Supply Chain Security: CBP Needs to Enhance Its Guidance and Oversight of High-Risk Maritime Cargo Shipments
Published: 2015-01-27T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The U.S. economy is dependent on a secure global supply chain. In fiscal year 2013, approximately 12 million maritime cargo shipments arrived in the United States. Within the federal government, CBP is responsible for administering cargo security, to include identifying “high-risk” maritime cargo shipments with the potential to contain terrorist contraband. GAO was asked to review CBP's disposition of such shipments.
This report discusses (1) how many maritime shipments CBP determined to be high risk and the extent to which CBP has accurate data on the disposition of such shipments, (2) the extent to which CBP consistently applies criteria and documents reasons for waiving examinations, and (3) the extent to which CBP ensures its policies on the disposition of high-risk shipments are being followed.
GAO analyzed CBP data on maritime shipments arriving in the United States during fiscal years 2009 through 2013. GAO also visited four CBP targeting units selected on the basis of the percentage of maritime shipments they waived, among other factors.
section_title: What GAO Found
paragraphs: From fiscal years 2009 through 2013, less than 1 percent of maritime shipments arriving in the United States were identified as high risk by U.S. Customs and Border Protection (CBP), but CBP does not have accurate data on their disposition (i.e., outcomes). CBP officials (targeters) are generally required to hold high-risk shipments for examination unless evidence shows that an examination can be waived per CBP policy. In particular, targeters at Advance Targeting Units (targeting units)—responsible for reviewing shipments arriving at ports within their respective regions—can waive an examination if they determine through research that (1) the shipment falls within a predetermined category (standard exception), or (2) they can articulate why the shipment should not be considered high risk (articulable reason), such as an error in the shipment's data. GAO found that CBP examined the vast majority of high-risk shipments, but CBP's disposition data are not accurate because of various factors—such as the inclusion of shipments that were never sent to the United States—and that the data overstate the number of high-risk shipments. On the basis of GAO's analyses and findings, CBP is taking steps to correct its data.
When determining the disposition of high-risk shipments, CBP's targeting units are inconsistently applying criteria to make waiver decisions and are incorrectly documenting the reasons for some waivers. CBP policy lacks definitions for standard exception waivers. As a result, targeters are inconsistently applying and recording standard exception waivers. Because of these inconsistencies, some targeting units may be unnecessarily holding shipments for examination, while others may be waiving shipments that should be examined. Developing definitions for standard exceptions could help ensure that CBP examines shipments as intended. Further, some targeters at targeting units GAO visited were unaware of the guidance on articulable reason waivers and were incorrectly documenting these waivers. As a result, CBP cannot accurately determine the extent to which articulable waivers are being issued and used judiciously per CBP policy. Updating and disseminating guidance in policy could help ensure targeters correctly document such waivers.
CBP has efforts in place, such as self-inspections, to provide oversight of its policies on the disposition (whether examined or waived) of high-risk shipments; however, these efforts are not sufficient. For example, the limited sample size of shipments used in self-inspections does not provide CBP with the best estimate of compliance at the national level. In addition, CBP's method for calculating the compliance rate does not accurately reflect compliance because it is not based on the number of shipments sampled. Developing an enhanced methodology for selecting sample shipments, and changing the method for calculating compliance, could improve CBP's estimate of compliance and its ability to identify and correct deficiencies.
This is a public version of a sensitive report that GAO issued in November 2014. It does not include details that CBP deemed sensitive security information.
section_title: What GAO Recommends
paragraphs: GAO recommends, among other things, that CBP define standard exception waiver categories and disseminate policy on documenting articulable reason waivers. Further, CBP should enhance its methodology for selecting shipments for self-inspections and change the way it calculates the compliance rate. The Department of Homeland Security concurred with GAO's recommendations.

section_title: Letter
paragraphs: The U.S. economy is dependent on the expeditious flow of millions of  tons of cargo each day through the global supply chain—the flow of  goods from manufacturers to retailers. According to the U.S. Department  of Transportation, the majority of U.S. imports arrive by ocean vessel. In  fiscal year 2013, approximately 12 million cargo shipments arrived at U.S.  seaports from foreign ports. Criminal or terrorist attacks using cargo  shipments can cause disruptions to the supply chain and can limit global  economic growth and productivity. Within the federal government, U.S.  Customs and Border Protection (CBP), part of the Department of  Homeland Security (DHS), is responsible for administering cargo security  and reducing the vulnerabilities associated with the supply chain.  According to DHS, balancing security concerns with the need to facilitate  the free flow of commerce, part of CBP’s mission, remains an ongoing  challenge.
CBP has developed a layered security strategy that uses a risk-based  approach to focus its limited resources on targeting and examining high- risk cargo shipments that could pose a risk while allowing other cargo  shipments to proceed without unduly disrupting commerce arriving in the  United States. CBP’s layered security strategy is based on programs that  include, among other things, analyzing information to identify shipments  that may be at high risk of transporting weapons of mass destruction or  other contraband, working with foreign governments to examine U.S.- bound high-risk shipments at foreign ports participating in the Container  Security Initiative (CSI), and providing benefits to companies that comply  with predetermined security measures through the Customs-Trade  Partnership Against Terrorism (C-TPAT) program. In October 2006,  Congress passed and the President signed the Security and  Accountability for Every Port Act (SAFE Port Act) of 2006, establishing a  statutory framework for key programs within CBP’s layered security  strategy that previously had been CBP initiatives not specifically required  by law. A brief description of the core programs that constitute CBP’s  layered security strategy is provided in appendix I.
An important element of CBP’s layered security strategy is obtaining  advance cargo information to help identify shipments that are potentially  high risk for containing terrorist contraband. CBP’s disposition options  (i.e., outcomes) for high-risk shipments include examinations or waivers.  According to CBP policy, high-risk shipments are to be examined, at a  minimum, by radiation detection and nonintrusive inspection (NII)  equipment. a high-risk shipment if it meets certain criteria. Specifically, CBP officials  at ports can waive an examination if they determine through research that  (1) the shipment falls within a predetermined category of stated  exceptions (standard exception), or (2) they can articulate why the  shipment should not be considered high risk (articulable reason). For  example, a shipment could be identified as high risk because it is  associated with a shipper on a terrorist watch list, but through further  research, CBP officials determine the shipper is not a true match to the  terrorist watch list and, therefore, the shipment should not be considered  high risk.
