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Report to Congressional Requesters:

United States Government Accountability Office:

GAO:

April 2005:

Container Security:

A Flexible Staffing Model and Minimum Equipment Requirements Would 
Improve Overseas Targeting and Inspection Efforts:

GAO-05-557:

GAO Highlights:

Highlights of GAO-05-557, a report to congressional requesters: 

Why GAO Did This Study:

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.

What GAO Found:

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.

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 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.

What GAO Recommends:

GAO recommends that CBP refine its staffing model to help improve the 
program’s ability to target shipments at foreign ports, develop minimum 
technical requirements for the detection capabilities of equipment used 
in the program, and complete development of performance measures for 
all program objectives. 

The Department of Homeland Security (DHS) generally concurred with our 
recommendations and described corrective actions to respond to them. 
The Department of State had no comments.

www.gao.gov/cgi-bin/getrpt?GAO-05-557.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Richard M. Stana at (202) 
512-8777 or stanar@gao.gov.

[End of section]

Contents:

Letter:

Results in Brief:

Background:

While CBP Has Enhanced Its Ability to Target Containers Overseas, 
Limitations Remain:

Some Containers Not Inspected for a Variety of Reasons:

CBP Has Made Progress Developing a Strategic Plan and Performance 
Measures for CSI, but Further Refinements Are Needed:

Conclusions:

Recommendations for Executive Action:

Agency Comments and Our Evaluation:

Appendix I: Objectives, Scope, and Methodology:

Objectives:

Scope and Methodology:

Data Reliability:

Appendix II: CSI Performance Measures, as of January 2005:

Appendix III: Comments from the Department of Homeland Security:

Appendix IV: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Staff Acknowledgments:

Related GAO Products:

Tables:

Table 1: CSI Operational Seaports, as of February 2005:

Table 2: CSI Outcome-Oriented Performance Measures:

Figures:

Figure 1: CBP's Domestic Process for Targeting and Inspecting Cargo 
Containers:

Figure 2: Commercial Sample Image Produced by an X-ray Imaging Machine 
of a Cargo Container Loaded on a Truck Trailer:

Figure 3: CSI Process for Targeting and Inspecting Cargo Containers 
Overseas:

Abbreviations:

ATS: Automated Targeting System:

CBP: U.S. Customs and Border Protection:

CSI: Container Security Initiative:

GPRA: Government Performance and Results Act of 1993:

ICE: U.S. Immigration and Customs Enforcement:

NTC: National Targeting Center:

OMB: Office of Management and Budget:

PRD: personal radiation detector:

RIID: radiation isotope identifier device:

RPM: radiation portal monitor:

WCO: World Customs Organization:

WMD: weapons of mass destruction:

United States Government Accountability Office:

Washington, DC 20548:

April 26, 2005:

The Honorable Susan M. Collins: 
Chairman: 
The Honorable Joseph I. Lieberman: 
Ranking Minority Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate:

The Honorable Norm Coleman: 
Chairman: 
The Honorable Carl Levin: 
Ranking Minority Member: 
Permanent Subcommittee on Investigations: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate:

The Honorable John D. Dingell: 
Ranking Minority Member: 
Committee on Energy and Commerce: 
House of Representatives:

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.[Footnote 1] 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.[Footnote 2] 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.[Footnote 3]

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.

Results in Brief:

We identified both positive and negative factors that affect CBP's 
ability to target shipments at overseas seaports. According to CBP 
officials, some of the positive factors are improved information 
sharing between U.S. and foreign customs operations and a heightened 
level of bilateral cooperation and international awareness regarding 
securing the whole global shipping system across governments. Related 
to these factors, as of February 2005 CBP had successfully negotiated 
agreements with host nations to allow CSI to operate in 34 foreign 
seaports. As of September 11, 2004, CSI teams were able to target 
approximately 65 percent of the U.S.-bound shipments coming through CSI 
ports to determine whether they were high-risk and should be referred 
to host government customs officials for inspection. This represents 
about 43 percent of all shipments transported to the United States by 
oceangoing cargo containers. However, other, negative factors limit 
CBP's ability to successfully target containers to determine if they 
are high-risk. One such factor is staffing imbalances, which impede CBP 
from targeting all containers shipped from CSI ports before they leave 
for the United States. While CBP has developed a staffing model to 
determine the required level of staff, political and practical 
considerations have limited the number of staff at some 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. 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. Another negative 
factor is weaknesses in manifest data, one source of data used for 
targeting shipments.

