Container Security: A Flexible Staffing Model and Minimum Equipment Requirements Would Improve Overseas Targeting and Inspection Efforts
Published: 2005-04-26T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In January 2002, U.S. Customs and Border Protection (CBP) initiated the Container Security Initiative (CSI) to address the threat that terrorists might use maritime cargo containers to ship weapons of mass destruction. Under CSI, CBP is to target and inspect high-risk cargo shipments at foreign seaports before they leave for destinations in the United States. In July 2003, GAO reported that CSI had management challenges that limited its effectiveness. Given these challenges and in light of plans to expand the program, GAO examined selected aspects of the program's operation, including the (1) factors that affect CBP's ability to target shipments at foreign seaports, (2) extent to which high-risk containers have actually been inspected overseas, and (3) extent to which CBP formulated and documented strategies for achieving the program's goals.
section_title: What GAO Found
paragraphs: Some of the positive factors that have affected CBP's ability to target shipments overseas are improved information sharing between U.S. and foreign customs staff and a heightened level of bilateral cooperation and international awareness of the need to secure the whole global shipping system. Although the program aims to target all U.S.-bound shipments from CSI ports, it has been unable to do so because of staffing imbalances. CBP has developed a staffing model to determine staffing needs but has been unable to fully staff some ports because of diplomatic considerations (e.g., the need for host government permission) and practical considerations (e.g., workspace constraints). As a result, 35 percent of these shipments were not targeted and were therefore not subject to inspection overseas. In addition, the staffing model's reliance on placing staff at CSI ports rather than considering whether some of the targeting functions could be performed in the United States limits the program's operational efficiency and effectiveness. CBP has not established minimum technical requirements for the detection capability of nonintrusive inspection and radiation detection equipment used as part of CSI. Ports participating in CSI use various types of nonintrusive inspection equipment to inspect containers, and the detection and identification capabilities of such equipment can vary. In addition, technologies to detect other weapons of mass destruction have limitations. Given these conditions, CBP has limited assurance that inspections conducted under CSI are effective at detecting and identifying terrorist weapons of mass destruction. A lthough CBP has made some improvements in the management of CSI, we found that further refinements to the bureau's management tools are needed to help achieve program objectives. In July 2003, we recommended that CBP develop a strategic plan and performance measures, including outcome-oriented measures, for CSI. CBP developed a strategic plan for CSI in February 2004 that contains three of the six key elements required for agency strategic plans, and CBP officials told us they continue to develop the other three elements. While it appears that the bureau's efforts in this area meet the intent of our prior recommendation to develop a strategic plan for CSI, we will continue to monitor progress in this area. CBP has also made progress in the development of outcome-oriented performance measures, particularly for the program objective of increasing information sharing and collaboration among CSI and host country personnel. However, CBP continues to face challenges in developing performance measures to assess the effectiveness of CSI targeting and inspection activities. Therefore, it is difficult to assess progress made in CSI operations over time, and it is difficult to compare CSI operations across ports.

section_title: Letter
paragraphs: Ocean cargo containers play a vital role in the movement of cargo between  global trading partners. In 2004, nearly 9 million ocean cargo containers  arrived and were offloaded at U.S. seaports. Responding to heightened  concern about national security since September 11, 2001, several U.S.  government agencies have focused efforts on preventing terrorists from  smuggling weapons of mass destruction (WMD) in cargo containers from  overseas locations to attack the United States and disrupt international  trade. Because of its frontline responsibilities for inspection at U.S. ports  of entry, the U.S. Customs and Border Protection (CBP) has the lead U.S.  role in ensuring ocean container security and reducing the vulnerabilities  associated with the overseas supply chain.
In light of the complexity and interconnectedness of global commerce,  international cooperation is a key factor in reducing the vulnerability of  oceangoing cargo. To help address its responsibility to ensure the security  of this cargo, CBP has in place a program known as the Container Security  Initiative (CSI). The program aims to target and inspect high-risk cargo  shipments at foreign seaports before they leave for destinations in the  United States. Under the program, foreign governments agree to allow  CBP personnel to be stationed at foreign seaports to use intelligence and  automated risk assessment information to target shipments to identify  those at risk of containing WMD or other terrorist contraband. CBP  personnel are to refer these high-risk shipments to host government  officials, who are then to determine whether to inspect the shipment  before it leaves the port for the United States. Host government officials  examine shipments with nonintrusive inspection equipment (such as X-ray  machines) and, if they deem it necessary, open the cargo containers to  physically examine the contents inside. As of February 2005, the CSI  program was operational at 34 foreign seaports, with plans to expand to an  additional 11 ports by the end of fiscal year 2005.
The program is promising, but our previous work has raised concerns  about its management and its ability to achieve its ultimate goal of  improved cargo security. In July 2003, we reported that CBP’s  management of CSI had not evolved from a short-term focus to a long-term  strategic approach. We recommended that the Secretary of the  Department of Homeland Security (DHS) work with the Commissioner of  U.S. Customs and Border Protection to develop (1) a strategic plan that  clearly lays out the program’s goals, objectives, and detailed  implementation strategies; (2) performance measures that include  outcome-oriented indicators; and (3) a human capital plan that clearly  describes how CSI will recruit, train, and retain staff to meet the program’s  growing demands as the bureau implements new program elements. In  March 2004, we testified that CBP’s targeting system does not incorporate  all key elements of a risk management framework and recognized  modeling practices in assessing the risks posed by oceangoing cargo  containers.
In light of the program’s planned expansion, we examined selected aspects  of the program’s operation and management. This report addresses the  following issues:  1.  What factors affect CBP’s ability to target shipments at overseas  seaports?  2.  Under CSI, to what extent have high-risk containers been inspected  overseas prior to their arrival at U.S. destinations?  3.  To what extent has CBP developed strategies and related management  tools for achieving the program’s goals?
To address all three objectives, we met with CBP officials in Washington,  D.C., who have program responsibilities for CSI and reviewed available  data and documentation for the program. To ascertain the degree to which  high-risk shipments were targeted and inspected overseas, we obtained  data on CSI targeting and inspection activity for each of the CSI ports. We  also met with CSI teams and host government officials at four overseas  ports. In addition, we observed elements of the targeting and inspection  processes at these ports and obtained and reviewed documentation of CSI  procedures provided by CBP and host government officials at these ports.  We also assessed the reliability of CBP’s data on the number of shipments  and containers subject to targeting and inspection under CSI and found  the data sufficiently reliable for use in our report. In addition, we  examined the status of the bureau’s efforts to implement our prior  recommendations for strategic and human capital plans and performance  measures for the program.
We conducted our work from February 2004 through February 2005 in  accordance with generally accepted government auditing standards. More  details about the scope and methodology of our work are presented in  appendix I.
subsections: section_title: Background
paragraphs: Several studies on maritime security conducted by federal, academic,  nonprofit, and business organizations have concluded that the movement  of oceangoing cargo in containers is vulnerable to some form of terrorist  action, largely because of the movement of shipments throughout the  supply chain. Relatively few importers own and operate all key aspects of  the cargo container transportation process, which includes overseas  manufacturing and warehouse facilities, carrier ships to transport goods,  and the transportation operation to receive the goods upon arrival. Most  importers must rely on second-hand parties to move cargo in containers  and prepare various transportation documents. Second-hand parties  within the cargo container supply chain may include exporters, freight  forwarders, customs brokers, inland transportation providers, port  operators, and ocean carriers. Every time responsibility for cargo in  containers changes hands along the supply chain, there is the potential for  a security breach; specifically, this change in responsibility creates  opportunities for contraband to be placed in containers and opportunities  for fraudulent documents to be prepared. According to the U.S.  Department of Transportation’s Volpe National Transportation Systems  Center, importers who own and operate all aspects of the supply chain  suffer the fewest security breaches because of their increased level of  control.