Radiation detection equipment detects radiation being emitted from a container. Through  an NII scan, CBP can identify anomalies in a container’s image that could, among other  things, indicate the presence of material to shield weapons of mass destruction. NII uses  X-rays or gamma rays to scan a container and create images of the container’s contents  without having to open it.
In response to your request, we reviewed CBP’s disposition of high-risk  maritime shipments in recent years. Specifically, this report addresses the  following objectives:  1.  How many maritime shipments arriving in the United States from fiscal  years 2009 through 2013 did CBP determine to be high risk and to  what extent does CBP have accurate data on the disposition of each  of those high-risk shipments?  2.  To what extent is CBP consistently applying standards and  documenting reasons for waiving examinations of high-risk  shipments?  3.  To what extent does CBP ensure that its policies on the disposition of  high-risk shipments are being followed?
This report is a public version of a prior sensitive report that we provided  to you. CBP deemed some of the information in the prior report sensitive  security information (SSI), which must be protected from public  disclosure.the specific number of shipments examined and waived, and data  reliability issues, 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.
Therefore, this report omits sensitive information regarding  To determine the number of maritime shipments arriving in the United  States that CBP determined to be high risk, we obtained and analyzed  data from CBP on the number of shipments and high-risk shipments, by  seaport, during fiscal years 2009 through 2013—the 5 most recent fiscal  years for which full-year data were available at the time of our review. To  determine the extent to which CBP has accurate data on the disposition  of each high-risk shipment, we analyzed CBP’s data to determine the  number of high-risk shipments examined and waived, as well as those  shipments not examined/not waived. We then reviewed the data for  obvious errors, discussed how the data were compiled with CBP officials,  and determined the accuracy of a subset of both waived and not  examined/not waived shipments from CBP’s fiscal year 2013 data by  further researching the disposition of each selected shipment with the  assistance of CBP officials. We determined that the data (1) were not  sufficiently reliable at the seaport level because not all shipments were  associated with the correct seaport where shipments were unloaded, and  (2) as discussed later in this report, contain errors that affect their  reliability for calculating the number of high-risk shipments and their  disposition. We did determine, though, that the data are sufficiently  reliable to illustrate the overall disposition of all high-risk shipments by  category—examined, waived, and not examined/not waived. We  analyzed data we received from CBP’s Fines, Penalties, and Forfeitures  Division on “gate outs”—cargo targeted for terrorism or enforcement  reasons that is released from CBP custody and departs a port without  authorization or examination—for fiscal years 2009 through 2013 in order  to determine the frequency of gate out occurrences relative to the overall  number of not waived/not examined shipments. We discussed the  process for collecting and recording gate out data with CBP officials from  the Fines, Penalties, and Forfeitures Division and determined that the  gate out data were sufficiently reliable for reporting the number of gate  out occurrences.
To determine the extent to which CBP is consistently applying standards  and documenting reasons for waiving examinations of high-risk  shipments, we analyzed CBP’s data on high-risk shipment waivers during  fiscal year 2013, reviewed CBP policies and guidance for waiving  examinations of high-risk shipments, and observed and discussed waiver  practices at the Advance Targeting Units (targeting units) we visited. We  conducted site visits to four targeting units that appeared to issue the  greatest percentage of waivers relative to the total high-risk maritime  cargo shipments that arrived at their respective seaports in fiscal year   Although the results from our visits to these four targeting units are  2013.not generalizable to all targeting units, the visits allowed us to understand  whether waiver documentation practices are consistent across these  targeting units, and how such practices affect the reliability of CBP’s  disposition data. In order to determine whether targeting units were  consistently using uniform criteria when applying standard exception  waivers to high-risk shipments, we asked CBP officials at each targeting  unit we visited to (1) define certain standard exception waivers listed in  CBP’s National Maritime Targeting Policy, and (2) comment on their  awareness of any existing CBP guidance regarding standard exceptions.  We compared CBP’s practices relative to standard exception waivers  against standards in Standards for Internal Control in the Federal  Government. We also spoke with CBP targeting unit officials about their  processes and practices for reviewing, approving, and documenting  articulable reason waivers for high-risk shipments. We compared the  processes and practices they use with CBP’s policy for approving such  waivers in the National Maritime Targeting Policy and CBP’s guidance on  documenting articulable reason waivers as prescribed in a February 2007  memorandum.
In order to determine the extent to which CBP ensures that its policies on  the disposition of high-risk shipments are being followed, we met with  CBP officials at both headquarters and targeting units responsible for the  management of high-risk maritime shipments and discussed their  oversight of CBP’s policies. We also met with officials from CBP’s Office  of Field Operations (OFO) to discuss their design and implementation of  the Self-Inspection Program for sea cargo targeting, including the  shipment sample size used to assess compliance and method for  calculating compliance. In addition, we reviewed CBP reports  summarizing the results of self-inspections, including the compliance rate  and individual reports submitted by the four targeting units we visited. We  then compared CBP’s methodology for conducting self-inspections with   Further, we  best practices outlined in guidance on design evaluations.reviewed quarterly reports produced by CBP outlining the disposition of  high-risk shipments and discussed how these reports are used to  determine whether CBP is meeting a Government Performance and  Results Act (GPRA) performance goal with officials from OFO. Finally, we  compared CBP’s efforts to assess the accuracy of its data used for GPRA  with standards in Standards for Internal Control in the Federal  Government. Additional details regarding our scope and methodology  are provided in appendix II.
We conducted this performance audit from January 2014 through January  2015 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.
subsections: section_title: Background
subsections: section_title: Identifying High-Risk Shipments
paragraphs: Through what is referred to as the 24-hour rule, CBP generally requires  vessel carriers to electronically transmit cargo manifests to CBP 24 hours  before cargo is loaded onto U.S.-bound vessels at foreign ports.  Through the Importer Security Filing and Additional Carrier Requirements  (known as the 10+2 rule), CBP requires importers and vessel carriers to  provide data elements for improved identification of cargo shipments that  may pose a risk for terrorism.CBP with 10 shipping data elements—such as country of origin—24  hours prior to loading, while vessel carriers are required to provide 2 data   Importers are responsible for supplying  elements—container status messages and stow plans—that are not  required by the 24-hour rule.
