Department of Homeland Security
 

Improvements Needed To Strengthen the 

Customs-Trade Partnership Against Terrorism Initial 

Validation Process for Highway Carriers 

OIG-12-86 June 2012
 
OFFICE OF INSPECTOR GENERAL

Department of Homeland Security

Washington, DC 20528 / www.oig.dhs.gov

JUN 1- 2012

MEMORANDUM FOR: Shawn C. Beddows

Acting Director

Customs-Trade Partnership Against Terrorism/Industry

Partnership Programs

U.S. Customs and Border Protection

FROM: Anne L. Richards t2vu./~J

Assistant Inspector General for Audits

SUBJECT: Improvements Needed to Strengthen the Customs- Trade

Partnership Against Terrorism Initial Validation Process for

Highway Carriers

Attached for your action is our final report, Improvements Needed to Strengthen the

Customs- Trade Partnership Against Terrorism Initial Validation Process for Highway

Carriers. We incorporated the formal comments from the U.S.Customs and Border

Protection (CBP)in the final report.

The reportcontains three recommendations aimed at improving CBP'sinitial validation

process for highway carriers. Your office concurred with all three recommendations. As

prescribed by the Department of Homeland Security Directive 077-1, Follow-Up and

Resolutions for the Office of Inspector General Report Recommendations, within 90

days of the date of this memorandum, please provide our office with a written response

that includes your (1) agreement or disagreement, (2) corrective action plan, and (3)

target completion date for each recommendation. Also, please include responsible

parties and any other supporting documentation necessary to inform us about the

current status of the recommendation. Until your response is received and evaluated,

the recommendations will be considered open and unresolved.

Consistent with our responsibility under the Inspector General Act, we are providing

copies of our report to appropriate congressional committees with oversight and

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

the report on our website for public dissemination.

Please call me with any questions, or your staff may contact John E. McCoy II, Deputy

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

Attachment
 

 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

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


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


Results of Audit .................................................................................................................. 3 


 C-TPAT Initial Validation Process For Highway Carriers Needs 

 To Be Strengthened............................................................................................... 3 


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


Management Comments and OIG Analysis ........................................................... 7 


Appendixes 

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


Appendix B: Management Comments to the Draft Report ............................... 11 


Appendix C: Major Contributors to This Report ................................................ 14 


Appendix D: Report Distribution ........................................................................ 15 


Abbreviations 

CBP U.S. Customs and Border Protection 

C-TPAT Customs-Trade Partnership Against Terrorism 

CY calendar year 

DHS Department of Homeland Security 

SCSS Supply Chain Security Specialists 

SOP Standard Operating Procedures 

SAFE Port Act Security Accountability For Every Port Act of 2006 

OIG Office of Inspector General 

Portal CTPAT Security Link Portal 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Executive Summary 

We conducted an audit of the Customs-Trade Partnership Against Terrorism Program to 

determine whether its initial validation process ensures that highway carriers’ security 

practices meet minimum security requirements. Customs-Trade Partnership Against 

Terrorism Program’s initial validation process does not always ensure that highway 

carriers’ security practices meet minimum security requirements. 

Specifically, documentation maintained by the Supply Chain Security Specialists for the 

initial validation process for highway carriers did not always confirm the accuracy and 

effectiveness of security measures declared in a carrier's Customs Trade Partnership 

Against Terrorism security profile. Supply Chain Security Specialists did not always 

follow Standard Operating Procedures, and did not include adequate details in the 

validation worksheet, explaining how they verified evidence of implementation for 

critical business partner and conveyance security procedures. These conditions 

occurred because the Customs Trade Partnership Against Terrorism Standard Operating 

Procedures did not indicate what evidence should be maintained to support conclusions 

made by Supply Chain Security Specialists or where this evidence should be included in 

the Security Link Portal, which it uses as its records management system. In addition, 

the “evidence of implementation” training provided to Supply Chain Security Specialists 

did not contain specific details of what should be obtained to support tests conducted 

for critical business partner and conveyance security requirements. The deficiencies 

that we identified in CBP’s initial validation process have reduced the agency’s ability to 

ensure that carriers’ security practices promote supply chain integrity, and could expose 

CBP to increased risk of compromised border security. 