As of September 11, 2004, host government officials inspected the 
majority of containers referred to them for inspection by CSI teams. 
However, 28 percent of these containers were not inspected for a 
variety of reasons. For example, 1 percent of the container referrals 
were denied by host government officials, generally because they 
believed the referrals were based on factors not related to security 
threats, such as drug smuggling. For referred containers that are not 
inspected by host governments overseas, the CSI team is supposed to 
refer the container for inspection by CBP upon arrival at the U.S. 
destination port. Although CBP officials did not have information going 
back to the inception of CSI, they 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 explained that some 
referred shipments were not inspected domestically because inspectors 
at U.S. ports received additional intelligence information that lowered 
the risk characterization of the shipments or because the shipments 
remained aboard the carrier while in the U.S. port. For the 72 percent 
of referred containers that were inspected overseas, CBP officials told 
us that no WMD were discovered. However, the inspection equipment used 
at CSI ports varies in detection capability and there are no minimum 
technical requirements for equipment used as part of CSI. In addition, 
technologies to detect other WMD have limitations. As a result, CBP has 
limited assurance that inspections conducted under CSI are effective at 
detecting and identifying terrorist WMD in containers.

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. CBP issued a strategic plan for CSI 
in February 2004 that contains three of the six key elements required 
for agency strategic plans: a mission statement, long-term objectives, 
and implementation strategies. The director of CBP's Strategic Planning 
and Audit Division told us the bureau continues to develop the other 
three elements for the CSI strategic plan: (1) describing how 
performance goals are related to general goals of the program, (2) 
identifying key external factors that could affect program goals, and 
(3) describing how programs are to be evaluated. 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.

We are making several recommendations to improve the program's ability 
to meet its objectives. These include revising its staffing model, 
developing minimum detection capability requirements for nonintrusive 
inspection equipment used in the program, and completing development of 
performance measures for all program objectives. We provided a draft of 
this report to the Secretary of DHS and the Department of State for 
comment. In its response, DHS noted that CBP generally agreed with our 
recommendations and cited corrective actions it either has taken or 
planned to take. The Department of State had no comments on the draft 
report.

Background:

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.[Footnote 4] 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.[Footnote 5]

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.[Footnote 6] 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.

CBP's Targeting and Inspection Approach at Domestic Ports:

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.[Footnote 7] 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.[Footnote 8] 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.

Figure 1: CBP's Domestic Process for Targeting and Inspecting Cargo 
Containers:

[See PDF for image]

[End of figure]

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.

Figure 2: Commercial Sample Image Produced by an X-ray Imaging Machine 
of a Cargo Container Loaded on a Truck Trailer:

[See PDF for image]

[End of figure]

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.

CBP Extended Its Targeting and Inspection Activities to Overseas 
Seaports:

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.

Table 1: CSI Operational Seaports, as of February 2005:

Country/region: Canada; 
CSI port: Halifax; 
Date CSI operations began at port: March 2002.

Country/region: Canada; 
CSI port: Montreal; 
Date CSI operations began at port: March 2002.

Country/region: Canada; 
CSI port: Vancouver; 
Date CSI operations began at port: February 2002.

Country/region: The Netherlands; 
CSI port: Rotterdam; 
Date CSI operations began at port: September 2002.

Country/region: France; 
CSI port: Le Havre; 
Date CSI operations began at port: December 2002.

