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Performance Measures Are Needed' which was released on January 25, 2008.

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United States Government Accountability Office: 
GAO:

Report to Congressional Requesters:

January 2008:

Supply Chain Security:

Examinations of High-Risk Cargo at Foreign Seaports Have Increased, but 
Improved Data Collection and Performance Measures Are Needed:

GAO-08-187: 

GAO Highlights:

Highlights of GAO-08-187, a report to congressional requesters. 

Why GAO Did This Study:

Customs and Border Protection’s (CBP) Container Security Initiative 
(CSI) aims to identify and examine high-risk U.S.-bound cargo at 
foreign seaports. GAO reported in 2003 and 2005 that CSI helped to 
enhance homeland security, and recommended actions to strengthen the 
program. This report updates information and assesses how CBP has (1) 
contributed to strategic planning for supply chain security, (2) 
strengthened CSI operations, and (3) evaluated CSI operations. To 
address these issues, GAO interviewed CBP officials and reviewed CSI 
evaluations and performance measures. GAO also visited selected U.S. 
and CSI seaports, and met with U.S. and foreign government officials. 

What GAO Found:

By collaborating on the development of the Department of Homeland 
Security’s Strategy to Enhance International Supply Chain Security, and 
by revising the CSI strategic plan as GAO recommended, CBP has 
contributed to the overall U.S. strategic planning efforts related to 
enhancing the security for the overseas supply chain. Also, CBP reached 
its targets of operating CSI in 58 foreign seaports, and thereby having 
86 percent of all U.S.-bound cargo containers pass through CSI seaports 
in fiscal year 2007—representing a steady increase in these measures of 
CSI performance. 

To strengthen CSI operations, CBP has sought to address human capital 
challenges and previous GAO recommendations by increasing CSI staffing 
levels closer to those called for in its staffing model and revising 
its human capital plan. However, challenges remain because CBP 
continues to rely, in part, on a temporary workforce; has not 
determined how to optimize its staffing resources; and reports 
difficulties in identifying sufficient numbers of qualified staff. In 
addition, CBP has enhanced relationships with host governments 
participating in CSI. However, hurdles to cooperation remain at some 
seaports, such as restrictions on CSI teams witnessing examinations. 

CBP improved its evaluation of CSI team performance at seaports, but 
limitations remain in the evaluation process that affect the accuracy 
and completeness of data collected. CBP has not set minimum technical 
criteria for equipment or systematically collected information on the 
equipment, people, and processes involved in CSI host government 
examinations of high-risk, U.S-bound container cargo. Also, CBP has not 
developed general guidelines to use in assessing the reliability of 
these examinations. Thus, CBP potentially lacks information to ensure 
that host government examinations can detect and identify weapons of 
mass destruction, which is important because containers are typically 
not reexamined in the United States if already examined at a CSI 
seaport. CBP refined overall CSI performance measures, but has not 
fully developed performance measures and annual targets for core CSI 
functions, such as the examination of high-risk containers before they 
are placed on vessels bound for the United States. These weaknesses in 
CBP’s data collection and performance measures potentially limit the 
information available on overall CSI effectiveness. 

Figure: Containers Stacked on a Vessel at a CSI Port: 

[See PDF for image] 

This figure is a photograph of containers stacked on a vessel at a CSI 
Port. 

Source: GAO. 

[End of figure] 

What GAO Recommends:

GAO recommends that CBP enhance data collected on CSI team performance, 
host government examinations, and related performance measures. CBP 
concurred with the recommendation to enhance data on team performance. 
It partially concurred with the need to enhance data on host 
examinations, stating that it already conducts actions to improve such 
data. However, these actions do not systematically collect data on 
people, processes, or technology used by host governments to examine 
U.S.-bound containers. CBP partially concurred with the need to enhance 
performance measures, but stated it already captures core program 
functions. We still see room for improvement. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.GAO-08-187]. For more information, contact 
Stephen L. Caldwell at (202) 512-9610 or caldwells@gao.gov. 

[End of section] 

Contents:

Letter:

Results in Brief:

Background:

CBP Collaborated on the DHS Strategy to Enhance International Supply 
Chain Security, and Met Goals for CSI Expansion and Increased Container 
Examination:

To Strengthen CSI Operations, CBP Has Taken Steps to Address Human 
Capital Challenges and Enhance Host Government Relations, but 
Operational Challenges Remain:

CBP Has Enhanced Its CSI Evaluations at CSI Seaports and Performance 
Measures but Still Does Not Capture Critical Information about Host 
Government Examination Systems:

Conclusions:

Recommendations for Executive Action:

Agency Comments and Our Evaluation:

Appendix I: Objectives, Scope, and Methodology:

Appendix II: Comments from the Department of Homeland Security:

Appendix III: Container Security Initiative Seaports:

Appendix IV: CSI Activities and Equipment:

Appendix V: CSI Performance Measures:

Appendix VI: GAO Contact and Staff Acknowledgments:

Related GAO Products:

Tables:

Table 1: Major U. S. Initiatives to Secure Oceangoing Containers:

Table 2: 58 CSI seaports as of September 2007:

Table 3: CSI Performance Measures:

Figures:

Figure 1: Overview of Key Participants Involved in Shipping Containers 
in the International Supply Chain:

Figure 2: Map of World with Countries Participating in CSI:

Figure 3: CSI Targeting and Examination Activities:

Figure 4: CBP Initiatives in the U.S. Supply Chain Security Strategy:

Figure 5: Number of Operational CSI Seaports and Percentage of Total 
U.S-bound Containers Passing Through CSI Seaports, 2002-2007:

Figure 6: View of the Physical Layout of a Congested CSI Seaport:

Figure 7: Stacked Containers on a Shipping Vessel at a CSI Seaport:

Figure 8: CSI Process for Targeting and Examining High-risk Containers 
Overseas:

Figure 9: CBP Official Using Radiation Isotope Identifier Device to 
Examine Container at CSI Seaport:

Figure 10: Commercial Sample Image Produced by Nonintrusive Imaging X- 
ray Equipment of a Container Loaded on a Truck Trailer:

Abbreviations:

ATS: Automated Targeting System:

C-TPAT: Customs Trade Partnership Against Terrorism:

CBP: U.S. Customs and Border Protection:

CSI: Container Security Initiative:

CSITE: Container Security Initiative Team Evaluation:

DHS: Department of Homeland Security:

DOE: Department of Energy:

NTCC: U.S. National Targeting Center Cargo:

WMD: weapons of mass destruction:

[End of section]

United States Government Accountability Office:
Washington, DC 20548:

January 25, 2008:

The Honorable Daniel K. Inouye: 
Chairman: 
The Honorable Ted Stevens: 
Vice Chairman: 
Committee on Commerce, Science, and Transportation: 
United States Senate: 

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

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

The Honorable John D. Dingell: 
Chairman: 
Committee on Energy and Commerce: 
House of Representatives: 

Oceangoing cargo containers play a vital role in the movement of cargo 
between global trading partners. In fiscal year 2007, more than 10 
million oceangoing cargo containers arrived at U.S. seaports--meaning 
roughly 28,000 oceangoing containers arrived each day that year. The 
terrorist attacks of 2001 heightened concerns about the ability of both 
the federal government and companies participating in international 
maritime commerce to identify and prevent weapons of mass destruction 
from being smuggled inside cargo containers bound for the United 
States. Balancing security concerns with the need to facilitate the 
free flow of commerce remains an ongoing challenge for the public and 
private sectors alike.