The data provided by carriers and importers in compliance with the 24- hour rule and the 10+2 rule are automatically fed into CBP’s Automated  Targeting System (ATS)—an enforcement and decision support system  that compares cargo and conveyance information against intelligence and  other law enforcement data. ATS consolidates data from various sources  to create a single, comprehensive record for each U.S.-bound shipment.  Among other things, ATS uses a set of rules that assess different factors  in the data to determine the risk level of a shipment. One set of rules  within ATS, referred to collectively as the maritime national security  weight set, is programmed to check for information or patterns that could  be indicative of suspicious or terrorist activity. Each rule in the set has a  specific weight value assigned to it, and for each risk factor that the rules  identify, the weight values are added together to calculate an overall risk  score for the shipment. ATS assesses and generates risk scores for  every cargo shipment as the shipment moves throughout the global  supply chain and new data are provided or existing data are revised. CBP  classifies the risk scores from the maritime national security weight set as  low, medium, or high risk. Shipments with connections to known or  suspected terrorists, as well as those that include invalid information, are  more likely to be classified as high risk; and shipments from shippers who  participate in CBP’s C-TPAT program, or “trusted shippers,” are more  likely to be classified as low risk. Because ATS collects and presents data  on shipments, CBP targets shipments—rather than individual  containers—for examination.
section_title: Targeting High-Risk Shipments
paragraphs: ATS automatically places high-risk shipments on hold, and CBP officials  (targeters) use information in ATS to identify (target) which high-risk  shipments should be examined or waived. If a shipment is held for  examination, a CBP Anti-Terrorism Contraband Enforcement Team  (enforcement team) is to conduct the examination, which is to include  scanning the cargo with NII equipment, among other things.  Enforcement team officials are to review the images produced with the NII  equipment to detect anomalies or shielding that could indicate the  presence of weapons of mass destruction or other contraband. If an  anomaly is detected, the shipment is to be transferred to a centralized  examination station and the contents of the container are to be removed  and physically examined. If contraband is discovered during the physical  examination, the shipment is to be seized by CBP; otherwise it is to be  released. The enforcement team is responsible for recording the  examinations it conducts, as well as the results, in the Cargo  Enforcement Reporting and Tracking System (CERTS)—a module within  ATS.
Examinations of high-risk shipments can be waived if a CBP targeter  determines that a high-risk shipment meets a “standard exception” or an  “articulable reason.” CBP policy lists the standard exceptions to  mandatory examinations. Waivers based on articulable reasons are  issued for reasons other than the standard exception categories. If a CBP  targeter conducts analysis of available information on a high-risk  shipment and determines there is no security risk, he or she is to seek  approval from the port director or his/her designee(s) and record the  waiver reason in CERTS within ATS. Figure 1 depicts possible targeting  outcomes for high-risk shipments.
In addition to obtaining manifest and shipping data (e.g., 10+2 data), CBP  requires the importers of goods to file entry documents so CBP can  assess and collect duties. Data provided in the entry documents are  assessed by ATS and can result in a shipment’s risk score previously  classified as low or medium risk based on manifest and shipping data to  become high risk. Entry documents can also have the opposite effect. For  example, entry information can confirm an entity is a C-TPAT member  and, therefore, drop the shipment’s score below the high-risk threshold.
Entry documents can be provided several days after a shipment’s arrival  in the United States and after a shipment leaves the port.
section_title: Advance Targeting Units
paragraphs: CBP targeters are assigned to targeting units located at or near selected  domestic ports, and their targeting efforts are focused on shipments  destined for ports within their respective regions. A targeting unit may be  responsible for targeting shipments arriving at one port or multiple ports in  its region. For example, targeters at the Port of Newark are also  responsible for targeting shipments that are bound for ports in New York.  CBP targeters at targeting units can review data as soon as carriers and  importers submit the required data (in accordance with the 24-hour rule  and the 10+2 rule), and the data are available in ATS. Once a shipment is  loaded onto a U.S.-bound vessel, CBP targeters continue to review  shipment data in ATS because shipment data can be updated with  additional or amended information. Targeters use other sources, such as  public records, open sources (e.g., Internet search engines), U.S.  government systems, and local port knowledge to assess whether the  shipment poses a high risk or whether the risk can be mitigated based on  research.
section_title: 100 Percent Scanning and Prior GAO Work
paragraphs: In August 2007, the Implementing Recommendations of the 9/11  Commission Act of 2007 (9/11 Commission Act) was enacted, which  required, among other things, that by July 2012, 100 percent of U.S.- bound cargo containers be scanned at foreign ports with both radiation  detection and NII equipment before being placed on U.S.-bound   In May 2012, the then secretary of homeland security  vessels.authorized a 2-year extension (until July 2014) of the deadline for  implementing the requirement.Security renewed the extension (until July 2016) and stated that “DHS’s  ability to fully comply with this unfunded mandate of 100 percent  scanning, even in  long term, is highly improbable, hugely expensive,  and in our judgment, not the best use of taxpayer resources to meet this  country’s port security and homeland security needs.” The Secretary also  stated that he instructed DHS, including CBP, to do a better job of  meeting the underlying objectives of the 100 percent scanning  requirement by, in part, refining aspects of CBP’s layered security  strategy.
In May 2014, the Secretary of Homeland  We have previously reported on the challenges CBP faces in  implementing the 100 percent scanning requirement.  In October 2009,  we recommended, among other things, that CBP conduct feasibility and  cost-benefit analyses of implementing the 100 percent scanning  requirement and provide the results to Congress along with any  suggestions of cost-effective alternatives to implementing the 100 percent  scanning requirement, as appropriate. CBP partially concurred with the  recommendations but did not implement them. We have also reported on  the programs that compose CBP’s layered security strategy. Specifically,  we have reviewed CBP’s efforts to collect additional data through the  10+2 rule and utilize these data to identify high-risk shipments; examine  high-risk shipments before they depart CSI ports; and validate security  measures taken by C-TPAT members. We made several  recommendations in these reports, including that CBP establish  milestones and time frames for including 10+2 data in its criteria used in  the identification of high-risk shipments. In December 2010, CBP  provided us with a project plan for integrating the data into its criteria, and  in early 2011, CBP implemented the updates to address risk factors  present in the 10+2 data.
section_title: Less than 1 Percent of Arriving Maritime Shipments from Fiscal Years 2009 through 2013 Were High Risk, but CBP Does Not Have Accurate Data on Their Disposition Percentage of High-Risk Shipments Is Very Low and CBP Has Examined the Vast Majority
paragraphs: We determined that less than 1 percent of the maritime shipments  arriving in the United States from fiscal years 2009 through 2013 were  high risk; however, CBP does not have accurate data on the number and  disposition of each high-risk shipment because of various factors. On the  basis of our analyses, CBP’s data overstate the number of high-risk  shipments, including those not examined/not waived. CBP is taking steps  to improve its data on the disposition of high-risk shipments.
