United States General Accounting Office

GAO Report to Congressional Committees

August 1998 CUSTOMS SERVICE

Inspectional Personnel

and Workloads

GAO/GGD-98-170

GAO United States

General Accounting Office

Washington, D.C. 20548

General Government Division

B-259233 

August 14, 1998

The Honorable Stephen Horn

Chairman, Subcommittee on

 Government Management,

 Information, and Technology

Committee on Government

Reform and Oversight

House of Representatives

The Honorable Phil Crane

Chairman, Subcommittee on Trade

Committee on Ways and Means

House of Representatives

On December 12, 1997, and January 29, 1998, respectively, you requested

that we review certain aspects of the U.S. Customs Service’s (Customs)

inspectional personnel and its commercial cargo and passenger

workloads. Specifically, you requested that we analyze (1) the implications

of any differences between the cargo and passenger inspectional

personnel levels at selected airports and seaports around the United States

and those determined by Customs to be appropriate for these ports

(assessed levels) and (2) any differences among the cargo and passenger

processing workload-to-inspector ratios at the selected ports and the

rationales for any significant differences in these ratios.

We briefed your offices on the results of our work on May 19 and May 21,

1998, respectively. This report documents the information that we were

able to obtain in response to your requests and that we presented at the

briefings. Specifically, this report discusses the reasons why we were not

able to perform the analyses you requested on the relationships between

assessed and actual personnel levels and workload-to-inspector ratios. In

addition, it presents information on (1) the cargo and passenger

inspectional personnel levels at selected ports and (2) the cargo and

passenger processing workloads at selected ports.

In developing the information in this report, we obtained and reviewed

relevant staffing, budget, and workload documents; interviewed cognizant

Customs officials at headquarters and nine ports; and visited four major

seaports and airports, where we observed cargo and passenger processing

operations. We did not assess the quality of Customs’ inspectional

personnel data. However, to obtain an indication of the overall quality of

the cargo and passenger workload data, we sought to identify whether

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Customs had any procedures for verifying such data. We also compared

workload data we obtained for each port from various sources and

attempted to reconcile any differences. Our objectives, scope, and

methodology are discussed in more detail in appendix I.

We performed our work between March and June 1998 in accordance with

generally accepted government auditing standards. We requested

comments on a draft of this report from the Secretary of the Treasury or

his designees. On August 4, 1998, Customs’ Assistant Commissioner for

Field Operations provided us with Customs’ comments. These comments

are discussed near the end of this letter.

Results in Brief We were not able to perform the requested analyses to identify the

implications of differences between assessed and actual inspectional

personnel levels because, as we reported in April 1998,1

 Customs had not

assessed the appropriate inspectional personnel levels for its ports. In that

report, we determined that Customs does not have a systematic,

agencywide process for assessing the need for inspectional personnel and

allocating such personnel to commercial cargo ports. Customs also does

not have such a process for assessing the need for inspectional personnel

to process land and sea passengers at ports. While Customs uses a

quantitative model to determine the need for additional inspectional

personnel to process air passengers (see table 1), the model is not

intended to establish the level at which airports should be staffed,

according to Customs officials.

Customs is in the early stages of responding to a recommendation in our

April 1998 report that it establish an inspectional personnel needs

assessment and allocation process.

Customs officials we interviewed at air and sea ports told us that the

current personnel levels, coupled with the use of overtime, enabled the

ports to process commercial cargo and passengers within prescribed

performance parameters, such as the inspection of passengers within 5

minutes of their retrieving checked baggage. The inspectional personnel

data that we obtained for the selected ports showed that at the end of

fiscal year 1997, the personnel levels at these ports were at or near the

levels for which funds were provided to the ports. For example, at the end

1

See Customs Service: Process for Estimating and Allocating Inspectional Personnel

(GAO/GGD-98-107, Apr. 30, 1998).

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of fiscal year 1997, while the funded level for Los Angeles International

Airport (LAX) was 336 inspectors, 320 inspectors were actually on board.

