uses technology to help determine the contents of a 

container without opening it.

9

Cargo manifests are prepared by the ocean carrier to describe the contents of a container.

Page 4 GAO-06-591T 
decisions on the extent of documentary review or physical inspection to 

be conducted. 

ATS is an important part of other layers in the security strategy. Under its 

CSI program, CBP places staff at designated foreign seaports to work with 

foreign counterparts to identify and inspect high-risk containers for 

weapons of mass destruction before they are shipped to the United States. 

At these foreign seaports, CBP officials use ATS to help target shipments 

for inspection by foreign customs officials prior to departing for the 

United States. Approximately 73 percent of cargo containers destined for 

the United States originate in or go through CSI ports. 

ATS is also an important factor in the Customs-Trade Partnership Against 

Terrorism (C-TPAT) program. C-TPAT is a cooperative program linking 

CBP and members of the international trade community in which private

companies agree to improve the security of their supply chains in return 

for a reduced likelihood that their containers will be inspected. 

Specifically, C-TPAT members receive a range of benefits, some of which 

could change the ATS risk characterization of their shipments, thereby 

reducing the probability of extensive documentary and physical 

inspection. 

CBP does not yet have key controls in place to provide reasonable 

assurance that ATS is effective at targeting oceangoing cargo containers 

with the highest risk of containing smuggled weapons of mass destruction. 

To address this shortcoming, CBP is (1) developing and implementing 

performance metrics to measure the effectives of ATS, (2) planning to 

compare the results of randomly conducted inspections with the results of 

its ATS inspections, (3) developing and implementing a simulation and 

testing environment, and (4) addressing recommendations contained in a 

2005 peer review. To date, none of these control activities have been fully 

completed or implemented.10 Thus, CBP does not yet have key internal 

controls in place to be reasonably certain that ATS is providing the best 

available information to allocate resources for targeting and inspecting 

CBP Currently Does 

Not Have Reasonable 

Assurance That ATS 

Is Effective 

 10The Comptroller General’s internal control standards state that internal control activities 

help ensure that management’s directives are carried out. Further, they state that the 

control activities should be effective and efficient in accomplishing the agency’s control 

objectives. GAO, Standards for Internal Control in the Federal Government, GAO/AIMD00-21.3.1, p. 11 (Washington, D.C.: November 1999). 

Page 5 GAO-06-591T 
containers that are the highest risk and thus not overlook inspecting 

containers that pose a high threat to the nation. 

CBP does not yet have performance measures in place to help it determine 

the effectiveness of ATS at targeting oceangoing cargo containers with the 

highest risk of smuggled weapons of mass destruction. The Comptroller 

General’s internal control standards include the establishment and review 

of performance measures as one example of a control activity to help an 

entity ensure it is achieving effective results.11 In July 2005, CBP 

contracted with a consulting firm to develop such performance metrics. 

CBP officials and personnel from this consulting firm told us that the 

firm’s personnel analyzed shipment information in ATS over a 2-year 

period to obtain additional insights into ATS’s performance and to 

determine whether ATS is more effective at targeting cargo containers for 

terrorism related risk than a random sampling inspection approach. CBP 

officials told us that the consulting firm’s personnel prepared a draft of the 

results of their analyses and that, as of March 21, 2006, CBP officials are 

reviewing these analyses. They also said that the consulting firm’s 

personnel are documenting the methodology for their analyses and related 

performance measures that CBP can use in the future. CBP officials 

expect to receive this methodology and the performance measures in April 

2006, and told us that they expect to begin using the measures in June 

2006. CBP officials also told us that they initially planned to have 

performance measures developed by August 31, 2005, but that this process 

has taken longer than expected because of delays in (1) obtaining security

clearances for the consulting firm’s personnel, (2) obtaining workspace for 

the firm’s staff, and (3) arranging for the appropriate levels of access to 

CBP’s information systems. 

CBP Does Not Yet Have 

Performance Measures to 

Gauge the Effectiveness of 

ATS in Targeting Cargo 

Containers, But is Working 

to Develop Them 

CBP Is Not Yet Using the 

Results of Random 

Inspections to Assess ATS 

Effectiveness 

Currently, CBP is not using the results of its random sampling program to 

assess the effectiveness of ATS. As part of its Compliance Measurement 

Program, CBP plans to randomly select 30,000 shipments based on entry 

information submitted by the trade community and examine those 

 11See GAO/AIMD-00-21.3.1, pps. 11 and 14. 