While CBP has noted that the likelihood of terrorists smuggling WMD into  the United States in cargo containers is low, the nation’s vulnerability to  this activity and the consequence of such a disaster are high. With about   90 percent of the world’s maritime cargo moving by containers, terrorist  action related to cargo containers could paralyze the maritime trading  system and quickly disrupt U.S. and global commerce. In a strategic  simulation of a terrorist attack sponsored by the consulting firm Booz  Allen Hamilton in 2002, representatives from government and industry  organizations participated in a scenario involving terrorist activities at U.S.  seaports. The scenario simulated the discovery and subsequent  detonation of “dirty bombs”—explosive devices wrapped in radioactive  material and designed to disperse radiological contamination—hidden in  cargo containers at various locations around the country. These “events”  led simulation participants to shut down every seaport in the United States  over a period of 12 days. Booz Allen Hamilton published a report in  October 2002 about the results of the simulation, which estimated that the  12-day closure would result in a loss of $58 billion in revenue to the United  States’ economy, including spoilage, loss of sales, manufacturing  slowdowns, and halts in production. Further, according to the report, it  would take 52 days to clear the resulting backlog of vessels and 92 days to  stabilize the container backlog, causing a significant disruption in the  movement of international trade.
subsections: section_title: CBP’s Targeting and Inspection Approach at Domestic Ports
paragraphs: According to CBP, the large volume of imports and the bureau’s limited  resources make it impractical to inspect all oceangoing containers without  disrupting the flow of commerce. CBP also noted 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. CBP has  implemented an approach to container security that attempts to focus  resources on particularly risky cargo while allowing other cargo to  proceed.
CBP’s domestic efforts to target cargo to determine the risk it poses rely  on intelligence, historical trends, and data provided by ocean carriers and  importers. Pursuant to federal law, CBP requires ocean carriers to  electronically transmit cargo manifests to CBP’s Automated Manifest  System 24 hours before the cargo is loaded on a ship at a foreign port.  This information is used by CBP’s Automated Targeting System (ATS).  ATS is characterized by CBP as a rule-based expert system that serves as a  decision support tool to assess the risk of sea cargo. In addition, CBP  requires importers to provide entry-level data that are entered into the  Automated Commercial System and also used by ATS. According to CBP  officials, ATS uses this information to screen all containers to determine  whether they pose a risk of containing WMD.
As shown in figure 1, CBP targeters at domestic ports target containers by  first accessing the bills of lading and their associated risk scores  electronically. The assigned risk score helps the targeters determine the  risk characterization of a container and the extent of documentary review  or inspection that will be conducted. For example, containers  characterized as high-risk are to be inspected. Containers characterized as  medium-risk are to be further researched. That is, targeters are to consider  intelligence alerts and research assistance provided by the National  Targeting Center (NTC) to the ports, and their own experience and  intuition, in characterizing the final risk of shipments. Containers  characterized as low-risk are generally to be released from the port  without further documentary review or inspection.
There are, generally, two types of inspections that CBP inspectors may  employ when examining cargo containers—nonintrusive inspections and  physical examinations. The nonintrusive inspection, at a minimum,  involves the use of X-ray or gamma-ray scanning equipment. As shown in  figure 2, the X-ray or gamma ray equipment is supposed to scan a  container and generate an image of its contents. CBP inspectors are to  review the image to detect any anomalies, such as if the density of the  contents of the container is not consistent with the description of the  contents.
If an anomaly is apparent in the image of the container, CBP inspectors are  to decide whether to conduct a physical examination of the container.  According to CBP officials, they have a policy to determine the type of  physical examination to be conducted depending on the location of the  anomaly.
CBP inspectors also are to use radiation detection devices to detect the  presence of radioactive or nuclear material. If the detectors indicate the  presence of radioactive material, CBP officials are to isolate the source  and contact the appropriate agency, such as the Department of Energy, for  further guidance.
section_title: CBP Extended Its Targeting and Inspection Activities to Overseas Seaports
paragraphs: Announced in January 2002, CSI was implemented to allow CBP officials  to target containers at overseas seaports so that any high-risk containers  may be inspected prior to their departure for U.S. destinations. According  to the CSI strategic plan, strategic objectives for CSI include (1) pushing  the United States’ zone of security beyond its physical borders to deter and  combat the threat of terrorism; (2) targeting shipments for potential  terrorists and terrorist weapons, through advanced and enhanced  information and intelligence collection and analysis, and preventing those  shipments from entering the United States; (3) enhancing homeland and  border security while facilitating growth and economic development  within the international trade community; and (4) utilizing available  technologies to leverage resources and to conduct examinations of all  containers posing a high risk for terrorist related activity. Another  objective cited by CBP officials, although not included in the CSI strategic  plan, is to raise the level of bilateral cooperation and international  awareness regarding the need to secure global trade.
To implement CSI, CBP negotiates and enters into bilateral arrangements  with foreign governments, specifying the placement of CBP officials at  foreign ports and the exchange of information between CBP and foreign  customs administrations. CBP first solicited the participation of the   20 foreign ports that shipped the highest volume of ocean containers to  the United States. These top 20 ports are located in 14 countries and  regions and shipped a total of 66 percent of all containers that arrived in  U.S. seaports in 2001. CBP has since expanded CSI to strategic ports,  which may ship lesser amounts of cargo to the United States but may also  have terrorism or geographical concerns. As shown in table 1, as of  February 2005, CSI was operational at 34 ports, located in 17 countries or  regions. For fiscal year 2004, the CSI budget was about $62 million, with a  budget of about $126 million in fiscal year 2005 for the program.
To participate in CSI, a host nation must meet several criteria. The host  nation must utilize (1) a seaport that has regular, direct and substantial  container traffic to ports in the United States; (2) customs staff with the  authority and capability of inspecting cargo originating in or transiting  through its country; and (3) nonintrusive inspection equipment with  gamma- or X-ray capabilities and radiation detection equipment.  Additionally, each potential CSI port must indicate a commitment to   (1) establishing an automated risk management system; (2) sharing critical  data, intelligence, and risk management information with CBP officials;   (3) conducting a thorough port assessment to ascertain vulnerable links in  a port’s infrastructure and commit to resolving those vulnerabilities; and  (4) maintaining a program to prevent, identify, and combat breaches in  employee integrity.
To prepare for implementation of CSI, CBP sends an assessment team to  each potential CSI port to collect information about the port’s physical and  information infrastructure, the host country’s customs operations, and the  port’s strategic significance to the United States. CBP then deploys a CSI  team, which generally consists of three types of officials—special agents,  targeters, and intelligence analysts.  These officials come from either CBP  or U.S. Immigration and Customs Enforcement (ICE).  The team leader is  a CBP officer or targeter who is assigned to serve as the immediate  supervisor for all CSI team members and is responsible for coordinating  with host government counterparts in the day-to-day operations. The team  leader is also to prepare a weekly report on container targeting and  inspection activity at the port. The targeters are team members  responsible for targeting shipments and referring those shipments they  determine are high-risk to host government officials for inspection. The  targeter may also observe inspections of containers. The intelligence  analyst is responsible for gathering information to support targeters in  their efforts to target containers. In addition, the special agents are to  coordinate all investigative activity resulting from CSI-related actions, as  well as liaison with all appropriate U.S. embassy attachés.
section_title: CSI Process for Targeting and Inspecting Cargo Containers Overseas
paragraphs: Although the targeting of cargo at domestic ports is primarily dependent  upon the ATS score, under CSI the targeting of cargo is largely dependent  on CBP targeters’ review of the ATS score in conjunction with reviews of  bills of lading, additional information provided by host government  officials, and, in at least one country, a unique set of targeting rules  developed jointly by CBP and host government officials. As shown in  figure 3, on the basis of the initial review, CBP officials are to either   (1) categorize shipments as low-risk, in which case the container holding  the shipment is loaded onto the departing vessel without being inspected,  or (2) conduct further research in order to properly characterize the risk  level of the shipment.