Country/region: France; 
CSI port: Marseilles; 
Date CSI operations began at port: January 2005.

Country/region: Germany; 
CSI port: Bremerhaven; 
Date CSI operations began at port: February 2003.

Country/region: Germany; 
CSI port: Hamburg; 
Date CSI operations began at port: February 2003.

Country/region: Belgium; 
CSI port: Antwerp; 
Date CSI operations began at port: February 2003.

Country/region: Belgium; 
CSI port: Zeebrugge; 
Date CSI operations began at port: October 2004.

Country/region: Republic of Singapore; 
CSI port: Singapore; 
Date CSI operations began at port: March 2003.

Country/region: Japan; 
CSI port: Yokohama; 
Date CSI operations began at port: March 2003.

Country/region: Japan; 
CSI port: Tokyo; 
Date CSI operations began at port: May 2004.

Country/region: Japan; 
CSI port: Nagoya; 
Date CSI operations began at port: August 2004.

Country/region: Japan; 
CSI port: Kobe; 
Date CSI operations began at port: August 2004.

Country/region: Hong Kong Special Administrative Region of China; 
CSI port: Hong Kong; 
Date CSI operations began at port: May 2003.

Country/region: Sweden; 
CSI port: Gothenburg; 
Date CSI operations began at port: May 2003.

Country/region: United Kingdom; 
CSI port: Felixstowe; 
Date CSI operations began at port: May 2003.

Country/region: United Kingdom; 
CSI port: Liverpool; 
Date CSI operations began at port: October 2004.

Country/region: United Kingdom; 
CSI port: Southampton; 
Date CSI operations began at port: October 2004.

Country/region: United Kingdom; 
CSI port: Thamesport; 
Date CSI operations began at port: October 2004.

Country/region: United Kingdom; 
CSI port: Tilbury; 
Date CSI operations began at port: October 2004.

Country/region: Italy; 
CSI port: Genoa; 
Date CSI operations began at port: June 2003.

Country/region: Italy; 
CSI port: La Spezia; 
Date CSI operations began at port: June 2003.

Country/region: Italy; 
CSI port: Livorno; 
Date CSI operations began at port: December 2004.

Country/region: Italy; 
CSI port: Naples; 
Date CSI operations began at port: September 2004.

Country/region: Italy; 
CSI port: Gioia Tauro; 
Date CSI operations began at port: October 2004.

Country/region: South Korea; 
CSI port: Busan; 
Date CSI operations began at port: August 2003.

Country/region: South Africa; 
CSI port: Durban; 
Date CSI operations began at port: December 2003.

Country/region: Malaysia; 
CSI port: Port Klang; 
Date CSI operations began at port: March 2004.

Country/region: Malaysia; 
CSI port: Tanjung Pelepas; 
Date CSI operations began at port: August 2004.

Country/region: Greece; 
CSI port: Piraeus; 
Date CSI operations began at port: July 2004.

Country/region: Spain; 
CSI port: Algeciras; 
Date CSI operations began at port: July 2004.

Country/region: Thailand; 
CSI port: Laem Chabang; 
Date CSI operations began at port: August 2004.

Source: CBP.

[End of table]

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.

CSI Process for Targeting and Inspecting Cargo Containers Overseas:

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.

Figure 3: CSI Process for Targeting and Inspecting Cargo Containers 
Overseas:

[See PDF for image]

[End of figure]

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.[Footnote 9] 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.[Footnote 10] 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.

While CBP Has Enhanced Its Ability to Target Containers Overseas, 
Limitations Remain:

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.

CSI Successes Have Enhanced CBP's Ability to Target Containers Overseas:

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.

CBP Staffing Imbalances Prevent Targeting of All Containers from CSI 
Ports:

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.[Footnote 11]

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.[Footnote 12]

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.