In the federal government, U.S. Customs and Border Protection (CBP), 
part of the Department of Homeland Security (DHS), is charged with 
managing, securing, and controlling the nation's border and in its 
capacity as the frontline border security agency, plays a lead role in 
facing maritime threats. CBP launched the Container Security Initiative 
(CSI) in January 2002, which through partnerships with its foreign 
counterparts, is designed to help protect global trade lanes by 
targeting and examining container cargo that poses a threat as early as 
possible in the global supply chain. As part of the program, foreign 
governments allow CBP officers to be stationed at foreign seaports. 
These officers use intelligence and automated risk assessment 
information to target shipments to identify those at risk of containing 
weapons of mass destruction (WMD) or other terrorist contraband. CBP 
and host government officials share the role of assessing the risk of 
U.S.-bound container cargo leaving the seaports of countries 
participating in CSI. CBP officers at the CSI seaports are responsible 
for targeting high-risk cargo shipped in containers and other tasks, 
whereas host government customs officials examine the high-risk cargo-
-when requested by CBP--by scanning containers using various types of 
nonintrusive inspection equipment, such as large-scale X-ray machines, 
or by physically searching the container's contents before it travels 
to the United States.

As part of its strategic plan, CBP is partnering with international 
trade and security groups to develop supply chain security standards 
that can be implemented by the world community. By engaging 
international organizations, CBP is contributing to the development of 
global security standards. Recent legislative actions intended to 
further enhance maritime security also updated requirements that affect 
CSI. In October 2006, Congress passed and the President signed 
legislation--the Security and Accountability for Every Port Act (SAFE 
Port Act) [Footnote 1]--establishing a statutory framework for CSI, 
which previously had been an agency initiative not specifically 
required by law. The act imposed various mandates, such as requiring 
CBP to take risk factors including cargo volume into account when 
designating seaports as CSI participants. In August 2007, the 
Implementing Recommendations of the 9/11 Commission Act of 2007 (9/11 
Act) was enacted, which requires, among other things, 100 percent 
scanning of U.S.-bound cargo containers by foreign seaports by 2012, 
with possible extensions for some ports--replacing a similar provision 
in the SAFE Port Act that did not have a deadline.[Footnote 2]

We have previously reported on CSI's progress in meeting its strategic 
goals and objectives. Our July 2003 and April 2005 reports on CSI 
acknowledged the program's important role in helping to enhance 
homeland security, but we also recommended actions to enhance the 
strategic planning for the program, such as better defining its goals, 
objectives, and performance measures. In addition, we recommended 
actions to strengthen the program's management and operations, such as 
conducting human capital planning (which affects CBP staffing levels at 
seaports) and establishing minimum technical capability requirements 
for equipment used to examine high-risk containers.[Footnote 3]

Recognizing the importance of the CSI program, you asked us to conduct 
another review. For this report, we assessed the following issues:

* How has CBP contributed to strategic planning for supply chain 
security efforts and the CSI program in particular, and what progress 
has been made in achieving CSI performance goals?

* How has CBP strengthened CSI operations in response to our 2005 
review and what challenges, if any, remain?

* How does CBP evaluate CSI seaport operations and assess program 
performance overall, and how has this process changed over time?

To address these objectives, we met with CBP officials who have program 
responsibilities for CSI, and reviewed available program data and 
documentation. Specifically, to review CBP's strategic planning 
initiatives, we reviewed national-level strategic planning documents 
and those created for DHS, CBP, and CSI. To determine CBP's progress in 
achieving its CSI program goals, we reviewed CBP's statistical data on 
container cargo and CSI program activities. To learn about how CBP has 
strengthened its operations, we reviewed our previous assessments of 
the CSI program, and examined CBP's efforts to implement our three 
prior recommendations. To assess CBP's progress, we met with CBP 
officials at the U.S. National Targeting Center - Cargo (NTCC) in 
Virginia and three domestic seaports in different geographical 
locations and representing varying volumes of container traffic. 
[Footnote 4] We also visited six CSI seaports located overseas that 
were selected based on several factors, including geographic and 
strategic significance, volume of container traffic, and when CSI 
operations began at the seaport. The results from our visits to 
seaports provided examples of CBP and host government operations but 
cannot be generalized beyond the seaports visited because we did not 
use statistical sampling techniques in selecting the seaports.

To determine what progress CBP has made in strengthening its tools for 
monitoring and measuring the progress of the CSI program, we reviewed 
the performance measures presented in the CSI strategic plan against 
criteria developed by the Office of Management and Budget and GAO. We 
also reviewed a nonrepresentative sample of CSI team evaluations. While 
these documents provided examples about program evaluation methods and 
CSI program operations, and generally corroborated our seaport site 
visit observations, our findings cannot be generalized to the program 
as a whole. We conducted this performance audit from May 2006 through 
January 2008 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. A detailed 
discussion of our scope and methodology is contained in appendix I.

Results in Brief:

CBP contributed to a new strategic planning document to guide efforts 
to secure the international supply chain, updated the CSI strategic 
plan, and reported achieving key CSI goals by increasing both the 
number of CSI locations and the proportion of total U.S.-bound 
containers passing through CSI seaports. By supporting the development 
of the Strategy to Enhance International Supply Chain Security that DHS 
was required to produce in accordance with the SAFE Port Act, and by 
revising and enhancing the strategic plan for CSI, as we had previously 
recommended, CBP has contributed to overall strategic planning efforts 
related to supply chain security. The supply chain security strategy, 
issued in July 2007, delineates the supply chain security roles, 
responsibilities, and authorities of federal, state, local, and private 
sector entities, and describes how CBP's portfolio of initiatives to 
address supply chain security, including CSI, is coordinated throughout 
the supply chain. As to achieving CSI performance goals, in fiscal year 
2007, CBP reached its targets of operating CSI in 58 foreign seaports 
and having 86 percent of all U.S.-bound containers passing through CSI 
seaports--where, according to CBP, there is an opportunity for the high-
risk cargo to be examined at foreign seaports before reaching the 
United States. These results represent a continued increase in both of 
these measures of CSI performance since CSI's inception in 2002. Also, 
CBP reported increases in the number of high-risk cargo containers 
examined by host governments at CSI seaports.

