In return for committing to making improvements to the security  of their shipments by joining the program, C-TPAT members may receive  benefits that result in reduced scrutiny of their shipments (e.g., reduced  number of inspections or shorter border wait times for their shipments). Of these  companies, CBP grants importers key program benefits. CBP officials told us that validations are not considered independent  audits, and the objectives, scope, and methodology of validations are  jointly agreed upon with the member representatives. Moreover, as we reported, CBP has no written guidelines for its supply  chain specialist to indicate what scope of effort is adequate for the  validation to ensure that the member’s security measures are reliable,  accurate, and effective, in part because it seeks to emphasize the  partnership nature of the program. In 3 years of C-TPAT operation, CBP has validated about   11 percent of its certified members. Third, we reported that CBP’s record keeping for the program is  incomplete, as key decisions are not always documented and  programmatic information is not updated regularly or accurately. GAO Recommendations and CBP Response

Our C-TPAT report recommended that the Secretary of Homeland Security  direct the Commissioner of U.S. Customs and Border Protection to take  the following five actions:    strengthen the validation process by providing appropriate guidance to  specialists conducting validations, including what level of review is  adequate to determine whether member security practices are reliable,  accurate, and effective;    determine the extent (in terms of numbers or percentage) to which  members should be validated in lieu of the original goal to validate all  members within 3 years of certification;   complete the development of performance measures, to include  outcome-based measures and performance targets, to track the  program’s status in meeting its strategic goals;   complete a human capital plan that clearly describes how the C-TPAT  program will recruit, train, and retain sufficient staff to successfully  conduct the work of the program, including reviewing security profiles,  vetting, and conducting validations to mitigate program risk; and  implement a records management system that accurately and timely  documents key decisions and significant operational events, including  a reliable system for (1) documenting and maintaining records of all  decisions in the application through validation processes, including but  not limited to documentation of the objectives, scope, methodologies,  and limitations of validations, and (2) tracking member status. Limitations Exist in Ability to Target Containers Overseas

In our CSI report, we noted that CBP officials told us 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. As we reported, one factor negatively affecting CBP’s ability to target  containers is staffing imbalances across ports. As a result of these imbalances, 35 percent of U.S.-bound  shipments from CSI ports were not targeted and were therefore not  subject to inspection overseas—the key goal of the CSI program. Some Containers Were Not Inspected for a Variety of Reasons

As we reported, 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 for a variety of reasons including  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. Further, we reported that for the 72 percent (10,343) of containers 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, the  inspection equipment used at CSI ports varies in detection capability, and  there are no minimum requirements for the detection capability of  equipment used for CSI. As a result, CBP has no absolute assurance that  inspections conducted under CSI are effective at detecting and identifying  WMD. CBP Has Made Progress Developing a Strategic Plan and Performance Measures for CSI, but Further Refinements Are Needed

As we reported, CBP has made some improvements in the management of  CSI, but further refinements to the bureau’s management tools are needed  to help achieve program goals. GAO Recommendations and CBP Response

Our CSI report recommended that the Secretary of Homeland Security  direct the Commissioner of U.S. Customs and Border Protection to 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; and   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. This concludes my statement.
Why GAO Did This Study

U.S. Customs and Border Protection (CBP) has in place two programs to help address the threat posed by terrorists smuggling weapons of mass destruction (WMD) into the United States: the Customs-Trade Partnership Against Terrorism (C-TPAT) and the Container Security Initiative (CSI). In July 2003, GAO reported that these programs had management challenges that limited their effectiveness. Given plans to expand both programs, in two recently issued reports GAO examined selected aspects of both programs' operations. This statement is a summary of those publicly available reports.

What GAO Found

In return for committing to making improvements to the security of their shipments, C-TPAT members receive a range of benefits that may change the risk characterization of their shipments, thereby reducing the probability of extensive inspection. Before providing benefits, CBP reviews the self-reported information contained in applicants' membership agreements and security profiles. Also, CBP assesses the compliance history of importers before granting them benefits. However, CBP grants benefits before members undergo the validation process, which is CBP's method to verify that their security measures are reliable, accurate, and effective. Although CBP's goal was to validate members within 3 years, to date it has validated 11 percent of them. Further, the validation process is not rigorous, as the objectives, scope, and methodology of validations are jointly agreed upon with the member, and CBP has no written guidelines to indicate what scope of effort is adequate for the validation. Also, although CBP has recently moved to a risk-based approach to selecting members for validation, it has not determined the number and types of validations that are needed to manage security risks or the CBP staff required to complete them. Further, CBP has not developed a comprehensive set of performance measures for the program, and key program decisions are not always documented and programmatic information is not updated regularly or accurately. The CSI program is designed to target and inspect high-risk cargo containers at foreign ports before they leave for the United States. It has resulted in improved information sharing between U.S. and foreign customs operations and a heightened level of international awareness regarding securing the global shipping system. Yet, several factors limit CBP's ability to successfully target containers to determine if they are high-risk. One factor is staffing imbalances, caused by political and practical considerations, which impede CBP's targeting efforts at CSI ports. As a result, 35 percent of U.S.-bound shipments from CSI ports were not targeted and not subject to inspection overseas--the key goal of the CSI program. In addition, as of September 11, 2004, 28 percent of the containers referred to host governments for inspection were not inspected overseas for various reasons such as operational limitations. One percent of these referrals were denied by host government officials, generally because they believed the referrals were based on factors not related to security threats. For the 72 percent of referred containers that were inspected overseas, CBP officials told us that no WMD were discovered. However, the nonintrusive inspection equipment used at CSI ports varies in detection capability, and there are no minimum technical requirements for equipment used as part of CSI. As a result, CBP has limited assurance that inspections conducted under CSI are effective at detecting and identifying terrorist WMD in containers. Finally, CBP continues to make refinements to the strategic plan and performance measures needed to help manage the program and achieve program goals. Until these refinements are completed, it will be difficult to assess progress made in CSI operations.