We made three recommendations that will aid CBP in strengthening its initial validation 

process for highway carriers. CBP management concurred with all three 

recommendations. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

The Customs-Trade Partnership Against Terrorism (C-TPAT), established in 2001, is a 

voluntary government-business initiative to build cooperative relationships that 

strengthen and improve the overall international supply chain process1 and U.S. border 

security. The program requires trade company participants to document and 

demonstrate their supply chain security procedures according to applicable U.S. 

Customs and Border Protection (CBP) C-TPAT security requirements. The Security and 

Accountability for Every (SAFE) Port Act of 2006 established time-sensitive mandates, 

such as reviewing and certifying security profiles within 90 days of submission, 

completing validations within 1 year of certification, to the extent practicable, and 

revalidating within 4 years of the initial validation.

As one of the measures geared toward meeting some of the requirements of the SAFE 

Port Act, C-TPAT established standard operating procedures (SOPs) for its Supply Chain 

Security Specialists (SCSSs). These security specialists travel the globe to visit partners 

and their facilities to validate that supply chain security practices and procedures meet 

the program’s minimum security criteria and agreed-upon security standards. 

The C-TPAT security criteria were jointly developed by CBP and the trade community. 

C-TPAT members receive the following benefits, among others: 

•	 Fewer CBP inspections (reduced border delays); 

•	 Priority processing for CBP inspections (front-of-the-line processing for 


inspections when possible); and 


•	 Eligibility to attend C-TPAT supply chain security training seminars. 

To further enhance processing and communication for C-TPAT participants and certified 

members, the program created the C-TPAT Security Link Portal (Portal), which it uses as 

its records management system. 

1

 The international supply chain process is the collaboration between partners (domestic and overseas) 

involved in moving raw materials, work-in-process inventory, or finished goods from the supplier to its 

final distribution point. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Results of Audit 

C-TPAT Initial Validation Process For Highway Carriers Needs To Be 

Strengthened 

Improvements are needed in CBP’s initial validation process for highway carriers 

to reduce the risk of compromised border security. Documentation maintained 

by the SCSSs for the initial validation process for highway carriers did not always 

confirm the accuracy and effectiveness of security measures declared in a 

carrier’s C-TPAT security profile. Specifically, SCSSs did not always follow SOPs 

and did not include adequate details in the validation worksheet to explain how 

they verified evidence of implementation for critical business partner and 

conveyance security procedures. These conditions occurred because the C-TPAT 

SCSS SOPs did not indicate what evidence should be maintained to support 

conclusions made by the SCSS or where this evidence should be included in the 

Portal. In addition, the “evidence of implementation” training provided to SCSSs 

did not contain specific details of what should be obtained to support tests 

conducted for critical business partner and conveyance security requirements. 

The deficiencies that we identified in CBP’s initial validation process have 

reduced the agency’s ability to ensure that carriers’ security practices promote 

supply chain integrity, and could expose CBP to increased risk of compromised 

border security. 

SCSSs Did Not Adequately Document Support for Critical Business Partner and 

Conveyance Security Procedures Verification 

SCSSs did not include adequate details in the validation worksheet to explain 

how they verified evidence of implementation for critical business partner and 

conveyance security requirements. The minimum security requirements 

mandate that highway carriers must have written and verifiable processes for 

screening business partners, and conveyance inspections must be systematic. 

However, specific evidence guidelines for this mandate have not been 

established for SCSSs. Evidence-of-implementation training was provided to 

SCSSs, but it did not contain details of what should be obtained to support tests 

conducted for critical business partner and conveyance security requirements. 

According to the SAFE Port Act, the program shall establish sufficient internal 

quality controls and records management to support its management systems, 

and maintain a records management system to document determinations on the 

reviews of each of its participants, including certifications, validations, and 

revalidations. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Regarding critical business partner procedures, 15 of 21 carriers we reviewed 

had validation worksheets on which the SCSS noted that procedures were in 

place. Of the remaining six carriers, the validation worksheet was not available 

for two carriers and the other four carriers did not comply with this business 

partner requirement. Our audit disclosed that, for 10 of the 15 carriers, the SCSS 

indicated on the validation worksheet that security requirements were verified; 

however, there was little to no information indicating what documentation was 

verified and who provided it. The validation worksheet for one carrier did 

contain explicit details. For the remaining four carriers, the SCSS used verbal 

statements as the sole evidence of implementation. We are not making 

recommendations regarding the use of verbal statements as evidence of 

implementation because C-TPAT has eliminated this practice from its guidance. 

