TSA EXPLOSIVES 

DETECTION CANINE 

PROGRAM

Actions Needed to 

Analyze Data and 

Ensure Canine Teams 

Are Effectively 

Utilized

Report to Congressional Requesters

January 2013

GAO-13-239

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-239, a report to 

congressional requesters

January 2013

TSA EXPLOSIVES DETECTION CANINE 

PROGRAM

Actions Needed to Analyze Data and Ensure Canine 

Teams Are Effectively Utilized

Why GAO Did This Study

TSA has implemented a multilayered 

system composed of people, 

processes, and technology to protect 

the transportation system. One of 

TSA’s security layers is NCP, 

composed of over 760 deployed 

explosives detection canine teams, 

including PSC teams trained to detect 

explosives on passengers. As 

requested, GAO examined (1) data 

TSA has on its canine program, what 

these data show, and to what extent 

TSA analyzed these data to identify 

program trends, and (2) the extent to 

which TSA deployed PSC teams using 

a risk-based approach and determined 

their effectiveness prior to deployment. 

To address these questions, GAO 

conducted visits to four geographic 

locations selected based on the 

number and type of canine teams 

deployed. The results of these site 

visits are not generalizable, but 

provided insights into NCP. GAO also 

analyzed TSA data from 2011 through 

2012, such as utilization data; 

reviewed documents, including 

response protocols; and interviewed 

DHS officials.

What GAO Recommends

GAO is recommending that TSA (1) 

regularly analyze data to identify 

program trends and areas working well 

or in need of corrective action, and (2) 

take actions to comprehensively 

assess the effectiveness of PSCs. If 

PSCs are determined to be effective, 

GAO is recommending that TSA 

coordinate with stakeholders to deploy 

PSC teams to the highest-risk airport 

locations and utilize them as intended. 

DHS concurred with GAO’s 

recommendations.

View videos

What GAO Found

of GAO’s June 2012 observation 

of PSC teams. Part 1, Part 2.

The Transportation Security Administration (TSA), the federal agency that 

administers the National Canine Program (NCP), is collecting and using key data 

on its canine program, but could better analyze these data to identify program 

trends. TSA collects canine team data using the Canine Website System (CWS), 

a central management database. TSA uses CWS to capture the amount of time 

canine teams conduct training as well as searching for explosives odor, among 

other functions. However, TSA has not fully analyzed the data it collects in CWS 

to identify program trends and areas that are working well or in need of corrective 

action. Such analyses could help TSA to determine canine teams’ proficiency, 

inform future deployment efforts, and help ensure that taxpayer funds are used 

effectively. For example:

• GAO analysis of canine team training data from May 2011 through April 2012 

showed that some canine teams were repeatedly not in compliance with 

TSA’s monthly training requirement, which is in place to ensure canine teams 

remain proficient in explosives detection. 

• GAO analysis of TSA’s cargo-screening data from September 2011 through 

July 2012 showed that canine teams primarily responsible for screening air 

cargo placed on passenger aircraft exceeded their monthly screening 

requirement. This suggests that TSA could increase the percentage of air 

cargo it requires air cargo canine teams to screen or redeploy teams. 

TSA has not deployed passenger screening canines (PSC)—trained to identify 

and track explosives odor on a person—consistent with its risk-based approach, 

and did not determine PSC teams’ effectiveness prior to deployment. TSA’s 2012 

Strategic Framework calls for the deployment of PSC teams based on risk; 

however, GAO found that PSC teams have not been deployed to the highest-risk 

airport locations. TSA officials stated that the agency generally defers to airport 

officials on whether PSC teams will be deployed, and some airport operators 

have decided against the use of PSC teams at their airports because of concerns 

related to the composition and capabilities of PSC teams. As a result of these 

concerns, the PSC teams deployed to higher-risk airport locations are not being 

used for passenger screening as intended, but for other purposes, such as 

screening air cargo or training. TSA is coordinating with aviation stakeholders to 

resolve concerns related to PSC team deployment, but has been unable to 

resolve these concerns, as of September 2012. Furthermore, TSA began 

deploying PSC teams in April 2011 prior to determining the teams’ operational 

effectiveness and before identifying where within the airport these teams would 

be most effectively utilized. TSA is in the process of assessing the effectiveness 

of PSC teams in the operational environment, but testing is not comprehensive 

since it does not include all areas at the airport or compare PSCs with already 

deployed conventional canines (trained to detect explosives in stationary 

objects). As a result, more comprehensive testing could provide TSA with greater 

assurance that PSC teams are effective in identifying explosives odor on 

passengers and provide an enhanced security benefit.

This is a public version of a sensitive report that GAO issued in December 2012. 

Information TSA deemed Sensitive Security Information has been redacted.

View GAO-13-239. For more information, 

contact Stephen Lord at (202) 512-4379 or 

lords@gao.gov.
Page i GAO-13-239 Explosive Detection Canines

Letter 1 

Background 6

TSA Collects and Uses Data to Track Canine Program 

Performance, but Could Better Analyze These Data to Identify 

Program Trends 10

TSA Has Not Deployed Passenger Screening Canine Teams to the 

Highest-Risk Airports and Did Not Determine Their 

Effectiveness Prior to Deployment 17

Conclusions 24

Recommendations for Executive Action 24

Agency Comments and Our Evaluation 25

Appendix I TSA Has Taken Actions to Enhance Program Training and 

Evaluation, and Research, Development, and Testing 28

Appendix II Objectives, Scope, and Methodology 31

Appendix III Comments from the Department of Homeland Security 35

Appendix IV GAO Contact and Staff Acknowledgments 39

Tables

Table 1: Total Number and Federal Costs of TSA Canine Teams by 

Type of Team 6

Table 2: Examples of Data Elements Recorded in CWS 10

Table 3: TSA’s Actions to Enhance NCP 28

Figures

Figure 1: Various Types of Canine Teams 8

Figure 2: Video Stills Showing Passenger Screening Canine (PSC) 

Teams Training in Airport Terminal, June 2012 21

Contents 
Page ii GAO-13-239 Explosive Detection Canines

Abbreviations

AAAE American Association of Airport Executives

ACI-NA Airports Council International-North America

ALEAN Airport Law Enforcement Agencies Network

CEB Canine Explosives Branch

CTES Canine Training and Evaluation Section

CWS Canine Website System

DHS Department of Homeland Security

DOD Department of Defense

FCC field canine coordinator

LEO law enforcement officer 

NCP National Canine Program

NPR nonproductive response

OSO Office of Security Operations

PSC passenger screening canine

S&T Science and Technology Directorate

SSI Sensitive Security Information

TSA Transportation Security Administration

TSI transportation security inspector

View GAO-13-239 Key Components 

TSA Explosives Detection Canine Program: Actions Needed to Analyze 

Data and Ensure Canine Teams Are Effectively Utilized. Please Click on 

hyperlink to View Part 1, Part 2. 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-13-239 Explosive Detection Canines

United States Government Accountability Office

Washington, DC 20548

January 31, 2013

The Honorable Jason Chaffetz

Chairman

Subcommittee on National Security

Committee on Oversight and Government Reform

House of Representatives

The Honorable Richard Hudson

Chairman

Subcommittee on Transportation Security

Committee on Homeland Security

House of Representatives

The Honorable Mike Rogers

Committee on Homeland Security

House of Representatives

Recent foiled terrorist plots in the fall of 2010—including a planned attack 

on the Washington, D.C., Metro system, and the discovery of explosive 

devices in air cargo packages transported on all-cargo aircraft bound for 

the United States from Yemen—underscore the existing threat to the U.S. 

transportation system. Within the Department of Homeland Security 

(DHS), the Transportation Security Administration (TSA) is the primary 

federal agency responsible for security of the nation’s transportation 

system. Since the terrorist attacks of September 11, 2001, TSA has 

implemented a multilayered system of security composed of people, 

processes, and technology to protect the transportation system. One of 

TSA’s security layers is the Office of Security Operations’ (OSO) National 

Canine Program (NCP), composed of over 760 explosives detection 

canine teams—a canine paired with a handler—aimed at deterring and 

detecting the use of explosive devices in the U.S. transportation system.

Through NCP, TSA trains, deploys, and certifies explosives detection 

canine teams. The program began under the Federal Aviation 

Administration in 1972 as a partnership with state and local law 

enforcement agencies with jurisdiction over airports by pairing law 

enforcement officer (LEO) handlers with conventional canines trained to 

detect explosives in objects (e.g., baggage and vehicles). In accordance 

 
 

Page 2 GAO-13-239 Explosive Detection Canines

with the Aviation and Transportation Security Act, which established TSA, 

the transfer of NCP to TSA was accomplished in March 2003.1 TSA 

subsequently expanded the program beyond airports to other 

transportation modes, including mass transit, and in January 2008, further 

expanded the program to include civilian transportation security inspector 

(TSI) canine teams responsible for screening air cargo. In 2011, TSA 

again expanded the program by deploying TSI handlers to airports with 

passenger screening canines (PSC)—conventional canines also trained 

to detect explosives being carried or worn on a person.

In 2008, pursuant to the Implementing Recommendations of the 9/11 

Commission Act of 2007,2 we reviewed TSA’s plans and capacity to 

increase its explosives detection canine teams.3 In that review, we 

reported that TSA had begun to increase its capacity to implement its 

plan to train, deploy, and certify additional explosives detection canine 

teams, as required. You requested additional information on TSA’s canine 

deployment plans, and canines’ effectiveness in detecting explosives. 

