Homeland Security: Preliminary Observations on Efforts to Target Security Inspections of Cargo Containers
Published: 2003-12-16T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: After the attacks of September 11, 2001, concerns intensified that terrorists would attempt to smuggle a weapon of mass destruction into the United States. One possible method for terrorists to smuggle such a weapon is to use one of the 7 million cargo containers that arrive at our nation's seaports each year. The Department of Homeland Security's U.S. Customs and Border Protection (CBP) is responsible for addressing the potential threat posed by the movement of oceangoing cargo containers. Since CBP cannot inspect all arriving cargo containers, it uses a targeting strategy, which includes an automated targeting system. This system targets some containers for inspection based on a perceived level of risk. In this testimony, GAO provides preliminary findings on its assessment of (1) whether CBP's development of its targeting strategy is consistent with recognized key risk management and computer modeling practices and (2) how well the targeting strategy has been implemented at selected seaports around the country.
section_title: What GAO Found
paragraphs: CBP has taken steps to address the terrorism risks posed by oceangoing cargo containers. These include establishing a National Targeting Center, refining its automated targeting system, instituting a national training program for its personnel that perform targeting, and promulgating regulations to improve the quality and timeliness of data on cargo containers. However, while CBP's strategy incorporates some elements of risk management, it does not include other key elements, such as a comprehensive set of criticality, vulnerability and risk assessments that experts told GAO are necessary to determine risk and the types of responses necessary to mitigate that risk. Also, CBP's targeting system does not include a number of recognized modeling practices, such as subjecting the system to peer review, testing and validation. By incorporating the missing elements of a risk management framework and following certain recognized modeling practices, CBP will be in a better position to protect against terrorist attempts to smuggle weapons of mass destruction into the United States. CBP faces a number of challenges at the six ports we visited. CBP does not have a national system for reporting and analyzing inspection statistics and the data provided to us by ports were generally not available by risk level, were not uniformly reported, were difficult to interpret, and were incomplete. CBP officials told us they have just implemented a new module for their targeting system, but it is too soon to tell whether it will provide consistent, complete inspection data for analyzing and improving the targeting strategy. In addition, CBP staff that received the national targeting training were not tested or certified to ensure that they had learned the basic skills needed to provide effective targeting. Further, space limitations and safety concerns about inspection equipment constrained the ports in their utilization of screening equipment, which has affected the efficiency of examinations.

section_title: Letter
paragraphs: I appreciate the opportunity to be here today to participate in this hearing  on the security of oceangoing cargo containers. In the aftermath of the  terrorist attacks of September 11, 2001, there is heightened concern that  terrorists may try to smuggle weapons of mass destruction into a U.S. port  using one of the millions of cargo containers that arrive at our nation’s  seaports each year. If terrorists did so and detonated such a weapon (e.g.,  a nuclear or radiological explosive device) at a seaport, the incident could  cause widespread death and damage to the immediate area, perhaps shut  down seaports nationwide, cost the U.S. economy billions of dollars, and  seriously hamper international trade.
The Department of Homeland Security and its U.S. Customs and Border  Protection (CBP) are responsible for addressing the threat posed by  terrorist smuggling of weapons in oceangoing containers. To carry out this  responsibility, CBP uses a targeting strategy, which includes a  computerized model called the Automated Targeting System, to help select  (or “target”) containers for additional review and/or inspection.  Organizations that are involved in security matters, such as CBP,  frequently employ certain risk management practices, including computer  modeling, to help them prioritize their activities and use of resources. In  essence, risk management is a systematic process to analyze threats,  vulnerabilities, and critical assets to better support management decisions.
This statement presents the preliminary results from our latest effort in a  series of GAO reports that evaluate CBP’s response to the terrorist threat.  Based upon our ongoing assessment of CBP’s targeting strategy for this  subcommittee, I will provide our preliminary findings on (1) whether  CBP’s development of its targeting strategy is consistent with recognized  risk management and computer modeling practices and (2) how well the  targeting strategy has been implemented at selected seaports around the  country. Our preliminary findings are based on extensive data collection  and analysis at CBP, consultations with experts in terrorism and risk  management, visits to six seaports, and related interviews with federal and  local government and private sector officials responsible for port security  and operations. Additional information on our scope and methodology can  be found at the end of this statement. Our work focused primarily on the  targeting system rather than the sufficiency of inspections at the ports  once a container has been targeted.