Regarding critical conveyance security procedures, 14 of 21 carriers had a 

validation worksheet on which the SCSS noted that procedures were in place. Of 

the remaining seven carriers, the validation worksheet was not available for two 

carriers and the other five carriers did not comply with this conveyance security 

requirement. Our audit disclosed that, for 11 of the 14 carriers, the SCSS 

indicated on the validation worksheet that security requirements were verified; 

however, there was little to no information indicating what documentation was 

verified and who provided it. The validation worksheet for one carrier did 

contain explicit details. For the remaining two carriers, the SCSS used verbal 

statements as evidence of implementation. 

Standard Operating Procedures Were Not Always Followed 

SCSSs did not always follow the established procedures. Specifically, they did 

not always: 

•	 Conduct a secondary vetting procedure on the carrier to confirm that no 

significant Customs violations had taken place; 

•	 Complete the initial validation within 1 year of the certification; or 

•	 Obtain signed certification letters. 

Secondary Vetting Not Conducted 

Our review of the Portal and hard copy files showed that SCSSs did not conduct 

secondary vetting for 3 of 21 carriers’ initial validations to ensure the accuracy of 

the initial vetting information. The Security Specialist SOP prescribes that the 

Vetting Processing Center conducts the initial vetting for all highway carriers. It 

also requires the SCSSs to ensure the Center’s vetting accuracy through 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

secondary vetting to confirm that no significant customs violations have taken 

place. During vetting, the SCSSs should identify recent activity that may not have 

occurred at the time of the initial vetting. While vetting partners, the SCSSs 

conduct research in internal CBP databases such as Automated Commercial 

System and open source information available on the Internet using the 

company and financial websites. According to the SCSS SOPs, the SCSSs should 

document all vetting results in the Vetting Results section of the Portal. It is 

critical that SCSSs follow the established vetting procedures to reduce the risk of 

security compromises in the supply chain. 

Initial Validation Not Completed Within 1 Year of Certification 

In our sample of 21 carriers, there were 4 instances in which the SCSS did not 

complete the initial validation within 1 year of the certification. Reasons for the 

delays were not documented in the Milestones section of the Portal. The SAFE 

Port Act Subtitle B, Section 215 (a) requires that the validation, including onsite 

assessment, must be completed no later than 1 year from the certification, to 

the extent possible. Chapter 4 of the SCSS SOPs restates this requirement. Table 

1 shows carrier certification and validation completion dates. The validation 

completion dates reflect the time period to establish compliance with this 

requirement. We could not locate a certification letter for one Houston highway 

carrier; therefore, we could not determine compliance. 

Table 1: Carriers Where the SCSS Did Not Complete the Initial Validation Within 1 

Year From the Certification 

Carrier Certification Date Validation 

Completion Date 

Lapse Time2 

Newark Carrier 1 3/4/2008 9/10/2009 190 days 

Houston Carrier 1 2/19/2008 3/12/2009 22 days 

Houston Carrier 2 7/7/2008 8/31/2009 55 days 

Houston Carrier 3 4/15/2008 8/10/2009 117 days 

Source: DHS OIG Office of Audits 

Certification Letters Not Signed 

In our sample, 20 of the 21 carriers’ certification letters did not contain a 

signature. For one carrier, there was no certification letter in either the Portal or 

hard copy files. Once the SCSS indicates approval of vetting and the Security 

Profile in the C-TPAT Portal, certification letters are automatically generated and 

uploaded. Initially, a C-TPAT official indicated that this situation could have 

2

 Lapse time is the number of days after the 1-year deadline. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

resulted from a programming glitch in the Portal, but later determined that a 

request to include the signature was not submitted. C-TPAT officials explained 

that the signature will be added as a part of the next Portal upgrade in January 

2012. The certification marks the beginning of the 1-year timeframe required by 

the SAFE Port Act for completion of the validation process. 

Conclusion 

CBP’s initial validation process for highway carriers needs to be strengthened to 

reduce the risk of compromised border security. At the exit conference, C-TPAT 

officials acknowledged that improvements were needed to enhance the initial 

validation process for highway carriers. C-TPAT has been updating the SOPs in 

conjunction with implementation of the next version of the Portal, has revised its 

training to include improved evidence-of-implementation practices, and plans to 

improve the Evaluation Assessment Branch oversight process. However, these 

improvements have not been finalized: the policy has not been updated, the 

Portal upgrade has not been completed, and improved SOPs have not been 

finalized. Accordingly, our findings remain relevant until corrective measures 

have been implemented. 