This report addresses the following questions:

(1) What data does TSA have on its canine program, what do 

these data show, and to what extent has TSA analyzed these data 

to identify program trends?

(2) To what extent has TSA deployed passenger screening canine 

teams using a risk-based approach and determined their 

effectiveness prior to deployment?

 

1

Enacted in November 2001, the Aviation and Transportation Security Act established, 

within the Department of Transportation, TSA as the agency responsible for securing the 

nation’s transportation systems, including civil aviation. See Pub. L. No. 107-71, § 101(a), 

115 Stat. 597 (2001). The Homeland Security Act of 2002 subsequently transferred TSA 

to the newly established Department of Homeland Security. See Pub. L. No. 107-296, § 

403, 116 Stat. 2135, 2178 (2002). 

2

See Pub. L. No. 110-53, § 1307, 121 Stat. 266, 395-97 (2007) (authorizing the 

appropriation of such sums as may be necessary to carry out section 1307, which relates 

to the capacity, standards, deployment, and procurement of explosives detection canine 

teams, for fiscal years 2007 through 2011). 

3

GAO, TSA’s Explosives Detection Canine Program: Status of Increasing Number of 

Explosives Detection Canine Teams, GAO-08-933R (Washington, D.C.: July 31, 2008).
 

Page 3 GAO-13-239 Explosive Detection Canines

In addition, this report includes information on the actions TSA has taken 

to enhance NCP since we issued our last report, in 2008 (see app. I).

This report is a public version of a prior sensitive report that we provided 

to you. TSA deemed some of the information in the prior report Sensitive 

Security Information (SSI), which must be protected from public 

disclosure.4 The Department of Defense (DOD) also determined some of 

the information in our report to be operationally sensitive. Therefore, this 

report omits sensitive information regarding the number of deployed 

canine teams by type, results of our analysis of canine team data, and 

TSA’s assessment of PSC teams, among other things. The information 

provided in this report is more limited in scope as it excludes such 

sensitive information, but it addresses the same questions as the 

sensitive report and the overall methodology used for both reports is the 

same.

To determine what data TSA has on its canine program, what these data 

show, and the extent to which TSA has analyzed these data to identify 

program trends, we interviewed TSA OSO officials about the type of 

canine team data they collect and analyze to monitor canine team 

performance consistent with Standards for Internal Control in the Federal 

Government.

5 Using data from the agency’s Canine Website System 

(CWS), we analyzed the number of training and utilization minutes 

recorded by canine handlers from May 2011 through April 2012—the 

most recent data available at the time of our analysis. We compared the

number of minutes canine teams spent training each month (known as 

training minutes) with TSA’s requirement. We analyzed the number of 

minutes canine teams were utilized each month (known as utilization 

minutes) by type of handler (LEO and TSI) to identify any differences. In 

addition, we collected and reviewed monthly reports on canine team 

training and utilization from canine team supervisors—an area canine 

coordinator and field canine coordinators. Further, we analyzed data from 

CWS for May 2012—the most recent data available at the time of our 

analysis—to determine the number of certified and decertified canine 

teams by type of handler. Moreover, we reviewed all available certification 

 

4

See 49 C.F.R. pt. 1520. 

5

GAO, Internal Control: Standards for Internal Control in the Federal Government, 

GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999). 
 

Page 4 GAO-13-239 Explosive Detection Canines

data from January 2011 through August 2012 provided by TSA.6 To 

assess the reliability of the CWS data on canine team training, utilization, 

and certification, we interviewed knowledgeable officials, reviewed the 

data for obvious errors and anomalies, and reviewed documentation. We 

determined the data were sufficiently reliable for our purposes. We also 

reviewed and analyzed the number of final canine responses—instances 

when the canine sits, indicating to its handler that it detects explosives 

odor—documented in CWS, and corresponding swab samples sent to 

TSA’s Canine Explosives Branch (CEB) to validate the canines’ 

responses and determine their effectiveness in detecting explosives odor. 

We found limitations in the final canine response data, as discussed later 

in this report, but we believe the data to be sufficiently reliable for 

generally comparing the number of canine responses with the number of 

swab samples.

To assess the extent to which TSA deployed PSC teams in a risk-based 

manner, consistent with TSA’s 2012 Strategic Framework, we compared 

TSA’s risk ranking of airports with the NCP’s canine asset spreadsheet 

that tracks the deployment location of canine teams. We reviewed TSA’s 

Recommended Operational Procedures for Canine Screening of 

Individuals to understand TSA’s procedures for deploying PSC teams and 

protocols for responding to final responses from PSCs. In addition, we 

interviewed PSC handlers at the two locations we visited where PSC 

teams were initially deployed.7 We also interviewed officials from Amtrak 

police and three major aviation industry associations—Airport Law 

Enforcement Agencies Network (ALEAN), Airports Council InternationalNorth America (ACI-NA), and American Association of Airport Executives 

(AAAE) because they represent stakeholders who expressed views to 

TSA on its deployment of PSC teams. While the results from our 

interviews are not generalizable to all PSC handlers and aviation 

stakeholders, they provided a range of perspectives on TSA’s PSC team 

utilization and response protocols. To determine the extent to which TSA 

determined the effectiveness of PSC teams, we compared the PSC 

assessment approach used by TSA and the DHS Science and 

 

6

Certification data represent the number of canine teams that are certified and decertified 

to detect explosives odor. 

7

In the context of this report, TSA deemed the specific locations we visited as SSI. 
 

Page 5 GAO-13-239 Explosive Detection Canines

Technology Directorate (S&T) with DHS guidance and best practices.8

Moreover, we reviewed the available test results from TSA and DHS 

S&T’s operational assessment of PSC teams’ effectiveness in different 

areas at the airport. In addition, we interviewed DHS S&T officials 

regarding the assessment methodology, and determined that the results 

were reliable. Finally, we reviewed TSA’s canine team cost data, as of 

January 2012, to identify the difference in costs among the various types 

of canine teams. To assess the reliability of the canine team cost data, we 

interviewed knowledgeable officials, and reviewed the data for obvious 

errors and anomalies. We determined the data were sufficiently reliable 

for the purposes of our report.

To summarize the actions TSA has taken to enhance NCP, we observed 

canine training at TSA’s Canine Training and Evaluation Section (CTES) 

at Lackland Air Force Base in Texas, as well as Auburn University’s 

Canine Detection Training Center in Alabama, because this is where 

some PSC teams were trained. Furthermore, we conducted site visits to 

the three locations with the greatest number of deployed canine teams in 

the mass transit, airport, and air cargo environments to observe canine 

teams training in their operational environments and interview LEO and 

TSI canine handlers.9 We also observed canine teams and interviewed 

handlers during a site visit we conducted at a fourth location so we could 

observe additional PSC teams. While the results from our interviews are 

not generalizable to all canine handlers, they provided a range of 

perspectives on canine handlers’ views on TSA’s training and evaluation 

process. Appendix II provides more details about our objectives, scope, 

and methodology.

We conducted this performance audit from January 2012 through January 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

 

8

DHS, National Infrastructure Protection Plan: Partnering to Enhance Protection and 

Resiliency (Washington, D.C.: 2009), and GAO, Performance Measurement and 

Evaluation: Definitions and Relationships, GAO-11-646SP (Washington, D.C.: May 2011). 

See also GAO, Executive Guide: Effectively Implementing the Government Performance 

and Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996).

9

In the context of this report, TSA deemed the specific locations we visited as SSI.
 

Page 6 GAO-13-239 Explosive Detection Canines

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

NCP’s mission is to deter and detect the introduction of explosive devices 

into the transportation system. As of September 2012, NCP has deployed 

762 of 921 canine teams for which it is able to fund across the 

transportation system. Table 1 shows the number of canine teams by 

type for which funding is available, as well as describes their roles, 

responsibilities, and costs to TSA. There are four types of LEO teams: 

aviation, mass transit, maritime, and multimodal, and three types of TSI 

teams: air cargo, multimodal, and PSC.

Table 1: Total Number and Federal Costs of TSA Canine Teams by Type of Team

Type of

canine team 

Number of

teams for which

funding is availablea Description of roles and responsibilities

TSA 

start-up costs

TSA 

annual costs b

LEO: aviation

b

491

Patrol airport terminals, including ticket counters, 

curbside areas, and secured areas; respond to calls to 

search unattended items, such as vehicles and 

baggage; screen air cargo; and serve as general 

deterrents to would-be terrorists or criminals $94,000 $63,000

LEO: mass 

transit

111

Patrol mass transit terminals; search platforms, 

railcars, and buses; respond to calls to search 

unattended items, such as baggage; and serve as 

general deterrents to would-be terrorists or criminals $84,000 $53,000

LEO: maritime

6 

Conduct similar activities as LEO mass transit teams 

at ferry terminals $84,000 $53,000

LEO: multimodal

27

Patrol and search transportation modes in their 

geographic area (e.g., aviation, mass transit, and 

maritime), and screen air cargo $94,000 $63,000

TSI: air cargo 120 Primarily screen air cargo $218,000 $159,000

TSI: multimodal 

46

Patrol and search transportation modes in their 

geographic area (e.g., aviation, mass transit, or 

maritime), and screen air cargo $218,000 $159,000

TSI: PSC 

120

Search for explosives odor on passengers in airport 

terminals $237,000 $164,000

Total 921 

Source: GAO using TSA data.

a

The number of teams for which funding is available is for fiscal year 2013.

b

Background 

The cost data are as of January 2012, and have been rounded to the nearest thousand. Start-up 

costs reflect the costs incurred by TSA during the first year the canine team is deployed. Annual costs 

include the operations and maintenance costs incurred by TSA to keep canine teams deployed after 

their first year in the program.
 