One Source of Targeting Data Has Limitations:

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.[Footnote 13] As we previously reported, terrorism 
experts, trade representatives, and CBP officials indicated that 
manifest data may contain unreliable information and are sometimes 
incomplete.[Footnote 14] 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.[Footnote 15] 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.

Some Containers Not Inspected for a Variety of Reasons:

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.

Some Containers Not Inspected Overseas because of Host Government 
Information:

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.

Some Containers Not Inspected Overseas because of Operational 
Limitations:

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.

Host Nations Deny Inspections for Some Containers Referred by CSI 
Teams: 

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.

Containers Not Inspected Overseas Can Be Inspected on U.S. Arrival:

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.

In the Absence of Minimum Technical Requirements, Inspection Equipment 
Capabilities Vary:

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.

CBP Has Made Progress Developing a Strategic Plan and Performance 
Measures for CSI, but Further Refinements Are Needed:

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.

CBP Completed a Strategic Plan for CSI, but Three Key Elements Are 
Still under Development:

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 
achieved,

* 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.[Footnote 16]

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.

CBP Has Developed Outcome-Oriented Performance Measures for Some 
Program Objectives:

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.[Footnote 17] 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.

Table 2: CSI Outcome-Oriented Performance Measures:

Measure: Number of foreign mitigated examinations, by category; 
Scope: The measure will be the number of examinations waived for a 
variety of reasons; 
FY 2004 baseline: 2,416 (cumulative); 
Cumulative FY 2005 target: Increase over baseline; track by categories; 
Long-term program goal: Increase information sharing and collaboration 
among CSI and host country personnel so that the number of foreign 
mitigated container exams is increased and legitimate trade is 
facilitated through the port.

Measure: Percentage of worldwide U.S.-destined containers processed 
through CSI ports; 
Scope: 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; 
FY 2004 baseline: 48%; 
Cumulative FY 2005 target: 68%; 
Long-term program goal: Increase information sharing and collaboration 
among CSI and host country personnel in order to prevent terrorist 
weapons from entering the country.

Source: CBP.

[End of table]

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.

Conclusions:

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.

Recommendations for Executive Action:

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.

Agency Comments and Our Evaluation:

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.

Signed by: 

Richard M. Stana: 
Director, Homeland Security and Justice Issues:

[End of section]

Appendix I: Objectives, Scope, and Methodology:

Objectives:

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?

Scope and Methodology:

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.

Data Reliability:

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.

[End of section]

Appendix II: CSI Performance Measures, as of January 2005:

Measure: Outcome measures.

Measure: Number of foreign mitigated examinations, by category; 
Scope: The measure will be the number of examinations waived because of 
a variety of reasons; 
FY 2004 baseline: 2,416 examinations (cumulative); 
Cumulative FY 2005 target: Increase over baseline; track by categories; 
Long-term program goal: Increase information sharing and collaboration 
among CSI and host country personnel so that the number of foreign 
mitigated container exams is increased and legitimate trade is 
facilitated through the port.

Measure: Percentage of worldwide U.S.-destined containers processed 
through CSI ports; 
Scope: 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; 
FY 2004 baseline: 48%; 
Cumulative FY 2005 target: 68%; 
Long-term program goal: Increase information sharing and collaboration 
among CSI and host country personnel in order to prevent terrorist 
weapons from entering the country.

Measure: Information measures: 

Measure: Number of intelligence reports based on CSI foreign sources; 
Scope: This measure will track the number of memorandums of information 
received (MOIR), which are narratives of intelligence gathered from CSI 
foreign sources; 
FY 2004 baseline: 17 cases; 
Cumulative FY 2005 target: Increase over baseline; 
Long-term program goal: Increase information sharing and collaboration 
among CSI and host country personnel in order to prevent terrorist 
weapons from entering the country.

Measure: Number of operational CSI ports; 
Scope: This measure identifies the total number of ports where CSI has 
been implemented; 
FY 2004 baseline: 30 ports; 
Cumulative FY 2005 target: 45 ports; 
Long- term program goal: Increase information sharing and collaboration 
among CSI and host country personnel in order to prevent terrorist 
weapons from entering the country.