Recommendations 

We recommend that the Assistant Commissioner, Office of Field Operations: 

Recommendation #1: 

Update the C-TPAT SCSS SOPs to explain what specific details should be included 

in the validation worksheet and how SCSSs should verify evidence of 

implementation for critical minimum security requirements. 

Recommendation #2: 

Revise the “evidence of implementation” training to explain how SCSSs should 

verify evidence of implementation for critical minimum security requirements 

and what information they should document to support conclusions. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendation #3: 

Ensure that SCSSs follow SOPs when conducting the initial validations of highway 

carriers or document reasons for deviations. 

Management Comments and OIG Analysis 

CBP submitted formal comments to our report. A copy of the CBP response is 

included as appendix B. We also received technical comments from CBP and 

have made changes to the report based on these comments. CBP concurred 

with all recommendations. Our analysis of the CBP response to the 

recommendations follows. 

Recommendation #1: 

Update the C-TPAT SCSS SOPs to explain what specific details should be included 

in the validation worksheet and how SCSSs should verify evidence of 

implementation for critical minimum security requirements. 

Management Response: CBP stated that it has reviewed the C-TPAT program 

and is in the process of incorporating specific instructions into existing or new 

SOPs regarding the details and supporting documentation that must be included 

in the validation worksheet. 

OIG Analysis: CBP’s comments are responsive to this recommendation. 

However, it will remain open and unresolved until CBP provides the SOPs that 

reflect the details and supporting documentation that must be included in the 

validation worksheet. 

Recommendation #2: 

Revise the “evidence of implementation” training to explain how SCSSs should 

verify evidence of implementation for critical minimum security requirements 

and what information they should document to support conclusions. 

Management Response: CBP stated that it has provided an enhanced version of 

“evidence of implementation” training to all C-TPAT staff and provided notice to 

the Field Office managers advising them that it was critical to ensure that SCSSs 

are gathering the appropriate evidence during the validation process. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

OIG Analysis: CBP’s comments are responsive to this recommendation. 

However, it will remain open and unresolved until CBP provides documentation 

that reflects how SCSSs should verify evidence of implementation for critical 

minimum security requirements and what information they should document to 

support conclusions. 

Recommendation #3: 

Ensure that SCSSs follow SOPs when conducting the initial validations of highway 

carriers or document reasons for deviations. 

Management Response: CBP stated that the C-TPAT National Training 

Coordinator will provide webinar training to the C-TPAT staff on a regular and 

recurring basis as SOPs are updated, approved, and issued to the field. CBP 

added that once the Portal upgrade is operational the SOPs will be linked to its 

related process minimizing the opportunities for misinterpretation of 

procedures. 

OIG Analysis: CBP’s comments are responsive to this recommendation. 

However, it will remain open and unresolved until CBP provides documentation 

that reflects evidence of training provided. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objectives, Scope, and Methodology 

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. 

We performed a selected review of the C-TPAT initial validation process to determine 

whether it ensures that highway carriers’ security practices meet minimum security 

requirements. We conducted this audit at CBP headquarters in Washington, DC. We 

interviewed C-TPAT program managers in headquarters responsible for the 

management and oversight of the program. We also held conference calls with C-TPAT 

officials assigned to field offices in Newark, NJ; Miami, FL; Houston, TX; Buffalo, NY; and 

New York, NY. 

We reviewed and compared the SAFE Port Act to C-TPAT annual plans and C-TPAT 

policies and procedures. We also reviewed documentation supporting validation 

activities. We evaluated initial validation activities, the worksheets resulting from the 

onsite visits, the suspension of benefits, and the removal of carriers from the program. 

Our review of the validation worksheets resulting from the site visits focused on two of 

nine minimum security requirements. Our assessment of these requirements revealed 

that the greatest risks to highway carriers are (1) business partners and (2) conveyance 

security. Our audit coverage included program information and statistics for calendar 

year (CY) 2009. 

