Cargo Container Inspections: Preliminary Observations on the Status of Efforts to Improve the Automated Targeting System
Published: 2006-03-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: U.S. Customs and Border Protection's (CBP) Automated Targeting System (ATS)--a computerized model that CBP officers use as a decision support tool to help them target oceangoing cargo containers for inspection--is part of CBP's layered approach to securing oceangoing cargo. GAO reported in February 2004 on challenges CBP faced in targeting oceangoing cargo containers for inspection and testified before Congress in March 2004 about the findings in that report. The report and testimony outlined recommendations aimed at (1) better incorporating recognized modeling practices into CBP's targeting strategy, (2) periodically adjusting the targeting strategy to respond to findings that occur during the course of its operation, and (3) improving implementation of the targeting strategy. This statement for the record discusses preliminary observations from GAO's ongoing work related to ATS and GAO's 2004 recommendations addressing the following questions: (1) What controls does CBP have in place to provide reasonable assurance that ATS is effective at targeting oceangoing cargo containers with the highest risk of smuggled weapons of mass destruction? (2) How does CBP systematically analyze security inspection results and incorporate them into ATS? and (3) What steps has CBP taken to better implement the rest of its targeting strategy at the seaports?
section_title: What GAO Found
paragraphs: CBP has not yet put key controls in place to provide reasonable assurance that ATS is effective at targeting oceangoing cargo containers with the highest risk of containing smuggled weapons of mass destruction. To provide assurance that ATS targets the highest-risk cargo containers as intended, CBP is (1) working to develop and implement performance measures related to the targeting of cargo containers, (2) planning to compare the results of its random inspections with its ATS inspection results, (3) working to develop and implement a testing and simulation environment, and (4) addressing recommendations contained in a 2005 peer review of ATS. CBP expects to begin using performance measures in June 2006 and enter the final phase of software development for its testing and simulation environment at the same time. However, to date, none of these four initiatives has been fully implemented. Thus, CBP does not yet have key internal controls in place to be reasonably confident that ATS is providing the best information to allocate resources for targeting and inspecting containers that are the highest risk and not overlook inspecting containers that pose a threat to the nation. CBP does not yet have a comprehensive, integrated system in place to analyze security inspection results and incorporate them into ATS. CBP currently adjusts ATS based on intelligence information it receives and has initiated a process to track suggestions submitted by CBP targeting officers at the seaports for modifying ATS. However, CBP has not yet implemented plans to refine ATS based on findings from routine security inspections. Without a more comprehensive feedback system, CBP is limited in refining ATS, a fact that could hinder the overall effectiveness of the targeting strategy. CBP has taken steps to improve implementation of the targeting strategy at the seaports. It has implemented a testing and certification process for its officers who complete the Sea Cargo Targeting Course that should provide better assurance of effective targeting practices. CBP has also made a good faith effort to address longshoremen's safety concerns regarding radiation emitted by nonintrusive inspection equipment by taking actions such as working with longshoremen's unions and other maritime organization to develop public radiation tests on the nonintrusive inspection equipment. Nevertheless, CBP has not been able to persuade one longshoremen's union to permit changes in the procedure for staging containers to increase inspection efficiency at some West Coast seaports where the union's members work.

section_title: Letter
paragraphs: I appreciate the opportunity to comment on our ongoing work on the U.S.  Customs and Border Protection’s (CBP) Automated Targeting System  (ATS)—a computerized model that CBP officers use as a decision support  tool to help them target oceangoing cargo containers for inspection.
In the aftermath of the terrorist attacks of September 11, 2001, there is  heightened concern that terrorists will attempt to smuggle a weapon of  mass destruction (e.g., a nuclear, biological, or radiological explosive  device) into the United States using one of the 11 million cargo containers  that arrive at our nation’s seaports. Because of the large volume of  imported containers, CBP maintains that it is unable to physically inspect  all oceangoing containers without disrupting the flow of commerce. Thus,  CBP uses a multilayered strategy for addressing the threat posed by the  movement of oceangoing containers, of which ATS is a key component.  CBP uses ATS to review documentation and assign a risk score for all  containers destined for U.S. ports. CBP officers located at domestic ports  or at 1 of the 40 foreign ports that participate in the Container Security  Initiative (CSI) then use these scores to help them make decisions on the  extent of additional documentary review and possible physical inspection  that will be conducted at the seaport.
