Ports are critical gateways for the movement of commerce through the international supply chain. The facilities, vessels, and infrastructure within ports, and the cargo containers passing through them, all have vulnerabilities that terrorists could exploit. Containers carrying goods that are shipped in oceangoing vessels are of particular concern because they can be filled overseas at many different locations and are transported through complex logistics networks before reaching U.S. ports. In addition, transporting a shipping container from its international point of origin to its final destination involves many different participants and many points of transfer. The container, or material in it, can be affected not only by the manufacturer or supplier of the material being shipped, but also by carriers who are responsible for getting the material to a port, as well as by personnel who load containers onto the ships. Others who interact with the cargo or have access to the records of the goods being shipped include exporters who make arrangements for shipping and loading, freight consolidators who package disparate cargo into containers, and forwarders who manage and process the information about what is being loaded onto the ship. Figure 1 illustrates many of the key participants and points of transfer involved from the time that a container is loaded for shipping to its arrival at the destination port and ultimately the importer. Several studies of 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. Every time responsibility for cargo in containers changes hands along the supply chain there is the potential for a security breach. As a result, vulnerabilities exist that terrorists could take advantage of by, for example, placing a WMD into a container for shipment to the United States or elsewhere. U.S. government officials believe that the likelihood of terrorists smuggling WMD into the United States in cargo containers is relatively low. While there have been no known incidents of containers being used to transport WMD, criminals have exploited containers for other illegal purposes, such as smuggling weapons, people, and illicit substances. In the federal government, CBP is responsible for overseeing oceangoing container security and reducing the vulnerabilities associated with the supply chain. While CBP officials at domestic ports continue efforts to identify and examine imports arriving in containers that may pose a risk for terrorism, CBP’s post-9/11 strategy also involves focusing security efforts beyond U.S. borders to target and examine cargo that may pose a risk for terrorism before it enters U.S. ports. CBP’s strategy is based on a layered approach of related initiatives that attempt to focus limited resources on potentially risky cargo shipped in containers bound for the United States while allowing other containers carrying cargo to proceed without unduly disrupting commerce. CBP’s layered strategy to address container security is complimented by DOE’s efforts to prevent the proliferation of nuclear materials. DOE has led U.S. efforts to detect radioactive material in cargo containers originating at foreign ports. A brief description of CBP and DOE initiatives is provided in table 1. CBP has taken a lead role in working with foreign customs administrations on approaches to standardize supply chain security worldwide. In 2004, CBP, along with 11 other member customs administrations of the WCO, formed the High Level Strategic Group to develop international standards for customs security practices. The group developed the WCO Framework of Standards to Secure and Facilitate Global Trade (commonly referred to as the SAFE Framework), the core concepts of which are based on components in CBP’s CSI and C-TPAT programs. For example, just as in the CSI program, the SAFE Framework states that members should use a risk-management system to target and identify cargo that may pose a risk for terrorism. Similar to C-TPAT, the SAFE Framework incorporates the concept of the Authorized Economic Operator (AEO) and provides technical guidance for customs administrations to develop an AEO program that offers incentives to companies that comply with predetermined minimum supply chain security standards. According to data from the WCO, as of July 2009, about 70 countries, including the 27 members states of the European Union, have implemented or have begun developing AEO programs. In the United States, C-TPAT is the designated AEO program and businesses participating in the program are Authorized Economic Operators. In June 2005, the 173-member customs administrations of the WCO adopted the SAFE Framework. Further, as of June 2009, 157 WCO members, including the United States, had signed letters of intent to implement the SAFE Framework (see fig. 2). While CBP has developed cooperative relationships with foreign governments to enhance the security of U.S.