subsections: section_title: Background
subsections: section_title: Maritime Cargo Containers Are Important and Vulnerable
paragraphs: Cargo containers are an important segment of maritime commerce.  Approximately 90 percent of the world’s cargo moves by container. Each  year, approximately 16 million oceangoing cargo containers enter the U.S.  carried aboard thousands of container vessels. In 2002, approximately 7  million containers arrived at U.S seaports, carrying more than 95 percent  of the nation’s non-North American trade by weight and 75 percent by  value. Many experts on terrorism—including those at the Federal Bureau  of Investigation and academic, think tank and business organizations— have concluded that the movement of oceangoing cargo containers are  vulnerable to some form of terrorist action. A terrorist incident at a  seaport, in addition to killing people and causing physical damage, could  have serious economic consequences. In a 2002 simulation of a terrorist  attack involving cargo containers, every seaport in the United States was  shut down, resulting in a loss of $58 billion in revenue to the U.S.  economy, including spoilage, loss of sales, and manufacturing slowdowns  and halts in production.
section_title: CBP Has A Layered Approach to Select and Inspect Cargo Containers
paragraphs: CBP is responsible for preventing terrorists and weapons of mass  destruction from entering the United States. As part of its responsibility, it  has the mission to address the potential threat posed by the movement of  oceangoing containers. To perform this mission, CBP has inspectors at the  ports of entry into the United States. While most of the inspectors assigned  to seaports perform physical inspections of goods entering the country,  some are “targeters”—they review documents and intelligence reports and  determine which cargo containers should undergo additional documentary  reviews and/or physical inspections. These determinations are not just  based on concerns about terrorism, but also concerns about illegal  narcotics and/or other contraband.
The CBP Commissioner said that the large volume of imports and its  limited resources make it impossible to physically inspect all oceangoing  containers without disrupting the flow of commerce. The Commissioner  also said it is unrealistic to expect that all containers warrant such  inspection because each container poses a different level of risk based on  a number of factors including the exporter, the transportation providers,  and the importer. These concerns led to CBP implementing a layered  approach that attempts to focus resources on potentially risky cargo  containers while allowing other cargo containers to proceed without  disrupting commerce.
As part of its layered approach, CBP employs its Automated Targeting  System (ATS) computer model to review documentation on all arriving  containers and help select or “target” containers for additional  documentary review and/or physical inspection. The ATS was originally  designed to help identify illegal narcotics in cargo containers. ATS  automatically matches its targeting rules against the manifest and other  available data for every arriving container, and assigns a level of risk (i.e.,  low, medium, high) to each container. At the port level, inspectors use  ATS, as well as other data (e.g., intelligence reports), to determine whether  to inspect a particular container. In addition, CBP has a program, called  the Supply Chain Stratified Examination, which supplements the ATS by  randomly selecting additional containers to be physically examined. The  results of the random inspection program are to be compared to the  results of ATS inspections to improve targeting. If CBP officials decide to  inspect a particular container, they might first use equipment such as the  Vehicle and Cargo Inspection System (VACIS) that takes a gamma-ray  image of the container so inspectors can see any visual anomalies. With or  without VACIS, inspectors can open a container and physically examine its  contents.
Other components of the layered approach include the Container Security  Initiative (CSI) and the Customs-Trade Partnership Against Terrorism (C- TPAT). CSI is an initiative whereby CBP places staff at designated foreign  seaports to work with foreign counterparts to identify and inspect high- risk containers for weapons of mass destruction before they are shipped  to the United States. C-TPAT is a cooperative program between CBP and  members of the international trade community in which private companies  agree to improve the security of their supply chains in return for a reduced  likelihood that their containers will be inspected.
section_title: Risk Management and Modeling Are Important Security Practices
paragraphs: Risk management is a systematic process to analyze threats,  vulnerabilities, and the criticality (or relative importance) of assets to  better support key decisions linking resources with prioritized efforts for  results. Risk management is used by many organizations in both  government and the private sector. In recent years, we have consistently  advocated the use of a risk management approach to help implement and  assess responses to various national security and terrorism issues. We  have concluded that without a risk management approach that provides  insights about the present threat and vulnerabilities as well as the  organizational and technical requirements necessary to achieve a  program’s goals, there is little assurance that programs to combat  terrorism are prioritized and properly focused. Risk management could  help to more effectively and efficiently prepare defenses against acts of  terrorism and other threats. Key elements of a risk management approach  are listed below.