Referrals of shipments to the host government for inspection are handled  in one of three ways—shipments are inspected or inspection is either  waived or denied. After receiving a referral for inspection from CSI teams,  host customs officials are to review the bills of lading of the shipments and  the reasons for the referrals to determine whether or not to inspect the  shipments. Some host governments collect information on U.S.-bound  shipments independent of CSI, which host officials also consider in  decisions of whether to inspect the referred shipments. Finally, if the host  government officials determine, on the basis of their review, that a  shipment is not high-risk, they will deny inspection of the shipment. For  any high-risk shipment for which an inspection is waived or denied, CSI  teams are to place a domestic hold on the shipment, so that it will be  inspected upon arrival at its U.S. destination. However, if CSI team  members are adamant that a cargo container poses an imminent risk to the  carrier or U.S. port of arrival but cannot otherwise convince the host  officials to inspect the container, CSI team members are to contact and  coordinate with the National Targeting Center to issue a do-not-load order  for national security. According to CBP officials, this order advises the  carrier that the specified container will not be permitted to be unloaded in  the United States until a time when any associated imminent risk to the  cargo container is neutralized. Once the risk is neutralized, the container is  to be loaded back onto the carrier and placed on hold for a domestic  examination. According to CBP officials, this type of do not load order has  been implemented six times since the inception of CSI.
As in the domestic inspection process, there are, generally, two types of  CSI inspections—nonintrusive inspections and physical inspections.  However, since CBP officials do not have the legal authority to inspect  U.S.-bound containers in foreign ports, the host government customs  officials are to conduct the inspections. According to CBP, in general, CBP  officials are to observe the inspections and document inspection results.  In addition, CBP officials, along with host government officials, may  review the images produced by the X-ray or gamma-ray equipment to  detect any anomalies that may indicate the presence of WMD. Also in  collaboration with host government officials, CBP officials are to review  the output produced by radiation detection devices to assess whether   radioactive or nuclear material is present. On the basis of the results of the  nonintrusive inspection, such as if an anomaly is apparent in the image of  the container, the host government and CBP officials must decide whether  to conduct a physical examination of the container. Our limited  observations at three ports confirmed that host nation officials allowed  CSI team members to observe the inspection process. CBP and host  government officials at the four CSI ports we visited indicated that if WMD  or related contraband were found during a CSI inspection, the host  government would be responsible for taking appropriate enforcement  measures and disposing of the hazardous material.
section_title: While CBP Has Enhanced Its Ability to Target Containers Overseas, Limitations Remain
paragraphs: We identified both positive and negative factors that affect CBP’s ability to  target shipments at overseas seaports. According to CBP officials, the CSI  program has produced factors that contribute to CBP’s ability to target  shipments at overseas seaports, including improved information sharing  between the CSI teams and host government officials regarding U.S.- bound shipments and a heightened level of bilateral cooperation on and  international awareness of the need for securing the global shipping  system. However, we found several factors that may limit the program’s  effectiveness at some ports, including (1) staffing imbalances at CSI ports  and (2) weaknesses in one source of data CBP relies upon to target  shipments.
subsections: section_title: CSI Successes Have Enhanced CBP’s Ability to Target Containers Overseas
paragraphs: One of the factors assisting with targeting of cargo is improved  information sharing between U.S. and host customs officials. CBP has  successfully negotiated agreements with several foreign governments to  allow for the operation of CSI at their overseas seaports. Through  September 11, 2004, CSI teams were able to target about 65 percent of the  shipments coming through 25 CSI ports to determine whether they were at  risk of containing WMD. This represented about 43 percent of all  oceangoing cargo container traffic to the United States. As of January  2005, CBP had expanded the program to 34 operational ports, with plans  to further expand the program to a total of 45 ports by the end of fiscal  year 2005. According to CBP officials, the overseas presence of CBP  officials has led to effective information sharing between the team and  host government officials regarding targeting of U.S.-bound shipments. For  example, CBP targeters at one of the ports we visited said that the  presence of CBP officials at CSI ports fosters cooperation by host nation  customs officials, such that more shipments characterized as high-risk and  referred for inspection would be denied inspection by the host  government if CBP officials were not present. According to CBP officials,  information from host government officials on U.S.-bound shipments has  been beneficial to CBP’s efforts to target shipments. They noted that the  additional information provided by host governments can be utilized to  address threats posed by U.S.-bound shipments. Additionally, CBP  officials noted that the CSI teams can provide this information to NTC to  incorporate into ATS to enhance CBP’s targeting capabilities. During one  of our port visits, host government officials noted that providing  information to CSI teams allows CBP officials to make more informed  decisions about which shipments are high-risk, reducing the number of  shipments deemed high-risk and referred for inspection by the host  government. Additionally, CBP and host government officials at this same  port told us that host government information also results in additional  inspections of U.S.-bound containers, beyond those referred by the CSI  team. For example, they said that in 2003, this host government identified  and inspected 30 high-risk U.S.-bound containers that were not identified  as high-risk by the CSI team.
Another positive factor reported to us is the level of bilateral cooperation  and international awareness regarding the need to secure global trade.  With the discovery and seizure of shipments under CSI of automatic  weapons, ammunition, and other falsely identified contraband, CBP noted  that many customs services around the world without strong law  enforcement capabilities are currently seeking additional legal authority to  strengthen their ability to fight terrorism. For example, CBP noted that in  June 2002, the World Customs Organization (WCO) passed a resolution to  enable ports in all of its member nations to begin to develop outbound  targeting programs consistent with the CSI model. In addition, in April  2004 the European Union and the Department of Homeland Security  signed an agreement that calls for intensifying and broadening the  agreement on customs cooperation and mutual assistance in customs  matters, to include cooperation on container security and related matters.   For example, the measures adopted in the agreement include the creation  of an information exchange network, an agreement on minimum  requirements applicable for European ports that wish to participate in CSI,  and identification of best practices concerning security controls of  international trade.
section_title: CBP Staffing Imbalances Prevent Targeting of All Containers from CSI Ports
paragraphs: One factor negatively affecting CBP’s ability to target containers is staffing  imbalances across ports and shortages at some ports. Although CBP’s goal  is to target all U.S.-bound containers at CSI ports before they depart for  the United States, it has not been able to place enough staff at some CSI  ports to do so. CBP has developed a CSI staffing model to determine the  staff needed to target containers. However, at some CSI ports CBP has  been unable to staff the CSI teams at the levels called for in the CSI  staffing model. In commenting on a draft of this report, DHS noted that the  35 percent of U.S.-bound shipments that were not targeted by CSI teams  were deemed low-risk by ATS and thus required no further review at CSI  ports. However, our discussions with CSI teams at two of the four ports  we visited indicated that those teams did not prioritize shipments for  targeting based on ATS score but instead prioritized shipments by  departure time. As a result, there is no assurance that all high-risk  shipments are targeted at CSI ports.
CBP has been unable to staff the CSI teams at the levels called for in the  CSI staffing model because of diplomatic and practical considerations.  CBP officials told us it is unrealistic to expect that CBP can place the  number of targeters indicated by its staffing model needed to review all  shipments at every CSI port. In terms of diplomatic considerations, the  host government may limit the overall number of U.S. government  employees to be stationed in the country and may restrict the size of the  CSI team. In terms of practical considerations, the host governments may  not have enough workspace available for CSI staff and may thus restrict  the size of the CSI team. The U.S. Department of State would also have to  agree to the size of the CSI teams, a decision that has to be balanced with  the mission priorities of the embassy, the programmatic and  administrative costs associated with increases in staffing, and security  issues related to the number of Americans posted overseas. According to  the State Department, the average cost of putting an American position  overseas will be approximately $430,000.
One of the features of the CSI staffing model that may contribute to the  staffing imbalance is its reliance on placing staff overseas at CSI ports. It  does not consider whether some of the targeting functions could be  performed in the United States. For example, the model does not consider  what minimum number of targeters need to be physically located at CSI  ports to carry out duties that require an overseas presence (such as  coordinating with host government officials) as opposed to other duties  that could be performed in the United States (such as reviewing manifests  and databases). As we noted in our 2002 report on a staffing framework  for use at U.S. embassies, federal agencies should consider options that  improve operational efficiency and effectiveness and that minimize  security risks, such as assessing which functions can occur in the United  States, as part of their framework for determining the right number of staff  to be placed overseas.
CBP has acknowledged that it cannot fully implement the CSI staffing  model and has supplemented staff at the CSI ports with domestic targeters  at NTC. According to CBP officials, CSI teams may contact these NTC  targeters and request that they help target specific shipments that CSI  teams at the ports are unable to target. The NTC targeters, after targeting  the shipments, are to notify the relevant CSI team with the results of their  targeting, including whether the shipments are high-risk and should be  referred to the host government for inspection. Although the NTC  targeters are available to provide assistance to CSI teams 24 hours a day,   7 days a week, CBP officials noted that even with the addition of these  targeters, the bureau has been unable to target every U.S.-bound shipment  before it departed a CSI port.
The use of domestic targeters demonstrates that CBP does not have to rely  exclusively on overseas targeters as called for in its staffing model. Our  observations at four CSI ports indicated that having CSI staff work directly  with host nation customs officials was beneficial to both the targeting and  the inspection processes. However, we also noted that the the targeters’  work focused on targeting ATS findings, as well as consulting various  automated databases, and did not include much interaction with host  government officials. For example, at two of the ports we visited CBP  officials told us that typically only one or two CSI team members dealt  directly with host customs officials. In addition, while CBP officials could  not provide us with port-specific or average costs of the CSI port teams,  they stated that it was more expensive to post staff overseas than in the  United States.
section_title: One Source of Targeting Data Has Limitations
paragraphs: Another factor that negatively affects CBP’s ability to target shipments is  the existence of limitations in one data source used. For CSI, CBP relies  on manifest information to assess the risk level of U.S.-bound shipments.
As we previously reported, terrorism experts, trade representatives, and  CBP officials indicated that manifest data may contain unreliable  information and are sometimes incomplete. We reported that manifests  are produced by second-hand parties (ocean carriers), not the importers  or exporters who have the most contact with and knowledge of the cargo.  In addition, manifests have historically been used to disguise detailed  information about containers’ contents, to prevent theft during transport  of the cargo. This is particularly applicable to high-value products, such as  electronics and apparel. In the same previous report, we also noted that  manifest data can be amended up to 60 days after oceangoing vessels  arrive at U.S. seaports, further limiting the use of manifest data for  determining a definitive risk level before cargo arrives. CBP officials at  CSI ports we visited indicated that despite the requirement that carriers  submit accurate and complete manifests to CBP 24 hours prior to the  cargo being loaded on the U.S.-bound vessel, some manifest data in ATS  remain vague or incomplete. For example, a CBP official at one CSI port  we visited said that in some cases the name of the freight forwarder was  used in place of the actual names of the importer and consignee. Although  CBP officials told us that the quality of the manifest data has improved,  there is no method to routinely verify whether the manifest data  accurately reflect the contents within the cargo container. CBP officials  told us that to try to address the shortcomings of manifests, CSI teams  consult other data to obtain information on shipments.  As mentioned  earlier, entry-level data are used.
section_title: Some Containers Not Inspected for a Variety of Reasons
paragraphs: Since the implementation of CSI through September 11, 2004, 28 percent  (4,013) of containers referred to host government officials for inspection  were not inspected, generally because of host government information  that suggested the containers were not high-risk or operational limitations  that prevented the containers from being inspected before they left the  port. In 1 percent of these cases, host government officials denied  inspections, generally because inspection requests were based on factors  not related to security threats, such as drug smuggling. Containers  designated as high-risk by CSI teams that are not inspected overseas are  supposed to be referred for inspection upon arrival at the U.S. destination  port. CBP officials noted that between July 2004 and September 2004,  about 93 percent of shipments referred for domestic inspection were  inspected at a U.S. port. CBP officials explained that some shipments  designated as high-risk by CSI teams were not inspected domestically  because inspectors at U.S. ports received additional information or entry  information that lowered the risk characterization of the shipments or  because the shipments remained aboard the carrier and were never  offloaded at a U.S. port. For the 72 percent (10,343) of containers referred  to host government officials for inspection that were inspected overseas,  CBP officials told us there were some anomalies that led to law  enforcement actions but that no WMD were discovered. However,  considering that the inspection equipment used at CSI ports varies in  detection capability and that there are no minimum requirements for the  detection capability of equipment used for CSI, CBP has no absolute  assurance that inspections conducted under CSI are effective at detecting  and identifying WMD.
subsections: section_title: Some Containers Not Inspected Overseas because of Host Government Information
paragraphs: Some of the containers referred for inspection were not inspected because  of additional information obtained by host government officials that  lowered the risk characterization of the container. An important aspect of  CSI is the information host government officials can provide in  determining whether a U.S.-bound container is at high risk of containing  WMD and should be inspected. For example, at one CSI port we visited,  the host customs official told us that although CBP officials referred a  shipment for inspection because the area from which the shipment  originated had known terrorist activity, the host government’s customs  officials had a thorough working history with the importer and believed  the shipment did not pose a threat. On the basis of this information, the  CSI team and the host nation customs officials agreed that the shipment  did not pose a threat and that inspection was not necessary.
section_title: Some Containers Not Inspected Overseas because of Operational Limitations
paragraphs: Some containers were not inspected at CSI ports because of operational  limitations that were generally beyond the control of CBP. For example,  since the program’s inception through September 11, 2004, some referred  containers were not inspected at CSI ports because the containers had  already been loaded on departing vessels. CBP officials and host  government customs officials explained that a container may already be  loaded on a vessel prior to its being referred for inspection because the  amount of time the container actually stays in the port—dwell time—may  be brief. CSI teams are not always able to target such containers and refer  them for inspection before they are loaded. According to CBP and host  government officials with whom we met, terminal operators intentionally  schedule the arrival and departure of containers in order to minimize  dwell time. However, CSI teams may not always know when containers  are due for departure. Host government customs officials at one of the  ports we visited said that until recently, the CSI team did not have access  to the port schedules for U.S.-bound containers; therefore, team members  could not prioritize the order in which they reviewed bills of lading for  U.S.-bound shipments based on container dwell time. However, as of July  2004, the CSI team at this port gained access to port schedule information  and now prioritizes its review of bills of lading based on container  departure time. Host government officials noted that this practice  decreases the number of containers waived for inspection.