We previously reported in February 2004 on the challenges CBP faced in  targeting oceangoing cargo containers for inspection and testified before  this Subcommittee in March 2004 about the findings in that report.  The  report and testimony outlined recommendations aimed at (1)  incorporating recognized modeling practices into its targeting strategy,  such as conducting simulated events and initiating an external peer  review, (2) periodically adjusting the targeting strategy to respond to  findings that occur during the course of its operation, and (3) improving  implementation of the targeting strategy at domestic seaports. This  subcommittee and other congressional requesters asked that we ascertain  whether CBP had implemented the recommendations we made to improve  the targeting strategy. Our work, in response to this request, has been  under way since last October, and we expect to complete the work and  provide this subcommittee and our other requesters with a report on the  final results later this year. In this statement, I will discuss our preliminary  observations on the status of these recommendations as part of the  following questions:    What controls does CBP have in place to provide reasonable assurance  that ATS is effective at targeting oceangoing cargo containers with the  highest risk of smuggled weapons of mass destruction?
How does CBP systematically analyze security inspection results and  incorporate them into ATS?
What steps has CBP taken to better implement the rest of its targeting  strategy at the seaports?
To address these questions, we interviewed CBP officials in headquarters  and visited six seaports: Baltimore, Charleston, Los Angeles-Long Beach,  Miami, New York-New Jersey, and Savannah. Because we did not select a  random sample of ports to visit, the results from these visits cannot be  generalized to ports nationwide. We also met with CBP’s contractor  responsible for conducting CBP’s peer review of ATS and longshoremen’s  union representatives. We reviewed CBP’s policies and procedures for  targeting and inspecting shipments, and its documentation on intelligence  gathering and dissemination, targeting strategies, random inspections,  training, and radiation safety as well as its peer review report. We also  examined information on officers trained and certified in CBP’s Sea Cargo  Targeting Training course. We did not independently validate the  reliability of CBP’s targeting results or test the effectiveness of ATS. We  conducted our work in response to this request from October 2005  through March 2006 in accordance with generally accepted government  auditing standards. Appendix I contains more detailed information on our  scope and methodology.
subsections: section_title: Background
paragraphs: Oceangoing cargo containers have an important role in the movement of  cargo between global trading partners. Approximately 90 percent of the  world’s trade is transported in cargo containers. In the United States  almost half of incoming trade (by value) arrives by containers aboard  ships. If terrorists smuggled a weapon of mass destruction into the nation  using a cargo container and detonated such a weapon 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 CBP are responsible for  addressing the threat posed by terrorist smuggling of weapons in  oceangoing containers. To carry out this responsibility, CBP uses a layered  security strategy. One key element of this strategy is ATS. CBP uses ATS  to review documentation, including electronic manifest information  submitted by the ocean carriers on all arriving shipments, to help identify  containers for additional inspection. CBP requires the carriers to submit  manifest information 24 hours prior to a United States-bound sea  container being loaded onto a vessel in a foreign port. ATS is a complex  mathematical model that uses weighted rules that assign a risk score to  each arriving shipment in a container based on manifest information. As  previously discussed, CBP officers use these scores to help them make  decisions on the extent of documentary review or physical inspection to  be conducted.
ATS is an important part of other layers in the security strategy. Under its  CSI program, 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.  At these foreign seaports, CBP officials use ATS to help target shipments  for inspection by foreign customs officials prior to departing for the  United States. Approximately 73 percent of cargo containers destined for  the United States originate in or go through CSI ports.
ATS is also an important factor in the Customs-Trade Partnership Against  Terrorism (C-TPAT) program. C-TPAT is a cooperative program linking  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.  Specifically, C-TPAT members receive a range of benefits, some of which  could change the ATS risk characterization of their shipments, thereby  reducing the probability of extensive documentary and physical  inspection.