On the basis of our analyses of CBP data for fiscal years 2009 through  2013, on average each year, approximately 11.6 million maritime  shipments arrived in the United States, and less than 1 percent of those  were determined by ATS to be high risk based on the maritime national  security weight set. CBP, on average, examined the vast majority of these  high-risk shipments, with less than 10 percent waived or not  examined/not waived.
subsections: section_title: CBP Does Not Have Accurate Data on the Disposition of All High- Risk Shipments
paragraphs: The numbers and percentages discussed above represent CBP’s data on  the number of high-risk shipments and their disposition, but our analyses  suggest that CBP does not have accurate data on the disposition of each  high-risk shipment because of various factors. In particular, CBP’s data  overstate the number of high-risk shipments, including those not  examined/not waived. On the basis of our analysis of selected waived  shipments, CBP’s data may also overstate the number of waived  shipments since not all shipments identified as waived were waived, but  we were unable to determine the full extent to which some shipments  identified as not waived/not examined were actually waived. CBP officials  stated that the data include (1) shipments where the carrier deleted the  bill of lading, meaning the shipments ultimately never arrived in the United  States (referred to as deleted bills), and (2) shipments for which ATS  assigned high risk scores only after entry was filed and the shipment had  been released from the port. In further iterations of the data CBP provided  us, CBP officials were able to identify the shipments in these two  categories and therefore provide us with more accurate data on the  number and disposition of high-risk shipments.
On the basis of our analyses of CBP’s fiscal year 2009 through 2013  data, deleted bills and shipments’ risk scores not rising above the high- risk threshold until after entry accounted for 8 percent, on average, of the  high-risk shipments identified in CBP’s data as waived. However, such  shipments were not high-risk shipments requiring review by a targeter  and therefore would not have been waived. Further, our analyses of  CBP’s data showed that deleted bills and risk scores not rising above the  high-risk threshold until after entry accounted for 48 percent, on average,  of the high-risk shipments identified in CBP’s data as not examined/not  waived. Therefore, nearly half of the shipments identified as not  examined/not waived in CBP’s data were, in fact, not high-risk shipments  requiring an examination or waiver even though they were identified as  such.
In addition to deleted bills and shipments with high risk scores only after  entry was filed, we also identified other factors contributing to CBP not  having accurate disposition data on high-risk shipments. We discussed a  nonprobability sample of high-risk shipments with CBP officials at the four  targeting units we visited. Specifically, we discussed two sets of  shipments—40 high-risk shipments identified in CBP’s data as waived,   We found that  and 40 shipments identified as not examined/not waived.CBP did not have accurate disposition data for the 40 high-risk shipments  identified as waived since 28 shipments were actually waived. For  example, we determined that 3 shipments were examined, but the  examinations were not recorded by CBP officials in CERTS within ATS.  According to CBP officials at one targeting unit we visited, the 3  shipments were not recorded because of confusion over who was to  record the examination. See table 1 for the actual disposition of the 40  high-risk shipments we analyzed that were identified in CBP’s data as  waived.
We determined that of the 40 high-risk shipments identified in CBP’s data  as not examined/not waived, 1 should have been examined, and 1  waived. The remaining 38 shipments were incorrectly identified as not  examined/not waived for various reasons, including 5 shipments that  were examined or waived and properly recorded, but ATS did not link the  records to the shipments. See table 2 for the actual disposition of the 40  high-risk shipments identified in CBP’s data as not examined/not waived.
CBP data on gate out occurrences—cargo targeted for terrorism or  enforcement that is released from CBP custody and departs a port  without authorization or examination—also call into question the accuracy  of CBP’s disposition data on high-risk shipments identified as not  examined/not waived. CBP requires ports to have a process in place for  identifying gate outs and, in 2006, developed a uniform process for ports  to report gate outs to CBP’s OFO. According to CBP data collected  through this process, the number of gate out occurrences is far less than  the number of high-risk shipments identified as not examined/not waived,  which would equate to a gate out. The number of not examined/not  waived high-risk shipments should, in theory, be the same as the number  of gate outs.
In response to our findings, CBP officials acknowledged that the factors  discussed above have contributed to CBP’s data not being accurate, and  they noted that CBP is taking steps to improve its data on the disposition  of high-risk shipments. For example, CBP has already developed a query  to identify shipments in its data that are not truly high risk at the time of  arrival, including deleted bills and shipments with high risk scores only  after arrival and entry is filed. CBP officials added that they are updating  the National Maritime Targeting Policy to include the requirement that  cargo examinations and waivers be recorded in CERTS within ATS since  not all officials are adhering to this requirement and the policy will be  finalized after we complete our review. In addition, enhancing certain  oversight mechanisms, as discussed later in the report, could help  address the inaccuracies in CBP’s data.
section_title: CBP Targeting Units Are Not Consistently Applying and Documenting Reasons for Waiving Examinations of High- Risk Shipments
paragraphs: When determining the disposition of high-risk shipments, CBP’s targeting  units are inconsistently applying criteria to make some waiver decisions  and are also incorrectly documenting the reasons for waivers. On the  basis of our review of CBP policy and visits to selected targeting units, we  determined that CBP has not established uniform definitions for standard  exception waiver categories; some CBP officials were unaware of existing  waiver guidance for articulable reason waivers; and some CBP targeters  across the targeting units we visited were inconsistently and inaccurately  recording waiver reasons in ATS. As a result, CBP cannot accurately  determine the extent to which standard exception waivers are used  consistently or whether waivers issued for articulable reasons are being  used judiciously, as required by policy.
subsections: section_title: Targeting Units Have Varying Definitions of What Constitutes Certain Standard Exceptions
paragraphs: CBP’s National Maritime Targeting Policy lists several standard exception  waivers, and we found inconsistencies regarding how certain standard  exception waiver categories are defined across the four targeting units we  visited. At these targeting units, we found that CBP targeters  consistently review manifest and shipping data, including data provided  through the 10+2 rule, to search for evidence that would indicate whether  or not a shipment should be waived based on a standard exception.  However, the criteria targeters at these targeting units are using to make  these determinations are not uniformly established by any central CBP  guidance or policy. Instead, they are developed locally by targeting unit  officials primarily on the basis of their experience and institutional  knowledge of the targeting process. Although CBP’s National Maritime  Targeting Policy identifies what the standard exception categories are, it  does not provide definitions for what specifically constitutes the various  standard exception categories.