Page 7 GAO-13-239 Explosive Detection Canines

TSA’s start-up costs for LEO teams include the costs of training the 

canine and handler, and providing the handler’s agency a stipend.10 The 

annual costs to TSA for LEO teams reflect the amount of the stipend.11

TSA’s start-up and annual costs for TSI canine teams are greater than 

those for LEO teams, because TSI handlers are TSA employees, so the 

costs include the handlers’ pay and benefits, service vehicles, and cell 

phones, among other things. PSC teams come at an increased cost to 

TSA compared with other TSI teams because of the additional training 

costs associated with providing decoys (i.e., persons pretending to be 

passengers who walk around the airport with explosive training aids).

From fiscal year 2010 to 2012, TSA funding for NCP increased from 

approximately $52 million to $101 million.12 During this time, TSA 

requested and was provided funding to increase the stipend it provides to

law enforcement agencies for participating in NCP, and of amounts 

appropriated in fiscal year 2012, $5 million was directed for 20 new 

canine teams.13 For fiscal year 2013, TSA is requesting approximately 

$96 million for its canine program, which is about $5 million less in 

funding than was appropriated in fiscal year 2012. TSA plans to continue 

to fund 921 canine teams, and cited savings on supplies, and efficiencies 

in operations, among others, as reasons for the reduced funding request.

Figure 1 shows LEO, TSI, and PSC teams performing searches in 

different environments.

 

10The annual stipend is the federal cost share TSA provides per LEO team pursuant to a 

cooperative agreement between TSA and the LEO team’s agency (state or local). Certain 

items and services are reimbursable by TSA through the stipend, including canine food 

and veterinary care. The LEO team’s agency is responsible for any costs incurred greater 

than the amount covered by the stipend.

11The LEO aviation and multimodal teams’ stipends are $10,000 more than those for other 

LEO teams because the teams are required to spend 25 percent of their time screening 

air cargo, per the cooperative agreement with TSA.

12TSA funds the NCP through three TSA activities: aviation regulation and other 

enforcement (aviation), surface transportation security inspectors and canines (surface), 

and air cargo. From fiscal years 2010 to 2012, TSA funding for NCP through the aviation 

and cargo activities approximately doubled.

13See H.R. Rep. No. 112-331, at 972 (Dec. 15, 2011) (regarding amounts appropriated for 

“Aviation Regulation and Other Enforcement”). 
 

Page 8 GAO-13-239 Explosive Detection Canines

Figure 1: Various Types of Canine Teams

TSA obtains canines at no cost to TSA through an interagency agreement 

with the Department of Defense. DOD reported that the most recent 

agreement, dated January 2012, requires TSA to request the number of 

canines it needs based on its annual requirement. TSA reported that on 

the basis of how many canine teams it plans to train, it requests up to 190 

canines each year. TSA also breeds canines at its Canine Breeding and 

Development Center at Lackland Air Force Base. Canines undergo 10 

weeks of explosives detection training before being paired with a handler 

at TSA’s CTES, also located at Lackland Air Force Base. Conventional 

canine handlers attend a 10-week training course, and PSC handlers 

attend a 12-week training course.14 Canines are paired with a LEO or TSI 

handler during their training course. After canine teams complete this 

initial training, and are acclimated to their home operating environment, 

they undergo a 10- to 14-day “training mission” with a CTES evaluator to 

 

14The majority of canine teams are trained by TSA’s CTES. However, because of 

resource constraints, TSA contracted with Strijder Group K9, which subcontracted to 

Auburn University’s Canine Detection Training Center to train some of the PSC teams. 
 

Page 9 GAO-13-239 Explosive Detection Canines

obtain initial certification to work in their home operating environment. 

During the training mission, the evaluator uses a checklist as a guide to 

determine if a canine team should be certified. Some items on the 

checklist are considered critical, and the canine team must demonstrate 

those necessary skills in order to be certified. After initial certification, 

canine teams are evaluated on an annual basis to maintain certification.

During the conventional explosives detection evaluation, canine teams 

must demonstrate their ability to detect all the explosive training aids15 the 

canines were trained to detect in five search areas.16 The five search 

areas are randomly selected among all the possible areas, but according 

to CTES, include the area that is most relevant to the type of canine team 

(e.g., teams assigned to airports will be evaluated in areas such as 

aircraft and cargo).17 Canine teams must find a certain percentage of the 

explosive training aids to pass their annual evaluation. In addition, a 

specified number of nonproductive responses (NPR)—when a canine 

responds to a location where no explosives odor is present—are allowed 

to pass an evaluation and maintain certification. After passing the 

conventional evaluation, PSC teams are required to undergo an 

additional annual evaluation that includes detecting explosives on a 

person, or being carried by a person. PSC teams are tested in different 

locations within the sterile area of an airport.18 A certain number of 

persons must be detected, and a specified number of NPRs are allowed 

for PSC certification.

 

15An explosive training aid is any explosive used to test and train a canine in explosives 

detection.

16TSA deemed details of the evaluation process, including the specific number and type of 

explosives as SSI. 

17TSA deemed details on the specific number and type of search areas as SSI. 

18The sterile area of an airport is the portion in an airport, defined in the airport’s security 

program, that provides passengers access to boarding aircraft and to which the access 

generally is controlled by TSA through the screening of persons and property. See 49 

C.F.R. § 1540.5.
 

Page 10 GAO-13-239 Explosive Detection Canines

TSA collects and uses key canine program data in its Canine Website 

System, a central management database, but it could better analyze 

these data to identify program trends. Through CWS, TSA captures the 

amount of time canine handlers spend on proficiency training as well as 

screening for explosives, among other functions.19 Table 2 highlights 

some of the key data elements included in CWS.

Table 2: Examples of Data Elements Recorded in CWS

Data element Description

Training minutes • Canine handlers record time spent conducting training to ensure canine teams maintain 

proficiency in detecting explosives odor.

• TSA requires canine teams to conduct 240 proficiency training minutes every 4 weeks (month) 

and for handlers to record training minutes in CWS within 48 hours.

Utilization minutes • LEO teams record time spent patrolling transportation terminals, searching for explosives odor in 

railcars and buses, for example, and screening air cargo.

• TSI teams record time spent screening cargo, which is their primary responsibility.

• TSA requires canine handlers to record utilization minutes in CWS within 48 hours.

Certification rates • CTES evaluators record the results (certified or decertified) of annual canine team evaluations.

• Certified teams are canine teams that passed their annual evaluation and are certified to search 

for explosives.

• Decertified teams are canine teams that failed their annual evaluation and are limited to training 

and providing mobile deterrence.

Short notice assessments • Field canine coordinators (FCC) administer short notice assessments—covert tests to assess 

canine teams’ level of operational effectiveness—on two canine teams within each participating 

agency they oversee each year.

• FCCs are required to document results of short notice assessments, and handlers are required 

to record results, in CWS.

Final canine responses • Canine handlers record final canine responses—instances when a canine sits, indicating to its 

handler that it detects explosives odor.

• Canine handlers are instructed to document final canine responses into CWS and submit swab 

samples to TSA’s Canine Explosives Branch to be analyzed for explosives odor.

Source: GAO using TSA documentation.

 

19TSA also collects data on PSC teams, such as training and utilization minutes, and 

number of final canine responses. However, as of September 2012, PSC data have not 

yet been incorporated into CWS. According to TSA officials, the agency plans to 

incorporate PSC data in CWS in March 2013 after enhancements to the system are 

completed.

TSA Collects and 

Uses Data to Track 

Canine Program 

Performance, but 

Could Better Analyze 

These Data to Identify 

Program Trends
 

Page 11 GAO-13-239 Explosive Detection Canines

NCP uses CWS data to track and monitor canine teams’ performance. 

Specifically, FCCs review CWS data to determine how many training and 

utilization minutes canine teams are conducting on a monthly basis. NCP 

management also analyzes CWS data to determine, for example, how 

many canine teams are certified in detecting explosive odors, as well as 

the number of teams that passed short notice assessments. However, 

TSA has not fully analyzed the performance data it collects in CWS to 

identify program trends and areas that are working well or in need of 

corrective action. Such analyses could better position TSA to determine 

canine teams’ proficiency, guide future deployment efforts, and help 

ensure that taxpayer funds are being used effectively.

TSA tracks the number of training minutes canine teams conduct on a 

monthly basis, as well as the types of explosives and search areas used 

when training, to ensure teams maintain their proficiency in detecting 

explosive training aids. However, TSA does not analyze training minute 

data over time (from month to month) and therefore is unable to 

determine trends related to canine teams’ compliance with the 

requirement. On the basis of our analysis of TSA’s data, we determined 

that some canine teams were repeatedly not in compliance with TSA’s 

240-minute training requirement, and identified differences in the rate of 

compliance between TSI and LEO teams.