section_title: CBP Currently Does Not Have Reasonable Assurance That ATS Is Effective
paragraphs: CBP does not yet have key controls in place to provide reasonable  assurance that ATS is effective at targeting oceangoing cargo containers  with the highest risk of containing smuggled weapons of mass destruction.  To address this shortcoming, CBP is (1) developing and implementing  performance metrics to measure the effectives of ATS, (2) planning to  compare the results of randomly conducted inspections with the results of  its ATS inspections, (3) developing and implementing a simulation and  testing environment, and (4) addressing recommendations contained in a  2005 peer review. To date, none of these control activities have been fully  completed or implemented. Thus, CBP does not yet have key internal  controls in place to be reasonably certain that ATS is providing the best  available information to allocate resources for targeting and inspecting  containers that are the highest risk and thus not overlook inspecting  containers that pose a high threat to the nation.
subsections: section_title: CBP Does Not Yet Have Performance Measures to Gauge the Effectiveness of ATS in Targeting Cargo Containers, But is Working to Develop Them
paragraphs: CBP does not yet have performance measures in place to help it determine  the effectiveness of ATS at targeting oceangoing cargo containers with the  highest risk of smuggled weapons of mass destruction. The Comptroller  General’s internal control standards include the establishment and review  of performance measures as one example of a control activity to help an  entity ensure it is achieving effective results.  In July 2005, CBP  contracted with a consulting firm to develop such performance metrics.  CBP officials and personnel from this consulting firm told us that the  firm’s personnel analyzed shipment information in ATS over a 2-year  period to obtain additional insights into ATS’s performance and to  determine whether ATS is more effective at targeting cargo containers for  terrorism related risk than a random sampling inspection approach. CBP  officials told us that the consulting firm’s personnel prepared a draft of the  results of their analyses and that, as of March 21, 2006, CBP officials are  reviewing these analyses. They also said that the consulting firm’s  personnel are documenting the methodology for their analyses and related  performance measures that CBP can use in the future. CBP officials  expect to receive this methodology and the performance measures in April  2006, and told us that they expect to begin using the measures in June  2006. CBP officials also told us that they initially planned to have  performance measures developed by August 31, 2005, but that this process  has taken longer than expected because of delays in (1) obtaining security  clearances for the consulting firm’s personnel, (2) obtaining workspace for  the firm’s staff, and (3) arranging for the appropriate levels of access to  CBP’s information systems.
section_title: CBP Is Not Yet Using the Results of Random Inspections to Assess ATS Effectiveness
paragraphs: Currently, CBP is not using the results of its random sampling program to  assess the effectiveness of ATS. As part of its Compliance Measurement  Program, CBP plans to randomly select 30,000 shipments based on entry  information submitted by the trade community and examine those  shipments to ensure compliance with supply chain security during fiscal  year 2006.
At this time, CBP is unable to compare the examination results from its  random sampling program with its ATS inspection results, as we  recommended in our 2004, report because CBP does not yet have an  integrated, comprehensive system in place to compare multiple sets of  data—like results of random inspections with results of routine ATS  inspections that were triggered by ATS scores and other operational  circumstances. Such a comparison would allow examination of if and why  the outcomes of ATS’s weighted rule sets are not consistent with the  expected outcomes possible in the universe of cargo containers, based on  sample projections. Furthermore, the Comptroller General’s standards for  internal control state that information should be recorded and  communicated to management and others within the entity who need it in  a form that enables them to carry out their responsibilities.
section_title: CBP Has Not Yet Tested the Effectiveness of ATS in Targeting Cargo Containers for Inspection but Has Plans to Do So
paragraphs: Currently, CBP does not conduct simulated events (e.g., covert tests and  computer-generated simulations)—a key control activity—to test and  validate the effectiveness of ATS in targeting oceangoing cargo containers  with the highest risk of containing smuggled weapons of mass destruction  and has not yet implemented a dedicated simulation and testing  environment. Without testing and validation, CBP lacks a vital mechanism  for evaluating ATS’s ability to identify high-risk containers.
In July 2005, CBP contracted with a consulting firm to obtain assistance in  the development of a computer-generated simulation and testing  environment. CBP officials report that they have the simulation  environment infrastructure in place and have processed mock manifest  data to simulate cargo linked to terrorism in the new environment. CBP is  currently reviewing the results of this test. Further, CBP officials told us  that the consulting firm is continuing to work with CBP to develop system  requirements so that officers can effectively use the simulation  environment. CBP expects to receive the consulting firm’s final input for  the simulation and testing environment by June 2006. CBP officials said  that they cannot estimate when this simulation and testing environment  will be fully operational until CBP receives the consulting firm’s final  product. As with the development of performance measures, CBP officials  also told us that this process has taken longer than expected because of   delays in (1) obtaining security clearances for the consulting firm’s  personnel, (2) obtaining workspace for the firm’s staff, and (3) arranging  for the appropriate levels of access to CBP’s information systems.