Because of the lack of CBP-wide definitions for the standard exception  categories, CBP targeters may be holding some shipments for  examinations that should be waived. Alternatively, CBP targeters may  also be waiving shipments that should have been examined. Differences  in how frequently targeting units receive certain types of shipments may  also affect the inconsistent interpretation of standard exceptions, and  ultimately influence the variance seen in the proportion of high-risk  shipments targeting units waive.
Defining standard exception waiver categories and disseminating those  definitions in policy would better allow targeting units and targeters to  consistently apply criteria when making and recording waiver decisions,  and could help ensure that CBP is examining shipments as intended. It is  key that government agencies implement effective internal controls in  order to minimize operational problems and achieve desired program  results. According to Standards for Internal Control in the Federal  Government, control activities help ensure that management’s directives   The control activities should be effective and efficient in  are carried out. accomplishing the agency’s objectives. Examples of control activities  include establishment and review of performance measures and  indicators, accurate and timely recording of transactions and events, and  appropriate documentation of transactions and internal controls. CBP  officials acknowledged that establishing definitions for standard  exceptions could reduce the inconsistent interpretation and  documentation of standard exception waivers.
section_title: CBP Is Unable to Determine if Its Policy Addressing Articulable Reason Waivers Is Being Followed
paragraphs: GAO/AIMD-00-21.3.1.
National Maritime Targeting Policy, which states that the port director or  his/her designee(s) is/are responsible for reviewing and approving high- risk shipment waiver requests based on articulable reasons.
While the targeting units we visited had proper procedures in place for  requesting and approving waivers, we found that CBP targeters at those  targeting units are not correctly documenting waivers based on articulable  reasons in accordance with CBP guidance. CBP issued a memorandum  in February 2007 that provides guidance on how targeters are to record  waivers in ATS based on articulable reasons. According to that guidance,  targeters are to select a specific drop-down menu option in CERTS as the  reason for every articulable reason waiver they issue and then targeters  are to provide comments in CERTS to support the justification for the  waiver. However, during our visits to the targeting units, and on the basis  of conversations we had with CBP targeters, we found that targeters’  understanding of how to record waivers in CERTS within ATS varied. Our  analysis of selected waived shipments (as previously discussed in this  report) and discussions with CBP targeters indicate that some targeters  are incorrectly recording some waiver reasons in ATS because they are  not familiar with the February 2007 CBP memorandum that specifies how  articulable reason waivers are to be recorded. According to a senior CBP  official, the National Maritime Targeting Policy, which was last  disseminated prior to the implementation of CERTS, has not been  updated to address the process for recording articulable waivers in  CERTS.
Neither we nor CBP could easily determine the full extent to which  articulable waiver reasons were recorded properly because waivers  based on articulable reasons cannot be segregated from waivers issued  for standard exceptions. The inconsistent recording of articulable reason  waivers in ATS limits CBP’s ability to determine whether targeting units  are following policy, since CBP’s National Maritime Targeting Policy  states that waivers based on articulable reasons are to be used  “judiciously.” In order to evaluate whether targeting units are judiciously  making waiver decisions based on articulable reasons, CBP would need  accurate records in ATS regarding the basis for why shipments were  waived in order to be able to easily distinguish the two types of waivers.
In particular, CBP is reliant on targeters’ selecting the appropriate waiver  reasons from the drop-down menu selections in CERTS in order to be  able to accurately analyze waiver data. Although the comments in the  remarks section of CERTS justifying the waiver may provide further  details regarding the reasons for waivers, it would be difficult for CBP to  accurately determine waiver reasons on the basis of large-scale data  queries of comments in the remarks section alone. Therefore, it is  important for targeters to select the proper drop-down menu options when  documenting waiver reasons. According to Standards for Internal Control  in the Federal Government, management must continually assess and  evaluate its internal controls to ensure that the control activities being  used are effective and updated when necessary. Updating and  disseminating guidance in policy on how to record articulable reason  waivers will help ensure that they are correctly recorded.
section_title: CBP’s Mechanisms to Oversee the Implementation of Disposition Policies Could Be Enhanced
paragraphs: CBP has some mechanisms to provide oversight of its policies on the  disposition of high-risk shipments, such as biannual self-inspections;  however, these are not sufficient to fully identify whether officials are  complying with policy on examinations and waivers. Further, CBP could  enhance the quality of its reports on the disposition of high-risk  shipments.
subsections: section_title: CBP Has Mechanisms to Determine if Its Policies Are Being Followed
paragraphs: CBP’s OFO has mechanisms to determine if CBP policies on the  disposition of high-risk shipments are being followed. Specifically, OFO  monitors compliance with policies on the disposition of high-risk  shipments through three efforts:
Self-Inspection Program: OFO requires port directors (or their  designees) to complete self-inspection worksheets on cargo targeting  every other year to determine whether CBP officials are following  policy when it comes to examining high-risk shipments and recording  those examinations. In addition to reporting any deficiencies, the  inspection reports sent to OFO are to include the corrective actions  taken to address the deficiencies identified.
Quarterly performance reports: CBP compiles data from ATS on high- risk shipments to measure CBP’s performance in reviewing high-risk  shipments in support of GPRA. Among other things, the quarterly  reports provide data on the number of high-risk shipments that arrived  at each U.S. seaport, including the number of shipments reviewed by  a targeter and the number waived.
Monitoring gate outs: CBP requires ports to uniformly report all gate  out occurrences to OFO as soon as the gate out is discovered. The  local port submits a notification worksheet to the Office of Cargo,  Conveyance and Security (within OFO) that, in turn, determines if a  gate out truly occurred.