To strengthen CSI operations over the last 2 years, CBP has sought to 
address human capital challenges and enhance relationships with host 
governments participating in CSI, but operational challenges remain. 
Our 2005 CSI report noted that CBP had not achieved its goal of 
targeting all U.S.-bound containers passing through CSI seaports for 
high-risk cargo before they depart for the United States because, in 
part, the agency had not been able to place enough staff at some CSI 
seaports. CBP has subsequently taken steps to implement related 
recommendations, including increasing overall staffing levels just 
above the 203 positions called for in its staffing allocation model by, 
among other things, adding 125 permanent staff to CSI seaports and 15 
staff to the NTCC, resulting in a parallel increase in the volume of 
container cargo that is targeted. Nevertheless, CBP continues to rely, 
in part, on a temporary workforce at CSI seaports and the NTCC; has yet 
to determine how to optimize its staffing resources even as the CSI 
program expands; and reports difficulties in identifying sufficient 
numbers of qualified individuals to hire for the program. In addition, 
findings from our CSI port site visits and our review of select CSI 
evaluations conducted by CBP suggest that relationships with host 
governments have improved over time, leading to increased information 
sharing between governments and a bolstering of host government customs 
and port security practices, among other things. However, we also found 
that levels of collaboration between U.S. and host government officials 
varied across CSI seaports and we identified hurdles to cooperation 
between CSI teams and their counterparts in the host government, such 
as host country legal restrictions that CBP officials said prevent CSI 
teams from observing examinations. CBP also continues to face 
logistical difficulties inherent in a seaport environment, often 
outside of its control, such as high-risk container cargo that is 
infeasible to access for examination.

CBP has enhanced how it collects data about CSI operations by 
strengthening its approach to on-site evaluations of teams of CBP 
officers at CSI seaports and has refined certain programwide 
performance measures, but weaknesses remain in CBP's evaluation and 
performance measurement efforts. Also, CBP lacks a process for 
systematically gathering information on the equipment, people, and 
processes used by host governments to examine U.S.-bound cargo 
containers identified as high-risk. Specifically, CBP has recently 
improved its process for conducting evaluations at CSI seaports by, 
among other things, testing the proficiency of the CBP officers who 
must identify high-risk cargo, and by introducing an electronic tool 
that enables CBP evaluation teams to systematically record their 
evaluative data. However, evaluators do not always use the data 
collection tools as intended, which makes it difficult for CBP to 
ensure that evaluations are consistently carried out or that evaluative 
data are reliable for management decisions. Also evaluators do not 
always follow up on recommendations made in previous evaluation 
reports--so CBP cannot ensure that previously identified problems have 
been addressed. Also, CBP has not set minimum technical capability 
criteria for equipment used at CSI seaports as we recommended in April 
2005 and as required under the SAFE Port Act for CSI and the 9/11 Act 
for future 100 percent scanning of U.S.-bound containers. Without such 
criteria and systematically collected information on equipment, people 
and processes involved in each host government's cargo, CBP does not 
have a sound basis for determining the reliability of the examination 
systems used at CSI seaports, which is of particular importance because 
only a small fraction of U.S.-bound high-risk containers are reexamined 
upon arrival in the United States. With respect to assessing CSI 
performance overall, over the past 2 years, CBP has revised its 
performance measurement system to provide decision makers with more 
accurate indicators of the program's progress--by setting some specific 
performance targets and modifying some existing measures--and to 
reflect CSI's continuing maturation. However, we identified limitations 
with the CSI performance measures, such as the omission of measures for 
a key core CSI function, the lack of annual performance targets, and 
misleading or confusing methods for calculating several performance 
measures. These limitations may potentially make it difficult for CBP 
and DHS managers and Congress to appropriately provide program 
oversight.

We are recommending that the Secretary of Homeland Security direct the 
Commissioner of CBP to take actions to help ensure that the agency has 
the information necessary to ensure that CSI is operating efficiently 
and effectively. Specifically, we are recommending that CBP (1) 
strengthen it's process for evaluating CSI teams at overseas ports by 
maintaining evaluation data, ensuring evaluation teams follow 
procedures, and monitoring the completions of recommendations from 
previous evaluations; (2) improve, in collaboration with host 
government officials, the information gathered about the host 
governments' examination systems to determine their reliability and 
whether mitigating actions or incentives are necessary to provide the 
desired level of security; and (3) enhance CSI performance measurement 
processes to better assess CSI performance overall.

We provided a draft of this report to the Department of State and DHS 
for their review and comment. The Department of State did not provide 
written comments but provided technical comments, which have been 
incorporated into the report as appropriate. DHS provided written 
comments--incorporating comments from CBP--on December 20, 2007, which 
are presented in Appendix II. In its written comments, DHS and CBP 
concurred with our recommendation on strengthening its process for 
evaluating CSI teams at overseas locations. CBP partially concurred 
with our recommendation to improve information gathered about host 
government examination systems. CBP agreed on the importance of an 
accepted examination process and noted it continues to take steps to 
address improvements in the information gathered about host 
governments' examination systems at CSI ports by working directly with 
host government counterparts, through the World Customs Organization, 
and providing capacity building training and technical assistance. 
While CBP does engage in capacity building with some CSI host 
governments, it does not systematically collect or assess information 
on the people, processes, or technology used by these host governments 
to examine high-risk U.S.-bound containers, and thus has limited 
assurance that CSI host government examination systems can detect and 
identify WMD. Finally, CBP partially concurred with our recommendation 
to enhance CSI performance measures to better assess CSI performance 
overall. CBP stated that it believes its current measures address core 
program functions of targeting and collaboration with host governments 
to mitigate or substantiate the risk of a maritime container destined 
for the United States. We disagree. As discussed in this report, a core 
element of the CSI program, specifically the extent to which U.S.-bound 
containers carrying high-risk cargo are examined at CSI seaports, is 
not addressed through CBP's performance measures.

Background:

Vulnerabilities of Containers in the International Supply Chain:

Seaports are critical gateways for the movement of commerce through the 
international supply chain. The facilities, vessels, and infrastructure 
within seaports, and the cargo passing through them, all have 
vulnerabilities that terrorists could exploit. The containers carrying 
goods that are shipped in oceangoing vessels are of particular concern 
because they can be filled overseas at many different locations and are 
transported through complex logistics networks before reaching U.S. 
seaports.

In addition, transporting such a shipping container from its 
international point of origin to its final destination involves many 
different participants and many points of transfer. The materials in a 
container can be affected not only by the manufacturer or supplier of 
the material being shipped, but also by carriers who are responsible 
for getting the material to a port and by personnel who load containers 
onto the ships. Others who interact with the cargo or have access to 
the records of the goods being shipped include, among others, exporters 
who make arrangements for shipping and loading, freight consolidators 
who package disparate cargo into containers, and forwarders who manage 
and process the information about what is being loaded onto the ship. 
Figure 1 illustrates many of the key participants and points of 
transfer involved from the time that a container is loaded for shipping 
to its arrival at the destination seaport and ultimately the importer.

Figure 1: Overview of Key Participants Involved in Shipping Containers 
in the International Supply Chain:

[See PDF for image] 

This figure contains three photographs as well as the following data: 

Export Side: 
Exporter; 
Freight consolidater; 
Inland carrier (truck, rail, smart vessel); 
Terminal operator; 
Freight forwarder; 
Customs Inspector; 
Photograph: Containerized goods ready for shipment; 
Photograph: Shipment aboard ocean carrier. 

Import Side: 
Customs broker; 
Customs inspector; 
Terminal operator; 
Inland carrier (truck, rail, smart vessel); 
Importer; 
Photograph: Arrival at receiving port. 

Source: GAO, DHS. 

[End of figure] 

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 cargo throughout 
the supply chain. Every time responsibility for cargo in containers 
changes hands along the supply chain there is the potential for a 
security breach, and thus, vulnerabilities exist that terrorists could 
take advantage of by placing a WMD into a container for shipment to the 
United States. While there have been no known incidents of containers 
being used to transport WMDs, criminals have exploited containers for 
other illegal purposes, such as smuggling weapons, people, and illicit 
substances, according to CBP officials. Finally, 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 consequences of such an attack are potentially high. In 2002, 
Booz Allen Hamilton sponsored a simulated scenario in which the 
detonation of weapons hidden in cargo containers shut down all U.S. 
seaports over a period of 12 days. The results of the simulation 
estimated that the port closure could result in a loss of $58 billion 
in revenue to the U. S. economy, along with significant disruptions to 
the movement of trade.

Efforts to Secure Containers in the International Supply Chain:

The federal government has taken many steps to secure the supply chain, 
including the cargo in containers destined for the United States. While 
CBP officials at domestic seaports continue efforts to identify and 
examine high-risk imports arriving in containers, CBP's post-September 
11 strategy also involves focusing security efforts beyond U.S. borders 
to target and examine high-risk cargo before it enters U.S. seaports. 
CBP's strategy is based on a layered approach of related initiatives 
that attempt to focus resources on potentially risky cargo shipped in 
containers while allowing other containers carrying cargo to proceed 
without unduly disrupting commerce into the United States. CBP has 
initiated most of these efforts, shown in table 1. However, the 
Department of Energy (DOE) has led U.S. efforts to detect radiation in 
cargo containers originating at foreign seaports.

Table 1: Major U. S. Initiatives to Secure Oceangoing Containers:

Initiative and year introduced: Automated Targeting System, (ATS), 1995 
(prototype); 
Department: DHS; 
Description: CBP uses this computerized decision support tool to review 
documentation, including electronic manifest information submitted by 
ocean carriers on all cargo destined for the United States to help 
identify shipments requiring additional scrutiny. ATS utilizes complex 
mathematical models with weighted rules that assign a risk score to 
each shipment based on manifested information. CBP officers review the 
rule firings that support the ATS score to help them make decisions on 
the extent of documentary review or examination to be conducted. 

Initiative and year introduced: 24-hour rule, 2002; 
Department: DHS; 
Description: CBP generally requires ocean carriers to electronically 
transmit cargo manifests to CBP's Automated Manifest System 24 hours 
before the U.S.-bound cargo is loaded onto a vessel at a foreign 
seaport. Carriers and importers are to provide information to CBP that 
is used to strengthen how ATS assigns risk scores. The cargo manifest 
information is submitted by ocean carriers on all arriving cargo 
shipments, and entry data (more detailed information about the cargo) 
are submitted by brokers. 

Initiative and year introduced: Container Security Initiative (CSI), 
2002; 
Department: DHS; 
Description: CSI places staff at participating foreign seaports to work 
with host country customs officials to target and examine high-risk 
cargo to be shipped in containers for weapons of mass destruction 
before they are shipped to the United States. CBP officials identify 
the high-risk containers and request that their foreign counterparts 
examine the contents of the containers. 

Initiative and year introduced: Customs-Trade Partnership Against 
Terrorism (C-TPAT), 2002; 
Department: DHS; 
Description: CBP develops voluntary partnerships with members of the 
international trade community comprised of importers; customs brokers; 
forwarders; air, sea, and land carriers; and contract logistics 
providers. Private companies agree to improve the security of their 
supply chains in return for various benefits, such as a reduced 
likelihood that their containers will be examined. 

Initiative and year introduced: Megaports Initiative, 2003; 
Department: DOE; 
Description: DOE installs radiation detection equipment at key foreign 
seaports, enabling foreign government personnel to use radiation 
detection equipment to screen shipping containers entering and leaving 
these seaports, regardless of the containers' destination, for nuclear 
and other radioactive material that could be used against the United 
States and its allies.

Initiative and year introduced: Secure Freight Initiative, 2007; 
Department: DHS, DOE; 
Description: Pilot program at selected CSI seaports to scan 100 percent 
of U.S.-bound cargo containers for nuclear and radiological materials 
overseas using integrated examination systems that couple nonintrusive 
inspection equipment and radiation detection equipment. 

Source: GAO.

Note: Cargo manifests are prepared by the ocean carrier and are 
composed of bills of lading for each shipment of cargo loaded on a 
vessel to describe the contents of the shipments. The bill of lading 
includes a variety of other information, such as the manufacturer of 
the cargo and the shipping line.

[End of table]

In January 2002, CBP began CSI to target container cargo at overseas 
seaports so that high-risk cargo could be examined prior to departure 
for the United States. More recently, Congress passed legislation 
affecting the CSI program, including (1) the SAFE Port Act enacted in 
October 2006 that established a statutory framework for CSI and, among 
other things, required a pilot program, now known as the Secure Freight 
Initiative, to determine the feasibility of 100 percent scanning of 
U.S.-bound cargo containers at foreign seaports; and (2) the 9/11 Act 
enacted in August 2007, that, among other things, requires by 2012, the 
scanning of all U.S.-bound containers at foreign seaports with 
potential exceptions if a seaport cannot meet that deadline.

For the CSI program, CBP officials stated that DHS expended about $138 
million and $143 million, respectively for fiscal years 2006 and 2007. 
The President's budget for fiscal year 2008 requested $156 million for 
CSI. CSI is now operating at 58 seaports in 33 foreign countries, as 
shown in figure 2. Appendix III lists the specific CSI seaports.

Figure 2: Map of World with Countries Participating in CSI:

[See PDF for image] 

This figure is a map of the world with countries participating in CSI 
indicated as follows: 

South, North and Central America, and the Carribean: 
Argentina; 
Bahamas; 
Brazil; 
Canada; 
Columbia; 
Dominican Republic; 
Honduras; 
Jamaica; 
Panama. 

Europe: 
Belgium; 
France; 
Germany; 
Greece; 
Israel; 
Italy; 
Netherlands; 
Portugal; 
Spain; 
Sweden; 
United Kingdom. 

Africa, Middle East: 
Egypt; 
Oman; 
South Africa; 
United Arab Emirates. 

Far East, South and Southeast Asia, Australia and the Pacific: 
China; 
Japan; 
Korea (Republic of); 
Malaysia; 
Pakistan; 
Singapore; 
Sri Lanka; 
Taiwan; 
Thailand. 

Source: GAO (map art), Map Resources (map), CBP (data). 

[End of figure] 

Core Elements and Security Activities of CSI Program:

According to CBP, the three core elements of CSI include (1) CBP 
identifying high-risk containers; (2) CBP requesting, where necessary, 
that host governments examine high-risk containers before they are 
shipped; and (3) host governments conducting examinations of high-risk 
containers. To integrate these elements into CSI operations, CBP 
negotiated and entered into bilateral, nonbinding arrangements with 
foreign governments, specifying the placement of CBP officials at 
foreign seaports and the exchange of information between CBP and 
foreign customs administrations. To participate in CSI, a host nation 
must meet several criteria developed by CBP. The host nation must 
utilize (a) a seaport that has regular, direct, and substantial 
container traffic to seaports in the United States; (b) customs staff 
with the capability of examining cargo originating in or transiting 
through its country; and (c) nonintrusive inspection equipment with 
gamma or X-ray capabilities and radiation detection equipment. 
Additionally, each potential CSI port must indicate a commitment to (d) 
establish an automated risk management system for identifying 
potentially high-risk container cargo; (e) share critical data, 
intelligence, and risk management information with CBP officials; (f) 
conduct a seaport assessment to ascertain vulnerable links in a port's 
infrastructure and commit to resolving those vulnerabilities; and (g) 
maintain a program to prevent, identify, and combat breaches in 
employee integrity.

As part of the arrangements with foreign governments participating in 
CSI, CBP most often stations teams of CBP officers at each foreign 
seaport to conduct CSI activities in collaboration with host government 
customs officials. While the number of CBP officers stationed at CSI 
seaports varies by location, typically a CSI team consists of (1) a CSI 
team leader, who manages the team and monitors the relationship with 
the host country; (2) CBP officers, who target high-risk cargo and 
observe (where possible) the host government's examination of 
containers carrying the cargo; (3) an intelligence research specialist, 
who assimilates data to support timely and accurate targeting of 
containers; and (4) a special agent responsible for CSI-related 
investigations at the seaport. According to CBP, it is ideal for the 
CSI team to be located in close physical proximity with host government 
customs counterparts to facilitate collaboration and information 
sharing. However, CBP officials also stated that the agency uses CBP 
officers stationed at the NTCC as needed to support the CBP officers 
located at the CSI seaports. The CBP officials at NTCC assist the CSI 
teams at high-volume seaports to ensure all containers that pass 
through CSI seaports are targeted to identify high-risk container 
cargo; carry out CSI targeting responsibilities for CSI seaports that 
do not have CBP officials stationed there; and, according to CBP 
officials, conduct targeting for U.S.-bound container cargo that does 
not pass through CSI seaports using national sweeps to identify high- 
risk container cargo.

At CSI seaports, CBP officers share responsibilities with host 
governments' customs officials to target and examine high-risk 
container cargo. Figure 3 describes the activities carried out by CBP 
officers and host government customs officials, respectively, to target 
and examine high-risk container cargo at CSI seaports.[Footnote 5]

Figure 3: CSI Targeting and Examination Activities:

[See PDF for image] 

This figure is a combination of descriptions of CSI Targeting and 
Examination Activities, with accompanying photographs, as follows: 

Targeting high-risk container shipments: 
CBP uses ATS to electronically review data about U.S.-bound shipments 
to produce a risk score, a process CBP refers to as screening. CBP 
officers review the ATS risk scores and may consider additional 
information or collaborate with host government officials to identify 
high-risk shipments with a nexus to terrorism—a process referred to as 
targeting.CBP officials make a final determination about which 
containers are high risk and will be referred to host government 
customs officials for examination. 
Photograph: 
CBP official conducting targeting activities at the NTC. 

Examining high-risk container shipments: 
CBP officials request that host government officials examine containers 
with high-risk shipments to detect WMD or other items with a nexus to 
terrorism. Examining a container involves using nonintrusive inspection 
equipment, radiation detection equipment, or both to scan the 
container’s contents. Typically, the radiation detection equipment is 
used, then large scale nonintrusive inspection equipment, to scan the 
container’s contents. The results of the scan will influence whether or 
not CBP requests that the host government conduct a physical search, 
during which a container is opened and its contents are removed for 
review.
Photograph: 
Container scanned with non-intrusive imaging x-ray equipment at a CSI 
port. 

Source: GAO and CBP. 

[End of figure]

CBP Collaborated on the DHS Strategy to Enhance International Supply 
Chain Security, and Met Goals for CSI Expansion and Increased Container 
Examination:

CBP has undertaken strategic planning to guide efforts to secure the 
international supply chain and, more specifically, to manage the CSI 
program. CBP contributed to an international supply chain security 
strategy DHS recently issued that builds on DHS's existing strategic 
framework for maritime security. In 2006 CBP enhanced its strategic 
plan for CSI by including three key elements missing from the plan's 
previous iteration, and has achieved two performance goals by expanding 
CSI locations and increasing the percentage of total U.S.-bound 
containers that pass through CSI seaports. Concurrently, CBP reported 
an increase in the number of high-risk containers examined by host 
governments participating in CSI.

Recently Issued International Supply Chain Security Strategy Builds on 
DHS's Existing Strategic Framework for Maritime Security:

When it published the Strategy to Enhance International Supply Chain 
Security in July 2007, DHS filled a gap that had existed between broad 
national strategies and program-specific plans in the federal 
government's strategic planning framework for maritime security. Over 
the last 5 years, DHS has made progress in developing a multilayered 
strategic framework for securing the maritime domain, including the 
international supply chain. This framework consists of high-level 
national strategies, such as the National Strategy for Maritime 
Security and the Maritime Commerce Security Plan, which describe the 
federal government's broad approach to maritime security. These plans 
are supplemented by a related hierarchy of documents that includes the 
DHS strategic plan, the CBP strategic plan, and the CSI program's own 
strategic plan.

Prior to July 2007, the federal government's maritime security 
framework touched on many specific aspects of maritime trade and 
commerce, such as how the CSI program contributes to securing 
containers bound for U.S. seaports. However, it did not provide a 
detailed description of how federal, state, and local authorities were 
to collaborate on supply chain security specifically. In addition, 
Congress included a provision in the SAFE Port Act of 2006 requiring 
DHS to develop a strategic plan to enhance the security of the 
international supply chain. Moreover, the DHS fiscal year 2007 
appropriation act withheld $5 million from DHS until a comprehensive 
strategic plan for port, cargo, and container security, which included 
specific elements, had been submitted to specified congressional 
committees. In response, CBP contributed to the Strategy to Enhance the 
International Supply Chain Security, which DHS developed and issued in 
July 2007. According to DHS, the supply chain security strategy is not 
meant to replace other strategic planning documents, but seeks to 
harmonize the goals of the various plans and programs into a 
multilayered, unified approach that can be further developed by DHS 
components, including CBP.

This new strategic planning document for supply chain security 
delineates the supply chain security roles, responsibilities, and 
authorities of federal, state, local, and private sector entities. The 
strategy seeks to build on the current multilayered strategic framework 
for maritime security by establishing an overarching framework for the 
secure flow of cargo through the supply chain--from point of origin to 
final destination. The strategy describes how CBP's portfolio of supply 
chain security initiatives--including CSI, C-TPAT, cargo screening 
using ATS, the 24-hour rule, and the use of nonintrusive inspection 
equipment to examine containers--addresses the various stages in the 
supply chain. In addition, the strategy provides details on how other 
organizations' programs or efforts--such as DOE's Megaports initiative, 
which places radiation detection equipment at foreign seaports-- 
contribute to different aspects of supply chain security. Figure 4 
describes the major components of the supply chain and the CBP 
initiatives that operate to secure them.

Figure 4: CBP Initiatives in the U.S. Supply Chain Security Strategy:

[See PDF for image] 

This figure is a flow-chart of CBP Initiatives in the U.S. Supply Chain 
Security Strategy, depicting the following data: 

Supply chain: 
* Packaging and cargo origination, Empty container; 

* Shipment consolidation, Storage; 

* Port of origin, Initiatives to secure the supply chain: 
- C-TPAT; 
- Cargo screening/ATS; 
- 24-hour rule; 
- CSI; 
- SFI; 

* Transshipment port; 

* Port of entry; 

* Storage, Shipment deconsolidation, Initiatives to secure the supply 
chain: 
- Examination of high-risk containers at U.S. seaports. 

* Destination. 

Source: GAO. 

[End of figure]

CBP Added Key Elements to the CSI Strategic Plan in Response to our 
2005 Recommendation:

At the program level, CBP has revised its CSI strategic plan, an 
important component of the DHS strategic framework described above, 
incorporating three critical elements that were absent from the plan's 
previous iteration. In our April 2005 report on CSI, we reported that 
the CSI strategic plan lacked three of the six key elements identified 
by the Government Performance and Results Act of 1993 for an agency 
strategic plan, including descriptions of:

1. how performance goals and measures are related to program objectives,

2. the external factors beyond the control of CBP that could affect the 
achievement of program objectives, and:

3. the evaluations that CBP conducts to monitor CSI.[Footnote 6]

We noted that, given the importance of having an effective strategic 
plan for the program, we would continue to monitor CBP's progress in 
refining the plan. CBP has subsequently taken steps to address our 
concerns. In the most recent version of the plan, released in August 
2006, CBP included information in three areas, as we had previously 
recommended. First, the CSI strategic plan links each performance 
measure to the strategic goal it supports. In addition, the plan 
describes how some performance measures were designed to act as proxies 
for program objectives that can be difficult to measure. Second, the 
CSI strategic plan also lists a variety of external factors that have 
the potential to influence CSI operations, including regional 
conflicts, organized crime, and changes in the political administration 
of a foreign government participating in CSI. Finally, the revised plan 
provides an explanation of the CSI team evaluation process, thus 
addressing the third issue identified in our April 2005 report. We 
discuss performance measure outcomes, other external factors, and CBP's 
evaluation process in greater detail later in this report.

CBP Met Performance Goals to Expand Number of CSI Seaports and to 
Increase Proportion of Total U.S.-bound Containers Passing Through CSI 
Seaports:

The August 2006 CSI strategic plan set specific goals for expanding the 
number of seaports participating in CSI, and set targets for related 
increases in the percentage of total U.S.-bound containers that pass 
through CSI seaports. As of September 2007, CBP reported meeting its 
goals in both of these areas. Specifically, the plan called for CBP to 
expand CSI program operations from 40 to 50 seaports by the end of 
fiscal year 2006, and to 58 seaports by the end of fiscal year 2007 
(see appendix III for a complete list of participating seaports). 
Having reached its goal of 58 CSI seaports, CBP officials reported it 
currently does not have plans to add other CSI seaports, as the costs 
associated with expanding the program further would outweigh the 
potential benefits. In addition, the plan set a performance target that 
by 2010, 86 percent of all U.S.-bound container cargo was to pass 
through CSI seaports.[Footnote 7] According to CBP, when U.S.-bound 
containers pass through CSI seaports there is an opportunity for high- 
risk cargo to be examined at the foreign seaport by the host 
governments participating in CSI, rather than upon arriving at a U.S. 
seaport. CBP reported that about 73 percent and about 80 percent of 
total U.S.-bound container cargo passed through CSI seaports in fiscal 
years 2005 and 2006, respectively, and that it reached its 2010 goal 
early by reaching approximately 86 percent by the end of fiscal year 
2007. Figure 5 shows that as the number of operational CSI seaports 
expanded from 2002 to 2007, the proportion of total U.S.-bound 
container cargo passing through CSI seaports also continued to 
increase.[Footnote 8]

Figure 5: Number of Operational CSI Seaports and Percentage of Total 
U.S-bound Containers Passing Through CSI Seaports, 2002-2007:

[See PDF for image] 

This figure is a multiple line graph illustrating the number of 
operational CSI Seaports and percentage of total U.S-bound containers 
passing through CSI Seaports, 2002-2007. The left vertical axis of the 
graph represents number of CSI ports from 0 to 90. The right vertical 
axis of the graph represents percentage of containers from 0 to 90. The 
horizontal axis of the graph represents fiscal years from 2002 to 2007. 
The following data is depicted: 

Fiscal year: 2002; 
Number of seaports conducting CSI operations: 4; 
Percentage of total U.S.-bound containers passing through at CSI ports: 
5%. 

Fiscal year: 2003; 
Number of seaports conducting CSI operations: 16; 
Percentage of total U.S.-bound containers passing through at CSI ports: 
39%. 

Fiscal year: 2004; 
Number of seaports conducting CSI operations: 26; 
Percentage of total U.S.-bound containers passing through at CSI ports: 
45%. 

Fiscal year: 2005; 
Number of seaports conducting CSI operations: 40; 
Percentage of total U.S.-bound containers passing through at CSI ports: 
73%. 

Fiscal year: 2006; 
Number of seaports conducting CSI operations: 50; 
Percentage of total U.S.-bound containers passing through at CSI ports: 
80%. 

Fiscal year: 2007; 
Number of seaports conducting CSI operations: 58; 
Percentage of total U.S.-bound containers passing through at CSI ports: 
86%. 

Source: GAO presentation of CBP data. 

[End of figure]

In implementing the CSI program and reaching its goal of 58 operational 
CSI seaports, CBP selected foreign seaports to participate in the 
program in three phases. CBP officials reported using the following 
general selection criteria for each phase as follows:[Footnote 9]

* Most of the 23 phase I seaports were selected because they shipped 
the highest volume of U.S.-bound container cargo.[Footnote 10]

* The 19 phase II seaports were selected based on factors such as cargo 
volume, strategic threat factors and the foreign government's level of 
interest in CSI.

* The 16 phase III seaports were selected using the phase II criteria 
as well as diplomatic or political considerations, such as the requests 
of foreign governments already participating in CSI.

As CBP expanded the number of CSI seaports and increased the proportion 
of total U.S.-bound container cargo passing through CSI seaports, the 
agency also achieved increases in security activities that occur at CSI 
seaports--targeting (CBP screens container cargo with ATS to produce 
risk scores and conducts additional review or research to ascertain 
risk levels) and examining high-risk container cargo (host government 
officials examine high-risk containers by scanning with nonintrusive 
inspection equipment or by physically searching the container). As of 
September 2007 CBP reported fully targeting 100 percent of all U.S.- 
bound container cargo to identify high-risk cargo as required by the 
SAFE Port Act.[Footnote 11] In addition, foreign governments 
participating in CSI have examined an increasing amount of high-risk 
container cargo as a growing proportion of total U.S.-bound containers 
pass through CSI seaports. In keeping with the CSI program's risk-based 
approach, CBP currently does not request that the host governments 
examine all U.S.-bound containers passing through the CSI seaports, 
just those that CBP officers have determined to be high-risk. In fiscal 
year 2006, the number of high-risk containers examined by host 
government officials at CSI seaports increased by 77 percent from the 
previous year to almost 71,000 containers. In fiscal year 2007, 
examinations continued to increase, reaching almost 137,000 containers. 
Moreover, in fiscal year 2007 CBP reported that host government 
officials examined approximately 96 percent of the container cargo 
referred for examination. CBP reported that about 4 percent of the 
referrals did not lead to examinations (about 5,600 requests) because 
(1) logistical difficulties arose, such as the container had already 
been loaded on the shipping vessel (about 5,200 requests),or (2) the 
host government denied the request (fewer than 400 requests).

To Strengthen CSI Operations, CBP Has Taken Steps to Address Human 
Capital Challenges and Enhance Host Government Relations, but 
Operational Challenges Remain:

CBP has made various operational improvements to CSI, though challenges 
remain. First, CBP has revised its human capital plan and added 
permanent staff at CSI seaports, though it reports difficulties in 
hiring and deploying qualified staff. Second, CBP's relations with CSI 
host governments we spoke to that conduct cargo examinations have 
improved over time, though access to key examination-related 
information and processes is limited by host governments at some CSI 
seaports. And finally, CBP's ability to conduct CSI program activities 
involves logistical challenges that are inherent to many seaport 
environments, such as those that are densely packed with equipment and 
personnel.

CBP Has Increased Permanent Staffing Levels at CSI Seaports, but Has 
Yet to Determine Optimum Distribution of Staff to Ensure All Critical 
Operations Are Performed:

The ability of the CSI program to operate in accordance with its 
mission and objectives depends, in part, on the success of its human 
capital strategy--and CBP's ability to manage and deploy staff in a way 
that ensures that critical security functions are performed. Our April 
2005 report on CSI noted that although CBP's goal is to target all U.S.-
bound cargo shipped in containers at CSI seaports before they depart 
for the United States, the agency had not been able to place enough 
officers at some CSI seaports to do so. Specifically, CBP had developed 
a CSI staffing allocation model to determine the staff needed to target 
container cargo. However, at some CSI seaports CBP had been unable to 
staff the CSI teams at the levels called for in the CSI staffing 
model.[Footnote 12] We noted that CBP's staffing model had not, at the 
time, considered whether some of the targeting functions could be 
performed in the United States. We recommended that CBP revise its 
staffing model to consider what functions need to be performed at CSI 
seaports and what functions can be performed in the United States, 
optimum levels of staff at CSI ports, and the cost of locating CBP 
targeters overseas at CSI seaports instead of the United States.

CBP has subsequently taken several steps to increase the number of CSI 
officers and to implement our 2005 recommendations. For example, in 
response to our concerns about staffing imbalances across seaports and 
shortages at the highest-volume seaports, CBP has increased staffing 
levels, bringing them closer to those called for in its staffing model--
resulting in a parallel increase in the volume of container cargo that 
is targeted. Also, CBP has added 15 staff to CSI targeting duty at the 
NTCC since 2005, composed of temporary and permanent officers. In 
addition, in fiscal year 2007 CBP deployed an additional 125 permanent 
and 68 temporary officers to CSI seaports. Considering the officers at 
both CSI seaports and the NTCC, as of November 2007, CBP had deployed 
209 CSI officers, which exceeds the 203 called for in the CSI staffing 
model. As a result of these efforts, CBP officials told us that they 
had increased their targeting of U.S.-bound container cargo from 65 
percent in April 2005 to 100 percent in September 2007.