As we reported in 2004, terrorism experts suggested that testing ATS by  covertly simulating a realistic event using probable methods of attack  would give CBP an opportunity to examine how ATS would perform in an  actual terrorist situation. CBP officials told us that although they are  considering implementing this kind of practice, they do not currently have  a program in place to conduct such tests. The Director of CBP’s  Management Inspections and Integrity Assurance office told us that in  mid-April 2006, his office will be presenting a proposal to the Acting  Commissioner and other senior management to request initiation of a  program to conduct testing of the CSI program that will include testing  ATS to help ensure that it is appropriately targeting the highest-risk cargo  in the CSI program.
section_title: CBP Is Working to Address Peer Review Recommendations
paragraphs: In response to our 2004 recommendation that CBP initiate an external  peer review of ATS, CBP contracted with a consulting firm to evaluate  CBP’s targeting methodology and recommend improvements.  Specifically, the contractor identified strengths of the CBP targeting  methodology and compared ATS with other targeting methodologies.  However, the peer review did not evaluate the overall effectiveness of ATS  because CBP did not have the systems in place to allow the contractor to  do so.
The contractor’s final report, issued in April 2005, identified many  strengths in the ATS targeting methodology, such as a very capable and  highly dedicated team and the application of a layered approach to  targeting. It also made several recommendations to improve the targeting  methodology that included control activities, such as (1) the development  of performance measures, (2) the development of a simulation and testing  environment, (3) the development and implementation of a structured  plan for continual rules enhancement, and (4) an evaluation and  determination of the effectiveness of the ATS targeting rules, several of  which reinforced the recommendations we made in our 2004 report.
CBP issued a detailed plan, which projected delivery dates, for responding  to the recommendations made in the contractor’s final report. However,  about half of these dates have not been met. For example, CBP projected  that it would have its testing and simulation environment in place by  September 30, 2005. Although CBP has been working on this effort, the  environment has not yet been implemented. As previously discussed, CBP  officials said that they cannot provide a current estimate of when this  simulation and testing environment will be fully operational.
section_title: Although CBP Strives to Refine ATS for Intelligence Information and Officer Feedback, It Is Not Yet Positioned to Use Inspection Results
paragraphs: CBP strives to refine ATS to include intelligence information it acquires  and feedback it receives from its targeting officers at the seaports, but it is  not able to systematically adjust ATS for inspection results. CBP does not  have a comprehensive, integrated system in place to report details on  security inspections nationwide that will allow management to analyze  those inspections and refine ATS. CBP officials said that they are  developing a system that will allow them to do so but did not know when  it will be fully operational. CBP officials cautioned that because an  inspection does not identify any contraband or a weapon of mass  destruction or its components, it may not necessarily indicate that a  particular rule is not operating as intended. They noted that terrorist  incidents may happen infrequently, and the rule therefore might operate  only when weapons, materials, or other dangerous contraband is actually  shipped. However, without analyzing and using security inspection results  to adjust ATS, CBP is limited in refining ATS, a fact that could hinder the  effectiveness of CBP’s overall targeting strategy.
subsections: section_title: CBP Adjusts ATS for Targeting Cargo Containers for Inspection Based on Intelligence
paragraphs: CBP adjusts ATS’s rules and weights for targeting cargo containers for  inspection in response to intelligence received on an ongoing basis. CBP’s  Office of Intelligence (OINT) is responsible for acquiring, reviewing,  analyzing, and disseminating intelligence. OINT officials told us they  receive information from the intelligence community, which includes  federal agencies such as the Central Intelligence Agency and the Federal  Bureau of Investigation. According to OINT officials, OINT disseminates  information to CBP’s offices at the seaports to, among other things,  support these offices’ targeting efforts related to cargo containers. For  example, the targeting officers may use information provided by OINT to  search ATS for information about shipments and containers. OINT  officials said they also disseminate information to CBP’s senior  management to inform them about risks associated with cargo containers.  CBP uses intelligence information to refine its targeting of cargo  containers for inspection by incorporating the intelligence information  into ATS to readily identify containers whose manifest information may  match or be similar to data contained in the intelligence information.