According to senior NCP officials, reasons canine teams may not meet 

the requirement include the canine or handler taking leave, sometimes as 

a result of sickness or injury, and participating in an annual evaluation, 

among other reasons. While these circumstances may lead to a team not 

completing the required minutes certain months during a year, our 

analysis further revealed that a certain number of canine teams did not 

meet the training requirement for a more extended period, at least 6 

months during the period analyzed. In light of this broader trend, NCP 

officials agreed that it would be useful to monitor compliance with training 

requirements over time to ensure canine teams maintain their proficiency 

in detecting explosives odor and stated that this information was 

previously unknown to TSA until we brought it to its attention. Analyzing 

the existing training data could help alert TSA to trends in noncompliance 

that could assist the agency in identifying canine team deficiencies and 

areas in need of corrective action. Specifically, such analyses could be 

used by program managers to place the canine handlers who do not meet 

the training requirement on a performance improvement plan, or 

ultimately remove the handlers from the canine program, among other 

actions.

Training Minutes
 

Page 12 GAO-13-239 Explosive Detection Canines

TSA tracks and monitors on a monthly basis the number of utilization 

minutes canine teams conduct searching for explosives, screening air 

cargo, and serving as a deterrent. TSA also collects monthly data on the 

amount of cargo TSI air cargo teams screen in accordance with the 

agency’s requirement, but hasn’t analyzed these data over time to 

determine if, for example, changes are in needed in the screening 

requirement or the number of teams deployed. Our analysis of CWS 

utilization data for the period from May 2011 through April 2012 showed 

that LEO teams consistently reported greater levels of monthly utilization 

minutes than TSI teams, and that on average, from September 2011 

through July 2012, TSI air cargo teams exceeded their monthly screening 

requirement. However, according to senior NCP officials, it is difficult to 

compare utilization rates directly because LEO and TSI teams record 

utilization minutes differently. LEO teams report their utilization minutes 

based on the amount of time they spend patrolling transportation 

terminals, searching baggage and vehicles, and screening air cargo, 

among other things. TSI teams, on the other hand, report their utilization 

minutes based on the time spent primarily screening air cargo.

According to senior NCP officials, the differences in how utilization 

minutes are recorded explains why utilization minutes vary so widely 

between LEO and TSI teams. While variances exist in utilization minutes 

for canine teams, opportunities exist to determine whether LEO and TSI 

teams are being utilized effectively. Unlike TSA’s monthly 240-minute 

training requirement, there is no minimum monthly canine utilization 

requirement to help ensure that canine teams are effectively utilized. 

According to senior NCP officials, the agency is considering whether a 

minimum requirement for, and a consistent definition of, utilization 

minutes should be applied to LEO and TSI teams in response to our 

review. In the absence of a consistent definition of utilization minutes or 

goals for utilization, it will be difficult for TSA to determine whether canine 

teams are being utilized effectively. Analysis of utilization minutes in light 

of stated goals could help TSA determine where LEO and TSI canine 

teams are most effectively utilized and could leverage such analysis to 

drive future deployment efforts.

In addition to capturing utilization minutes, TSA also collects and 

analyzes data monthly on the amount of cargo TSI air cargo canine 

teams screen in accordance with the agency’s requirement. However, it is 

unclear how the agency uses this information to identify trends to guide 

longer-term future program efforts and activities. Our analysis of TSA’s 

cargo screening data from September 2011 through July 2012 showed 

that TSI air cargo teams nationwide generally exceeded their monthly 

Utilization Minutes
 

Page 13 GAO-13-239 Explosive Detection Canines

requirement to screen air cargo placed on passenger aircraft. This 

suggests that TSA could increase the percentage of air cargo it requires

canine teams to screen, or redeploy additional TSI air cargo teams. For 

example, while TSI air cargo teams have generally met or exceeded their 

monthly screening requirement, as of September 2012, the agency has 

yet to deploy all of its 120 TSI air cargo teams for which funding is 

available. However, TSA has not utilized the trends in cargo screening 

data to guide agency decision making as to whether the current and 

planned deployment number of TSI teams by location is appropriate. 

Three of the four supervisory TSI officials we interviewed stated that 

staffing levels of TSI teams were sufficient. However, one supervisory TSI 

official stated that his TSI staffing level was more than double what was 

needed to meet TSA’s screening requirement and provide adequate 

coverage for the airport.20 However, TSA plans to deploy additional TSI 

teams to this airport in the near future. As TSA continues to roll out TSI 

air cargo teams to reach its goal of 120 teams nationwide for which it has 

funding, an analysis of utilization data could better inform agency decision 

makers regarding future TSI air cargo screening requirements, and 

number of canine team deployments by location.

TSA tracks the number of certified and decertified canine teams, but is 

unable to analyze these data to identify trends in certification rates 

because these data were not consistently tracked and recorded prior to 

2011. Our analysis of CWS certification data revealed that approximately 

the same percentage of LEO and TSI teams were TSA certified in 2011 

and 2012. While the certification data show a high percentage of certified 

canine teams for the time periods analyzed, it is unclear whether 

certifications rates have changed over time for LEO and TSI canine 

teams because reliable data for older periods of time were not available.

According to TSA officials, while LEO certification rates have remained 

constant for a 2-year time period, TSI certification rates have increased 

substantially since 2008, when TSI teams were initially deployed. TSA 

officials attributed the initially low TSI certification rates to lack of 

management support and limited availability of explosive training aids. 

However, we could not determine what, if any, variances existed in the 

 

20TSI air cargo teams at this particular airport exceeded TSA’s screening requirement 

during all 11 months of data we analyzed.

Certification Rates
 

Page 14 GAO-13-239 Explosive Detection Canines

certification rates among LEO and TSI teams over time because CTES 

reported it was unable to provide certification rates by type of canine team 

for calendar years 2008 through 2010. According to CTES, the agency 

recognizes this deficiency and is in the process of implementing 

procedures to address data collection, tracking, and record-keeping 

issues. It will be important for TSA to continue to capture and analyze 

these data to understand the differences that may exist between LEO and 

TSI canine teams; how these differences may affect their effectiveness; 

and what steps, if any, need to be taken to address any differences.

To help provide reasonable assurance that canine teams are proficient in 

detecting explosives odor, NCP conducts and collects information on

covert tests conducted by FCCs that assess canine teams’ operational 

effectiveness in detecting and responding to possible explosives, which 

TSA refers to as short notice assessments. However, TSA has not 

analyzed the results of these assessments beyond the pass and fail rate, 

which limits NCP’s ability to determine the effectiveness of its canine 

teams. Furthermore, these assessments were suspended in May 2012 

because of FCC staffing shortages. NCP began conducting short notice 

assessments in April 2011, and FCCs conducted 159 short notice 

assessments in 2011.21 While these tests can be helpful in identifying 

canine deficiencies, without analyzing the results of these tests to 

determine if there are any search areas or type of explosives in which 

canine teams are more effective compared with others, and what, if any, 

training may be needed to mitigate deficiencies, TSA is missing an 

opportunity to fully utilize them. Resuming and analyzing the results of 

short notice assessments will provide TSA with additional information on 

the effectiveness of its canine teams in detecting explosives odor, 

including determining the conditions under which canine teams are most 

or least effective. According to NCP officials, TSA is in the process of 

hiring 10 additional FCCs and expects all 10 will be employed in early 

2013, at which time NCP plans to resume the assessments, and analyze 

the results.

 

21TSA deemed the specific number of canine teams that passed and failed short notice 

assessments as SSI.

Short Notice Assessments
 

Page 15 GAO-13-239 Explosive Detection Canines

Our analysis of final canine responses and data on corresponding swab 

samples used to verify the presence of explosives odor revealed that 

canine teams are not submitting swab samples to NCP’s Canine 

Explosives Branch, which is an important component of TSA’s quality 

assurance process. In March 2011, TSA issued guidance to FCCs 

instructing canine handlers on how to collect and submit swab samples of 

final responses to CEB to verify the presence of explosives odor. Such 

samples can confirm canines are effectively detecting explosives odor, 

although there are limitations to taking swab samples, and a sample that 

does not confirm the presence of odor does not necessarily mean the 

canine falsely detected explosives odor (e.g., the sample may have been 

taken from the wrong part of the item). The purpose of the guidance was 

to develop a standardized process of collecting swab samples to 

determine canine teams’ effectiveness in detecting explosives odor. 

However, we found that canine handlers did not always submit swab 

samples. Specifically, we determined that the number of swab samples 

sent by canine handlers to TSA’s CEB for scientific review was far lower 

than the number of final canine responses recorded in CWS. For 

instance, in 2011, of the total number of final canine responses recorded 

in CWS, LEO and TSI canine teams submitted swab samples for 8 

percent of the final responses to CEB for scientific study after the 

guidance was issued.22 NCP stated that 49 percent of the final canine 

responses entered in CWS were improperly or incorrectly recorded by 

canine handlers, and the remaining 51 percent of cases did not have to 

be submitted to CEB for scientific study since submission under the 

guidance was not a requirement. However, NCP officials agreed that 

tracking and scientifically measuring final canine responses could help 

NCP measure canine teams’ effectiveness in detecting explosives in their 

operational environments, such as an airport or air cargo facility. 

According to these officials, the agency will take steps to require canine 

handlers to submit swab samples to CEB. For example, the requirement 

will be added to NCP’s Standard Operating Practices and Procedures, 

which is expected to be issued by March 2013. In addition, senior NCP 

officials told us the agency will clarify this policy with program supervisors 

and canine handlers, and modify CWS to more easily allow handlers to 

document when a swab sample is collected and sent to CEB for study. If 

 

22TSA deemed the specific number of final canine responses and swab samples as SSI.

Final Canine Responses
 

Page 16 GAO-13-239 Explosive Detection Canines

these steps are implemented effectively, the issues we raised will be 

addressed.

Of the final canine responses that could have been submitted to CEB, 

NCP reported that almost half were resolved locally by identifying sources 

of odors consistent with those canines are trained to detect. However, 

NCP could not determine the resolution of the remaining cases that were 

not submitted to CEB, and for which no final resolution was documented 

at the local level. As our analysis has shown, capturing and analyzing 

additional information on final canine responses over time is an important 

quality assurance step and may help TSA and other interested 

stakeholders to more accurately determine the extent to which canine 

teams are effectively detecting explosive materials in real world 

scenarios.

Standards for Internal Control in the Federal Government requires 

agencies to ensure that ongoing monitoring occurs during the course of 

normal operations to help evaluate program effectiveness.23 TSA collects 

and uses key canine team performance data, but it has not fully analyzed 

these data, consisting of training and utilization minutes, certification 

rates, and results of short notice assessments and final canine 

responses. Such analyses could help TSA management identify program 

trends to better target resources and activities based on what is working 

well and what may be in need of corrective action. According to NCP 

officials, while FCCs review training and utilization data on a monthly 

basis, NCP does not have the time or staff resources to analyze such 

data over time. However, canine handlers collectively spend a significant 

amount of time providing the data to NCP, and such analyses could better 

position TSA to determine the proficiency of its canine teams, guide future 

deployment efforts, and help ensure taxpayer funds are being used 

effectively.

 

23GAO/AIMD-00-21.3.1. 
 

Page 17 GAO-13-239 Explosive Detection Canines

TSA’s 2012 Strategic Framework calls for the deployment of PSC teams 

based on risk; however, airport stakeholder concerns about the 

appropriateness of TSA’s response resolution protocols for these teams 

have resulted in PSC teams not being deployed to the highest-risk airport 

terminals and concourses. Moreover, TSA began deploying PSC teams 

prior to determining the teams’ operational effectiveness and before 

identifying where within the airport these teams could be most effectively 

utilized to screen passengers.

In April 2011, TSA began deploying PSC teams to airports terminals and 

concourses, and plans to deploy all 120 PSC teams for which it has 

funding by the end of calendar year 2013.24 TSA’s Strategic Framework 

calls for the deployment of PSC teams based on risk; however, we found 

that PSC teams have not been deployed to the highest-risk airport 

terminals and concourses based on TSA’s high-risk list. TSA officials 

stated that PSC teams were not deployed to the highest-risk terminals 

and concourses for various reasons, including concerns from an airport 

law enforcement association about TSA’s decision to deploy PSC teams 

with civilian TSI handlers and the appropriateness of TSA’s response 

resolution protocols. These protocols require the canine handler to be 

accompanied by two additional personnel that may, but not always, 

include a law enforcement officer. According to representatives from an 

airport law enforcement association, these protocols are not appropriate 

for a suicide bombing attempt requiring an immediate law enforcement 

response.

According to TSA officials, the lack of agreed-upon response resolution 

protocols with local law enforcement officials has complicated efforts to 

introduce PSCs at some airports. For example, seven airport operators 

have declined the deployment of PSC teams because of concerns 

 

24For the purposes of this report, “airport terminal” refers to the entire terminal complex 

and is inclusive of both the public and the sterile sides, whereas “concourse” refers to the 

sterile portion of the terminal where passenger gates are located. Details on how TSA 

developed its airport risk ranking and the rank of specific airports were deemed SSI by 

TSA. 

TSA Has Not 

Deployed Passenger 

Screening Canine 

Teams to the HighestRisk Airports and Did 

Not Determine Their 

Effectiveness Prior to 

Deployment 

TSA Has Deployed PSC 

Teams to Airports; 

However, PSC Teams Have 

Not Been Deployed to the 

Highest-Risk Terminals 

and Concourses
 

Page 18 GAO-13-239 Explosive Detection Canines

expressed by airport stakeholders regarding TSA’s response resolution 

protocols and whether they are adequate for dealing with potential 

threats, such as suicide bombers.25 According to TSA’s Assistant 

Administrator for the Office of Security Operations, TSA’s goal is to 

deploy PSC teams to airports where there is a supportive working 

environment, and accordingly, TSA does not generally require that PSC 

teams be accepted for use at an airport. However, TSA reported that if it 

identified a specific threat to an airport, it would use its authority to deploy 

the PSC teams regardless of any airport stakeholder opposition to the 

decision, but it has not had to do so.

Representatives from three major aviation industry associations we 

interviewed support using PSC teams in airports, but also raised 

concerns surrounding TSA’s PSC response resolution protocols. These 

concerns were primarily related to TSA deploying PSCs with unarmed 

TSI handlers rather than LEO handlers because of the differences in their 

abilities to respond to a potential threat, such as a suicide bomber.26

According to TSA officials, TSA deployed PSCs with TSI handlers in a 

manner consistent with the report of the Committee on Appropriations of 

the House of Representatives, which accompanies the committee’s DHS 

fiscal year 2013 appropriations bill.27 Officials from an association 

representing airport law enforcement officers recommended that PSC 

teams be accompanied by three LEOs, among other reasons, to help 

reduce the potential liability and response times associated with 

responding to a possible suicide bomber. Representatives from an 

association representing airport law enforcement officers and TSA 

officials stated that they have been working together to try to address 

concerns regarding TSA’s response resolution protocols; however, they 

have not been able to reach an agreement on this issue, as of September 

2012. TSA maintains that PSCs are similar to the agency’s other 

 

25In one instance, the airport authority declined the deployment of PSC teams because 

the airport was in the process of constructing a new terminal and could not accommodate 

the canine teams.

26Unlike LEOs, TSIs are unarmed civilians with no authority to take law enforcement 

action (e.g., arrest or detain). 

27See H.R. Rep. No. 112-492, at 71 (May 23, 2012) (providing, among other things, that 

the committee included funding in its bill (H.R.5855, 112th Cong. (2d Sess. 2012)) for an 

additional 24 canine teams for the aviation environment, as well as an additional 26 teams 

in the surface environment). As of January 2013, a fiscal year 2013 appropriations act for 

DHS has not been enacted.
 

Page 19 GAO-13-239 Explosive Detection Canines

screening tools used to detect explosives, and thus a final response from 

a PSC should trigger the same type of law enforcement response to 

potential threats identified through other screening measures.28

Additionally, TSA officials stated that airport operators are required to 

adopt and maintain TSA-approved security programs that, among other 

things, provide for a law enforcement presence and capability at the 

airport that is adequate to ensure the safety of passengers, and that their 

current approach of using LEOs in support of TSI-led PSC operations is 

consistent with this requirement.29

However, TSA’s decision to deploy PSC teams only to airports where 

they would be willingly accepted by stakeholders has resulted in PSC 

teams not being deployed to the highest-risk airport terminals and 

concourses on its high-risk list. Given that PSC teams cost $164,000 

annually per team, TSA is not using the teams in the most cost-effective 

manner to enhance security if it is limited to deploying them at lower-risk 

airports and concourses. Moreover, PSC teams at the two high-risk 

airports we visited are not being used for passenger screening because 

TSA and the local law enforcement agencies have not reached 

agreement on the PSC response resolution protocols. Thus, rather than 

being utilized for their intended primary purpose—passenger screening—

PSC teams are being used to screen air cargo or conduct training. TSA 

officials agreed that the decision to defer to airport stakeholders’ 

willingness to have PSC teams deployed to their airports has resulted in 

PSCs not being optimally utilized. While we recognize the value of 

obtaining airport stakeholder buy-in, deploying PSC teams to the highestrisk airport terminals and concourses in accordance with its Strategic 

Framework, could help TSA better deploy future PSC teams in a costeffective manner, and utilize the PSC teams that have already been 

deployed for their intended purposes to enhance security.

 

28TSA employs various measures, including canines, to meet its statutory mandate to 

screen all passengers and property for explosives and other prohibited items prior to 

permitting them transport on passenger or cargo aircraft. See 49 U.S.C. § 44901. 

29See 49 C.F.R. §§ 1542.101, 1542.103(12), 1542.215-1542.217. 
 

Page 20 GAO-13-239 Explosive Detection Canines

TSA began deploying PSC teams in April 2011 prior to determining the 

teams’ operational effectiveness and before identifying where within the 

airport environment these teams would be most effectively utilized. 

According to TSA officials, operational assessments did not need to be 

conducted prior to their deployment because canines were being used to 

screen passengers by other entities, such as airports in the United 

Kingdom, and TSA leadership focused on initially deploying PSC teams 

to a single location within the airport—the sterile area—because it thought

it would be the best way to foster stakeholders’ acceptance of the teams. 

However, in June 2012, DHS S&T and TSA began conducting operational 

assessments to help demonstrate the effectiveness of PSC teams, and 

plans to complete additional PSC effectiveness testing in 2013 at 

additional airports. To assess the effectiveness of PSC teams in detecting 

explosives odor, TSA and DHS S&T are assessing their capabilities 

based on several factors.30 On the basis of these results, DHS S&T and 

TSA’s NCP recommended that the assessment team conduct additional 

testing and that additional training and guidance be provided to canine 

teams.31

As part of our review, we visited two airports at which PSC teams have 

been deployed and observed training exercises in which PSC teams 

accurately detected explosives odor (i.e., positive response), failed to 

detect explosives odor (i.e., miss), and falsely detected explosives odor 

(i.e., non productive response). See the hyperlink in the note for figure 2 

for videos of training exercises at one airport showing instances when 

PSC teams detected, and failed to detect explosives odor.

 

30Details on the PSC assessment factors were deemed SSI by TSA.

31Since the initial test was conducted at an airport with PSC teams trained by Auburn 

University, the assessment team recommended that similar PSC capability assessments 

be conducted at airports with CTES-trained PSC teams.

TSA Plans to Complete 

PSC Effectiveness 

Assessments in 2013; 

Initial Results Indicate 

Performance Challenges
 

Page 21 GAO-13-239 Explosive Detection Canines

Figure 2: Video Stills Showing Passenger Screening Canine (PSC) Teams Training in Airport Terminal, June 2012

Note: To view the full videos, please click on hyperlink to view, Part 1, Part 2.

On the basis of the results of DHS’s assessments, TSA could have 

benefited from completing operational assessments of PSCs before 

deploying them on a nationwide basis to determine whether they are an 

effective method of screening passengers in the U.S. airport environment. 

TSA officials stated that operational assessments did not need to occur 

prior to deployment because the agency does not consider PSCs a new 

screening method. Moreover, according to DHS S&T’s Canine Explosives 

Detection Project Manager, some PSC teams needed to be deployed 

operationally at airports before their effectiveness could be assessed. 

While we agree that some PSC teams needed to be deployed for 

operational assessments to occur, this testing could have been 

completed before TSA started deploying additional PSC teams on a 
 

Page 22 GAO-13-239 Explosive Detection Canines

nationwide basis beyond the three pilot site airports. As discussed earlier, 

TSA plans to deploy all 120 teams for which it has funding by the end of 

calendar year 2013. Best practices for program performance call for 

agencies to use performance information to assess efficiency, identify 

performance gaps, and ensure intended goals are met.32 We previously 

reported on the need for TSA to validate detection methods before 

deploying new screening methods. For example, TSA proceeded with 

deploying its Screening of Passengers by Observation Techniques 

behavior detection program on a nationwide basis before determining 

whether the list of passenger behaviors and appearances underpinning 

the program were scientifically validated, and whether these techniques 

could be applied on a large scale for counterterrorism purposes in an 

airport environment. Assessing the effectiveness of PSCs in the 

operational environment could help provide TSA with reasonable 

assurance that PSCs are effective in identifying explosives odor on 

passengers and provide an enhanced security benefit.

Additionally, TSA has not completed an assessment to determine where 

within the airport PSC teams would be most effectively utilized. According 

to TSA’s Assistant Administrator for the Office of Security Operations, to 

alleviate airport stakeholders’ concerns regarding TSA’s response 

resolution protocols, the agency initially deployed PSC teams to the 

sterile areas, thereby enabling TSA to gather data on the value of PSC 

teams in the airport environment while reducing the likelihood of a final 

response from a PSC resulting in the closure of a checkpoint since an 

individual has already passed through several layers of screening when 

entering the sterile area. However, aviation stakeholders we interviewed, 

raised concerns about this deployment strategy, stating that PSC teams 

would be more effectively utilized in non sterile areas of the airport, such 

as curbside or in the lobby areas. Specifically, two of the three aviation 

industry representatives we interviewed stated that deploying PSC teams 

to the sterile area, rather than the public area, could limit their ability to 

detect and deter potential suicide bombers entering the airport. According 

to TSA’s Assistant Administrator for the Office of Security Operations, 

TSA initially deployed PSC teams to the sterile area because it thought it 

 

32DHS’s National Infrastructure Protection Plan, and our previous work on program 

assessment state that performance metrics and associated program evaluations are 

needed to determine if a program works and to identify adjustments that may improve its 

results. DHS, National Infrastructure Protection Plan: Partnering to Enhance Protection 

and Resiliency, GAO-11-739SP, and GAO/GGD-96-118. 
 

Page 23 GAO-13-239 Explosive Detection Canines

would foster stakeholders’ acceptance of PSC teams and does not 

generally consider the deployment of PSC teams to the sterile area as a 

permanent or most optimal use of the PSC teams. Instead, the agency 

maintains that the best use of PSC teams is in the public area or at the 

screening checkpoint.

TSA has since deployed PSC teams to the passenger screening 

checkpoints. According to NCP officials, the agency is also considering 

providing some PSCs to LEOs to work on the public side of the airport. 

However, DHS S&T does not plan to assess the effectiveness of PSCs 

on the public side, beyond the checkpoint, since TSA was not planning to 

deploy PSCs to the public side of the airport when DHS S&T designed its 

test plan. Comprehensive operational assessments that include a 

comparison of PSC teams in both the sterile and public areas of the 

airport could help TSA determine if it is beneficial to deploy PSCs to the 

public side of airports, in addition to or in lieu of the sterile area and 

checkpoint. Moreover, Standards for Internal Control in the Federal 

Government stresses the need for agencies to provide reasonable 

assurance of the effectiveness and efficiency of operations, including the 

use of the entity’s resources.33

During the June 2012 assessment of PSC teams’ effectiveness, TSA 

conducted one of the search exercises with three conventional canine 

teams. Although this assessment was not intended to be included as part 

of DHS S&T and TSA’s formal assessment of PSC effectiveness, the 

results of this assessment suggest, and TSA officials and DHS S&T’s 

Canine Explosives Detection Project Manager agreed, that a systematic 

assessment of PSCs with conventional canines could provide TSA with 

information to determine whether PSCs provide an enhanced security 

benefit compared with conventional LEO aviation canine teams that have 

already been deployed to airport terminals. An assessment would help 

clarify whether additional investments for PSC training are warranted. 

Moreover, since PSC teams are trained in both conventional and 

passenger screening methods, TSA could decide to convert existing PSC 

teams to conventional canine teams, thereby limiting the additional 

resource investments associated with training and maintaining the new 

PSC teams. Additionally, as previously discussed, should TSA decide to 

deploy some of the PSCs scheduled to be deployed in 2013 with LEO 

 

33GAO/AIMD-00-21.3.1. 
 

Page 24 GAO-13-239 Explosive Detection Canines

handlers, rather than TSI handlers, TSA could further reduce program 

costs and increase costs savings, as a PSC team led by a LEO handler 

could cost TSA $53,000 annually per team, compared with $164,000, the 

current annual cost per TSI-led PSC team. Moreover, TSA officials and 

aviation industry stakeholders stated that deploying PSCs with 

experienced LEO canine handlers could reduce the learning curve 

associated with becoming a PSC handler.

Securing the nation’s vast and diverse transportation system is a 

challenging task that is complicated by the ever-changing and dynamic 

threat environment. TSA’s National Canine Program is an important and 

growing component of its efforts to achieve this goal. However, a 

systematic analysis of key program data that TSA currently collects, 

consisting of training and utilization minutes, certification rates, results of 

short notice assessments (covert tests), and canine responses to the 

possible presence of explosives, could better position TSA to identify 

program trends to better target resources and activities based on what is 

working well and what may be in need of corrective action. In addition, a 

comprehensive assessment of passenger screening canines and 

conventional canine teams in all areas of the airport could provide TSA 

with greater assurance that passenger screening canine teams are a 

cost-effective screening tool and are being optimally utilized. Such 

analyses could help TSA determine the appropriate number, type, and 

placement of canine teams needed to best secure the U.S. transportation 

system. Finally, if effective, deploying passenger screening canine teams 

to the highest-risk airport terminals and concourses will provide TSA with 

greater assurance that the PSC teams are deployed in a manner that 

targets the most pressing security needs in a cost-effective manner.

To help ensure TSA analyzes canine team data to identify program 

trends, and determines if PSC teams provide an added security benefit to 

the civil aviation system, and if so, deploys PSC teams to the highest-risk 

airports, we recommend that the Administrator of the Transportation 

Security Administration direct the Manager of the NCP to take the three 

following actions:

• Regularly analyze available data to identify program trends and areas 

that are working well and those in need of corrective action to guide 

program resources and activities. These analyses could include, but 

not be limited to, analyzing and documenting trends in proficiency 

training, canine utilization, results of short notice assessments (covert 

Conclusions 

Recommendations for 

Executive Action
 

Page 25 GAO-13-239 Explosive Detection Canines

tests) and final canine responses, performance differences between 

LEO and TSI canine teams, as well as an assessment of the optimum 

location and number of canine teams that should be deployed to 

secure the U.S. transportation system.

• Expand and complete testing, in conjunction with DHS S&T, to assess 

the effectiveness of PSCs and conventional canines in all airport 

areas deemed appropriate (i.e., in the sterile area, at the passenger 

checkpoint, and on the public side of the airport) prior to making 

additional PSC deployments to help (1) determine whether PSCs are 

effective at screening passengers, and resource expenditures for PSC 

training are warranted, and (2) inform decisions regarding the type of 

canine team to deploy and where to optimally deploy such teams 

within airports.

• If PSCs are determined to provide an enhanced security benefit, TSA 

should coordinate with airport stakeholders to deploy future PSC 

teams to the highest-risk airports, and ensure that deployed PSC 

teams are utilized as intended, consistent with its statutory authority to 

provide for the screening of passengers and their property.

We provided a draft of the sensitive version of this report to the 

Departments of Defense and Homeland Security on November 13, 2012, 

for their review and comment. DOD did not provide comments. DHS 

provided written comments, which are reprinted in appendix III. DHS 

concurred with all three recommendations, and identified actions taken or 

planned to implement the recommendations.

DHS concurred with the first recommendation, that TSA regularly analyze 

canine team data to identify program trends, and areas working well and 

those in need of correction action. DHS stated that NCP is planning to 

reestablish yearly comprehensive assessments of canine teams’ 

compliance with program requirements, and implement corrective action, 

when necessary. Furthermore, TSA is upgrading CWS, and in March 

2013 will be able to capture data on PSC teams, as it currently does for 

conventional canine teams. We support TSA’s actions to implement these 

yearly assessments, as well as the upgrade to CWS to collect information 

on PSC teams. We believe it is important for TSA to also review its 

analysis of canine teams’ performance screening air cargo in order to 

inform future decisions on the percentage of air cargo that it requires 

canine teams to screen, as well as the number of TSI air cargo canine 

teams needed to meet TSA’s air cargo screening requirement. TSA 

should also analyze its data, including results of short notice assessments 

Agency Comments 

and Our Evaluation
 

Page 26 GAO-13-239 Explosive Detection Canines

and final canine responses, to assess canine team performance in order 

to mitigate any explosives detection challenges and determine canine 

teams’ strengths. Such actions, in conjunction with TSA’s planned efforts, 

would meet the intent of the recommendation.

DHS concurred with the second recommendation, to expand and 

complete testing to assess the effectiveness of PSC teams and 

conventional canines in areas of the airport deemed appropriate. DHS 

stated that TSA and DHS S&T will conclude testing of PSC teams in the 

sterile areas of airports in February 2013, and have begun testing PSC 

teams in the public areas of the airports. In addition, TSA will discuss with 

DHS S&T developing testing protocols for conventional canines. We 

support TSA’s actions to assess the effectiveness of PSC teams, and 

encourage TSA to incorporate conventional canines into future testing to 

demonstrate if PSCs provide an enhanced explosives detection benefit 

relative to conventional canines, given their increased cost.

DHS also stated that TSA anticipates deploying all 120 of the PSC teams 

for which it received authorization by the end of calendar year 2013. If 

PSC teams are not proven to be effective based on TSA and DHS S&T’s 

assessments, we strongly encourage TSA to reconsider deploying PSC 

teams for which it has not already allocated or obligated resources. Such 

action, in conjunction with TSA’s planned efforts, would meet the intent of 

the recommendation.

DHS concurred with the third recommendation, to deploy PSC teams to 

the highest-risk airports. DHS stated that TSA will deploy future teams to 

the highest-priority airports as identified by both its operational and riskbased analyses, and it continues to evaluate and modify its risk-based 

analysis as needed. We support TSA’s efforts to deploy PSC teams to the 

highest-risk airports in order to provide an additional layer of security 

where it is most needed, and continue to believe that TSA first needs to

determine if PSCs provide an enhanced security benefit and, if so, 

coordinate such deployments with airport stakeholders. Such action, in 

conjunction with TSA’s planned efforts, should address the intent of the 

recommendation.

DHS also provided technical comments which we incorporated, as 

appropriate.
 

Page 27 GAO-13-239 Explosive Detection Canines

If you or your staff have any questions about this report, please contact 

me at (202) 512-4379 or lords@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made key contributions to this report are 

listed in appendix IV.

Stephen M. Lord

Director, Homeland Security and Justice Issues
Appendix I: TSA Has Taken Actions to 

Enhance Program Training and Evaluation, 

and Research, Development, and Testing

Page 28 GAO-13-239 Explosive Detection Canines

Since our review of the Transportation Security Administration’s (TSA) 

National Canine Program (NCP) in 2008, the agency has taken actions to 

enhance the program in the areas of (1) training and evaluation, and (2) 

research, development, and testing with the DHS Science and 

Technology Directorate (S&T). Table 3 provides an overview of these 

efforts.

Table 3: TSA’s Actions to Enhance NCP

Area TSA action 

Training and evaluation Implementing a course for evaluators to reduce subjectivity and ensure consistency during 

evaluations

Sending its most experienced evaluators to be present at all canine team evaluations

Deploying regional instructors to the field to provide canine teams with hands-on training

Research, development, and testing Operational assessments: implementing explosives odor recognition tests to mitigate canine 

team detection weaknesses identified during operational assessments conducted in the air 

cargo environment

Behavior and genetics: researching behavioral, physiological, and genetic identifiers of a 

successful explosives detection canine

Source: GAO using TSA and DHS S&T documentation.

Training and evaluation. Canine handlers we interviewed in four 

locations (74 of 75 handlers), generally spoke positively of the instruction 

they had received during their training courses and missions. For 

example, some canine handlers cited the hands-on instruction and 

feedback they received from TSA Canine Training and Evaluation Section 

(CTES) evaluators during their training missions as particularly beneficial. 

However, some canine handlers we interviewed (26 of 67 evaluated) 

suggested that TSA seek ways to improve the consistency and objectivity 

of the evaluation process. For example, some canine handlers stated that 

while one evaluator may consider a canine sitting a few feet away from 

the explosive training aid a “fringe” response and count it positively, 

another evaluator would consider the same scenario a nonproductive 

response (NPR). As noted earlier, a specified number of NPRs are 

allowed to pass an evaluation and maintain certification. In July 2011, 

CTES formed a committee comprising various TSA officials and canine 

handlers to conduct a review of its evaluation process. The committee 

suggested creating a “Train the Evaluator” course to reduce 

inconsistencies in the evaluation process. CTES subsequently created an 

evaluation unit, which will be implementing the course on consistently 

applying evaluation guidelines later this calendar year. Furthermore, in 

January 2012, CTES began sending its most experienced evaluators to 

all annual evaluations to help improve the consistency and objectivity of 

Appendix I: TSA Has Taken Actions to 

Enhance Program Training and Evaluation, 

and Research, Development, and Testing
Appendix I: TSA Has Taken Actions to 

Enhance Program Training and Evaluation, 

and Research, Development, and Testing

Page 29 GAO-13-239 Explosive Detection Canines

the evaluation process. Specifically, according to CTES officials, one of 

the two evaluators conducting the evaluation is to be from the evaluation 

unit, which is composed of CTES’s 12 most experienced evaluators. The 

committee supported actions to provide greater consistency during the 

evaluation process but stated that the evaluations are fair, and ultimately 

not the reason for canine teams failing evaluations. Rather, the committee 

cited a lack of local training support for canine teams once they are 

deployed to their home units. As a result, CTES is in the process of 

deploying regional trainers to the field to assist canine teams with 

proficiency training. Thus far, 23 of 27 regional trainers have been 

deployed to the field. CTES planned to deploy all 27 regional trainers by 

December 2012.

Research, development, and testing. Through its Canine Explosives 

Detection Project, DHS S&T is working to enhance TSA canine 

effectiveness through two efforts: (1) conducting operational assessments 

of canine detection capabilities in the air cargo environment, and (2) 

determining the behavioral, physiological, and genetic identifiers of a 

successful explosives detection canine.

Operational assessments: DHS S&T has conducted a series of 

tests assessing the ability of canine teams to detect explosives in 

air cargo.1 During the most recent series of tests, conducted in 

2009 and 2010, DHS S&T determined canines can be an effective 

tool in detecting explosives in the air cargo environment, but 

recommended more frequent and appropriate training.2

DHS S&T and TSA also conducted a pilot test to determine if 

private, or third-party, canine teams could be used by the air cargo 

industry to screen air cargo for the purposes of meeting the 

mandate to screen 100 percent of air cargo.3 According to TSA, 

 

1

DHS S&T has not conducted assessments of TSA canine teams in other transportation 

modes, such as mass transit, according to DHS S&T officials.

2

TSA deemed details on the type of air cargo configurations tested as SSI. 

3

The Implementing Recommendations of the 9/11 Commission Act of 2007, enacted in 

August 2007, mandated that DHS establish a system within 3 years of enactment to 

screen 100 percent of air cargo transported on all passenger aircraft—U.S. and foreign 

flagged—traveling to, from, or within the United States. See Pub. L. No. 110-53. § 

1602(a), 121 Stat. at 266, 477-79 (codified at 49 U.S.C. § 44901(g)).
Appendix I: TSA Has Taken Actions to 

Enhance Program Training and Evaluation, 

and Research, Development, and Testing

Page 30 GAO-13-239 Explosive Detection Canines

the pilot concluded in September 2011, and TSA determined that 

utilizing third-party canine teams to screen air cargo could be a 

viable option, but there would also be challenges, including 

providing the resources needed to maintain oversight of the 

program. TSA leadership is evaluating whether to move forward 

with the implementation of a third-party canine program. Allowing 

the air cargo industry to use canines could increase its ability to 

meet the screening mandate by overcoming challenges we have 

previously reported.4

Behavior and genetics: DHS S&T, in collaboration with a private 

company, Dog Genetics, and the University of Texas, is 

researching behavioral, physiological, and genetic identifiers of a 

successful explosives detection canine. DHS S&T is reviewing the 

history of proven explosives detection canines within NCP and is 

attempting to identify behaviors and DNA markers that are 

indicative a canine will be successful at explosives detection. The 

goal of this research is to allow TSA to better select which canines 

to breed, and which to select for explosives detection training. 

This is a long-term effort and DHS S&T estimates this research 

will be completed in fiscal year 2015.

 

4

See, for example, GAO, Aviation Security: TSA Has Made Progress but Faces 

Challenges in Meeting the Statutory Mandate for Screening Air Cargo on Passenger 

Aircraft, GAO-10-446 (Washington, D.C.: June 28, 2010).
Appendix II: Objectives, Scope, and 

Methodology

Page 31 GAO-13-239 Explosive Detection Canines

This report addresses the following objectives:

(1) What data does TSA have on its canine program, what do 

these data show, and to what extent has TSA analyzed these data 

to identify program trends?

(2) To what extent has TSA deployed passenger screening canine 

teams using a risk-based approach and determined their 

effectiveness prior to deployment?

In addition, this report summarizes the actions TSA has taken to enhance 

its National Canine Program since we issued our last report, in 2008.1

To determine what data TSA has on its canine program, what these data 

show, and the extent to which TSA has analyzed these data to identify 

program trends, we interviewed TSA’s Office of Security Operations 

headquarters and field officials about the type of data they collect and 

how they analyze the data to monitor canine team effectiveness 

consistent with Standards for Internal Control in the Federal 

Government.

2 Specifically, we interviewed canine branch chiefs at 

headquarters who oversee the operations of NCP. We also interviewed 

an area canine coordinator and field canine coordinators, and supervisory 

transportation security inspectors who oversee canine teams in the field. 

Using data from the agency’s Canine Website System (CWS), we 

analyzed training and utilization minutes from May 2011 through April 

2012—the most recent data available at the time of our analysis. We 

compared the number of training minutes canine teams conducted each 

month with TSA’s training requirement documented in its Canine Manual

and cooperative agreements with law enforcement agencies. We 

analyzed the number of minutes canine teams were utilized by type of 

canine team to identify any differences between law enforcement officer 

(LEO) and transportation security inspector (TSI) teams. In addition, we 

collected and reviewed monthly reports on canine team training and 

utilization from an area canine coordinator and field canine coordinators. 

Further, we analyzed certification data from CWS for May 2012—the 

most recent data available at the time of our analysis—to determine the 

number of certified and decertified canine teams by type of team (LEO 

 

1

GAO-08-933R. 

2

GAO/AIMD-00-21.3.1.

Appendix II: Objectives, Scope, and 

Methodology 
Appendix II: Objectives, Scope, and 

Methodology

Page 32 GAO-13-239 Explosive Detection Canines

and TSI). Moreover, we reviewed TSA certification data by type of team 

from January 2011 through August 2012. To assess the reliability of the 

CWS data on canine team training, utilization, and certification, we 

interviewed knowledgeable officials, reviewed the data for obvious errors 

and anomalies, and reviewed documentation. We determined the data 

were sufficiently reliable for our purposes. We also reviewed and 

analyzed the number of final canine responses documented in CWS, and 

corresponding swab samples sent to TSA’s Canine Explosives Branch 

(CEB) to validate canines’ ability to detect explosives odor. Specifically, 

we compared the number of final canine responses recorded in CWS with 

the number of swab samples sent to CEB from the time the guidance was 

issued on collecting swab samples in March 2011 to July 2012—the most 

current data available at the time of our request. We found limitations in 

the final canine response data, as discussed in the report, but we believe 

the data to be sufficiently reliable for generally comparing the number of 

canine responses with the number of swab samples.

To assess the extent TSA deployed passenger screening canines (PSC) 

in a risk-based manner, consistent with TSA’s 2012 Strategic Framework, 

we compared the risk rankings TSA assigned to airport terminals with 

NCP’s September 2012 canine asset spreadsheet—which tracks the 

deployment location of TSA’s canine assets. We also interviewed senior 

TSA and NCP headquarters and field officials to obtain information on the 

extent to which risk and other factors, such as stakeholder concerns, 

were considered when deploying PSC teams. We also reviewed TSA’s 

Recommended Operational Procedures for Canine Screening of 

Individuals to understand the agency’s operational procedures and 

protocols for deploying and resolving final responses by PSC teams. In 

addition, we interviewed PSC handlers at two locations we visited where 

PSCs were initially deployed.3 We also interviewed officials from Amtrak 

police, and three major aviation industry associations—Airport Law 

Enforcement Agencies Network (ALEAN), Airports Council InternationalNorth America (ACI-NA), and American Association of Airport Executives 

(AAAE)—to discuss their views on PSC utilization and response 

protocols. While the results from our interviews are not generalizable to 

all PSC handlers and aviation stakeholders, they provided views on 

TSA’s utilization of PSC teams and protocols for resolving final 

responses.

 

3

In the context of this report, TSA deemed the specific locations we visited as SSI. 
Appendix II: Objectives, Scope, and 

Methodology

Page 33 GAO-13-239 Explosive Detection Canines

To determine the extent to which TSA determined the effectiveness of 

PSC teams, we compared the PSC assessment approach used by TSA 

and DHS S&T with DHS guidance and best practices.4 We also 

interviewed senior TSA and DHS S&T officials to obtain information on 

the extent to which a comprehensive assessment of the effectiveness of 

PSC teams had been completed in the operational environment, including 

determining (1) where within the airport environment (i.e. sterile, 

checkpoint, and public areas) PSC teams would most effectively utilized, 

and (2) whether PSCs provide an added benefit in terms of cost and 

security to conventional canines. Moreover, we reviewed the test results 

from TSA and DHS S&T’s assessment to determine the extent to which 

PSC teams have been proven effective in different areas at the airport, 

consistent with the environments described in TSA’s Recommended 

Operational Procedures for Canine Screening of Individuals and best 

practices in Standards for Internal Control in the Federal Government.

5 In 

addition, we interviewed DHS S&T officials regarding the testing 

methodology, and determined that the results are reliable. We also 

observed PSC teams in their operational environments during our site 

visits, and served as decoys—passengers with concealed explosive 

training aids—during PSC training exercises in airport terminals, and 

videotaped the PSC teams. We reviewed canine team costs data, as of 

January 2012, to identify the difference in costs among the various types 

of canine teams. To assess the reliability of the canine team cost data, we 

interviewed knowledgeable officials, reviewed the data for obvious errors 

and anomalies, and reviewed documentation. We determined the data 

were sufficiently reliable for our purposes.

To summarize the actions TSA has taken to enhance NCP since our 

2008 review, we reviewed TSA’s canine team training and evaluation 

procedures. We discussed these procedures with trainers, instructors, 

and evaluators at TSA’s CTES. In addition, we observed canine training 

at CTES at Lackland Air Force Base in Texas, as well as Auburn 

University’s Canine Detection Training Center in Alabama because this is 

where some PSC teams were trained. We discussed canine training and 

evaluation practices with the Department of Defense’s Military Working 

Dog Program, and the Scientific Working Group on Dog and Orthogonal 

 

4

DHS, National Infrastructure Protection Plan: Partnering to Enhance Protection and 

Resiliency, GAO-11-646SP, and GAO/GGD-96-118. 

5

GAO/AIMD-00-21.3.1.
Appendix II: Objectives, Scope, and 

Methodology

Page 34 GAO-13-239 Explosive Detection Canines

Detector Guidelines. Furthermore, we conducted site visits to the three 

locations with the greatest number of deployed canine teams in the mass 

transit, airport, and air cargo environments to observe canine teams 

training in their operational environments and interview LEO and TSI 

canine handlers.6 We also observed canine teams and interviewed 

handlers during a site visit we conducted to a fourth location so we could 

observe additional PSC teams. While the results from our interviews are 

not generalizable to all canine handlers, they provided a range of 

perspectives on canine handlers’ views on the training and evaluation 

process. We reviewed DHS S&T’s efforts to conduct research, 

development, and testing to enhance canine effectiveness through its 

Canine Explosives Detection Project. Specifically, we reviewed 

agreements and contracts with project participants to develop homemade 

explosive training aids to broaden threat detection, evaluate the 

effectiveness of canine teams in detecting explosives in air cargo, and 

conduct research on breeding and genetics to select canines best suited 

for explosives detection. We also discussed the status of these efforts 

with DHS S&T officials.

We conducted this performance audit from January 2012 through January 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

 

6

In the context of this report, TSA deemed the specific locations we visited as SSI. 
Appendix III: Comments from the Department 

of Homeland Security

Page 35 GAO-13-239 Explosive Detection Canines

Appendix III: Comments from the 

Department of Homeland Security
Appendix III: Comments from the Department 

of Homeland Security

Page 36 GAO-13-239 Explosive Detection Canines
Appendix III: Comments from the Department 

of Homeland Security

Page 37 GAO-13-239 Explosive Detection Canines
Appendix III: Comments from the Department 

of Homeland Security

Page 38 GAO-13-239 Explosive Detection Canines
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 39 GAO-13-239 Explosive Detection Canines

Stephen M. Lord, (202) 512-4379 or lords@gao.gov

In addition to the contact named above, Steve Morris, Assistant Director, 

and Lisa Canini, Analyst-in-Charge, managed this review. Josh Diosomito 

and Michelle Woods made significant contributions to the work. Lydia 

Araya, Chuck Bausell, Michele Fejfar, Richard Hung, Thomas F. 

Lombardi, Douglas Manor, Linda Miller, Erin O’Brien, Jessica Orr and 

Jessica Smith also contributed to this report.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(441125)
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