Page 6 GAO-06-591T 
shipments to ensure compliance with supply chain security during fiscal

year 2006.12

At this time, CBP is unable to compare the examination results from its 

random sampling program with its ATS inspection results, as we 

recommended in our 2004, report because CBP does not yet have an 

integrated, comprehensive system in place to compare multiple sets of 

data—like results of random inspections with results of routine ATS 

inspections that were triggered by ATS scores and other operational 

circumstances. Such a comparison would allow examination of if and why 

the outcomes of ATS’s weighted rule sets are not consistent with the 

expected outcomes possible in the universe of cargo containers, based on 

sample projections. Furthermore, the Comptroller General’s standards for 

internal control state that information should be recorded and 

communicated to management and others within the entity who need it in

a form that enables them to carry out their responsibilities.13 

CBP Has Not Yet Tested 

the Effectiveness of ATS in 

Targeting Cargo 

Containers for Inspection 

but Has Plans to Do So 

Currently, CBP does not conduct simulated events (e.g., covert tests and 

computer-generated simulations)—a key control activity—to test and 

validate the effectiveness of ATS in targeting oceangoing cargo containers 

with the highest risk of containing smuggled weapons of mass destruction 

and has not yet implemented a dedicated simulation and testing 

environment. Without testing and validation, CBP lacks a vital mechanism 

for evaluating ATS’s ability to identify high-risk containers. 

In July 2005, CBP contracted with a consulting firm to obtain assistance in

the development of a computer-generated simulation and testing 

environment. CBP officials report that they have the simulation 

environment infrastructure in place and have processed mock manifest 

data to simulate cargo linked to terrorism in the new environment. CBP is 

currently reviewing the results of this test. Further, CBP officials told us 

that the consulting firm is continuing to work with CBP to develop system

requirements so that officers can effectively use the simulation 

environment. CBP expects to receive the consulting firm’s final input for 

the simulation and testing environment by June 2006. CBP officials said 

 12Entry information is documentation to declare items arriving in the United States. Entry

information allows CBP to determine what is included in a shipment. Entry information

provides more detail on a container’s contents than manifest information. 

13See GAO/AIMD-00-21.3.1, p. 18. 

Page 7 GAO-06-591T 
that they cannot estimate when this simulation and testing environment 

will be fully operational until CBP receives the consulting firm’s final 

product. As with the development of performance measures, CBP officials 

also told us that this process has taken longer than expected because of 

delays in (1) obtaining security clearances for the consulting firm’s 

personnel, (2) obtaining workspace for the firm’s staff, and (3) arranging 

for the appropriate levels of access to CBP’s information systems. 

As we reported in 2004, terrorism experts suggested that testing ATS by 

covertly simulating a realistic event using probable methods of attack 

would give CBP an opportunity to examine how ATS would perform in an 

actual terrorist situation.14 CBP officials told us that although they are 

considering implementing this kind of practice, they do not currently have

a program in place to conduct such tests. The Director of CBP’s 

Management Inspections and Integrity Assurance office told us that in 

mid-April 2006, his office will be presenting a proposal to the Acting 

Commissioner and other senior management to request initiation of a 

program to conduct testing of the CSI program that will include testing 

ATS to help ensure that it is appropriately targeting the highest-risk cargo 

in the CSI program. 

CBP Is Working to Address 

Peer Review 

Recommendations

In response to our 2004 recommendation that CBP initiate an external 

peer review of ATS, CBP contracted with a consulting firm to evaluate

CBP’s targeting methodology and recommend improvements.15

Specifically, the contractor identified strengths of the CBP targeting 

methodology and compared ATS with other targeting methodologies. 

However, the peer review did not evaluate the overall effectiveness of ATS 

because CBP did not have the systems in place to allow the contractor to

do so. 

The contractor’s final report, issued in April 2005, identified many 

strengths in the ATS targeting methodology, such as a very capable and 

highly dedicated team and the application of a layered approach to 

targeting. It also made several recommendations to improve the targeting 

methodology that included control activities, such as (1) the development 

of performance measures, (2) the development of a simulation and testing 

environment, (3) the development and implementation of a structured 

 14GAO-04-352SU. 