Measure: Number of positive findings, by category; 
Scope: 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; 
FY 2004 baseline: Baseline to be established; 
Cumulative FY 2005 target: Target to be established; 
Long-term program goal: Prevent terrorists, means of terrorism, illegal 
drugs, and other illegal activity.

Measure: Number of investigative cases initiated because of CSI 
intelligence; 
Scope: 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; 
FY 2004 baseline: 20 cases; 
Cumulative FY 2005 target: 10 percent increase over the baseline--22 
cases; 
Long-term program goal: Increase information sharing and collaboration 
among CSI and host country personnel in order to prevent terrorist 
weapons from entering the country.

Measure: Efficiency measure: 

Measure: Average cost per CSI port to achieve operational status; 
Scope: 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; 
FY 2004 baseline: $395,000; 
Cumulative FY 2005 target: $403,000; 
Long-term program goal: Increase information sharing and collaboration 
among CSI and host country personnel so that the number of foreign 
mitigated container exams is increased and legitimate trade is 
facilitated through the port.

Measure: Implementation measures: 

Measure: Cumulative number of countries with signed declarations of 
principles; 
Scope: This measure records the number of declarations of principles 
signed with countries where CSI ports are planned; 
FY 2004 baseline: 20 countries; 
Cumulative FY 2005 target: 30 countries; 
Long- term program goal: Not applicable.

Measure: Cumulative number of CSI ports with completed capacity 
assessments; 
Scope: These data will come from the number of completed pre-
operational assessments that are on file for CSI ports; 
FY 2004 baseline: 43 ports; 
Cumulative FY 2005 target: 51 ports; 
Long-term program goal: Not applicable.

Measure: Number of CSI ports with completed infrastructures; 
Scope: This measure records the engineering statements of work that 
have been completed for candidate CSI ports; 
FY 2004 baseline: 28 ports; 
Cumulative FY 2005 target: 38 ports; 
Long-term program goal: Not applicable.

Measure: Number of CSI ports transitioned to permanent status; 
Scope: This measure keeps track of the number of ports where CSI 
operations have been transitioned from temporarily assigned staff to 
permanent staff; 
FY 2004 baseline: 2 ports; 
Cumulative FY 2005 target: 15 ports; 
Long-term program goal: Not applicable.

Source: CBP.

[End of table]

[End of section]

Appendix III: Comments from the Department of Homeland Security:

[See PDF for image]

[End of figure]

[End of section]

Appendix IV: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Richard M. Stana (202) 512-8777; 
Stephen L. Caldwell (202) 512-9610:

Staff Acknowledgments:

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.

[End of section]

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Port Security: Planning Needed to Develop and Operate Maritime Worker 
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Homeland Security: Preliminary Observations on Efforts to Target 
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Posthearing Questions Related to Aviation and Port Security. GAO-04- 
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Container Security: Expansion of Key Customs Programs Will Require 
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Homeland Security: Challenges Facing the Department of Homeland 
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Transportation Security: Federal Action Needed to Help Address Security 
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Transportation Security: Post-September 11th Initiatives and Long-Term 
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Border Security: Challenges in Implementing Border Technology. GAO-03- 
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Customs Service: Acquisition and Deployment of Radiation Detection 
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Port Security: Nation Faces Formidable Challenges in Making New 
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FOOTNOTES

[1] Throughout this report, we use the term weapons of mass destruction 
to refer to chemical, biological, radiological, or nuclear agents or 
weapons. Some agencies define WMD to include large conventional 
explosives as well. Another term being used almost synonymously with 
WMD is weapons of mass effect, which refers to a terrorist attack that 
would not explicitly fit this definition of WMD. As clearly 
demonstrated by the events of September 11, a terrorist attack would 
not have to fit the definition of WMD to achieve mass effect in terms 
of mass casualties, destruction of critical infrastructure, economic 
losses, and disruption of daily life nationwide.