For our carrier analysis, we began with 400 highway carriers that C-TPAT validated in CY 

2009 for all of its field offices from the Portal. A total of 188 highway carriers’ initial 

validations were listed as being completed during CY 2009 for the Newark, Miami, and 

Houston field offices. We reviewed a judgmental sample of 21 initial validations 

completed in CY 2009 to ensure that C-TPAT personnel conducted work in accordance 

with SOPs and the SAFE Port Act, that documentation was adequate to support SCSSs’ 

conclusions, and that key elements were properly approved and completed in a timely 

manner. Accordingly, the results of our testing represented the characteristics of the 

judgmental sample and were not projected to the population from which it was 

selected. In addition, we relied on C-TPAT initial validation data from the Portal and 

verified the accuracy of database information obtained for the cases reviewed. 

We conducted this performance audit between September 2010 and September 2011 

pursuant to the Inspector General Act of 1978, as amended, and according to generally 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

accepted government auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based upon our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and conclusions 

based upon our audit objectives. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Management Comments to the Draft Report 

1300 Pennsylvania Avenue NW 

W.clllnglOn, DC 20229 

u. S. Customs and 

Border Protection 

April II, 20 12 

Charles K. Frlwards 

Acting Inspector General 

Department of Homeland Security 

245 Murray Drive, SW, Building 4 1 0 

Washington, DC 20528 

Re: The OUice of Inspector General 's Draft Report Entitled, "Improvements Needed to 

Strengthen the CusToms-Trade Partnership Against Terrorism Initial Validation 

Process for IIighway Carricrs - For Official Use Only" 

Dear Mr. Edwards: 

Thank yOll fnr the upportunity to review and comment 011 the Office of Inspector 

General's (OlG's) draft report entitled "Improvements Needed to Strengthen the CustomsTrade Partnership Against Terrorism Initial Validation Process [or Highway Carriers - For 

Official Use Only," (project no. OIG-IO-IOI-AUD-CBP). U.S. Customs and Border 

Protection (CBP) appreciates the QIG's work in planning and conducting its review and 

issuing this report. 

CBP concurs with the OIO's recommenuatiuns and believes they will strengthen the 

Customs-Trade Partnership Against Terrorism (C-TPA n Program. However, CBP would 

like to emphasize that it employs a layered enforcement strategy with multiple checks and 

balances to reduce the likelihood of contrahand being smuggled into the U.S. The C-TPAT 

Program does not stand alone on the front line, but compliments and is complimented by 

other CBP programs and actions such as the Container Security Initiati·\ie (CS1), N(ITlIntmsive lnspection technolugy (NIl), targeting, K-9 and physical inspections. 

CBP w()l1ld like [0 nutt: several instances with in the report which. if clorified may 

decrease the perception left by the report that C-TP AT is not effective in decreasing the 

likelihood of contra hand being smuggled intu the U.S. The audit occurred during a 

transitional period for C-TPA T since improving upon the receipt of evidence of 

implementation was already being addressed by the program internally. For example, a 

working group had already been assembku aud an evidence of implementation matrix and 

webinar session was developed for the Supply Chain Security Specialists (SCSS) as a result. 

In auuitioll, the audit indicates that secondary vetting was not conducted. However, 

all highway carriers are vetted through the Free and Secure Trade (FAST) Vetting Center. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

2 

Evidence of secondary vetting by C-TPA T SCSS was not found for some of the cases, but in 

each of the cases reviewed, at least one level of vetting occurred, SCSS reviewed and 

approved the security profile submitted to CBP, conducted a validation, issued a repon and 

followed up with the member company regarding identified security enhancements. 

The finding that standard operating procedures (SOPs) were not always followed, 

does not explain the full scnpe ofuu:: situation. The deficiency identified was really that the 

milestones section orthc account did not mention why the validation did not occur !.luring 

the required timeframe. The deficiency wa .... nuL that the validation exceeded the nonnlll 

time parameters, but rather that the account lacked any justification supporting a basis for 

exceeding the timerrame for validation. The Safe Port Act language, states that the 9O-day 

and I-year timeframes shall be met to the extent practicable. See 6 U.S.c. S 964 (c), 6 

USC. § 965 (a). C·TrAT personnel must often cancel, postpone or defer travel to cerl.!:!in 

areas due to security concerns, natural disasters and health warnings, which can Icad to nn 

initial validation nul being completed within I year of certification. 

The report makes three recommendations for CBP. A summary of e BP actions and 

corrcc.:tivc plans to address the recommendations is provided below' 

Recommend.ation #1: Update C·TPAT SCSS SOPs to explain what specific details should 

be included in the validation worksheet and bow SCSSs should verify evidence of 

implementation for critical minimum security requirements. 

CBP Response: Concur. In 2010, the program initiated a comprehensive review of the 

methods and means used by SCSS to verify a partner company's compliance with the 

security criteria, including examples of evidence of implementation. These best practices 

were incorporated into a matrix and shared as training resource to all SCSSs. In a parallel 

effort, thc Evaluation and Assessment Branch (EAB) initiated a comprehensive review of 

existing SOPs and identified several new processes, wllich the program had initiated to 

improve the program and needed to be incorporated into cxisting or new SOPs. These 

effol1s are converging, and now the SOPs that cover the validation proce~s will include 

specific instructions regarding the details and sUPPOlting documentation that must be 

included in the validation worksheet. The details contained in the worksheet!'> arc dusely 

examined by supervisors when reviewing reports and c.:IUsschecked by the EAB during their 

sample (judils. 

Completion Date: "'fay 31, 2012 

Recommendation #2: Revise the "evidence of implementation" training to explain how 

SCSSs should verify evidence of implementation for critical minimum security requirements 

and what information they should document to suppan cOllclu!'>iollS. 

CBP Re!iponse: Concur. The C·TPAf Staff was provided with "Evidence of 

Implementation" training on Septemrer 9, 2010. The C· TrAT National Training 

Coordinator (NTC) worked with Field Training Coordinators (FTC) to develop an enhi1lH.::ed 

version of the training, which was prO\'ided to tht: sLaITon Mareh 20, 2012 via webinar. 

Additionally, the C-TPAT Program Director sent a memo to the Field Offtce Managers on 

 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

3 

March 21,20 12 advising them that it was critical to ensure that SCSSs are gathering the 

appropriate evidence during (he validation proce~s. Managers were reminded to pny close 

attention to in this area when conducting their field assessments ofSCSSs. Recently, 

BlackBerry devices were updated to provide camera functionality, This feature will be a 

valuable too l for SCSSs when capturing evidence of implementalion during site visits. 

Photographs of documents and physical security measures can now be easily captured and 

uploaded to the C·TPAT web portal as additional evidence to support particul ar findings and 

observations. 

Accordingly, CBP respectfully requests closure of Recommendation #2. Supporting 

documentation to dose this recommendation will be provided. 

Recommentilltiurl #3: Ensure tbat SCSSs follow SOPs when conducting the initial 

validations ofhighwny carriers or document reasons for deviations. 

CBP Response: Concur. The C-TPAT >lational Training Coordinator (NTC) will provide 

webinar training to the C-TPAT staff on a regular basis as SOPs are appmved and issued to 

the field. In May of2012, a webinar training ~essiol1 on the newly approved Vetting SOP is 

scheduled. Subsequent training sessions will be held throughout CY 2012 as new SOPs and 

updated SOPs arc approved from HQ and issued to the field. Once Porll'll2.0 is operational 

each SOP will be linked to its process allowiTlg SCSSs immediate access. This operational 

linkage will minimize the opportunities for confusion and/or misinterpretation of 

procedures. Additionally, many SOPs will include training aids, checklists and other 

documentation intended to assist the SCSS. 

Completion Date: December 31, 20 12 

With regard to the sensiti vity of the draft report, CBP has identified information 

within the rtp0l1 requiring restricted public access based on a designation of "For Official 

Use Only." Accordingly, CHP's sensitivity and technical comments will be provided 

separately. 

Once again, thank you for the opportunity to comment on the dmft report. We look 

forward to working with you on future reviews. If you have any questions, please have a 

member of your staff conlaet Katlnyn Dapkins, Audit Liaison, QUke of Internal Affairs at 

(202) 325-7732. 

James F. Tomsheek 

Assistant Commissioner 

Office of Internal Affairs 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

Major Contributors to This Report 

Alexander Best, Director 

Inez Jordan, Audit Manager 

Nancy Pergolizzi, Project Lead 

Duane Albert, Program Analyst 

Melissa Motley, Program Analyst 

Brian Smythe, Program Analyst 

Shanelle Jones-Quintanilla, Program Analyst 

Katrina Bynes, Independent Reference Reviewer 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Commissioner, CBP 

CBP Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as appropriate 

www.oig.dhs.gov 15 OIG-12-86 
ADDITIONAL INFORMATION AND COPIES 

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