We were also not able to perform the analyses to identify

workload-to-inspector ratios and rationales for any differences in these

ratios because we did not have a sufficient level of confidence in the

quality of the workload data. We identified significant discrepancies in the

workload data we obtained from Customs headquarters, a Customs

Management Center (CMC),2

 and two ports. For example, for fiscal year

1997, data from Customs headquarters indicated that John F. Kennedy

International Airport (JFK) and Newark International Airport processed a

total of about 1.4 million cargo entries (shipments) of all types, including

those with a value of less than $1,250 (informal entries) and those with a

value of over $1,250 (formal entries). However, data from the New York

CMC indicated that these airports processed about 1.5 million formal

entries alone, almost 100,000 entries more than the number headquarters

had for all entries at these ports. We could not obtain specific explanations

for such discrepancies without Customs having to conduct extensive

additional work. We also could not identify any systematic controls over

the quality of the data.

In addition, workload was only one of several factors considered by

Customs in the few assessments—which focused on its drug-smuggling

initiatives—completed since 1995 to determine its needs for additional

inspectional personnel and allocate such personnel to ports. Customs also

considered factors such as the threat of drug smuggling, budgetary

constraints, and legislative limitations.

Background Created in 1789, Customs is one of the federal government’s oldest

agencies. Customs is responsible for collecting revenue from imports and

enforcing customs and related laws. Customs also processes persons,

carriers, cargo, and mail into and out of the United States. In fiscal year

1997, Customs collected about $19 billion in revenues and processed about

18 million import entries; about 128 million vehicles and trucks; about

706,000 commercial aircraft; about 214,000 vessels; and about 442 million

air, land, and sea passengers entering the country. Customs performs its

mission with a workforce of about 19,500 personnel at its headquarters in

Washington, D.C., and at 20 CMCs, 20 Special Agent-in-Charge offices, and

301 ports of entry around the country. At the end of fiscal year 1997,

2

On October 1, 1995, Customs closed its 7 regional and 42 district offices and replaced them with 20

CMCs. The CMCs have oversight responsibilities over Customs’ ports of entry.

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Customs had deployed 7,207 inspectors at these ports. This represented an

increase of 17 percent over the level in fiscal year 1992, the earliest year

for which complete data were available.

The nine ports we visited or contacted—LAX Airport; Los Angeles/Long

Beach Seaport; JFK Airport; New York/Newark Seaport; Newark

International Airport; and the Houston and Detroit air and sea ports—were

among the busiest of their kind in the United States in fiscal year 1997.

According to Customs workload data, these ports accounted for about

31 percent of all air and sea passengers and about 19 percent of all cargo

entries processed by Customs in fiscal year 1997. The ports also accounted

for about 21 percent of all inspectors deployed by Customs at the end of

fiscal year 1997.

Implications of

Differences Between

Assessed and Actual

Inspectional

Personnel Levels

Could Not Be

Determined

We were not able to perform the requested analyses to identify the

implications of differences between assessed and actual inspectional

personnel levels because Customs had not assessed the appropriate

inspectional personnel levels for its ports. Customs had not done so

because it does not have a systematic, agencywide process for assessing

the need for inspectional personnel and allocating such personnel to

process commercial cargo at air, sea, and land ports and to process

passengers at sea and land ports. While Customs uses a quantitative model

to determine the need for additional inspectional personnel to process air

passengers, the model is not intended to establish the level at which

airports should be staffed. Customs is in the early stages of responding to

a recommendation in our April 1998 report3

 that it establish an

inspectional personnel needs assessment and allocation process.

Inspectional personnel levels at the selected ports at the end of fiscal year

1997 were at or near the levels for which funds had been provided to the

ports. According to Customs officials we interviewed at air and sea ports,

these personnel levels, coupled with the use of overtime, enabled the ports

to process commercial cargo and passengers within prescribed

performance parameters.

3

GAO/GGD-98-107.

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Customs Has Not

Determined Appropriate

Inspectional Personnel

Levels for Its Ports

In our April 1998 report, we reported that Customs does not have a

systematic, agencywide process for determining its need for inspectional

personnel for processing commercial cargo and allocating such personnel

to ports of entry nationwide. We also reported that, accordingly, Customs

had not determined the appropriate inspectional personnel levels for each

of its cargo ports and for its cargo processing functions. In addition, we

reported that while Customs had moved in this direction since 1995 by

conducting three assessments and two allocations, these assessements

and allocations were limited because they (1) focused on the need for

additional positions rather than first determining the feasibility of moving

existing positions, Customs’ drug-smuggling initiatives rather than its

overall cargo processing operations, and Southwest border ports and

certain air and sea ports considered to be at risk from drug smuggling

rather than all 301 ports; (2) used different assessment and allocation

factors each year; and (3) were conducted with minimal involvement from

nonheadquarters Customs units, such as CMCs and ports. Accordingly, we

pointed out that focusing only on a single aspect of its operations (i.e.,

countering drug smuggling); not consistently including the key field

components (i.e., CMCs and ports) in the personnel decisionmaking

process; and using different assessment and allocation factors from year

to year could prevent Customs from accurately estimating the need for

inspectional personnel and then allocating them to ports.