[2] GAO, Container Security: Expansion of Key Customs Programs Will 
Require Greater Attention to Critical Success Factors, GAO-03-770 
(Washington, D.C., July 25, 2003).

[3] GAO, Homeland Security: Summary of Challenges Faced in Targeting of 
Oceangoing Cargo Containers for Inspection, GAO-04-557T (Washington, 
D.C., March 2004).

[4] The supply chain consists of all stages involved, directly or 
indirectly, in fulfilling a customer request. These include the 
manufacturer, suppliers, transporters, warehouses, retailers, and 
customers. A supply chain involves the flow of information, product, 
and funds between the different stages.

[5] Department of Transportation, Volpe National Transportation Systems 
Center, Intermodal Cargo Transportation: Industry Best Security 
Practices (Cambridge, Mass.: June 2002).

[6] Mark Gerencser, Jim Weinberg, and Don Vincent, Port Security 
Wargame: Implications for U.S. Supply Chains, (Booz Allen Hamilton, 
October 2002).

[7] Cargo manifest transmission requirements are located in regulations 
promulgated under Section 343 of the Trade Act of 2002, Public Law 107- 
210, as amended by Section 108 of the Maritime Transportation Security 
Act, Public Law 107-295. Cargo manifests are composed of bills of 
lading for each shipment laden on a vessel. A bill of lading includes 
the name of the shipping line, importer, consignee (recipient of the 
shipment), and manufacturer. The bill of lading also identifies the 
commodity being shipped, the date the shipment was sent, the number of 
containers used to transport the shipment, the port where the 
containers were laden on the U.S.-bound vessel, and the country from 
which the shipment originated. 

[8] An expert system is a model that can chain together input data and 
intercept queries in order to make inferences.

[9] Host government officials at one of the four CSI ports we visited 
conducted physical inspections of all containers referred to them by 
the CSI team.

[10] Host government officials at one of the four CSI ports we visited 
also used an explosive detection device during nonintrusive inspections.

[11] U.S. Office of Management and Budget, Department of State and 
International Assistance Programs, Budget of the United States 
Government, Fiscal Year 2006 (Washington, D.C.: February 2005).

[12] GAO, Overseas Presence: Framework for Assessing Embassy Staff 
Levels Can Support Rightsizing Initiatives, GAO-02-780 (Washington, 
D.C.: July 2002).

[13] According to CBP officials, importers typically do not submit 
entry-level data to CBP at the same time that manifest data are 
submitted. As a result, only limited entry-level data are available at 
the time of review.

[14] GAO, Homeland Security: Summary of Challenges Faced in Targeting 
Oceangoing Cargo Containers for Inspection, GAO-04-557T (Washington, 
D.C.: February 20, 2004).

[15] GAO-04-557T. The regulations governing submission of amended 
manifest data are located in 19 CFR 4.12.

[16] GAO, Results-Oriented Government: GPRA Has Established a Solid 
Foundation for Achieving Greater Results, GAO-04-38 (Washington, D.C.: 
March 10, 2004).

[17] In addition to the outcome measures listed in table 4, CBP also 
developed what the bureau calls information measures to gauge CBP's 
progress in increasing information sharing and collaboration among CSI 
and host country personnel. See appendix II for a description of these 
and other CSI performance measures.

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U.S. Government Accountability Office

441 G Street NW, Room LM

Washington, D.C. 20548:

To order by Phone:

Voice: (202) 512-6000:

TDD: (202) 512-2537:

Fax: (202) 512-6061:

To Report Fraud, Waste, and Abuse in Federal Programs:

Contact:

Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470:

Public Affairs:

Jeff Nelligan, managing director,

NelliganJ@gao.gov

(202) 512-4800

U.S. Government Accountability Office,

441 G Street NW, Room 7149

Washington, D.C. 20548: