GAO Reports That CSI Could be Improved With Flexible Staffing, Minimum Equipment Requirements, Etc.

The report examined selected aspects of the Container Security Initiative's (CSI's) operation, including: (1) the factors that affect U.S. Customs and Border Protection's (CBP's) ability to target shipments at foreign seaports, (2) the extent to which high-risk containers have actually been inspected overseas, and (3) the extent to which CBP formulated and documented strategies for achieving CSI's goals.

(See ITT's Online Archives or 06/02/05 news, 05060205, for BP summary of CSI's most recent expansion to the port of Santos, Brazil and a list of other CSI ports.)

GAO Concerned By Reliance on Manifest Info, Containers Not Being Inspected

The GAO notes that it found certain positive factors that have improved CBP's ability to target shipments overseas (such as 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); however, the GAO also certain negative factors impacting CSI, including (partial list):

CSI's reliance on manifest data. The GAO states that a factor negatively affecting CBP's ability to target shipments involves CBP's reliance on manifest information. The GAO explains that for CSI, CBP's relies on manifest information to assess the risk level of U.S.-bound shipments even though various experts and CBP officials have indicated that manifest data may contain unreliable information and are sometimes incomplete.

Some containers are not inspected. The GAO states that since the implementation of CSI through September 11, 2004, 28% 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, but also because of operational limitations, host nations denying inspections for certain containers referred by CSI teams, etc.

The GAO explains that containers designated as high-risk by CSI teams 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% of shipments referred for domestic inspection were inspected at a U.S. port. CBP officials explain 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.

Staffing levels. The GAO states that 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 CSI ports have limited the program's ability to target potentially high-risk shipments at some foreign seaports before they depart for the U.S. The GAO warns that this problem may be exacerbated as CBP continues to expand CSI to additional overseas seaports.

Lack of minimum technical requirements. The GAO states that 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. The GAO recognizes that establishing minimum technical requirements may be difficult to address; however, 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 U.S.

Lack of a complete CSI strategic plan. The GAO notes that CBP has developed a strategic plan for the CSI program; however, this plan contains only three of the six key elements required for agency strategic plans. CBP officials have told the GAO that they continue to develop the remaining three elements. Although GAO is not making a recommendation related to the strategic plan at this time, it will continue to monitor CBP's progress in refining the plan.

Lack of outcome-based performance measures. The GAO adds that CBP has not developed outcome-based performance measures or proxy measures for all of its program objects. Without these outcome-based performance measures on which to base program evaluation, the GAO states that CBP will have difficulties in assessing the effectiveness of CSI as a homeland security program.

GAO Recommends Revised Staffing Model, Technical Requirements, Etc.

To help ensure that the objectives of CSI are achieved, the GAO is recommending that the Secretary of Homeland Security and the CBP Commissioner take the following actions:

Revise CSI staffing model. The GAO recommends that the CSI staffing model be revised to consider: (1) what functions need to be performed at CSI ports and what functions can be performed in the U.S.; (2) the optimum levels of staff needed at CSI ports to maximize 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 U.S.

According to the GAO, CBP agreed with this recommendation and said that modifications to the model would allow for program objectives to be achieved in a cost-effective manner. CBP intends to 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.

Establish minimum technical requirements for nonintrusive inspection equipment. The GAO states that minimum technical requirements should be established for 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.

The GAO states that CBP agreed to evaluate the feasibility of making such requirements for the imaging and radiation detection devices in use at CSI ports. CBP did not commit to implement the recommendation because host governments purchase the equipment for use at CSI ports and a legal issue may exist regarding CBP's ability to impose such requirements.

Develop outcome-based performance measures. The GAO's third recommendation states that performance measures should be developed that include outcome-based measures and performance targets (or proxies as appropriate) to track the program's progress in meeting all of its objectives.

The GAO states that CBP agreed with this recommendation, and noted 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 added that this would be an ongoing activity.

(See ITT's Online Archives or 08/05/03 and 05/12/04 news, 03080505 and 04051215, for BP summaries of an earlier GAO report and testimony on expansion of CSI & Customs-Trade Partnership Against Terrorism (C-TPAT), as well as CBP's targeting of cargo containers, respectively.)

(See ITT's Online Archives or 05/31/05 and 06/20/05 news, 05053115 and 05062010, for BP summaries of a Senate Homeland Security Committee hearing on C-TPAT and CSI, as well as an expert's testimony on these programs' weaknesses, respectively.)

(See ITT's Online Archives or 06/21/05 and 06/22/05 news, 05062110 and 05062215, for two-part BP summary on a GAO report identifying C-TPAT weaknesses with regard to cargo security.)

GAO Report (GAO-05-557, dated April 2005) available at http://www.gao.gov/new.items/d05557.pdf