In its assessment for fiscal year 1997 (conducted in 1995), to estimate the

number of inspectional personnel needed, Customs combined factors such

as the need to (1) fully staff inspectional facilities and (2) balance

enforcement efforts against violators with the need to move legitimate

cargo and passengers through the ports. In its assessments for fiscal years

1998 and 1999 (conducted in 1996 and 1997, respectively), Customs used

factors such as the number and location of drug seizures and the

perceived threat of drug smuggling, including the use of rail cars to

smuggle drugs. To allocate to the ports the inspectional personnel that

were funded by Congress, Customs used factors such as (1) commercial

cargo workloads and (2) specific aspects of the drug smuggling threat,

such as attempts by private sector employees at sea and air ports to assist

drug smuggling organizations in their efforts to smuggle drugs (described

by Customs as “internal conspiracies”).

Customs also does not have a systematic inspectional personnel

assessment and allocation process for processing land passengers. In 1995,

Customs assessed the need for additional inspectional personnel to

process incoming land passengers but since then has not done such an

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assessment. As with the assessments for cargo processing, this assessment

was limited to Southwest border ports to address drug smuggling and

related border violence. The primary factor considered in this assessment

was the physical configuration, i.e., the number of primary passenger

lanes, of the ports involved.

Customs has not assessed the need for inspectional personnel to process

sea passengers. According to Customs officials at the Newark seaport,

because of the cyclical nature of the sea passenger workload (in terms of

the time of week and year), they did not assign inspectional personnel to

process sea passengers on a full-time basis. The port assigned inspectional

personnel from other functions, such as cargo processing, on an “as

needed” basis to process sea passengers. Conversely, a Customs official at

the Los Angeles/Long Beach seaport indicated that it would be

operationally desirable to have dedicated inspectional personnel to

process sea passengers that arrive on board cruise ships three days a

week. This port also assigned inspectors to process sea passengers on an

as needed basis.

Quantitative Model Used to

Estimate Need for

Inspectional Personnel for

Air Passenger Processing

Unlike its cargo and other passenger processing functions, Customs has

employed a quantitative model since 1993 to determine the need for

additional inspectional personnel to process air passengers at the 16

largest international airports in the United States, including the 5 airports

we visited or contacted.4

 In developing its recommendations for

inspectional personnel, the model utilized the following factors in its

formula: (1) the number of arriving international passengers and the

activities required to clear them for entry, (2) workforce productivity,

(3) growth in workload, (4) the number of passenger terminals at each

port, (5) enforcement risk (threat), and (6) the number of positions

equivalent to the amount of overtime spent to operate a particular port.

Table 1 shows the model’s recommendations for inspectional positions

and Customs’ allocations of such positions to the five airports we visited

or contacted for fiscal year 1998 and the recommendations for fiscal year

1999.

4

The 16 airports each handle more than 700,000 international passengers. The additional personnel are

funded through revenues from user fees established by the Consolidated Omnibus Budget

Reconciliation Act of 1985 as amended, codified at 19 U.S.C. 58c.

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Table 1: Results of Customs’ Air

Passenger Staffing Allocation Model

for Selected Airports, Fiscal Years

1998 and 1999

Airport

Number of additional

inspectional positions

recommended for FY

1998

Number of additional

inspectional positions

allocated for FY 1998

Number of additional

inspectional positions

recommended for FY

1999

JFK 108 12 88

LAX 20 16 (8)

Newark 9 2 14

Houston (9) 0 (6)

Detroit 18 10 8

Note 1: Numbers in parentheses indicate that the model considered these ports to be overstaffed

for that fiscal year.

Note 2: The allocation of inspectional positions for fiscal year 1999 is pending the results of

congressional appropriations.

Source: U.S. Customs Service.

Customs officials considered the model to be an analytical tool in their

decisionmaking. As such, the model is not intended to establish the level

at which airports should be staffed. Rather, the model’s results and

recommendations are considered to be an indicator of the additional

inspectional positions needed by each of the 16 ports, given the six factors

discussed earlier that the model considers.

The model’s results and recommendations are reviewed by Customs

officials and are modified in two primary ways. First, Customs does not

allocate all of the positions recommended for particular ports. According

to Customs officials, because additional inspectional positions have

generally not been available from regular (“Salaries and Expenses”)

appropriations, Customs has provided additional positions to airports

mainly by funding them through user-fee revenues.5

 However, according to

these officials, user-fee revenues each fiscal year were not sufficient to

fund all of the positions the model estimated were needed. For example,

for fiscal year 1998, a total of 142 additional positions were actually funded

by user-fee revenues, while the model estimated that 288 additional

positions were needed. The model recommended that out of the 288

estimated additional positions, JFK Airport needed 108 additional positions

and LAX Airport needed 20 additional positions. As a result of internal

reviews by Customs officials, JFK Airport was allocated 12 positions and

5

In our April 1998 report, we indicated that the President’s budgets for fiscal years 1997 to 1999 did not

request all of the additional inspectional positions that Customs estimated it needed for its commercial

cargo processing operations. Congress funded the number of positions that were requested for fiscal

years 1997 and 1998. As of August 1998, fiscal year 1999 appropriations were pending.

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LAX Airport was allocated 16 positions. For fiscal year 1999, the model

recommended that out of the 175 total additional positions it estimated as

needed, JFK Airport needed 88 additional positions. As discussed below,

the model indicated that LAX Airport was overstaffed. As of August 1998,

the allocation of inspectional personnel was pending the outcome of

congressional appropriations for fiscal year 1999. The appropriations

would determine the actual number of additional positions that could be

funded.

Second, Customs did not move existing positions from airports that the

model indicated were overstaffed. For example, for fiscal year 1998, the

model indicated that 4 airports were overstaffed by a total of 37 positions.

For fiscal year 1999, the model indicated that LAX Airport was overstaffed

by 8 positions and that 4 other airports were overstaffed by a total of 42

positions. In our April 1998 report,6

 Customs officials stated that they

generally did not reallocate existing inspectional personnel for several

reasons, including legislative limitations placed on the movement of

certain positions, such as those funded by user-fee revenues for specific

purposes at specific locations. In addition, according to the Customs

official who administers the model, primarily because the model did not

take into account certain factors, such as sudden changes in airline

markets, Customs did not plan to move positions from the ports that the

model indicated were overstaffed.

Customs’ Response to Our

Recommendation on Need

for Inspectional Personnel

Assessment and Allocation

Process

In our April 1998 report, we concluded that in order to successfully

implement the Government Performance and Results Act of 1993 (the

Results Act) (P.L. 103-62),7

 Customs had to determine its needs for

inspectional personnel for all of its operations and ensure that available

personnel were allocated where they were needed most. Accordingly, we

recommended that, as a sound strategic planning practice, Customs

establish a systematic process that would properly align its inspectional

personnel with its operational activity goals, objectives, and strategies.

6

GAO/GGD-98-107.

7

The Results Act was enacted to improve the efficiency and effectiveness of federal programs. The

Results Act required that executive agencies develop strategic plans in which, among other things,

they defined their missions and established performance goals and measures for each of their program

activities. Customs’ Strategic Plan for fiscal years 1997 through 2002 established performance goals

and measures for its program activities. The Results Act also required that strategic plans describe,

among other things, (1) the human and other resources needed and (2) how agencies proposed to align

these resources with their activities to support mission-related goals and objectives.

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Customs’ Assistant Commissioner for Field Operations told us that, in

part, as a result of reviewing the April 1998 report and its

recommendation, Customs recognizes that staffing imbalances may exist

at certain ports. In a June 1998 written response to our recommendation,

Customs detailed the steps it was taking to implement it. Specifically,

Customs indicated that it had awarded a contract for the development of a

resource allocation model that would define the work of Customs’ core

occupations and prioritize workload. The model also is to process data

using performance measurement methodologies, be compatible with cost

accounting and other management controls, and establish linkages

between core occupations and support positions. Upon delivery of the

model, Customs indicated it would customize a process for using it to

meet changing personnel needs and new initiatives. The model is

scheduled to be ready for implementation by fiscal year 1999.

In conjunction with the development of the resource allocation model,

Customs indicated that it was undertaking an initiative to assess and

improve the quality of the data to be used in the model. Specifically, the

initiative is to review and confirm data definitions and sources and assess

the quality of the data.

Inspectional Personnel

Levels at Selected Ports

Were at or Near Funded

Levels

Table 2 shows the combined (cargo and passenger processing) onboard

inspectional personnel levels at the end of fiscal year 1997 at the ports we

visited or contacted. According to Customs officials at the ports,

inspectors who are not funded by user-fee revenues often shift between

cargo and passenger processing functions, depending on workload

demands and the need to work overtime. Consequently, it could be

difficult to establish the exact number of inspectors dedicated to each

function at any given time. Accordingly, we did not separate the staffing

levels by function.

Table 2 also shows that the onboard personnel levels for each port were

very near the levels funded from appropriations. According to Customs

officials, under its current “staff-to-budget”8

 procedures, rather than

“authorized” levels, Customs tracks its personnel levels at ports through

“tables-of-organization”—which reflect the number of positions that are

funded at a particular port—and the number of personnel onboard.

8

According to Customs officials, under the “staff-to-budget” concept, rather than attempting to fill

“authorized” positions, which was unrealistic given funding levels, Customs seeks to fill the number of

positions that its appropriated funding actually allows.

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Table 2: Table-Of-Organization

(Funded) and Onboard Inspectional

Personnel Levels for Selected Ports,

as of September 30, 1997

Port

Inspectional Personnel

Levels (Funded)

Inspectional Personnel

Levels (Onboard)

LAX Airport 336 320

Los Angeles/Long Beach Seaport 156 145

JFK Airport 563 531

Newark Airport 100 95

New York/Newark Seaport 307 292

Houston Airport 62 58

Houston/Galveston Seaport 93 89

Detroit Airport 43 43

Detroit Seaport 2 2

Source: U.S. Customs Service.

According to Customs officials at the ports we visited or contacted, the

existing inspectional personnel above and the use of overtime funds

enabled the ports to process arriving international passengers and cargo

within the performance measures established by Customs for these

functions in its strategic plan. The performance measure for processing air

passengers requires that 95 percent of such passengers be cleared within 5

minutes from the time they retrieve their checked luggage, while the

measure for air cargo (formal entries) requires that 99.6 percent of such

entries be released in 1 day.9

Workload-ToInspector Ratios and

Rationales for

Differences Could Not

Be Determined

We were not able to develop reliable workload-to-inspector ratios because

we could not establish a sufficient level of assurance regarding the overall

quality of the workload data to conduct further analyses. Specifically, we

identified significant discrepancies in the workload data as reported from

Customs headquarters and a CMC and ports for two ports. For example,

headquarters workload data—considered by Customs to be the official

data—showed that the Newark Seaport processed 154,206 sea passengers

in fiscal year 1997. However, the port itself reported that it processed

186,957 passengers that same year. The data discrepancies for JFK Airport

are discussed earlier in this report. We could not obtain specific reasons

for these discrepancies without Customs having to conduct additional

9

Customs’ fiscal year 1997 performance plan included a performance measure for examining incoming

cargo. The plan called for 3.1 percent of such cargo to be examined. In its fiscal year 1999 budget

request submission, Customs reported that, overall, 2.6 percent of cargo had been examined in fiscal

year 1997. It also reported that the cargo examination performance measure was being discontinued as

part of Customs’ ongoing efforts to improve and refine its performance measures. The ports we visited

or contacted reported that they examined an average of 2.2 percent of incoming cargo in fiscal year

1997.

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work. In addition, we could not identify any systematic internal controls

over the accuracy and reliability of such data, either at Customs

headquarters or at the CMCs and ports we visited or contacted.

Workload is one of several factors that Customs considered in the

assessments and allocations done over the past 3 years. According to

Customs officials, the drug-smuggling threat—such as the use of rail cars

to smuggle drugs—was the primary factor considered in these

assessments and allocations. As discussed earlier, Customs also

considered budgetary constraints and legislative limitations in its

personnel assessment and allocation decisionmaking.

Cargo and Passenger

Processing Workloads at

Selected Ports

Table 3 shows the cargo and passenger processing workloads for fiscal

year 1997 at the selected ports we visited or contacted as reported by

Customs headquarters. The cargo workload data are presented as totals of

all types of entries, including formal entries, for each port.

Table 3: Cargo and Passenger

Processing Workloads for Selected

Ports, Fiscal Year 1997

Port Passengers Cargo (all entries)

LAX Airport 7,317,123 604,038

LA/Long Beach Seaport 804,418 800,511

JFK Airport 9,710,193 786,617

Newark Airport 2,613,760 660,159

Newark Seaport 154,206 660,159

Houston Airport 1,881,970 59,575

Houston/Galveston Seaport 17,424 97,125

Detroit Airport 1,460,469 45,250

Detroit Seaport 12,557 18,747

Note 1: Customs uses the same code to track cargo entries at the Newark sea and air ports.

Source: U.S. Customs Service headquarters database.

Conclusions We could not perform the staffing and workload analyses requested by the

Subcommittees because (1) Customs had not assessed the level of

appropriate staffing at its ports and (2) of concerns about the quality of

Customs’ workload data. In addition, Customs considered factors other

than workload—such as budget constraints and legislative limitations—in

determining its need for inspectional personnel and allocating such

personnel to ports. According to Customs officials, these factors must be

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considered in their decisionmaking in order to maximize the effectiveness

of deployed resources.

Based on statements to us by senior Customs officials and their response

to the recommendation in our April 1998 report, we believe that Customs

has recognized that staffing imbalances may exist at certain ports and that

it needs to improve the manner in which it assesses the need for and

allocates inspectional personnel to ports of entry. Customs’ actions—the

award of a contract to develop a resource allocation model and an

initiative to improve the quality of data in its management database—are

steps in the right direction to address the personnel assessment and

allocation issues we identified during our work. Given these steps by

Customs, we are not making any recommendations in this report.

Agency Comments

and Our Evaluation

We requested comments on a draft of this report from the Secretary of the

Treasury or his designees. On August 4, 1998, Customs’ Assistant

Commissioner for Field Operations provided us with Customs’ comments

on the draft. The Assistant Commissioner generally agreed with the

information presented in the report and its conclusions and provided

technical comments and clarifications, which we have incorporated in this

report where appropriate.

We are sending copies of this report to the Chairmen and Ranking

Minority Members of the congressional committees that have

responsibilities related to Customs, the Secretary of the Treasury, and the

Acting Commissioner of Customs. Copies will also be made available to

others on request. Major contributors to this report are listed in appendix

II. If you have any questions or wish to discuss the information in this

report, please contact Brenda J. Bridges, Assistant Director, on

(202) 512-5081 or me on (202) 512-8777.

Norman J. Rabkin

Director, Administration

 of Justice Issues

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Contents

Letter 1

Appendix I 

Objectives, Scope,

and Methodology

16

Appendix II 

Major Contributors to

This Report

19

Tables Table 1: Results of Customs’ Air Passenger Staffing Allocation

Model for Selected Airports, Fiscal Years 1998 and 1999

7

 Table 2: Table-of-Organization and Onboard Inspectional

Personnel Levels for Selected Ports, as of September 30, 1997

10

 Table 3: Cargo and Passenger Processing Workloads for Selected

Ports, Fiscal Year 1997

11

Abbreviations

CMC Customs Management Center

JFK John F. Kennedy International Airport

LAX Los Angeles International Airport

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Appendix I 

Objectives, Scope, and Methodology

Our objectives in this review were to analyze (1) the cargo and passenger

inspectional personnel levels at selected airports and seaports around the

United States and the implications of any differences between these levels

and those determined by Customs to be appropriate for these ports

(assessed levels) and (2) the cargo and passenger processing workloads

and related workload-to-inspector ratios at the selected ports and the

rationales for any significant differences in these ratios.

To identify the cargo and passenger inspectional personnel levels at the

selected ports and the implications of any differences between the

assessed and actual personnel levels, we reviewed budget documents and

summaries, staffing statistics, cargo and passenger processing

performance data, and Customs’ strategic plan for fiscal years 1997 to

2002. We also interviewed Customs officials at headquarters, Customs

Management Centers (CMC), and ports where we also observed cargo and

passenger processing operations. In addition, we sought to determine how

Customs assesses the need for inspectional personnel and allocates such

personnel to ports of entry to process cargo and passengers. Accordingly,

we reviewed documents related to Customs’ three assessments since 1995

focusing on its drug smuggling initiatives and documents related to

Customs’ air passenger processing model, including a September 1992

report about the model done for Customs by two consulting firms. We did

not independently assess the validity and reliability of the air passenger

processing model or its results. However, we conducted a limited review

of the consultants’ report and discussed its findings and

recommendations—and Customs’ responses to them—with cognizant

Customs officials. Because of the similarities in the subject matter, we

relied extensively on information in our April 1998 report10 that focused on

Customs’ inspectional personnel assessment and allocation processes for

commercial cargo ports.

To identify the cargo and passenger processing workloads and any related

workload-to-inspector ratios at the selected ports and the rationales for

any significant differences in these ratios, we obtained and reviewed

workload data from Customs headquarters, CMCs, and ports. Given time

constraints, we did not independently verify the accuracy and reliability of

Customs’ workload data. However, to obtain some indication of the

overall quality of these data, we sought to identify whether Customs had in

place any procedures for verifying data. Customs officials could not

identify any formal, systematic procedures to verify data quality. Some

port officials told us that they informally monitored data in management

10GAO/GGD-98-107.

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Appendix I 

Objectives, Scope, and Methodology

reports to detect potential errors. In addition, we compared workload data

obtained from headquarters, CMCs, and ports and identified several

discrepancies, such as those in the number of cargo entries at John F.

Kennedy International (JFK) Airport. While Customs officials said they

could not explain specific discrepancies in the data without conducting

lengthy additional work, they provided some general reasons that could

potentially explain the discrepancies. These reasons included the

possibility that some ports tracked workload data differently from

Customs headquarters.

We visited the CMCs in Los Angeles and New York and the Los Angeles

International Airport (LAX), Los Angeles/Long Beach Seaport, JFK Airport,

New York/Newark Seaport, and Newark International Airport, which,

although not part of our original scope, we visited due to its proximity to

the seaport—at the request of the Subcommittees. We subjectively

selected both the airports and seaports each in Houston and Detroit and

telephonically interviewed cognizant officials from these ports in response

to the Trade Subcommittee’s request following our May 21, 1998, briefing

that we expand the geographic scope of our work to include ports along

the Northern and Southern borders of the United States.

As discussed earlier, the nine ports we visited or contacted were among

the busiest of their kind in the United States in fiscal year 1997. JFK Airport

was the busiest in terms of passenger workload and the second busiest in

terms of cargo workload and had flights arriving from all over the world.

The Newark Airport, while seventh in terms of passenger workload, has

been experiencing rapid growth. Specifically, the number of passengers

arriving at the airport had grown by 67 percent between fiscal years 1992

and 1997, while the number of arriving flights had grown by 30 percent

during the same period. The New York/Newark Seaport was the second

busiest in terms of cargo workload, which was expected to grow by over

10 percent annually for the next 4 years. The Los Angeles/Long Beach

Seaport was the busiest in terms of cargo workload, collecting 18

percent—about $4 billion—of the duties, fees, and taxes collected by

Customs nationwide in fiscal year 1997. LAX Airport was the third busiest

in terms of passenger workload and fifth busiest in terms of cargo

workload. For example, over 7 million passengers and 41,000 flights were

cleared through LAX Airport in fiscal year 1997. The Houston/Galveston

Seaport was the eighth busiest in terms of cargo processing, while the

Houston Airport was the eighth busiest in terms of passenger processing.

The airport’s workload had grown by between 12 to 15 percent annually

over the past 2 to 3 years. The Detroit Airport was the 13th busiest in

Page 17 GAO/GGD-98-170 Inspectional Personnel and Workloads
Appendix I 

Objectives, Scope, and Methodology

terms of passenger processing, while the seaport processed a relatively

small number of cargo entries and vessel crew.

The results related to inspectional staffing levels and cargo and passenger

workloads apply only to the five ports we visited and the four ports we

telephonically contacted and cannot be generalized to all Customs ports.

Page 18 GAO/GGD-98-170 Inspectional Personnel and Workloads
Appendix II 

Major Contributors to This Report

General Government

Division, Washington,

D.C.

Brenda J. Bridges, Assistant Director

Barry J. Seltser, Assistant Director, Design, Methodology, and Technical

 Assistance

Seto J. Bagdoyan, Evaluator-in-Charge

Sidney H. Schwartz, Senior Statistician, Design, Methodology, and

 Technical Assistance

Donald E. Jack, Evaluator

Wendy C. Simkalo, Evaluator

(264441) Page 19 GAO/GGD-98-170 Inspectional Personnel and Workloads
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