section_title: Host Nations Deny Inspections for Some Containers Referred by CSI Teams
paragraphs: In addition to operational limitations that prevent referred containers from  being inspected at CSI ports, host government officials have denied  inspection for about 1 percent of the containers referred to them by CBP  officials. According to CBP officials, the majority of these denials occurred  early in the program’s operation as both CSI teams and host government  officials implemented the program. For example, host government officials  at one CSI port we visited indicated that some of these denials were for  inspection requests based on factors not related to security threats, such  as drug smuggling. They told us their rationale in denying these requests  was that CBP could inspect these containers in the United States, and  identifying customs violations was not the purpose of CSI. At another port  we visited, CSI team officials told us that host customs officials initially  denied inspections of shipments referred solely because of the shipment’s  ATS score, preferring to instead have referrals that were further  researched by the CSI team to help ensure that shipments were truly high- risk.  As noted earlier, if the CSI team members are adamant that a cargo  container poses an imminent risk to the conveyance or the U.S. port of  arrival, they can coordinate with the National Targeting Center to issue a  do-not-load order to prevent the container from being placed on the ship.
section_title: Containers Not Inspected Overseas Can Be Inspected on U.S. Arrival
paragraphs: Containers with high-risk shipments that are not inspected overseas are  supposed to be referred for inspection upon arrival at the U.S. destination  port. Effective November 21, 2003, CSI team members were required to  place domestic exam holds on high-risk containers that had not been  inspected overseas. That is, the CSI team is supposed to request a  domestic inspection for all containers for which an inspection was waived  or denied by marking, in ATS, the container for a domestic hold and  notifying the director of the U.S.-destination port. The CSI team is also  supposed to request domestic exams for shipments that were inspected  overseas but not to the satisfaction of the CSI team, such as if there was a  disagreement over the interpretation of the X-ray image produced during  the nonintrusive inspection or if the host nation was not willing to perform  a physical exam after an anomaly was detected. However, not all  shipments referred for a domestic inspection by CSI teams are inspected.  Although CBP has not systematically tracked since the program’s  inception whether containers placed on domestic hold are examined,  according to CBP, it began tracking this information in July 2004. CBP  officials told us that between July 2004 and September 2004, 93 percent of  the shipments placed on CSI for domestic exam hold were actually  inspected at a U.S. port. CBP explained that U.S. port officials did not  inspect about 2 percent of the shipments placed on domestic exam hold  during this time period because the shipments were either remaining on  board at the U.S. port or additional intelligence information convinced  them that the shipment no longer needed to be characterized as high-risk.  For the remaining 5 percent of shipments that were not inspected  domestically, CBP officials told us the bureau cannot confirm what action  was taken on these shipments because of data input errors by domestic  inspectors. CBP officials also noted that they were unable to confirm  whether any shipments placed on domestic exam hold prior to July 2004  were actually inspected upon arrival in the United States because of these  same data input errors.
section_title: In the Absence of Minimum Technical Requirements, Inspection Equipment Capabilities Vary
paragraphs: As of September 11, 2004, host governments had inspected 72 percent  (10,343) of all containers referred to them by CSI teams since the  inception of the program. These containers were inspected using  nonintrusive inspections and physical examinations. According to CBP  and host government officials, variation in the extent of physical  examinations depends on anomalies detected during the nonintrusive  inspection. CBP officials also told us that no WMD have been discovered  under CSI.
There are two different types of radiation detection devices used at CSI  ports to inspect cargo containers—radiation isotope identifier devices  (RIID) and radiation portal monitors (RPM)—each with different  detection and identification capabilities. While both devices can detect the  presence of radioactive material, only the RIID can determine whether or  not the type of radiation emitted by the material actually poses a threat or  whether it is a normal emission of radiation, such as that found in ceramic  tile. In addition, there is another type of radiation detection device used at  CSI ports to help ensure the safety of CSI team members—personal  radiation detectors (PRD).  According to radiation detection experts,  PRDs are personal safety devices to protect against radiation exposure,  they are not adequate as search instruments.  A scientist at the  Department of Energy Los Alamos National Laboratory who was involved  in the testing of radiation detection equipment said that PRDs have a  limited range and are not designed to detect weapons-usable nuclear  material.
There are also various types of X-ray and gamma-ray imaging machines  used at CSI ports to inspect cargo containers, and their detection and  identification capabilities may vary. According to CBP, there are various  brands of imaging machines used to conduct nonintrusive inspections at  CSI ports. These brands of machines differ in their penetration  capabilities, scan speed, and several other factors. Despite this variability  in detection and inspection capability, CBP officials told us that the  inspection equipment used at all CSI ports had inspection capabilities at  least as good as the nonintrusive inspection equipment used by CBP at  domestic ports. CBP officials told us that prior to establishing CSI at a  foreign port, CBP officials conducted on-site assessments of the  nonintrusive inspection equipment used at the port. More recently, CBP  conducted an assessment of the capabilities of the equipment in use at  each CSI port against the capabilities of one brand of equipment. This  assessment indicated that with the exception of equipment used in one  country, all equipment had capabilities that met or exceeded those of this  brand of equipment. In addition, technologies to detect other WMD have  limitations. According to CBP officials, the bureau has not established  minimum technical requirements for the nonintrusive inspection  equipment or radiation detection equipment that can be used as part of  CSI because of sovereignty issues, as well as restrictions that prevent CBP  from endorsing a particular brand of equipment. Although CBP cannot  endorse a particular brand of equipment, the bureau could still establish  general technical capability requirements for any equipment used under  CSI similar to other general requirements CBP has for the program, such  as the country committing to establishing an automated risk management  system. Because the CSI inspection could be the only inspection of a  container before it enters the interior of the United States, it is important  that the nonintrusive inspection and radiation detection equipment used as  part of CSI meets minimum technical requirements to provide some level  of assurance of the likelihood that the equipment could detect the  presence of WMD.
section_title: CBP Has Made Progress Developing a Strategic Plan and Performance Measures for CSI, but Further Refinements Are Needed
paragraphs: Although CBP has made some improvements in the management of CSI,  we found that further refinements to the bureau’s management tools are  needed to help achieve program goals. In July 2003, we recommended that  CBP develop a strategic plan and performance measures, including  outcome-oriented measures, for CSI. In February 2004, CBP finalized a  strategic plan for CSI containing three of the six key elements identified by  the Government Performance and Results Act of 1993 (GPRA) for an  agency strategic plan: a mission statement, objectives, and implementation  strategies. CBP officials told us the bureau plans to incorporate the  remaining three elements into the CSI strategic plan, specifying how  performance goals are related to general goals of the program, identifying  key external factors that could affect program goals, and describing how  the program will be evaluated. CBP has also made progress in the  development of outcome-oriented performance measures for some  objectives, particularly for the objective of increasing information sharing  and collaboration among CSI and host country personnel. However,  further refinements are needed to assess the effectiveness of the other  program objectives, including CSI targeting and inspection activities.
subsections: section_title: CBP Completed a Strategic Plan for CSI, but Three Key Elements Are Still under Development
paragraphs: In July 2003, we recommended that CBP develop a strategic plan for CSI.  CBP developed a strategic plan in February 2004. According to GPRA,  executive agency strategic plans should include    a comprehensive mission statement,    general goals and objectives,    a description of how the general goals and objectives are to be    a description of how performance goals and measures are related to  the general goals and objectives of the program,    an identification of key factors external to the agency and beyond its  control that could affect the achievement of general goals and  objectives, and    a description of the program evaluations.
These six key elements are required for executive agency strategic plans  and thus serve as a good baseline to measure other long-term planning  efforts. In addition, we have found that high-quality plans include  strategies to mitigate the effects of external factors, although such  strategies are not a legislative requirement.