However, as discussed below, we found weaknesses in some of the  mechanisms CBP uses to provide oversight of its policies.
section_title: CBP Needs to Improve Oversight of Its Policies to Better Identify ATS Data Deficiencies
paragraphs: We found that CBP’s efforts are not sufficient to identify when officials are  not following policies on high-risk shipments and, subsequently,  deficiencies in how data are recorded in ATS, including examinations and  waivers. The Self-Inspection Program requires port directors or their  designees to analyze selected shipments and complete a worksheet  composed of three questions to check compliance with policies on  examining high-risk shipments and recording examinations. The three  worksheet questions are as follows:  1.  Were cargo examination findings input within CERTS and, when  appropriate, within other systems?  2.  Were all shipments that received an ATS score at or above the  national security threshold score placed on hold?  3.  Did all shipments that received an ATS score at or above the national  security threshold undergo a mandatory examination utilizing, at a  minimum, an NII imaging system and screening with radiation  detection technology?
The guidance provided on how to select shipments to answer the three  questions, depending on the question, states that 10 percent of all  shipments are to be randomly selected, with a minimum of 10 shipments  and no more than 20 shipments, or 20 shipments are to be randomly  selected among high-risk shipments. After port directors or their  designees submit their completed worksheets, CBP OFO calculates the  national compliance rate by dividing the number of worksheets that have  at least 1 shipment that did not conform to policy by the total number of  self-inspection worksheets submitted to OFO.
Given that the sample size is generally the same for all port directors  regardless of the number of shipments their ports receive, on the basis of  our analysis, the sample does not provide CBP with an efficient estimate  of compliance at the national level. For example, by allocating additional  samples to ports with more arriving shipments, the national compliance  estimate could have a reduced sampling error. Through its Self- Inspection Program, CBP has identified a minimal number of  noncompliant shipments requiring corrective action. For example, five  corrective actions were taken nationwide based on the 2011 self- inspection reporting cycle, and two corrective actions based on the 2012  cycle. CBP’s compliance rate was over 93 percent for both cycles,  leading CBP to reduce the frequency of the self-inspections for maritime  cargo targeting from every year to every other year, according to CBP  OFO officials. However, as discussed previously, we determined that 3 of  40 shipments identified as waived were actually examined, but the  examinations were not properly recorded and 6 of 40 shipments identified  as not examined/not waived were examined or waived, but not properly  recorded. Thus, CBP’s compliance estimates may be overstated. CBP  could improve its ability to estimate national compliance rates for maritime  cargo targeting practices through different methods. For example, CBP  could increase the number of shipments sampled by ports with the  greatest number of arriving shipments or consider a stratified sample with  strata defined in terms of size of ports and other factors that might be  related to compliance or risk, such as whether shipments appear in its  data as not examined/not waived. By enhancing its methodology for  selecting shipment samples, CBP could better identify any deficiencies  and take appropriate corrective actions. According to a Director in OFO,  CBP is considering changing the shipment sample size to a percentage of  high-risk shipments, which would result in port directors of larger ports  analyzing a greater number of shipments than the 20 shipments per  question they currently sample. However, CBP has not finalized its plans  for making this change.
Further, CBP’s method for calculating the compliance rate does not  accurately reflect compliance nationwide because it does not calculate  the rate based on the number of shipments sampled. Rather, CBP  calculates the rate based on the number of worksheets that contained  shipments for which policy was not followed regardless of whether it was  1 shipment or all shipments included in the worksheet. According to  guidance on design evaluations, the data should be analyzed in a way  that allows valid conclusions to be drawn from the evaluation. CBP  could improve its ability to estimate national compliance with maritime  cargo targeting practices by changing its compliance rate calculation to  divide the number of shipments (the unit of measure) that did not conform  to policy by the total number of shipments sampled, rather than  calculating the rate based on the number of worksheets.
In addition to the limited nature of the self-inspections, we also found that  CBP does not fully assess the reliability of the data it analyzes on the  disposition of high-risk shipments for the quarterly reports it produces in  support of GPRA. Through our reliability assessment of CBP’s data, we  identified high-risk shipments that were not high risk and shipments for  which the disposition (e.g., waived) was not recorded accurately (as  previously discussed). An independent review team contracted by DHS to  verify and validate the completeness and reliability of CBP’s performance  data used for the GPRA measure on high-risk cargo determined that CBP  only addressed significant anomalies in its data contained in the quarterly  reports and recommended, in May 2014, that CBP develop a formal  quality control process for field data. recommendation “with reservations,” adding that it believed reinforcing  existing policies and procedures through the local CBP command  structure would address the errors. However, in CBP’s data we also  found errors not attributable to field data.
section_title: Conclusions
paragraphs: Energetics, Independent Verification and Validation of Performance Measure Data: FY  2014 Review and Report of Findings (May 2014). statute, the Secretary of Homeland Security has instructed DHS,  including CBP, to do a better job of meeting the underlying objectives of  the 100 percent scanning requirement by, in part, refining aspects of  CBP’s layered security strategy. Given that examining and waiving, if  appropriate, high-risk shipments are critical aspects of CBP’s strategy, it  is important for CBP to ensure that these practices are carried out  consistently and that results of its targeters’ actions regarding the  disposition of high-risk cargo shipments are recorded accurately. CBP is  starting to take actions to correct errors in its data and revise its National  Maritime Targeting Policy, but it needs to take further actions to ensure its  policies are consistently being followed and to enhance the reliability of its  high-risk shipment data. For example, without defining the standard  exceptions in policy, CBP is not able to ensure that all high-risk shipments  are being appropriately examined or waived. Further, without updating  and disseminating policy on how to record such waivers, CBP will not be  able to determine whether its targeting units are using articulable reason  waivers judiciously, as called for in policy. Moreover, enhancing the  methodology used in CBP’s Self-Inspection Program will allow it to better  identify instances where policy is not being followed and implement  corrective actions. Such actions, in turn, could help CBP better ensure  that its policies on the disposition of high-risk shipments are being  followed.
section_title: Recommendations for Executive Action
paragraphs: To help ensure compliance with policies on waiving high-risk shipments,  we recommend that the Commissioner of CBP direct OFO to take the  following two actions: develop a definition for each of the standard exception waiver  categories and include those definitions in policy to ensure that  targeting units are consistently applying those definitions when  making and documenting waiver decisions in CERTS, and update and disseminate policy to ensure that all targeting units are  correctly documenting waivers based on articulable reasons in  CERTS.
To enhance oversight of the disposition of high-risk shipments— examinations and waivers—we recommend that the Commissioner of  CBP direct OFO to take two actions: develop an enhanced methodology for selecting shipment samples  used for self-inspection to increase the likelihood that any potential  deficiencies will be identified so that corrective actions can be taken to  reduce errors in the future, and develop a better national estimate of compliance with maritime cargo  targeting policies by calculating the compliance rate based on  individual shipments rather than worksheets.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of the sensitive version of this report to DHS for its  review and comment. DHS provided technical comments, which have  been incorporated into this report, as appropriate. DHS also provided  written comments, which are reprinted in appendix III. In its comments,  DHS concurred with the report’s four recommendations and described  actions it has under way or planned to address the recommendations by  June 30, 2015.
DHS concurred with the first recommendation and stated that CBP plans  to develop a definition for each of the standard exception waiver  categories. DHS concurred with the second recommendation and stated  that CBP will provide guidance on issuing waivers based on articulable  reasons in its updated National Cargo Targeting Policy. DHS concurred  with the third recommendation and stated that CBP has updated its self- inspection worksheet for the 2015 inspection cycle in response to the  recommendation. DHS concurred with the fourth recommendation and  stated that CBP will develop the ability to generate reports on  noncompliant high-risk shipments and require port directors or their  designees to review the reports and take corrective actions based on  noncompliant shipments. If implemented as planned, these actions  should address the intent of the recommendations to improve CBP’s  disposition of high-risk shipments.
In its comments, DHS also referred to a fifth recommendation related to  reviewing port codes. Because DHS deemed the details of this  recommendation and its response as sensitive security information, they  are not included in this public version of the report.
If you or your staff have any questions about this report, please contact  me at (202) 512-7141 or GroverJ@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.
section_title: Appendix I: Description of CBP’s Layered Security Strategy for Maritime Cargo Shipments
paragraphs: This appendix describes the core programs related to U.S. Customs and  Border Protection’s (CBP) strategy for ensuring the security of maritime  cargo. CBP has developed this strategy to mitigate the risk of weapons of  mass destruction, terrorist-related material, or other contraband being  smuggled into the United States. CBP’s strategy is based on related  programs that attempt to focus resources on high-risk shipments while  allowing other cargo shipments to proceed without unduly disrupting the  flow of commerce into the United States. The strategy includes obtaining  advanced cargo information to identify high-risk shipments, using  technology to inspect cargo, and partnering with foreign governments and  the trade industry. Table 3 provides a brief description of some of the core  programs that compose this security strategy.
section_title: Appendix II: Objectives, Scope, and Methodology
paragraphs: This report addresses U.S. Customs and Border Protection’s (CBP)  disposition of high-risk maritime cargo shipments. More specifically, our  objectives were to examine (1) the number of maritime shipments arriving  in the United States from fiscal years 2009 through 2013 that CBP  determined to be high risk and the extent to which CBP has accurate data  on the disposition of each of those high-risk shipments, (2) the extent to  which CBP is consistently applying standards and documenting reasons  for waiving examinations of high-risk shipments, and (3) the extent to  which CBP ensures that its policies on the disposition of high-risk  shipments are being followed.
To address all of these objectives, we reviewed CBP policies regarding  the targeting and waiving of high-risk shipments, analyzed CBP data, and  spoke with key CBP officials at both headquarters and selected targeting  units. To determine the number of maritime shipments arriving in the  United States that CBP determined to be high risk, we obtained data from  CBP on the number of shipments and high-risk shipments that arrived in  the United States by seaport during fiscal years 2009 through 2013—the  5 most recent fiscal years for which full-year data were available at the  time of our review. To determine the extent to which CBP has accurate  data on the disposition of each high-risk shipment, we analyzed CBP’s  data to determine the number of high-risk shipments examined, and  waived—the disposition options we identified in CBP’s National Maritime  Targeting Policy—as well as those shipments not examined/not waived.We excluded foreign cargo remaining on board (FROB) shipments— cargo not discharged in the United States—from the scope of our review  to focus on shipments unloaded at United States seaports. To assess the  reliability of the data, we reviewed the data for obvious errors and  discussed our observations with CBP officials who compiled the data. We  also discussed with CBP officials how the data are entered and  maintained and interviewed officials who enter the data in CBP’s  Automated Targeting System (ATS). We also selected a nonprobability  sample of shipments from CBP’s fiscal year 2013 data to determine the  accuracy of the disposition data. Specifically, from the list of waived  shipments in CBP’s fiscal year 2013 shipment data, we selected a  nonprobability sample of 40 waived shipments that represented a variety  of waiver reasons recorded in ATS. We also selected a second  nonprobability sample of 40 not examined/not waived shipments from the  same set of data, to include shipments CBP identified as deleted bills and  shipments with high-risk scores only after entry was filed. These shipment  samples were associated with the four Advance Targeting Units (targeting  units) we visited (see below for site visit selection criteria). We discussed  the accuracy of both sample sets with targeting unit officials. We  determined that CBP’s data likely overstate the number of high-risk  shipments, including those not examined/not waived, but the data are  sufficiently reliable to illustrate the overall disposition of all high-risk  shipments by category—examined, waived, and not examined/not  waived—since a small percentage of shipments were waived and not  examined/not waived relative to the number examined.
In addition to analyzing CBP’s disposition data, we collected and  analyzed gate out data for fiscal years 2009 through 2013 from CBP’s  Fines, Penalties, and Forfeitures Division in order to determine the  frequency of gate out occurrences relative to the overall number of not  waived/not examined shipments. To assess the reliability of the data, we  reviewed gate out case files and assessed whether the information  contained in the files matched with fiscal years 2009 through 2013 gate  out data we received from CBP. We also discussed the process for  collecting and recording gate out data with CBP officials from the Fines,  Penalties, and Forfeitures Division. We determined that the gate out data  were sufficiently reliable for reporting the number of gate out occurrences.
To determine the extent to which CBP is consistently applying standards  and documenting reasons for waiving examinations of high-risk  shipments, we analyzed CBP’s data on high-risk shipment waivers  recorded during fiscal year 2013, reviewed CBP policies and guidance on  waiving examinations of high-risk shipments, and observed and  discussed waiver practices at the targeting units we visited. We  conducted site visits to four targeting units that appeared to issue the  greatest percentage of waivers relative to the total high-risk maritime  cargo shipments that arrived in their respective seaports in fiscal year  2013. These targeting units also represent a variety of geographical  locations within the United States, as they are situated on the Gulf, East,  and West Coasts. Additionally, they encompass seaports of varying sizes  based on arriving shipments, ranging from approximately 146,000  shipments to 4.4 million shipments. We reviewed selected samples of  waived shipments in CBP’s data with officials at each targeting unit in  order to gain an understanding of how targeters selected and  documented waiver reasons, including standard exceptions for each of  the shipments. Although the results from our visits to these four targeting  units are not generalizable to all targeting units across the United States,  the visits allowed us to understand whether waiver documentation  practices are consistent across the targeting units we visited, and how  such practices affect the reliability of CBP’s disposition data.
We asked CBP officials at each targeting unit we visited to define certain  standard exception waivers listed in CBP’s National Maritime Targeting  Policy in order to determine whether targeting units were consistently  using uniform criteria when applying standard exception waivers to high- risk shipments. Additionally, we asked targeters to comment on their  awareness of any existing CBP policy or central guidance regarding the  definition of the various standard exceptions. We compared CBP’s  practices relative to standard exception waivers against standards in  Standards for Internal Control in the Federal Government, which state  that control activities should be effective and efficient in accomplishing the  agency’s objectives.targeting units we visited about their processes for reviewing and  approving articulable reason waivers for high-risk shipments and  assessed their compliance with CBP policy on approving waivers  documented in the National Maritime Targeting Policy. At each of the four  targeting units, we also met with CBP targeters to discuss and observe  their practices for recording examination waivers based on articulable  reasons in ATS. We then compared those practices with CBP guidance   We spoke with CBP officials at each of the four  on how to record articulable reasons waivers, as prescribed in a February  2007 CBP memorandum.
In order to determine the extent to which CBP ensures that its policies on  the disposition of high-risk shipments are being followed, we met with  CBP officials at both headquarters and targeting units responsible for the  management of high-risk maritime shipments and discussed their  oversight of CBP’s policies. We met with officials from CBP’s Office of  Field Operations (OFO) to discuss their design and implementation of the  Self-Inspection Program for maritime cargo targeting, including the  shipment sample size used to assess compliance and method for  calculating compliance. We reviewed CBP reports summarizing the  results of self-inspections, including the compliance rate, as well as  individual reports submitted by the four targeting units we visited. We then  compared CBP’s methodology for conducting self-inspections with best  practices outlined in guidance on design evaluations. reviewed quarterly reports produced by CBP outlining the disposition of  high-risk shipments and discussed with officials from OFO how these  reports are used to determine whether CBP is meeting a Government  Performance and Results Act (GPRA) performance goal. We compared  CBP’s efforts to assess the accuracy of its data used in support of GPRA  with standards in Standards for Internal Control in the Federal  Government.Forfeitures Division to discuss CBP’s procedures for identifying and  reporting gate outs.
We also met with officials from CBP’s Fines, Penalties, and  We conducted this performance audit from January 2014 through January  2015 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.
GAO-12-208G.
section_title: Appendix III: Comments from the Department of Homeland Security
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
paragraphs: Jennifer Grover, Director, (202) 512-7141 or GroverJ@gao.gov.
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Stephen Caldwell (Director),  Christopher Conrad (Assistant Director), Lisa Canini, and Daniel  McKenna made key contributions to this report. Also contributing to this  report were Frances Cook, Eric Hauswirth, Tracey King, Stanley Kostyla,  Thomas Lombardi, Ruben Montes de Oca, Jessica Orr, and Mark  Ramage.
section_title: Related GAO Products
paragraphs: Maritime Critical Infrastructure Protection: DHS Needs to Better Address  Port Cybersecurity. GAO-14-459. Washington, D.C.: June 5, 2014.
Maritime Security: Progress and Challenges with Selected Port Security  Programs. GAO-14-636T. Washington, D.C.: June 4, 2014.
Maritime Security: Progress and Challenges in Key DHS Programs to  Secure the Maritime Borders. GAO-14-196T. Washington, D.C.:  November 19, 2013.
Supply Chain Security: DHS Could Improve Cargo Security by  Periodically Assessing Risks from Foreign Ports. GAO-13-764.  Washington, D.C.: September 16, 2013.
Supply Chain Security: CBP Needs to Conduct Regular Assessments of  Its Cargo Targeting System. GAO-13-9. Washington, D.C.: October 25,  2012.
Maritime Security: Progress and Challenges 10 Years after the Maritime  Transportation Security Act. GAO-12-1009T. Washington, D.C.:  September 11, 2012.
Supply Chain Security: Container Security Programs Have Matured, but  Uncertainty Persists over the Future of 100 Percent Scanning.  GAO-12-422T. Washington, D.C.: February 7, 2012.
Supply Chain Security: CBP Has Made Progress in Assisting the Trade  Industry in Implementing the New Importer Security Filing Requirements,  but Some Challenges Remain. GAO-10-841. Washington, D.C.:  September 10, 2010.
Supply Chain Security: Feasibility and Cost-Benefit Analysis Would Assist  DHS and Congress in Assessing and Implementing the Requirement to  Scan 100 Percent of U.S.-Bound Containers. GAO-10-12. Washington,  D.C.: October 30, 2009.
Supply Chain Security: Challenges to Scanning 100 Percent of U.S.- Bound Cargo Containers. GAO-08-533T. Washington, D.C.: June 12,  2008.
Supply Chain Security: U.S. Customs and Border Protection Has  Enhanced Its Partnership with Import Trade Sectors, but Challenges  Remain in Verifying Security Practices. GAO-08-240. Washington, D.C.:  April 25, 2008.
Supply Chain Security: Examinations of High-Risk Cargo at Foreign  Seaports Have Increased, but Improved Data Collection and Performance  Measures Are Needed. GAO-08-187. Washington, D.C.: January 25,  2008.