CBP documentation and our observations showed that CBP headquarters  personnel incorporate intelligence information into ATS by adjusting  ATS’s existing rules and weights and creating new rules and weights that  result in a higher risk score being assigned to a container whose manifest  information may match or be similar to data contained in the intelligence  information. CBP officers can also conduct queries or create lookouts in  ATS that will search all manifest data in the system to identify those  containers whose manifest information may match or be similar to data  contained in the intelligence information. Once ATS identifies these  containers, CBP officers are to then designate these containers for  inspection. When CBP receives credible intelligence information that  requires immediate action, CBP officials also report that they can initiate a  special operation to address specific concerns identified in the intelligence  data. CBP officials at the six seaports we visited reported that they  sometimes receive intelligence information from local sources such as  state and local law enforcement. Officials at five of these seaports  reported that they will use such information to help them make decisions  regarding targeting efforts. Additionally, officials at five of the six seaports  we visited said that if the information they receive has national  implications, they will notify CBP headquarters personnel, who will make  a determination regarding potential adjustments to ATS.
section_title: CBP Targeting Officers at the Seaports Have Provided Few Suggestions for Adjusting ATS
paragraphs: In the late summer of 2005, CBP headquarters initiated a process to  formally track its targeting officers’ suggestions to enhance ATS for  targeting cargo containers for inspection. Targeting officers at all six  seaports we have visited are aware of the process for providing  suggestions to CBP headquarters. According to documentation maintained  by headquarters, CBP officers at the seaports have provided few  suggestions to date.
CBP headquarters officials said that although they have received few  suggestions for modifying ATS, they do not believe this is an indication of  ATS’s effectiveness. These officials stated that overall the feedback they  have received from CBP targeting officers at the seaports related to the  operation and usefulness of ATS has been positive.
We reviewed the report CBP uses to track these suggestions and found  that since it was established, CBP headquarters has received 20  suggestions for enhancing the ATS component responsible for targeting  oceangoing cargo containers for inspection. Some of these suggestions  relate to modifying ATS’s rules, while others focused on other aspects of  ATS such as enhancing the organization and presentation of ATS screens  by changing the size of an icon and the fonts or text used.
section_title: CBP Is Not Using Inspection Results to Systematically Adjust ATS, but It Is Developing a System to Allow it to Do So
paragraphs: CBP is not using inspection results to systematically adjust ATS for  targeting cargo containers for inspection because CBP does not yet have a  comprehensive, integrated system in place that can report sufficient  details for analyzing inspection results. CBP officials said that although  they can analyze inspection results on a case-by-case basis to identify  opportunities to refine ATS, such as when an inspection results in a  seizure of some type of contraband, they currently do not have a reporting  mechanism in place that will allow them to view inspection results  nationwide to identify patterns for systematically adjusting ATS. CBP is  developing the Cargo Enforcement Reporting Tracking System (CERTS)  to document, among other things, all cargo examinations so that  documentation substantiating the examinations will be available for  analysis by management to adjust ATS. CBP officials said they will begin  testing CERTS in the spring of 2006.  CBP officials told us that once testing  of CERTS is complete, they will be in a better position to estimate when   CERTS can be fully implemented.
CBP officials cautioned that because an inspection does not identify any  contraband or a weapon of mass destruction or its components, it may not  necessarily indicate that a particular rule is not operating as intended.  They noted that terrorist incidents may happen infrequently and the rule  therefore might operate only when weapons, materials, or other dangerous  contraband is actually shipped. However, without using inspection results  to adjust ATS, CBP may not be targeting and inspecting containers with  the highest risk of containing smuggled weapons of mass destruction.
section_title: CBP Has Taken Steps to Better Implement the Targeting Strategy at the Seaports
paragraphs: CBP has implemented a testing and certification process for its officers  who complete the Sea Cargo Targeting Course that should provide better  assurance of effective targeting practices. CBP has also made a good faith  effort to address longshoremen’s safety concerns regarding radiation  emitted by nonintrusive inspection equipment. Nevertheless, it has not  been able to persuade one longshoremen’s union to permit changes in the  procedure for staging containers to increase inspection efficiency.
subsections: section_title: CPB Has Implemented a Testing and Certification Process for Officers Who Target Cargo Containers for Inspection
paragraphs: In our 2004 report, we recommended that CBP establish a testing and  certification process for CBP staff who complete the national targeting  training to provide reasonable assurance that they have sufficient  expertise to perform targeting work.  CBP has implemented such a  testing and certification process.
