CBP Has Layered Approach to Select and Inspect Cargo Containers

CBP is responsible for preventing terrorists and weapons of mass  destruction from entering the United States. As part of its responsibility, it  has the mission to address the potential threat posed by the movement of  oceangoing containers. These  determinations are not just based on concerns about terrorism, but also  concerns about illegal narcotics and/or other contraband. The Commissioner  also said it is unrealistic to expect that all containers warrant such  inspection because each container poses a different level of risk based on  a number of factors including the exporter, the transportation providers,  and the importer. Positive Steps Taken, but Targeting Strategy Lacks Some Key Components of Risk Management and Modeling

		CBP Has Taken Several Steps to Improve Its Targeting Strategy

CBP has recognized the potential vulnerability of oceangoing cargo  containers and has reviewed and updated some aspects of its layered  targeting strategy. CBP officials told us that, given the urgency to take steps to  protect against terrorism after the September 11, 2001, terrorist attacks,  they had to take an “implement and amend” approach. The rule is intended to improve  the quality and the timeliness of manifest information submitted to  CBP, which is important because CBP relies extensively on manifest  information for targeting. Targeting Strategy Does Not Incorporate Some Key Elements of Risk Management

While CBP’s targeting strategy incorporates some elements of risk  management, our discussions with terrorism experts and our comparison  of CBP’s targeting system with recognized risk management practices  showed that the strategy does not fully incorporate all key elements of a  risk management framework. CBP has not performed a comprehensive set of assessments for cargo  containers. Targeting Strategy Faces Implementation Challenges

		CBP Lacks National System to Track Cargo Container Inspections by Risk Category

We found a number of deficiencies in CBP’s national system for reporting  and analyzing inspection statistics. Staff Testing and Certification Could Help Strengthen Targeting Process

CBP does not have an adequate mechanism to test or certify the  competence of targeters in their national targeting training program. Not all longshoremen’s unions have  safety concerns regarding VACIS inspections. In the context of  possible smuggling of weapons of mass destruction in cargo containers at  our nation’s seaports, it is vital that CBP use its resources to maximize the  effectiveness of its targeting strategy to reduce this uncertainty. Without  incorporating all elements of a risk management framework and utilizing  recognized modeling practices, CBP cannot be sure that its targeting  strategy is properly focused and prioritized. Finally,  without instituting a national inspection reporting system, testing and  certifying CBP officials that receive the targeting training, and resolving  the safety concerns of longshoremen unions, the targeting system’s  effectiveness as a risk management tool may be limited. One way in which the  Department of Homeland Security’s U.S. Customs and Border Protection  has already begun to manage risk is by developing and implementing the  Automated Targeting System to target high-risk oceangoing containerized  cargo for inspection. Mitigation selection. Appendix III: Recognized Modeling Practices Applicable to the Review of ATS

This appendix details the recognized modeling practices that GAO used to  assess CBP’s computerized targeting model, known as the ATS. Simulated events could include “red teams” attempting to smuggle a fake  WMD into the United States hidden in an oceangoing cargo container.
Why GAO Did This Study

After the attacks of September 11, 2001, concerns intensified that terrorists would attempt to smuggle a weapon of mass destruction into the United States. One possible method is to use one of the 7 million cargo containers that arrive at our seaports each year. Addressing the potential threat posed by the movement of oceangoing cargo containers falls to the Department of Homeland Security's U.S. Customs and Border Protection (CBP). Since CBP cannot inspect all arriving cargo containers, it uses a targeting strategy, including an Automated Targeting System. This system targets containers for inspection based on perceived level of risk. In this testimony, GAO summarizes its work on (1) whether the development of CBP's targeting strategy is consistent with recognized key risk management and modeling practices and (2) how well the strategy has been implemented at selected seaports.

What GAO Found

CBP has taken steps to address the terrorism risks posed by oceangoing cargo containers, but its strategy neither incorporates all key elements of a risk management framework nor is it entirely consistent with recognized modeling practices. Actions CBP has taken included refining the Automated Targeting System to target cargo containers that are a high risk for terrorism, or other smuggling, for physical inspection. CBP has also implemented national targeting training and sought to improve the quality and timeliness of manifest information, which is one of the inputs for its Automated Targeting System. However, regarding risk management, CPB has not performed a comprehensive set of assessments vital for determining the level of risk for oceangoing cargo containers and the types of responses necessary to mitigate that risk. Regarding recognized modeling practices, CBP has not subjected the Automated Targeting System to adequate external peer review or testing. It has also not fully implemented a process to randomly examine containers in order to test the targeting strategy. Without incorporating all key elements of a risk management framework and recognized modeling practices, CBP cannot be reasonably sure that its targeting strategy provides the best method to protect against weapons of mass destruction entering the United States at its seaports. GAO's visits to selected seaports found that the implementation of CBP's targeting strategy faces a number of challenges. Although port officials said that inspectors were able to inspect all containers designated by the Automated Targeting System as high-risk, GAO's requests for documentation raised concerns about the adequacy of CBP's data to document these inspections. CBP lacks an adequate mechanism to test or certify the competence of students who participate in their national targeting training. Additionally, CBP has not been able to fully address longshoremen's safety concerns related to inspection equipment. Addressing these concerns is important to ensure that cargo inspections are conducted safely and efficiently. Challenges to both the development and the implementation of CBP's targeting strategy, if not addressed, may limit the effectiveness of targeting as a tool to help ensure homeland security.