CSI’s strategic plan includes three of these key elements:     a mission statement: “to prevent and deter terrorist use of maritime  containers while facilitating movement of legitimate trade”;    objectives, including (a) pushing the United States’ zone of security  beyond its physical borders to deter and combat the threat of  terrorism; (b) targeting shipments for potential terrorists and terrorist  weapons, through advanced and enhanced information and intelligence  collection and analysis, and preventing those shipments from entering  the United States; (c) enhancing homeland and border security while  facilitating growth and economic development within the international  trade community; and (d) utilizing available technologies to leverage  resources and to conduct examinations of all high-risk containers  (another objective cited by CBP officials, although not included in the  CSI strategic plan, is to raise the level of bilateral cooperation and  international awareness regarding the need to secure global trade); and    various descriptions of how general goals and objectives are to be  achieved.
However, CBP has not yet incorporated the other three key elements into  its strategic plan. For example, the CSI strategic plan does not include a  description of how performance goals and measures are related to  program objectives. At the time the strategic plan was developed, CBP  lacked performance goals and measures. We discuss performance  measures in more detail in the next section.
In addition, the CSI strategic plan does not identify external factors  beyond the control of CBP that could affect the achievement of program  objectives. Such external factors could include economic, demographic,  social, technological, or environmental factors. Two external factors that  could be addressed in the CSI strategic plan are the extent to which host  governments can provide additional information to contribute to the  targeting process and the various operational limitations that prevent all  high-risk containers from being inspected overseas.
In addition, the CSI strategic plan does not include a description of  program evaluations. Although evaluations are not described in the CSI  strategic plan, CBP conducts periodic evaluations of CSI ports in order to  determine areas in which implementation of CSI can be improved and to  determine whether CSI should continue to operate at that port. However,  these evaluations do not employ a systematic methodology or identify the  basis on which program success is determined. GPRA defines a program  evaluation as an objective and formal assessment of the implementation,  results, impact, or effects of a program or policy. Program evaluations are  used to ensure the validity and reasonableness of program goals and  strategies, as well as identify factors likely to affect program performance.  Specifically, CBP has not identified and planned which CSI elements will  be assessed at each port; rather, assessment topics are generated ad hoc.  In addition, assessment topics differ over time, preventing CBP from  determining the extent to which CSI teams addressed issues raised in  previous evaluations. For example, in its July 2003 evaluation of one CSI  port, CBP’s Office of International Affairs identified the following  problems: (1) lack of information available to the intelligence research  specialist, (2) the need to make better information available to CSI team  members, and (3) the lack of follow-through on shipments through CSI  ports that were referred for domestic exam. However, none of these issues  was discussed in the Office of International Affairs’ next evaluation of this  port in December 2003. Similarly, the assessment topics for CSI port  evaluations also differ across ports, making it difficult to make  comparisons across ports.
In February 2005, CBP officials told us that CBP is revising the CSI  strategic plan to address the elements we raise in this report. While it  appears that the bureau’s initial efforts in this area meet the intent of our  prior recommendation to develop a strategic plan for CSI, we cannot  determine the effectiveness of further revisions to the plan without first  reviewing and evaluating them. We will continue to monitor CBP’s efforts  in this area.
section_title: CBP Has Developed Outcome-Oriented Performance Measures for Some Program Objectives
paragraphs: In July 2003, we recommended that CBP expand efforts already initiated to  develop performance measures for CSI that include outcome-oriented  indicators. Until recently, CBP based the performance of CSI on program  outputs such as (1) the number and percentage of bills of lading reviewed,  further researched, referred for inspection, and actually inspected, and   (2) the number of countries and ports participating in CSI.
As of January 2005, CBP had developed 11 performance indicators for CSI,  2 of which it identified as outcome-oriented: (1) the number of foreign  mitigated examinations and (2) the percentage of worldwide U.S.-destined  containers processed through CSI ports. As indicated in table 2, both  outcome indicators are used to assess CBP’s progress in meeting its  objective of increasing information sharing and collaboration among CBP  officials and host country personnel.
However, the way in which one of these indicators is measured needs  refinement. The measure for the number of foreign mitigated examinations  is the number of shipments referred to host governments that were not,  for a variety of reasons, inspected overseas. Specifically, according to  CBP, an increase in the number of examinations waived or denied  suggests an increase in the number of unnecessary examinations that were  prevented. However, the number of examinations waived or denied by  host nations are not appropriate measures for the prevention of  unnecessary exams. A shipment is inspected unnecessarily if, when  provided with additional information on the shipment, the CSI team and  the host nation would have agreed that the shipment was not high-risk  and, therefore, the inspection should not have taken place. However, if an  inspection is waived because of operational limitations, the implication  may not be that the CSI team thinks the inspection is unnecessary. To the  contrary, the CSI team and host government may agree that the shipment  should be inspected. Similarly, a host nation denial of an inspection does  not imply that the CSI team believes the inspection is unnecessary.  Conversely, when a referral for inspection is categorized as denied, by  definition, the CSI team believes the shipment should be inspected, but the  host government refuses to conduct the inspection. In response to our  review, CBP officials acknowledged that its inclusion of waivers because  of operational limitations or denials of inspections in this measure was  inappropriate.
CBP noted that each of the performance measures for assessing  information sharing and collaboration with host nations will be pilot- tested at numerous CSI ports to assess their feasibility, utility, relevancy,  and the likelihood that they will produce information that is actionable.  According to CBP, the measures may be revised based on the evaluation of  the pilot to improve their effectiveness in assessing program performance  and outcomes.
According to Office of Management and Budget (OMB) and CBP officials,  developing outcome-oriented performance measures that measure the  effectiveness of programs that aim to deter or prevent specific behaviors is  challenging. For example, one of CSI’s objectives is to deter terrorists’ use  of oceangoing cargo containers. However, according to host government  officials at one port we visited and CBP officials, it is difficult to develop a  meaningful measure for the extent to which implementation of CSI has  discouraged terrorists from using oceangoing cargo containers to smuggle  WMD into the United States. In January 2005, CBP developed a  performance indicator to measure CSI’s progress in preventing terrorists’  use of oceangoing cargo containers that measures the amount of terrorist  contraband, illegal drugs, and other illegal activity found during CSI  inspections. However, this indicator may not be a meaningful measure of  deterrence of terrorist activity, since the inclusion of narcotics is not  relevant to the program’s objectives, and according to CBP, no terrorist  weapons or weapons material have been detected prior to or during the  implementation of CSI.
According to OMB, when agencies face difficulty in developing outcome- based performance measures, they are encouraged to develop proxy  measures. Proxy measures are used to assess the effectiveness of program  functions, such as the targeting and inspection processes of CSI, rather  than directly assess the effectiveness of the program. For example, CBP  could develop a proxy measure associated with targeting and inspection,  such as the percentage of containers randomly inspected domestically that  was not characterized by CBP officials as high-risk that actually contained  WMD. CBP could also use random inspections to measure if containers  from CSI ports that were not identified as high-risk actually contained  WMD and, therefore, should have initially been identified as high-risk.  According to terrorism experts and representatives of the international  trade community, random inspections could be an effective practice to  supplement and test CBP’s targeting and inspection processes.
Terrorism experts and shipping industry representatives also suggest that  staging covert, simulated terrorist events could test the effectiveness of  both the targeting and inspection processes of CSI. Simulated events could  include smuggling fake WMD into the United States using an oceangoing  cargo container. Such events could help determine whether the targeting  procedures led to the identification of the container as high-risk and  whether any subsequent inspection activities actually detected the fake  WMD. CBP could, therefore, develop proxy measures associated with this  activity for CSI, such as the percentage of staged containers that were  identified as high-risk and the percentage of staged containers for which  the fake WMD was detected during the inspection process. In response to  our prior work on container security, CBP officials agreed with our  recommendation that containers be subject to such tests.
CSI lacks performance goals and measures for its objective of enhancing  homeland and border security while facilitating growth and economic  development within the international trade community. Regarding the  enhancement of homeland and border security, there are no performance  goals for CSI. According to host government officials at CSI ports we  visited and shipping industry representatives with whom we met, CSI has  resulted in increased international awareness of supply chain security.  Officials from the World Customs Organization predicted that as more  countries partner with CBP through CSI, there will be increased  consistency in the way in which the supply chain and ports are secured  worldwide. One WCO official also stated that CBP’s efforts through  initiatives such as CSI provide guidance for developing countries on how  to improve their supply chain security efforts. While these testimonials  help identify some benefits of CSI, CBP does not have performance  indicators and goals to actually measure the extent to which the program  has resulted in enhanced homeland and border security.
Regarding facilitating economic growth, there are also no performance  measures for CSI. According to host government officials with whom we  met at one CSI port, they are willing to participate in CSI as long as the  program does not disrupt the flow of trade. An example of such a  disruption would be the delayed departure of a vessel because of a CSI  inspection or the instruction not to load a container on a departing vessel  because of a CSI inspection. Discussions with CBP and host government  officials and representatives of the shipping industry indicate that CBP has  been successful in not disrupting the flow of trade through CSI. However,  CBP has not developed associated performance goals and measures to  demonstrate its reported success in achieving this objective. In  commenting on a draft of this report, DHS noted that CBP is continuing to  refine existing performance measures and develop new performance  measures for its program goals. For example, CBP was developing a cost  efficiency measure to measure the cost of work at a port and to contribute  to staffing decisions. CBP believes that its continued revisions to the CSI  strategic plan have also allowed CSI staff to refine performance measures  and the bureau’s data collection methodology.
section_title: Conclusions
paragraphs: CBP has made progress in its implementation of CSI, but the program  could be further improved by taking steps to help ensure its effectiveness  in preventing WMD from entering the United States via cargo containers.  First, CBP’s inability to staff all CSI ports to the level suggested by its  staffing model and the model’s assumption that all staff should be located  at the CSI ports have limited the program’s ability to target potentially  high-risk shipments at some foreign seaports before they depart for the  United States. This problem may be exacerbated as CBP continues to  expand CSI to additional overseas seaports. Second, without minimum  technical requirements for the nonintrusive inspection equipment used as  part of CSI, CBP has limited assurance that the equipment in use can  successfully detect all WMD. While we recognize that establishing such  requirements may be a difficult issue to address, it is important that CBP  establish them because the CSI inspection may be the only inspection of  some containers before they enter the interior of the United States. Third,  CBP has developed a strategic plan for the CSI program and indicated that  it will refine the plan to include key elements described in GPRA. Although  we are not making a recommendation related to its strategic plan, given  the importance of having an effective strategic plan for the program, we  will continue to monitor the bureau’s progress in refining the plan. Finally,  while CSI has apparently resulted in some benefits, such as cooperation  with foreign governments and enhanced international awareness of  container security, CBP has not developed outcome-based performance  measures or proxy measures for all of its program objectives. Without  outcome-based performance measures on which to base program  evaluations, CBP will have difficulties assessing the effectiveness of CSI as  a homeland security program.
section_title: Recommendations for Executive Action
paragraphs: To help ensure that the objectives of CSI are achieved, we recommend  that the Secretary of the Department of Homeland Security direct the  Commissioner of U.S. Customs and Border Protection take the following  three actions:  revise the CSI staffing model to consider (1) what functions need to be  performed at CSI ports and what functions can be performed in the  United States, (2) the optimum levels of staff needed at CSI ports to  maximize the benefits of targeting and inspection activities in  conjunction with host nation customs officials, and (3) the cost of  locating targeters overseas at CSI ports instead of in the United States;    establish minimum technical requirements for the capabilities of  nonintrusive inspection equipment at CSI ports, to include imaging and  radiation detection devices, that help ensure that all equipment used  can detect WMD, while considering the need not to endorse certain  companies and sovereignty issues with participating countries;    develop performance measures that include outcome-based measures  and performance targets (or proxies as appropriate) to track the  program’s progress in meeting all of its objectives.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Secretary of DHS and the  Department of State for comment. We received comments from the DHS  Acting Director, Departmental Liaison, that are reprinted in appendix III.  DHS generally agreed with our recommendations and outlined actions  CBP either had taken or was planning to take to implement them. The  Department of State had no comments.
CBP agreed with our recommendation on CSI’s staffing model and said  that modifications to the model would allow for program objectives to be  achieved in a cost-effective manner. Specifically, CBP said that it would  evaluate the minimum level of staff needed at CSI ports to maintain an  ongoing dialogue with host nation officials, as well as assess the staffing  levels needed domestically to support CSI activities. If properly  implemented, these actions should address the intent of this  recommendation.
In addressing our recommendation to establish minimum technical  requirements for the capabilities of the nonintrusive inspection equipment  used at CSI ports, CBP agreed to evaluate the feasibility of making such  requirements for the imaging and radiation detection devices in use at CSI  ports but did not commit to implement our recommendation. CBP noted  that because host governments purchase the equipment for use at CSI  ports, a legal issue may exist regarding CBP’s ability to impose such  requirements. CBP noted it would also seek comment and advice from  other U.S. government agencies that would be affected by such a decision.  Although CBP cannot endorse a particular brand of equipment, the bureau  could still establish general technical capability requirements for any  equipment used under CSI similar to other general requirements CBP has  for the program, such as the country committing to establishing an  automated risk management system. Because the CSI inspection could be  the only inspection of a container before it enters the interior of the United  States, it is important that the nonintrusive inspection and radiation  detection equipment used as part of CSI meet minimum technical  requirements to provide some level of assurance of the likelihood that the  equipment could detect the presence of WMD.
CBP agreed with our recommendation on developing performance  measures, noting that it would continue to refine, evaluate, and implement  any and all performance measures needed to track the progress in meeting  all of CSI’s objectives. CBP noted that this would be an ongoing activity. If  properly implemented, these plans should help address the intent of this  recommendation.
DHS also offered technical comments and clarifications, which we have  considered and incorporated where appropriate.
If you or your staffs have any questions about this report, please contact  me at (202) 512-8777 or at stanar@gao.gov. Key contributors to this report  are listed in appendix IV. This report will also be available at no charge on  the GAO Web site at http://www.gao.gov.
section_title: Appendix I: Objectives, Scope, and Methodology
subsections: section_title: Objectives
paragraphs: We addressed the following issues regarding the U.S. Customs and Border  Protection’s (CBP) Container Security Initiative (CSI):    What factors affect CBP’s ability to target high-risk shipments at  overseas seaports?
Under CSI, to what extent have high-risk containers been inspected  overseas prior to their arrival at U.S. destinations?
To what extent has CBP developed strategies and related management  tools for achieving the program’s goals?
section_title: Scope and Methodology
paragraphs: To address our first issue—what factors affect CBP’s ability to target  shipments at overseas seaports—we first reviewed relevant GAO reports  on CBP’s Automated Targeting System (ATS) and CSI. We then met with  CBP headquarters officials to hold discussions and review documents  related to CSI’s overall targeting strategy, criteria for identifying high-risk  containers, efforts to evaluate the program, efforts to refine targeting,  training provided to CSI targeters, and the criteria for staffing at CSI ports.  We also visited the National Targeting Center, which serves as CBP’s  central targeting facility related to terrorism. At this facility, we met with  cognizant officials and discussed ATS categorization of containers by risk  level, how cargo containers’ scores are transmitted to targeters at CSI  ports, the training provided to the ATS targeters, the types of information  and intelligence utilized by targeters, and recent and planned refinements  to ATS. We also met with officials from the European Commission and the  World Customs Organization (WCO) in Brussels, Belgium, and discussed  how the CSI program has been implemented and its impact on container  security.
Also related to this first issue, we visited four overseas CSI ports. We  selected these ports on the basis of the volume of containers shipped to  the United States, geographic dispersion, and time the CSI team was in  operation. At these ports, we met with the CSI teams to discuss and review  documents related to the overall targeting process, the types of  information used in the targeting process, efforts to evaluate the targeting  process, the impact other CBP initiatives may have had on the targeting  process, and requests for information to host governments. We also  observed operations at each of the ports, including targeters reviewing  manifest information.
To address our second issue—to what extent have high-risk containers  been inspected overseas prior to their arrival at U.S. destinations—we met  with officials from CBP headquarters and CSI port teams to hold  discussions and review documents related to the overall inspection  process, types of inspections, inspection equipment used, statistics on  inspections conducted at CSI ports, and levels of cooperation with host  governments. At the four ports we visited, we also met with foreign  government customs officials to discuss the role of the CSI teams in the  inspection process, the criteria they use in deciding whether to inspect a  container that was referred for inspection by the CSI team, the criteria  they use in deciding the type of inspection to be conducted, the  procedures they use to safeguard containers once inspected, and the types  of inspection equipment they used.
To address our third issue—to what extent has CBP developed clearly  formulated and documented strategies for achieving the program’s goals— we reviewed GAO reports examining management factors that were  necessary components for the successful management of cabinet  departments, agencies, and, by extension, individual programs.  Specifically, we focused our review on two management factors—the  development of performance measures and strategic planning—because of  their general importance in the literature. We reviewed Office of  Management and Budget (OMB) and Government Performance and  Results Act of 1993 (GPRA) guidance on performance measures and goals  to assess the extent CBP has incorporated them into the CSI program. We  also discussed CSI strategies for achieving program goals with officials  from CBP headquarters, CSI teams, and host governments. We also  obtained and reviewed CBP evaluations of CSI port teams to assess the  methodology used to conduct evaluations.
We conducted our work from February 2004 through February 2005 in  accordance with generally accepted government auditing standards.
section_title: Data Reliability
paragraphs: To assess the reliability of CBP’s data on the number of shipments and  containers subject to targeting and inspection under CSI, we (1) obtained  source data on targeting and inspection activity for two 1-week periods  from CSI teams at two ports, (2) compared the source data with the data  generated by CBP’s Automated Targeting System (ATS) for the same   2-week period, (3) discussed discrepancies between the source data and  ATS data with CBP officials at these ports, and (4) obtained CBP  headquarters’ responses to our questionnaire regarding the reliability of  ATS and the data that are produced by the system. Although our initial  reliability testing indicated that there were some inconsistencies between  the source data and the data generated by ATS, generally because of  human input error, we were able to work with CSI team officials to resolve  most of the discrepancies. In addition, the differences between the source  data and ATS data were so small that the results of our analysis, at least  for this 2-week period, would have remained the same regardless of which  data we used. Therefore, we determined that the CSI targeting and  inspection data generated by ATS are sufficiently reliable for use in  supporting our findings regarding the extent to which high-risk  containerized shipments are identified and inspected prior to arrival at  U.S. destinations.
section_title: Appendix II: CSI Performance Measures, as of January 2005
paragraphs: Appendix II: CSI Performance Measures, as of  January 2005 The measure will be the  number of  examinations waived  because of a variety of  reasons.
2,416 examinations  (cumulative)
This measure will utilize  the annual volume of  U.S.-destined  containers processed  through all CSI ports  prior to lading and  divide it by the annual  worldwide number of  U.S.-destined  containers.
This measure will track  the number of  memorandums of  information received  (MOIR), which are  narratives of  intelligence gathered  from CSI foreign  sources.
This measure identifies  the total number of  ports where CSI has  been implemented.
Number of positive findings, by category  This measure includes  identifying the number  and type of “positive  findings” documented  because of CSI  participation. Positive  findings occur when  examinations  performed on  containers yield a  positive result such as  implements of terror,  narcotics, forced labor,  uninvoiced or  unmanifested good,  restricted merchandise,  hazardous materials, or  other results. Note that  the CSI goal is to find  implements of terror;  other categories are  peripheral benefits.
This measure tracks  the number of  investigative cases  opened either in the  United States or at a  foreign location  because of intelligence  gathered by CSI staff at  foreign ports.
The average cost per  CSI port includes site  assessments and  certifications, telecom  circuit installation, local  area network (LAN) and  office equipment,  commercial off-the- shelf software, office  furniture, radiation  isotope identification  devices (RIID),  purchase of  automobiles, initial  lease and utilities costs,  and initial shipping  costs.
This measure records  the number of  declarations of  principles signed with  countries where CSI  ports are planned.
section_title: Appendix III: Comments from the Department of Homeland Security
section_title: Appendix IV: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: In addition to those named above, Mark Abraham, Kristy N. Brown,  Kathryn E. Godfrey, Stanley J. Kostyla, and Deena D. Richart made key  contributions to this report.
section_title: Related GAO Products
paragraphs: Cargo Security: Partnership Program Grants Importers Reduced  Scrutiny with Limited Assurance of Improved Security. GAO-05-404  (Washington, D.C.: March 11, 2005).
Homeland Security: Process for Reporting Lessons Learned from Seaport  Exercises Needs Further Attention. GAO-05-170 (Washington, D.C.:  January 14, 2005).
Port Security: Planning Needed to Develop and Operate Maritime Worker  Identification Card Program. GAO-05-106 (Washington, D.C.: December  10, 2004).
Maritime Security: Better Planning Needed to Help Ensure an Effective  Port Security Assessment Program. GAO-04-1062 (Washington, D.C.:  September 30, 2004).
Maritime Security: Substantial Work Remains to Translate New  Planning Requirements into Effective Port Security. GAO-04-838  (Washington, D.C.: June 30, 2004).
Border Security: Agencies Need to Better Coordinate Their Strategies  and Operations on Federal Lands. GAO-04-590 (Washington, D.C.: June  16, 2004).
Homeland Security: Summary of Challenges Faced in Targeting  Oceangoing Cargo Containers for Inspection. GAO-04-557T (Washington,  D.C.: March 31, 2004).
Rail Security: Some Actions Taken to Enhance Passenger and Freight  Rail Security, but Significant Challenges Remain. GAO-04-598T  (Washington, D.C.: March 23, 2004).
Department of Homeland Security, Bureau of Customs and Border  Protection: Required Advance Electronic Presentation of Cargo  Information. GAO-04-319R (Washington, D.C.: December 18, 2003).
Homeland Security: Preliminary Observations on Efforts to Target  Security Inspections of Cargo Containers. GAO-04-325T (Washington,  D.C.: December 16, 2003).
Posthearing Questions Related to Aviation and Port Security.   GAO-04-315R (Washington, D.C.: December 12, 2003).
Homeland Security: Risks Facing Key Border and Transportation  Security Program Need to Be Addressed. GAO-03-1083 (Washington, D.C.:  September 19, 2003).
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).
Transportation Security: Federal Action Needed to Help Address  Security Challenges. GAO-03-843 (Washington, D.C.: June 30, 2003).
Transportation Security: Post-September 11th Initiatives and Long- Term Challenges. GAO-03-616T (Washington, D.C.: April 1, 2003).
Border Security: Challenges in Implementing Border Technology.   GAO-03-546T (Washington, D.C.: March 12, 2003).
Customs Service: Acquisition and Deployment of Radiation Detection  Equipment. GAO-03-235T (Washington, D.C.: October 17, 2002).
Port Security: Nation Faces Formidable Challenges in Making New  Initiatives Successful. GAO-02-993T (Washington, D.C.: August 5, 2002).