CBP conducted two evaluations that assessed its targeting training  program—a job performance assessment and a job task analysis. With the  results of these evaluations, CBP concluded that a certification component  should be added to the training program and the Sea Cargo Targeting  Training course content should remain unchanged. CBP officials then  updated the course materials to encompass the inclusion of the  certification component. In October 2004, CBP began certifying officers  who successfully completed the Sea Cargo Targeting Training course.  Since the establishment of the testing and certification component for the  Sea Cargo Targeting Training course, CBP data indicate that it has trained  and certified 278 of its officers responsible for targeting cargo as of March  24, 2006.
While CBP has conducted a job performance assessment prior to the  incorporation of a certification program for Sea Cargo Targeting Training,  it has not yet formally assessed the impact that revised training and  certification has had on officers’ targeting of oceangoing cargo containers.  However, a CBP official said that CBP has recently initiated planning  efforts to begin such an evaluation and expects to complete the evaluation  in May 2006. Nevertheless, supervisory officers from five of the six CBP  offices at the seaports we visited said that the mandatory training and  certification program has been beneficial. These supervisory officers told  us that the training and certification improves the confidence of targeters,  provides the ability for officers to improve their targeting productivity, and  provides an opportunity for officers to gain a broader perspective into the  targeting environment by examining passenger and outbound targeting.
section_title: Despite CBP Action to Address Longshoremen’s Safety Concerns, Efficiency Concerns Remain on the West Coast
paragraphs: In our 2004 report, we discussed concerns that longshoremen had  regarding the safety of driving cargo containers through the gamma ray  imaging system, one type of nonintrusive inspection equipment used to  examine containers to detect potential contraband or weapons of mass  destruction. Because this equipment emits radiation as it takes images of  the inside of cargo containers, some longshoremen expressed concerns  about the health effects of this radiation. As a result of these safety  concerns, the longshoremen’s union representing West Coast  longshoremen established a policy that prevents its members from driving  containers through the gamma ray imaging system. In response, CBP  altered its procedures at ports affected by this policy. For example, at  some West Coast ports, CBP allows longshoremen to stage cargo  containers away from the dock, in rows at port terminals, so that CBP  officers can then drive the gamma ray imaging system over a group of  containers.
However, this procedure can be space-intensive and time-consuming  compared to the procedure utilized at East and Gulf Coast ports, whereby  the gamma ray imaging system machinery is operated by a CBP officer and  parked in place while longshoremen drive the cargo containers through  the machinery. At other West Coast ports, the longshoremen get out of  the trucks after transporting the cargo containers so that CBP officials can  drive the gamma ray imaging system cargo over the container.  This is also  time-consuming compared to the procedure utilized at the East and Gulf  Coast ports.
In response to our recommendation that CBP work with longshoremen to  address their safety concerns, CBP engaged in two efforts: (1) establishing  CBP’s radiation threshold in accordance with the Nuclear Regulatory  Commission’s (NRC) federal guidelines for public radiation exposure and  advertising this threshold to longshoremen through the unions, and (2)  working with longshoremen’s unions and other maritime organizations to  develop public radiation tests on nonintrusive inspection equipment.  Officials from the West Coast union that prohibits its members from  driving through the gamma ray imaging system told us that the union is  satisfied with CBP efforts to operate the gamma ray imaging system in an  alternative format, to comply with the union’s policy of receiving no  amount of man-made radiation. Despite CBP efforts to assure this union  that the amount of radiation emitted by the gamma ray imaging system is  within safe levels, a union representative told us that CBP will not  convince the union to change its policy unless it eliminates radiation  emission from inspection equipment.  -     -     -     -     -  In closing, ATS is an integral part of CBP’s layered security strategy. A  well-functioning ATS is crucial to the effective screening of cargo  containers at domestic and CSI foreign ports, as well as cargo shipped by  the trade community participating in C-TPAT. While CBP is working to  make improvements to ATS, our ongoing work indicates that it is not yet  in a position to gauge the effectiveness of ATS. We are continuing to  review CBP’s plans and actions to improve ATS and will report to this  subcommittee and the other requesters later this year.
section_title: GAO Contacts and Acknowledgments
paragraphs: Contact points for our Offices of Congressional Relations and Public  Affairs may be found on the last page of this statement. For further  information about this testimony, please contact me at 202-512-8777 or at  stanar@gao.gov. Debra Sebastian, Assistant Director; Chan-My J. Battcher;  Lisa L. Berardi; Wayne A. Ekblad; and Jessica A. Evans made key  contributions to this report. Additional assistance was provided by  Frances Cook, Kathryn E. Godfrey, Nancy A. Hess, Arthur L. James, Jr.,  Stanley J. Kostyla, and Vanessa R. Taylor.
section_title: Appendix I: Scope and Methodology
paragraphs: To address each of our objectives, we met with U.S. Customs and Border  Protection (CBP) officials in headquarters and six seaports including,  Baltimore, Charleston, Los Angeles-Long Beach, Miami, New York- Newark, and Savannah. These seaports were selected based on the  number of cargo containers arriving at the seaport and their geographic  dispersion as reported by the U.S. Department of Transportation. At these  locations, we also observed targeting and inspection operations. Because  we did not select a random, probability sample of ports to visit, the results  from these visits cannot be generalized to ports nationwide. We also spoke  with CBP’s contractor responsible for conducting CBP’s peer review and  longshoremen’s union representatives.
To evaluate how CBP provides assurance that the Automated Targeting  System (ATS) targets the highest-risk oceangoing cargo containers for  inspection, we reviewed CBP documentation and prior GAO work on  performance measures. Additionally, we reviewed CBP’s peer review  report. To gain an understanding of CBP’s random sampling program, we  met with CBP officials responsible for this program and reviewed and  analyzed CBP documentation, including procedures for examining the  randomly selected shipments and documenting the results of the  inspections completed for those shipments. We did not independently  validate the reliability of CBP’s targeting results.
To assess how CBP adjusts ATS to respond to findings that occur during  the course of its operational activities, we met with CBP officials  responsible for gathering and disseminating intelligence and for  incorporating intelligence into CBP’s targeting operations. Further, we  reviewed CBP policies and procedures on intelligence gathering and  disseminating as well as intelligence received and resulting changes to  ATS rules and weights. We did not assess the quality of intelligence  received or the appropriateness of adjusted rules and weights. To  determine how targeting officers’ feedback and inspection results are used  to adjust ATS rules and weights, we met with CBP officials responsible for  collecting and maintaining data on suggestions provided by targeting  officers and reviewed CBP data on the suggestions received over a 7  month period. Regarding inspection results, we reviewed CBP’s policies  and procedures for documenting inspection results. Additionally, we  reviewed CBP’s manuals identifying the specific details of an inspection  completed and observed officers entering inspection results into the ATS  findings module during our site visits. Further, during these visits, we  discussed how CBP offices at the seaports may use inspection results to  enhance their targeting efforts. Last, we met with CBP officials and  reviewed CBP documentation on its current and planned findings module.
To determine the status of recommendations from GAO’s February 2004  report to (1) establish a testing and certification process for CBP staff who  complete the national targeting training to provide assurance that they  have sufficient expertise to perform targeting work and (2) work with  longshoremen’s unions to address fully their safety concerns so that the  noninstrusive inspection equipment can be used to conduct inspections  efficiently and safely, we reviewed and analyzed data on the number of  officers trained and certified in sea cargo targeting. We also reviewed  CBP’s Sea Cargo Training Manual as well as CBP evaluations assessing the  quality of its Sea Cargo Training course. We did not assess the quality of  this training. Regarding longshoremen’s union concerns, we reviewed  scientific literature related to radiation safety and the Nuclear Regulatory  Commission guidelines on radiation levels. We also spoke with  longshoremen’s representatives to discuss whether CBP had addressed  their concerns since we issued our 2004 report. Last, we also met with  CBP’s Radiation Safety Officer to gain a further understanding of the  potential risks associated with CBP’s inspection equipment and actions he  took to address longshoremen’s concerns. We did not assess the  appropriateness of radiation safety levels used by CBP.
We conducted our work from October 2005 through March 2006 in  accordance with generally accepted government auditing standards.
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