15GAO-04-352SU. 

Page 8 GAO-06-591T 
plan for continual rules enhancement, and (4) an evaluation and 

determination of the effectiveness of the ATS targeting rules, several of 

which reinforced the recommendations we made in our 2004 report.16

CBP issued a detailed plan, which projected delivery dates, for responding 

to the recommendations made in the contractor’s final report. However, 

about half of these dates have not been met. For example, CBP projected 

that it would have its testing and simulation environment in place by 

September 30, 2005. Although CBP has been working on this effort, the 

environment has not yet been implemented. As previously discussed, CBP 

officials said that they cannot provide a current estimate of when this 

simulation and testing environment will be fully operational. 

CBP strives to refine ATS to include intelligence information it acquires 

and feedback it receives from its targeting officers at the seaports, but it is 

not able to systematically adjust ATS for inspection results. CBP does not 

have a comprehensive, integrated system in place to report details on 

security inspections nationwide that will allow management to analyze 

those inspections and refine ATS. CBP officials said that they are 

developing a system that will allow them to do so but did not know when 

it will be fully operational. CBP officials cautioned that because an 

inspection does not identify any contraband or a weapon of mass 

destruction or its components, it may not necessarily indicate that a 

particular rule is not operating as intended. They noted that terrorist 

incidents may happen infrequently, and the rule therefore might operate 

only when weapons, materials, or other dangerous contraband is actually 

shipped. However, without analyzing and using security inspection results 

to adjust ATS, CBP is limited in refining ATS, a fact that could hinder the 

effectiveness of CBP’s overall targeting strategy.

Although CBP Strives 

to Refine ATS for 

Intelligence 

Information and 

Officer Feedback, It Is 

Not Yet Positioned to 

Use Inspection 

Results 

CBP Adjusts ATS for 

Targeting Cargo 

Containers for Inspection 

Based on Intelligence 

CBP adjusts ATS’s rules and weights for targeting cargo containers for 

inspection in response to intelligence received on an ongoing basis. CBP’s 

Office of Intelligence (OINT) is responsible for acquiring, reviewing, 

analyzing, and disseminating intelligence. OINT officials told us they 

receive information from the intelligence community, which includes 

federal agencies such as the Central Intelligence Agency and the Federal 

 16GAO-04-352SU. 

Page 9 GAO-06-591T 
Bureau of Investigation.17 According to OINT officials, OINT disseminates 

information to CBP’s offices at the seaports to, among other things, 

support these offices’ targeting efforts related to cargo containers. For 

example, the targeting officers may use information provided by OINT to 

search ATS for information about shipments and containers. OINT 

officials said they also disseminate information to CBP’s senior 

management to inform them about risks associated with cargo containers. 

CBP uses intelligence information to refine its targeting of cargo 

containers for inspection by incorporating the intelligence information 

into ATS to readily identify containers whose manifest information may 

match or be similar to data contained in the intelligence information. 

CBP documentation and our observations showed that CBP headquarters 

personnel incorporate intelligence information into ATS by adjusting 

ATS’s existing rules and weights and creating new rules and weights that 

result in a higher risk score being assigned to a container whose manifest 

information may match or be similar to data contained in the intelligence 

information. CBP officers can also conduct queries or create lookouts in 

ATS that will search all manifest data in the system to identify those 

containers whose manifest information may match or be similar to data 

contained in the intelligence information.18 Once ATS identifies these 

containers, CBP officers are to then designate these containers for 

inspection. When CBP receives credible intelligence information that 

requires immediate action, CBP officials also report that they can initiate a 

special operation to address specific concerns identified in the intelligence 

data. CBP officials at the six seaports we visited reported that they 

sometimes receive intelligence information from local sources such as 

state and local law enforcement. Officials at five of these seaports 

reported that they will use such information to help them make decisions

regarding targeting efforts. Additionally, officials at five of the six seaports 

we visited said that if the information they receive has national 

 17The intelligence community is a federation of executive branch agencies and 

organizations that work separately and together to conduct intelligence activities necessary

for the conduct of foreign relations and the protection of the national security of the United 

States. 

18A query is a search an individual officer creates to seek information from ATS about 

shipments and containers based on specific criteria to assist in the officer’s targeting 

decisions. A lookout is a query that CBP headquarters or officers at the seaports can create 

that will notify all officers making targeting decisions when a shipment’s manifest data are

similar to or match the search criteria. . 

Page 10 GAO-06-591T 
implications, they will notify CBP headquarters personnel, who will make 

a determination regarding potential adjustments to ATS. 

In the late summer of 2005, CBP headquarters initiated a process to 

formally track its targeting officers’ suggestions to enhance ATS for 

targeting cargo containers for inspection. Targeting officers at all six 

seaports we have visited are aware of the process for providing 

suggestions to CBP headquarters. According to documentation maintained

by headquarters, CBP officers at the seaports have provided few 

suggestions to date. 

CBP headquarters officials said that although they have received few 

suggestions for modifying ATS, they do not believe this is an indication of

ATS’s effectiveness. These officials stated that overall the feedback they

have received from CBP targeting officers at the seaports related to the 

operation and usefulness of ATS has been positive. 

We reviewed the report CBP uses to track these suggestions and found 

that since it was established, CBP headquarters has received 20 

suggestions for enhancing the ATS component responsible for targeting 

oceangoing cargo containers for inspection. Some of these suggestions 

relate to modifying ATS’s rules, while others focused on other aspects of

ATS such as enhancing the organization and presentation of ATS screens 

by changing the size of an icon and the fonts or text used. 

CBP Targeting Officers at 

the Seaports Have 

Provided Few Suggestions 

for Adjusting ATS 

CBP Is Not Using 

Inspection Results to 

Systematically Adjust ATS, 

but It Is Developing a 

System to Allow it to Do 

So 

CBP is not using inspection results to systematically adjust ATS for 

targeting cargo containers for inspection because CBP does not yet have a

comprehensive, integrated system in place that can report sufficient 

details for analyzing inspection results. CBP officials said that although

they can analyze inspection results on a case-by-case basis to identify 

opportunities to refine ATS, such as when an inspection results in a 

seizure of some type of contraband, they currently do not have a reporting 

mechanism in place that will allow them to view inspection results 

nationwide to identify patterns for systematically adjusting ATS. CBP is 

developing the Cargo Enforcement Reporting Tracking System (CERTS) 

to document, among other things, all cargo examinations so that 

documentation substantiating the examinations will be available for 

analysis by management to adjust ATS. CBP officials said they will begin

testing CERTS in the spring of 2006. CBP officials told us that once testing 

of CERTS is complete, they will be in a better position to estimate when 

CERTS can be fully implemented. 

Page 11 GAO-06-591T 
CBP officials cautioned that because an inspection does not identify any 

contraband or a weapon of mass destruction or its components, it may not 

necessarily indicate that a particular rule is not operating as intended. 

They noted that terrorist incidents may happen infrequently and the rule 

therefore might operate only when weapons, materials, or other dangerous 

contraband is actually shipped. However, without using inspection results 

to adjust ATS, CBP may not be targeting and inspecting containers with 

the highest risk of containing smuggled weapons of mass destruction. 

CBP has implemented a testing and certification process for its officers 

who complete the Sea Cargo Targeting Course that should provide better 

assurance of effective targeting practices. CBP has also made a good faith 

effort to address longshoremen’s safety concerns regarding radiation 

emitted by nonintrusive inspection equipment. Nevertheless, it has not 

been able to persuade one longshoremen’s union to permit changes in the 

procedure for staging containers to increase inspection efficiency. 

CBP Has Taken Steps 

to Better Implement 

the Targeting Strategy 

at the Seaports

CPB Has Implemented a 

Testing and Certification 

Process for Officers Who 

Target Cargo Containers 

for Inspection 

In our 2004 report, we recommended that CBP establish a testing and 

certification process for CBP staff who complete the national targeting 

training to provide reasonable assurance that they have sufficient 

expertise to perform targeting work. 19 CBP has implemented such a 

testing and certification process. 

CBP conducted two evaluations that assessed its targeting training 

program—a job performance assessment and a job task analysis. With the 

results of these evaluations, CBP concluded that a certification component 

should be added to the training program and the Sea Cargo Targeting 

Training course content should remain unchanged. CBP officials then 

updated the course materials to encompass the inclusion of the 

certification component. In October 2004, CBP began certifying officers 

who successfully completed the Sea Cargo Targeting Training course. 

Since the establishment of the testing and certification component for the 

Sea Cargo Targeting Training course, CBP data indicate that it has trained 

 19GAO-04-352SU. 

Page 12 GAO-06-591T 
and certified 278 of its officers responsible for targeting cargo as of March 

24, 2006.

20

While CBP has conducted a job performance assessment prior to the 

incorporation of a certification program for Sea Cargo Targeting Training, 

it has not yet formally assessed the impact that revised training and 

certification has had on officers’ targeting of oceangoing cargo containers. 

However, a CBP official said that CBP has recently initiated planning 

efforts to begin such an evaluation and expects to complete the evaluation

in May 2006. Nevertheless, supervisory officers from five of the six CBP 

offices at the seaports we visited said that the mandatory training and 

certification program has been beneficial. These supervisory officers told 

us that the training and certification improves the confidence of targeters, 

provides the ability for officers to improve their targeting productivity, and 

provides an opportunity for officers to gain a broader perspective into the 

targeting environment by examining passenger and outbound targeting. 

Despite CBP Action to 

Address Longshoremen’s

Safety Concerns, 

Efficiency Concerns 

Remain on the West Coast 

In our 2004 report,21 we discussed concerns that longshoremen had 

regarding the safety of driving cargo containers through the gamma ray 

imaging system, one type of nonintrusive inspection equipment used to 

examine containers to detect potential contraband or weapons of mass 

destruction. Because this equipment emits radiation as it takes images of 

the inside of cargo containers, some longshoremen expressed concerns 

about the health effects of this radiation. As a result of these safety 

concerns, the longshoremen’s union representing West Coast 

longshoremen established a policy that prevents its members from driving 

containers through the gamma ray imaging system. In response, CBP 

altered its procedures at ports affected by this policy. For example, at 

some West Coast ports, CBP allows longshoremen to stage cargo 

containers away from the dock, in rows at port terminals, so that CBP 

officers can then drive the gamma ray imaging system over a group of 

containers. 

 20A CBP official estimated that CBP has approximately 300 officers responsible for

targeting oceangoing cargo containers. However, CBP is currently surveying its offices to 

determine a more precise estimate and will have this information available within the next

month. 

21GAO-04-352SU.

Page 13 GAO-06-591T 
However, this procedure can be space-intensive and time-consuming 

compared to the procedure utilized at East and Gulf Coast ports, whereby 

the gamma ray imaging system machinery is operated by a CBP officer and 

parked in place while longshoremen drive the cargo containers through 

the machinery.22 At other West Coast ports, the longshoremen get out of 

the trucks after transporting the cargo containers so that CBP officials can

drive the gamma ray imaging system cargo over the container. This is also 

time-consuming compared to the procedure utilized at the East and Gulf 

Coast ports. 

In response to our recommendation that CBP work with longshoremen to 

address their safety concerns, CBP engaged in two efforts: (1) establishing 

CBP’s radiation threshold in accordance with the Nuclear Regulatory 

Commission’s (NRC) federal guidelines for public radiation exposure and 

advertising this threshold to longshoremen through the unions, and (2) 

working with longshoremen’s unions and other maritime organizations to

develop public radiation tests on nonintrusive inspection equipment. 

Officials from the West Coast union that prohibits its members from

driving through the gamma ray imaging system told us that the union is 

satisfied with CBP efforts to operate the gamma ray imaging system in an 

alternative format, to comply with the union’s policy of receiving no 

amount of man-made radiation. Despite CBP efforts to assure this union 

that the amount of radiation emitted by the gamma ray imaging system is 

within safe levels, a union representative told us that CBP will not 

convince the union to change its policy unless it eliminates radiation 

emission from inspection equipment. 

- - - - - 

In closing, ATS is an integral part of CBP’s layered security strategy. A 

well-functioning ATS is crucial to the effective screening of cargo 

containers at domestic and CSI foreign ports, as well as cargo shipped by 

the trade community participating in C-TPAT. While CBP is working to 

make improvements to ATS, our ongoing work indicates that it is not yet

in a position to gauge the effectiveness of ATS. We are continuing to 

review CBP’s plans and actions to improve ATS and will report to this 

subcommittee and the other requesters later this year. 

 22GAO-04-352SU. 

Page 14 GAO-06-591T 
Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this statement. For further 

information about this testimony, please contact me at 202-512-8777 or at 

stanar@gao.gov. Debra Sebastian, Assistant Director; Chan-My J. Battcher;

Lisa L. Berardi; Wayne A. Ekblad; and Jessica A. Evans made key 

contributions to this report. Additional assistance was provided by 

Frances Cook, Kathryn E. Godfrey, Nancy A. Hess, Arthur L. James, Jr., 

Stanley J. Kostyla, and Vanessa R. Taylor. 

GAO Contacts and 

Acknowledgments 

Page 15 GAO-06-591T 
Page 16 GAO-06-591T 

Appendix I: Scope and Methodology 

To address each of our objectives, we met with U.S. Customs and Border 

Protection (CBP) officials in headquarters and six seaports including, 

Baltimore, Charleston, Los Angeles-Long Beach, Miami, New YorkNewark, and Savannah. These seaports were selected based on the 

number of cargo containers arriving at the seaport and their geographic 

dispersion as reported by the U.S. Department of Transportation. At these 

locations, we also observed targeting and inspection operations. Because 

we did not select a random, probability sample of ports to visit, the results 

from these visits cannot be generalized to ports nationwide. We also spoke 

with CBP’s contractor responsible for conducting CBP’s peer review and 

longshoremen’s union representatives. 

To evaluate how CBP provides assurance that the Automated Targeting 

System (ATS) targets the highest-risk oceangoing cargo containers for 

inspection, we reviewed CBP documentation and prior GAO work on 

performance measures. Additionally, we reviewed CBP’s peer review 

report. To gain an understanding of CBP’s random sampling program, we 

met with CBP officials responsible for this program and reviewed and 

analyzed CBP documentation, including procedures for examining the 

randomly selected shipments and documenting the results of the 

inspections completed for those shipments. We did not independently 

validate the reliability of CBP’s targeting results. 

To assess how CBP adjusts ATS to respond to findings that occur during 

the course of its operational activities, we met with CBP officials 

responsible for gathering and disseminating intelligence and for 

incorporating intelligence into CBP’s targeting operations. Further, we 

reviewed CBP policies and procedures on intelligence gathering and 

disseminating as well as intelligence received and resulting changes to 

ATS rules and weights. We did not assess the quality of intelligence 

received or the appropriateness of adjusted rules and weights. To 

determine how targeting officers’ feedback and inspection results are used 

to adjust ATS rules and weights, we met with CBP officials responsible for 

collecting and maintaining data on suggestions provided by targeting 

officers and reviewed CBP data on the suggestions received over a 7

month period. Regarding inspection results, we reviewed CBP’s policies 

and procedures for documenting inspection results. Additionally, we 

reviewed CBP’s manuals identifying the specific details of an inspection 

completed and observed officers entering inspection results into the ATS 

findings module during our site visits. Further, during these visits, we 

discussed how CBP offices at the seaports may use inspection results to 

enhance their targeting efforts. Last, we met with CBP officials and 

reviewed CBP documentation on its current and planned findings module. 
To determine the status of recommendations from GAO’s February 2004 

report to (1) establish a testing and certification process for CBP staff who 

complete the national targeting training to provide assurance that they 

have sufficient expertise to perform targeting work and (2) work with 

longshoremen’s unions to address fully their safety concerns so that the 

noninstrusive inspection equipment can be used to conduct inspections 

efficiently and safely, we reviewed and analyzed data on the number of 

officers trained and certified in sea cargo targeting. We also reviewed 

CBP’s Sea Cargo Training Manual as well as CBP evaluations assessing the 

quality of its Sea Cargo Training course. We did not assess the quality of 

this training. Regarding longshoremen’s union concerns, we reviewed 

scientific literature related to radiation safety and the Nuclear Regulatory

Commission guidelines on radiation levels. We also spoke with 

longshoremen’s representatives to discuss whether CBP had addressed 

their concerns since we issued our 2004 report. Last, we also met with 

CBP’s Radiation Safety Officer to gain a further understanding of the 

potential risks associated with CBP’s inspection equipment and actions he

took to address longshoremen’s concerns. We did not assess the 

appropriateness of radiation safety levels used by CBP. 

We conducted our work from October 2005 through March 2006 in 

accordance with generally accepted government auditing standards. 

Page 17 GAO-06-591T (440502) 
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