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DHS Report to Congress on 100% Scanning Pilot Available ("Public Release" Version)

The Senate Homeland Security and Governmental Affairs Committee has posted the public version of U.S. Customs and Border Protection's report to Congress on its 18-month Secure Freight Initiative (SFI) International Container Security (100% scanning) pilot program1.

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(The first three pilot ports (Puerto Cortes, Honduras; Port Qasim, Pakistan; and Southampton, UK) became fully operational on October 12, 2007. Scanning equipment was later deployed to certain terminals in Hong Kong; Salalah, Oman; Port Busan, South Korea; and Singapore.)

According to CBP, the lessons learned from the SFI/ICS pilot include:

Timely 100% Scanning/Targeting was Feasible at Three Initial Ports

In the initial three ports, SFI has demonstrated the operational feasibility of integrating various scanning technologies and transmitting data in near-real time for review and analysis.

SFI has also demonstrated that scanning data associated with maritime containers at a port of lading can be integrated into CBP's Automated Targeting System (ATS) and reviewed alongside the targeting system's risk assessment rule sets. To date, CBP has successfully integrated, transmitted, and received thousands of data files from the three operational ports.

Containers Arriving with SFI Data Were Subject to Fewer Exams

A preliminary analysis of the potential trade facilitation benefits of SFI has indicated that containers arriving in the U.S. accompanied by SFI data do not experience the same rate of examination at U.S. ports as containers that originate from non-SFI locations. As well, the additional data elements gathered at the foreign port assist CBP officers in more quickly and efficiently mitigating risk and adjudicating radiation alarms occurring at a domestic seaport.

Costs of Scanning May Outweigh Benefits

The initial deployments under SFI also demonstrate the significant costs associated with procuring and deploying scanning technology and the supporting information technology (IT) infrastructure. A chart in the report indicates that the Department of Homeland Security's (DHS') and Department of Energy's (DOE's) combined costs are almost $60 million.

Although DHS and DOE funded the initial phase of SFI deployments, the equipment, IT,

and personnel costs associated with expanding the program to cover all U.S. bound traffic from the more than 700 different ports that ship to the U.S. - many significantly larger and more complex than any of the first three pilots - means that the benefit of immediate widespread deployments must be weighed against DHS' funding needs to address other homeland security vulnerabilities.

Transshipped Cargo Presents Challenges

The initial SFI pilots have demonstrated that technical and operation solutions are not yet available to capture transshipped cargo efficiently. New equipment and software must be developed to address the considerable challenge of scanning containers that often transit through ports quickly and without necessarily being placed on trucks or passing through port gates.

While the SFI/ICS deployments in Honduras, the United Kingdom, and Pakistan indicate that 100% scanning of U.S.-bound maritime containers is possible on a limited scale in low volume ports processing primarily gate traffic, this process will be difficult to achieve with transshipped containers delivered to the port facility from the waterside.

Initial Three Ports Were Very Accommodating

In these first three ports, the U.S. government benefited from considerable host nation cooperation, low cargo volumes, low transshipment rates, and technology and infrastructure costs covered primarily by the U.S. government. DHS notes that these accommodating and supportive conditions do not exist in all ports shipping to the U.S.

Some Ports Want to End Participation Once Pilot Complete

CBP notes that while the United Kingdom was a strong partner in implementing multiple security programs to help protect the supply chain and was one of the first foreign customs services to participate in SFI, it has also limited its participation in the SFI program after completion of the pilot on April 12, 2008. The U.K. chose not to staff the SFI site in Southampton after April and has reverted back to Container Security Initiative (CSI) protocols. The U.S. government has been considering alternative solutions to continue operations.

In addition, the government of Singapore has requested that all equipment be removed at the end of the SFI pilot phase, despite the 100% scanning mandate established by the 9/11 Act.

Singapore projections indicate that SFI will have a detrimental effect on the processing times in the port.

DHS to Focus SFI Expansion on High-Risk Trade Corridors

As it develops a specific policy going forward, DHS will prioritize its resources and efforts by focusing on specific higher risk trade corridors where the most security benefit can be realized.

This approach accords with the current risk-based strategy, best addresses the greatest threats to the U.S., and represents the most worthwhile investment of limited available resources for the scanning of cargo containers at foreign ports.

(This report for certain Congressional committees was required by the Security and Accountability for Every (SAFE) Port Act of 2006.)

1CBP launched SFI in December 2006 and established the SFI ICS pilot program. Under the SFI/ICS, an integrated scanning system, consisting of radiation portal monitors (RPMs) and non-intrusive inspection (NII) imaging systems, is used to scan containers as they move through foreign ports.

Through optical character recognition (OCR) technology, data from these systems is integrated and provided to CBP officers who determine if the container should be referred to the host nation for secondary examination prior to lading.

For the CBP officers, SFI/ICS provides additional data points that are used in conjunction with advanced manifest data, such as 24-Hour Rule information, Customs-Trade Partnership Against Terrorism (C-TPAT) information, and the ATS to assess the risk of each container coming to the U.S.

(See ITT's Online Archives or 06/18/08 news, 08061805, for BP summary of a Senate Homeland Security/Governmental Affairs Committee press release on report.

See ITT's Online Archives or 06/16/08 news, 08061615, for BP summary of GAO testimony identifying nine challenges to SFI Pilot and 100% scanning.

See ITT's Online Archives or 06/13/08 news, 08061320, for BP summary of a World Customs Organization report questioning the effectiveness of 100% scanning.

See ITT's Online Archives or 04/08/08 news, 08040805, for BP summary of CBP testimony on its support of targeting scanning over 100% scanning at foreign ports.

See ITT's Online Archives or 06/09/08 news, 08060905, for BP summary announcing the Senate Commerce Subcommittee's hearing on June 12, 2008 to examine SFI and 100% scanning.)

CBP "Report to Congress on Integrated Scanning System Pilots (Security and Accountability for Every Port Act of 2006, Section 231)" available at http://commerce.senate.gov/public/_files/SFIReport_PublicRelease_FINAL_Consolidated.pdf.

CBP Deputy Commissioner Ahern'stestimony on this report before the Subcommittee on Surface Transportation and Merchant Marine Infrastructure, Safety, and Security (dated 06/12/08) available at http://www.cbp.gov/xp/cgov/newsroom/congressional_test/pilot_ports.xml )