-bound cargo containers before they are placed on a vessel, several factors at foreign ports that impact the security of cargo are beyond CBP’s control. For example, while CBP has developed specific standards for the inspection equipment used to scan cargo containers at domestic ports, CBP has potentially limited assurance that this inspection equipment is capable of detecting and identifying potential WMD at foreign ports. Additionally, while CBP can issue a “do not load” order so that a specific cargo container would not be allowed on a U.S.-bound vessel, it has no authority to compel host governments to participate in security programs or to scan cargo containers that it has determined may pose some risk. For example, when CBP determines that cargo in a particular container at a CSI or SFI port poses some risk, it must request that the host government’s customs service conduct a physical examination of the container since CBP has no authority to do so itself. Similarly, unlike domestic ports, CBP cannot compel private sector entities operating at foreign ports to participate in security initiatives. For example, at one port, for a period of approximately 2 months, the terminal operator ceased to provide CBP information on which containers leaving the port were bound for the United States. As a result, CBP had greater difficulty determining which containers were U.S.- bound and, therefore, should be scanned with imaging equipment. Under these circumstances, CBP would still have the option of preventing the cargo containers from being loaded onto U.S. bound vessels, or flagging the containers for further inspection once they arrive in the United States. There are generally two types of cargo container examinations—scanning equipment and physical searches—used as part of the SFI and CSI programs. There are two basic types of scanning equipment currently used to examine cargo containers that do not require the container to be opened: (1) radiation detection equipment, including radiation portal monitors, and (2) non-intrusive imaging equipment (NII), which may use X-rays or gamma rays. Radiation detection equipment, such as radiation portal monitors (RPM) and radiation isotope identification devices (RIID) detect the presence of radioactive material that may be in a container. RIIDs and certain types of RPMs can identify the type of material emitting the radiation and whether the material poses a threat or is a naturally occurring radioactive material, such as that found in certain ceramic tiles. We observed at domestic and foreign ports that if radioactive emissions were detected from a cargo container, customs officials used a handheld RIID to determine whether the radiation being emitted posed a threat. The second type of equipment, referred to as NII, uses X-rays or gamma rays to scan a container and create images of the container’s contents without opening it. Examples of a RPM, handheld RIID, and NII are depicted in figure 3. CBP officials, along with host government officials, review the images produced with the NII to detect anomalies or shielding that could indicate the presence of WMD. The 100 percent scanning provision of the 9/11 Act requires containers to be scanned with both radiation detection and NII equipment; doing so may identify WMD material that is successfully shielded from detection by RPM. The average time at which a container is processed through the scanning system is 3 to 5 minutes. If the use of the RIID is necessary, the average time increases another 5 to 10 minutes. In response to the SAFE Port Act requirement to implement a pilot program to determine the feasibility of scanning 100 percent of U.S.-bound containers with both RPM and NII equipment, CBP, the State Department, and DOE jointly announced the formation of SFI in December 2006 as an effort to build upon existing container security measures by enhancing the U.S. government’s ability to ensure containers are scanned for nuclear and radiological material overseas and better assess the risk of inbound containers. In essence, SFI builds upon the CSI and Megaports programs by combining each program’s scanning technology equipment. To accomplish this, CBP met with terminal operators to identify foreign ports for inclusion in the pilot program to scan 100 percent of U.S.-bound containers. Based on discussions with terminal operators and subsequent discussions with host government officials, three ports were selected to implement the SAFE Port Act pilot program: Qasim, Pakistan; Puerto Cortes, Honduras; and Southampton, United Kingdom. According to CBP officials, while initiating the SFI program at these ports satisfied the SAFE Port Act requirement to implement the program at three ports, CBP also selected the ports of Hong Kong; Busan, South Korea; and Salalah, Oman to more fully demonstrate the capability of the integrated scanning system at larger, more complex ports with higher percentages of transshipment container cargo—cargo containers from one port that are taken off a vessel at another port to be placed on another vessel bound for the United States. For example, port officials told us that at the Ports of Hong Kong, Singapore, and Salalah, transshipment cargo constitutes about 50 percent, 87 percent, and 99 percent of U.S.-bound containers, respectively.