Threat assessment: A threat assessment identifies adverse events that  can affect an entity, which may be present at the global, national, or  local level.
Vulnerability assessment: A vulnerability assessment identifies  weaknesses in physical structures, personnel protection systems,  processes or other areas that may be exploited by terrorists.
Criticality assessment: A criticality assessment identifies and evaluates  an entity’s assets or operations based on a variety of factors, including  importance of an asset or function.
Risk assessment: A risk assessment qualitatively and/or quantitatively  determines the likelihood of an adverse event occurring and the  severity, or impact, of its consequences.
Risk characterization: Risk characterization involves designating risk  on a scale, for example, low, medium, or high. Risk characterization  forms the basis for deciding which actions are best suited to mitigate  risk.
Risk mitigation: Risk mitigation is the implementation of mitigating  actions, taking into account risk, costs, and other implementation  factors.
Systems Approach: An integrated systems approach to risk  management encompasses taking action in all organizational areas,  including personnel, processes, technology, infrastructure, and  governance.
Monitoring and evaluation: Monitoring and evaluation is a continuous  repetitive assessment process to keep risk management current and  relevant. It includes external peer review, testing, and validation.
Modeling can be an important part of a risk management approach. To  assess modeling practices related to ATS, we interviewed terrorism  experts and representatives of the international trade community who  were familiar with modeling related to terrorism and/or ATS and reviewed  relevant literature. There are at least four recognized modeling practices  that are applicable to ATS as a decision-support tool.
Conducting external peer review: External peer review is a process  that includes an assessment of the model by independent and qualified  external peers. While external peer reviews cannot ensure the success  of a model, they can increase the probability of success by improving  the technical quality of projects and the credibility of the decision- making process.
Incorporating additional types of information: To identify documentary  inconsistencies, targeting models need to incorporate various types of  information to perform complex “linkage” analyses. Using only one  type of information will not be sufficient enough to yield reliable  targeting results.
Testing and validating through simulated terrorist events: A model  needs to be tested by staging simulated events to validate it as a  targeting tool. Simulated events could include “red teams” that devise  and deploy tactics in an attempt to define a system’s weaknesses, and  “blue teams” that devise ways to mitigate the resulting vulnerabilities  identified by the red team.
Using random inspections to supplement targeting: A random selection  process can help identify and mitigate residual risk (i.e., the risk  remaining after the model-generated inspections have been done), but  also help evaluate the performance of the model relative to other  approaches.
section_title: Positive Steps Taken, But Targeting Strategy Lacks Key Components Of Risk Management And Modeling
paragraphs: CBP has taken several positive steps to address the terrorism risks posed  by oceangoing cargo containers. For example, CBP established the  National Targeting Center to serve as the national focal point for targeting  imported cargo containers and distributing periodic intelligence alerts to  the ports. CBP also modified its ATS, which was originally designed to  identify narcotics contraband, to include targeting rules for terrorism that  could identify high-risk containers for possible physical screening and  inspection. In addition, CBP developed a training course for staff  responsible for targeting cargo containers. Further, CBP also promulgated  regulations aimed at improving the quality and timeliness of transmitted  cargo manifest data for use in the targeting system. However, while its  strategy incorporates some elements of risk management, CBP has not  performed a comprehensive set of threat, criticality, vulnerability and risk  assessments that experts said are vital for determining levels of risk for  each container and the types of responses necessary to mitigate that risk.  Regarding recognized modeling practices, CBP has not subjected ATS to  external peer review or testing as recommended by the experts we  contacted. Further, CBP has implemented a random inspection designed  to improve its targeting rules, but officials at ports can waive the  inspections.
subsections: section_title: CBP Has Taken Several Steps to Improve Its Targeting Strategy
paragraphs: CBP has recognized the potential threat posed by oceangoing cargo  containers and has reviewed and updated some aspects of its layered  targeting strategy. According to CBP officials, several of the steps that  CBP has taken to improve its targeting strategy have resulted in more  focused targeting of cargo containers that may hold weapons of mass  destruction. CBP officials told us that, given the urgency to take steps to  protect against terrorism after the September 11, 2001, terrorist attacks,  that they had to take an “implement and amend” approach. That is, they  had to immediately implement targeting activities with the knowledge they  would have to amend them later. Steps taken by CBP include the  following:  In November 2001, the U.S. Customs Service established the National  Targeting Center to serve as the national focal point for targeting  imported cargo for inspection. Among other things, the National  Targeting Center interacts with the intelligence community and  distributes to the ports any intelligence alerts it receives. The National  Targeting Center also assists targeters in conducting research on  incoming cargo, attempts to improve the targeting of cargo, and  manages a national targeting training program for CBP targeters.
In August 2002, CBP modified the ATS as an anti-terrorism tool by  developing terrorism-related targeting rules and implementing them  nationally. According to CBP officials responsible for ATS, these  targeting rules were developed in consultation with selected  intelligence agencies, foreign governments, and companies. CBP is now  in the process of enhancing the ATS terrorism-related rules. The  newest version of the ATS rules, which is still being tested, gives added  risk points when certain rules apply collectively to the same container.  CBP refers to this as the “bundling” of rules. In these circumstances,  CBP would assume an elevated level of risk for the cargo. Related to  this, CBP is currently in the process of developing and implementing  further enhancements—known as the “findings module”—to capture  additional information related to individual inspections of cargo  containers, such as whether an inspection resulted in the discovery of  contraband.
In 2002, CBP also developed a 2-week national training course to train  staff in targeting techniques. The course is intended to help ensure that  seaport targeters have the necessary knowledge and ability to conduct  effective targeting. The course is voluntary and is conducted  periodically during the year at the Los Angeles, Long Beach and Miami  ports, and soon it will be conducted at the National Targeting Center.  In fiscal year 2003, approximately 442 inspectors completed the formal  training and CBP plans to train an additional 374 inspectors in fiscal  year 2004.
In February 2003, CBP began enforcing new regulations about cargo  manifests—called the “24 hour rule”—which requires the submission of  complete and accurate manifest information 24 hours before a  container is loaded on a ship at a foreign port. Penalties for non- compliance can include a CBP order not to load a container on a ship  at the port of origin or monetary fines. The rule is intended to improve  the quality and timeliness of the manifest information submitted to  CBP, which is important because CBP relies extensively on manifest  information for targeting. According to CBP officials we contacted,  although no formal evaluations have been done, the 24-hour rule is  beginning to improve both the quality and timeliness of manifest  information. CBP officials acknowledged, however, that although  improved, manifest information still is not always accurate or reliable  data for targeting purposes.
section_title: Targeting Strategy Does Not Incorporate Key Elements of Risk Management
paragraphs: While CBP’s targeting strategy incorporates some elements of risk  management, our discussions with terrorism experts and our comparison  of CBP’s targeting system to recognized risk management practices  showed that the strategy does not fully incorporate all key elements of a  risk management framework. Elements not fully incorporated are  discussed below.
CBP has not performed a comprehensive set of assessments for cargo  containers. CBP has attempted to assess the threat of cargo containers  through contact with governmental and non-governmental sources.  However, it has not assessed the vulnerability of cargo containers to  tampering or exploitation throughout the supply chain, nor has it  assessed which port assets and operations are the most critical in  relation to their mission and function. These assessments, in addition  to threat assessments, are needed to understand and identify actions to  mitigate risk.
CBP has not conducted a risk characterization for different forms of  cargo, or the different modes of transportation used to import cargo.  CBP has made some efforts in this regard by characterizing the risk of  each oceangoing cargo containers as either low, medium, or high-risk.  But, CBP has not performed a risk characterization to assess the  overall risk of cargo containers, or determine how this overall risk  characterization of cargo containers compares with sea cargo arriving  in other forms, such as bulk cargo (e.g., petroleum and chemical gas  shipments) or break-bulk cargo (e.g., steel and wood shipments).  Additionally, CBP has not conducted risk characterization to compare  the risk of cargo containers arriving by sea with the risk of cargo  containers (or other cargo) arriving by other modes, such as truck or  rail. These characterizations would enable CBP to better assess and  prioritize the risks posed by oceangoing cargo containers and  incorporate mitigation activities in an overall strategy.
CBP actions at the ports to mitigate risk are not part of an integrated  systems approach. Risk mitigation encompasses taking action in all  organizational areas, including personnel, processes, technology,  infrastructure, and governance. An integrated approach would help  assure that taking action in one or more areas would not create  unintended consequences in another. For example, taking action in the  areas of personnel and technology—adding inspectors and scanning  equipment at a port—without at the same time ensuring that the port’s  infrastructure is appropriately reconfigured to accept these additions  and their potential impact (e.g., more physical examinations of  containers), could add to already crowded conditions at that port and  ultimately defeat the purpose of the original actions.
We recognize that CBP implemented the ATS terrorist targeting rules in  August 2002 due to the pressing need to utilize a targeting strategy to  protect cargo containers against terrorism, and that CBP intends to amend  the strategy as necessary. However, implementing a comprehensive risk  management framework would help to ensure that information is available  to management to make choices about the best use of limited resources.  This type of information would help CBP obtain optimal results and would  identify potential enhancements that are well-conceived, cost-effective,  and work in tandem with other system components. Thus, it is important  for CBP to amend its targeting strategy within a risk management  framework that takes into account all of the system’s components and  their vital linkages.
section_title: Targeting Strategy Not Consistent With Key Recognized Modeling Practices
paragraphs: Interviews with terrorism experts and representatives from the  international trade community who are familiar with CBP’s targeting  strategy and/or terrorism modeling told us that the ATS is not fully  consistent with recognized modeling practices. Challenges exist in each of  the four recognized modeling practice areas that these individuals  identified: external peer review, incorporating different types of  information, testing and validating through simulated events, and using  random inspections to supplement targeting.
With respect to external review, CBP consulted primarily with in-house  subject matter experts when developing the ATS rules related to  terrorism. CBP officials told us that they considered these  consultations to be an extensive process of internal, or governmental,  review that helped adapt ATS to meet the terrorist threat. With a few  exceptions, CBP did not solicit input from the extended international  trade community or from external terrorism and modeling experts.
With respect to the sources and types of information, ATS relies on the  manifest as its principal data input, and CBP does not mandate the  transmission of additional types of information before a container’s  risk level is assigned. Terrorism experts, members of the international  trade community, and CBP inspectors at the ports we visited  characterized the ship’s manifest as one of the least reliable or useful  types of information for targeting purposes. In this regard, one expert  cautioned that even if ATS were an otherwise competent targeting  model, there is no compensating for poor input data. Accordingly, if the  input data are poor, the outputs (i.e., the risk assessed targets) are not  likely to be of high quality. Another problem with manifests is that  shippers can revise them up to 60 days after the arrival of the cargo  container. According to CBP officials, about one third of these manifest  revisions resulted in higher risk scores by ATS—but by the time these  revisions were received, it is possible that the cargo container may  have left the port. These problems with manifest data increase the  potential value of additional types of information.
With respect to testing and validation, CBP has not attempted to test  and validate ATS through simulated events. The National Targeting  Center Director told us that 30 “events” (either real or simulated) are  needed to properly test and validate the system. Yet CBP has not  conducted such simulations to test and validate the system. Without  testing and validation, CBP will not know whether ATS is a statistically  valid model and the extent to which it can identify high-risk containers  with reasonable assurance. The only two known instances of simulated  tests of the targeting system were conducted without CBP’s approval  or knowledge by the American Broadcast Company (ABC) News in  2002 and 2003. In an attempt to simulate terrorist smuggling highly  enriched uranium into the United States, ABC News sealed depleted  uranium into a lead-lined pipe that was placed into a suitcase and later  put into a cargo container. In both instances, CBP targeted the  container that ABC News used to import the uranium, but it did not  detect a visual anomaly from the lead-lined pipe using the VACIS and  therefore did not open the container.
With respect to instituting random inspections, CBP has a process to  randomly select and examine containers regardless of the risk. The  program—the Supply Chain Stratified Examination—measures  compliance with trade laws and refocused it to measure border  security compliance. One aspect of this new program is random  inspections. However, CBP guidance states that port officials may  waive the random inspections if available resources are needed to  conduct inspections called for by ATS targeting or intelligence tips.  Accordingly, although the containers targeted for inspection may be  randomly selected, the containers being inspected from the program  may not be a random representation. Therefore, CBP may not be able  to learn all possible lessons from the program and, by extension, may  not be in a position to use the program to improve the ATS rules.
section_title: Targeting Strategy Faces Implementation Challenges
paragraphs: Our visits to six seaports found that the implementation of CBP’s targeting  strategy faces a number of challenges. Specifically, CBP does not have a  uniform national system for reporting and analyzing inspection statistics  by risk category that could be used for program management and  oversight. We also found that the targeters at ports that completed the  national training program were not tested and certified, so there is no  assurance that they have the necessary skills to perform targeting  functions. Further, we found that space limitations and safety concerns  constrain the ports in their utilization of screening equipment, which can  affect the efficiency of examinations.
subsections: section_title: CBP Lacks National System To Track Cargo Container Inspections By Risk Category
paragraphs: A CBP official told us that CBP does not have a national system for  reporting and analyzing inspection statistics by risk category. While  officials at all the ports provided us with inspection data, the data from  some ports were generally not available by risk level, were not uniformly  reported, were difficult to interpret, and were not complete. In addition,  we had to contact ports several times to obtain these data, indicating that  basic data on inspections were not readily available. All five ports that  gave information on sources of data said they had extracted data from the  national Port Tracking System. However, this system did not include  information on the number of non-intrusive examinations or physical  examinations conducted, according to risk category. Moreover, a CBP  headquarters official stated that the data in the Port Tracking System are  error prone, including some errors that result from double counting. One  port official told us that the Port Tracking System was not suitable for  extracting the examination information we had requested, so they had  developed a local report to track and report statistics. Our findings are  consistent with a March 2003 Treasury Department Inspector General  Report which found, among other things, that inspection results were not  documented in a consistent manner among the ports and examination  statistics did not accurately reflect inspection activities. A CBP official  said that they are in the process of developing a replacement for the Port  Tracking System to better capture enforcement statistics but this new  system is still in its infancy.
Separately, CBP officials said that they are trying to capture the results of  cargo inspections through an enhancement to ATS called the findings  module. A National Targeting Center official stated that the findings  module would allow for more consistency in capturing standardized  inspection results and would also serve as a management control tool.  National Targeting Center officials said that the module would be able to  categorize examination results according to the level of risk. A CBP  official told us the module was being implemented nationwide in late  November 2003. While the ATS findings module shows potential as a  useful tool for capturing inspection results, it is too soon to tell whether it  will provide CBP management with consistent, complete inspection data  for analyzing and improving the targeting strategy.
section_title: Staff Testing and Certification Could Help Strengthen Targeting Process
paragraphs: While over 400 targeters have completed the new national targeting  training, CBP has no mechanism to test or certify their competence. These  targeters play a crucial role because they are responsible for making  informed decisions about which cargo containers will be inspected and  which containers will be released. According to National Targeting Center  officials, the goal is for each U.S. seaport to have at least one targeter who  has completed national targeting training so that the knowledge and skills  gained at the training course can be shared with other targeters at their  port of duty. To train other staff, however, the targeter who took the  training must have attained a thorough understanding of course contents  and their application at the ports. Because the targeters who complete the  training are not tested or certified on course materials, CPB has little  assurance that the targeters could perform their duties effectively or that  they could train others to perform effectively.
CBP could have better assurance that staff can perform well if CBP tested  or certified their proficiency after they have completed the national  targeting training. This would also increase the likelihood that course  participants are in a position to effectively perform targeting duties and  could train others at the ports on how to target potentially suspicious  cargo. Further, it would lessen the likelihood that those who did not do  well in class are placed in these important positions. Such testing and  certification of targeting proficiency would demonstrate CBP’s intent to  ensure that those responsible for making decisions about whether and  how to inspect containers have the knowledge and skills necessary to  perform their jobs well.
section_title: Space Limitations and Safety Concerns Constrain Use Of Inspection Equipment
paragraphs: One of the key components of the CBP targeting and inspection process is  the use of non-intrusive inspection equipment. CBP uses inspection  equipment, including VACIS gamma-ray imaging technology, to screen  selected cargo containers and to help inspectors decide which containers  to further examine. A number of factors constrain the use of non-intrusive  inspection equipment, including crowded port terminals, mechanical  breakdowns, inclement weather conditions, and the safety concerns of  longshoremen at some ports. Some of these constraints, such as space  limitations and inclement weather conditions, are difficult if not  impossible to avoid.
According to CBP and union officials we contacted, concern about the  safety of VACIS is a constraint to using inspection equipment. Union  officials representing longshoremen at some ports expressed concerns  about the safety of driving cargo containers through the VACIS because it  emits gamma rays when taking an image of the inside of the cargo  container. Towing cargo containers through a stationary VACIS unit  reportedly takes less time and physical space than moving the VACIS  equipment over stationary cargo containers that have been staged for  inspection purposes. As a result of these continuing safety concerns, some  longshoremen are unwilling to drive containers through the VACIS. CBP’s  response to these longshoremen’s concerns has been to stage containers  away from the dock, arraying containers in rows at port terminals so that  the VACIS can be driven over a group of containers for scanning purposes.  However, as seaports and port terminals are often crowded, and there is  often limited space to expand operations, it can be space-intensive and  time consuming to stage containers. Not all longshoremen’s unions have  safety concerns regarding VACIS inspections. For example, at the Port of  New York/New Jersey, longshoremen’s concerns over the safety of  operating the VACIS were addressed after the union contacted a  consultant and received assurances about the safety of the equipment.  Similar efforts by CBP to convince longshoremen’s unions about the safety  of VACIS have not been successful at some of the other ports we visited.
In closing, as part of a program to prevent terrorists from smuggling  weapons of mass destruction into the United States, CBP has taken a  number of positive steps to target cargo containers for inspection.  However, we found several aspects of their targeting strategy are not  consistent with recognized risk management and modeling practices. CBP  faces a number of other challenges in implementing its strategy to identify  and inspect suspicious cargo containers. We are now in the process of  working with CBP to discuss our preliminary findings and to develop  potential recommendations to resolve them. We plan to provide the  subcommittee with our final report early next year.
This concludes my statement. I would now be pleased to answer any  questions for the subcommittee.
section_title: Contacts and Acknowledgments
paragraphs: For further information about this testimony, please contact me at (202)  512-8816. Seto Bagdoyan, Stephen L. Caldwell, Kathi Ebert, Jim Russell,  Brian Sklar, Keith Rhodes, and Katherine Davis also made key  contributions to this statement.
section_title: Appendix: Scope And Methodology
paragraphs: To assess whether the CBP’s development of its targeting strategy is  consistent with recognized risk management and modeling practices, we  compiled a risk management framework and recognized modeling  practices, drawn from an extensive review of relevant public and private  sector work, prior GAO work on risk management, and our interviews  with terrorism experts. We selected these individuals based on their  involvement with issues related to terrorism, specifically concerning  containerized cargo, the ATS, and modeling. Several of the individuals that  we interviewed were referred from within the expert community, while  others were chosen from public texts on the record. We did not assess  ATS’s hardware or software, the quality of the threat assessments that  CBP has received from the intelligence community, or the appropriateness  or risk weighting of its targeting rules.
To assess how well the targeting strategy has been implemented at  selected seaports in the country, we visited various CBP facilities and the  Miami, Los Angeles-Long Beach, Philadelphia, New York-New Jersey, New  Orleans, and Seattle seaports. These seaports were selected based on the  number of cargo containers processed and their geographic dispersion. At  these locations, we observed targeting and inspection operations; met with  CBP management and inspectors to discuss issues related to targeting and  the subsequent physical inspection of containers; and reviewed relevant  documents, including training and operational manuals, and statistical  reports of targeted and inspected containers. At the seaports, we also met  with representatives of shipping lines, operators of private cargo  terminals, the local port authorities, and Coast Guard personnel  responsible for the ports’ physical security. We also met with terrorism  experts and representatives from the international trade community to  obtain a better understanding of the potential threat posed by cargo  containers and possible approaches to countering the threat, such as risk  management.
We conducted our work from January to November 2003 in accordance  with generally accepted government auditing standards.
section_title: Related GAO Products
paragraphs: Maritime Security: Progress Made in Implementing Maritime  Transportation Security Act, but Concerns Remain. GAO-03-1155T.  Washington, D.C.: September 9, 2003.
Container Security: Expansion of Key Customs Programs Will Require  Greater Attention to Critical Success Factors. GAO-03-770. Washington,  D.C.: July 25, 2003.
Homeland Security: Challenges Facing the Department of Homeland  Security in Balancing its Border Security and Trade Facilitation  Missions. GAO-03-902T. Washington, D.C.: June 16, 2003.
Container Security: Current Efforts to Detect Nuclear Material, New  Initiatives, and Challenges. GAO-03-297T. Washington, D.C.: November  18, 2002.
Customs Service: Acquisition and Deployment of Radiation Detection  Equipment. GAO-03-235T. Washington, D.C.: October 17, 2002.
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