The agency also developed cost estimates for placing a mix of permanent 
and temporary staff at CSI seaports (with permanent staff costing about 
$330,000 per year and temporary staff about $275,000 per year) in 
response to our recommendation. CBP reported that the advantages of 
placing officers at CSI seaports on a permanent rather than a temporary 
basis include greater opportunities for enhanced communication and 
coordination with host governments, and less disruption due to fewer 
rotations into and out of the country. At one CSI port that we visited, 
host government customs officials told us that the presence of 
permanent staff facilitated increased information sharing, which over 
time could lead to a decrease in unnecessary examinations.

Despite the progress it has made, CBP continues to face staffing 
challenges. CBP officials told us, for example, they continue to face 
challenges in obtaining sufficient numbers of qualified officers to be 
permanently deployed at CSI seaports. For example, CBP officials 
reported that only 9 qualified applicants applied for 40 permanent 
positions at CSI seaports. Officials told us that CSI must compete for 
staff with targeting or seaport experience with other CBP programs or 
positions, such as C-TPAT or other programs that operate at the NTCC. 
To fill open positions at CSI seaports, CBP officials reported that in 
some instances officers have been deployed who have not received all of 
the required training. In addition, CBP evaluation data we reviewed 
showed examples of CBP officers at CSI seaports lacking key skills, 
such as the ability to target proficiently or communicate in the local 
language.

In addition, CBP has taken action to enhance its human capital planning 
process for CSI, but has not yet included important factors in its 
staffing allocation model. As we reported in 2005, one of the features 
of the CSI staffing model that may contribute to staffing imbalances 
was its reliance on placing officers overseas at CSI seaports. It did 
not consider what functions could be done in the United States. In May 
2006, in response to our recommendations, CBP issued a human capital 
plan that did not specify that CSI targeting positions be located at 
CSI seaports, thus recognizing that officers could support CSI seaports 
from the NTCC in the United States. CBP officers assigned to the NTCC 
perform many of the same roles as officers at CSI seaports, including 
reviewing bills of lading.[Footnote 13] CBP officers at the NTCC review 
bills of lading for high-volume seaports where the placement of the 
number of CSI officers required to review all bills of lading is 
unfeasible.[Footnote 14] In addition, according to CBP officials, CBP 
officers at the NTCC review bills of lading for U.S.-bound cargo from 
CSI seaports where no CBP officers are stationed. Though CBP's 2006 
human capital plan generally recognizes that some CSI functions can be 
performed at either a CSI seaport or at the NTCC, the staffing 
allocation model used to calculate the number of targeters necessary to 
review bills of lading for each CSI port does not include factors that 
specify where these positions should be located.

In addition, CBP's staffing allocation model does not take into account 
activities other than targeting--such as witnessing host government 
examinations--that CSI officers perform at CSI seaports. According to 
CBP, the agency stations as many of the total officers needed as 
possible at the CSI seaports, but if the number of officers needed is 
higher than the number of officers allowed by the host government or 
available to be stationed in the seaport, then the remainder of the 
officers target from the NTCC.[Footnote 15] However, we found that CBP 
has still not systematically determined the optimal number of officers 
that need to be physically located on-site at CSI seaports to carry out 
duties that require an overseas presence (such as coordinating with 
host government officials or witnessing the examinations they conduct) 
as opposed to other duties that could be performed off-site in the 
United States (such as reviewing bills of lading and databases). Also, 
CBP's revised CSI human capital plan does not include costs related to 
placing temporary staff at the NTCC and thus does not have the data 
needed to conduct a cost-benefit analysis for determining the optimal 
location for its CSI officers.[Footnote 16] As we noted in our 2002 
report on a staffing framework for use at U.S. embassies, federal 
agencies should consider factors such as cost and physical security of 
foreign operations and consider options such as relocating staff to the 
United States, as part of their framework for determining the right 
number of staff to be placed overseas.[Footnote 17] Determining optimal 
staffing levels is particularly important in light of ongoing 
challenges CBP reports facing to identify sufficient numbers of 
qualified individuals to hire for the program, and in light of the 
program's recent expansion to additional seaports around the world.

While CBP has taken steps to implement the recommendations from our 
April 2005 report, further action is needed regarding the staffing 
allocation model. Specifically, as we recommended in 2005, the model 
should be revised to consider (1) what functions need to be performed 
at CSI seaports and what functions can be performed in the United 
States, (2) the optimum levels of staff needed at CSI seaports to 
maximize the benefits of targeting and examination activities in 
conjunction with host nation customs officials, and (3) the cost of 
locating targeting positions overseas at CSI seaports instead of in the 
United States.

Level of Collaboration between U.S. and Host Customs Officials Has 
Improved, but Challenges Remain at Some CSI Seaports:

CSI's strategic plan emphasizes the importance of CBP's continued 
efforts to foster partnerships with foreign customs officials at CSI 
seaports to improve CSI operations. Specifically, according to CBP 
headquarters officials, when CSI teams stationed at foreign seaports 
develop strong interpersonal relations with foreign government 
officials, it leads to increased trust and information sharing and thus 
improved targeting and examination of high-risk cargo. While the extent 
of cooperation across all of the 58 CSI seaports now operating is 
difficult to quantify, our observations at 6 CSI seaports and our 
review of select CSI team evaluations provide examples of how 
collaboration can benefit the CSI program, and conversely, how the lack 
thereof can hinder progress.[Footnote 18]

At all 6 CSI seaports we visited, CBP officers or host government 
officials told us that the relationship between the CSI team and the 
host government has been positive or has improved over time. CBP and 
host government officials we spoke with at all of the seaports we 
visited reported that establishing trust and collegiality has led to 
increased information sharing, resulting in more effective targeting 
and examination of high-risk container cargo. For example, CBP officers 
noted instances in which host customs officials would occasionally 
notify them of container cargo they thought could be high-risk, so that 
CBP could take a closer look at the information available in ATS 
related to the container cargo. In addition, a few CBP officers or host 
government officials stated that the presence of CSI teams at foreign 
seaports has in many instances helped to prevent unnecessary 
examinations because information provided by host government customs 
officials has led to lower risk profiles for certain container cargo.

Moreover, CBP officials reported that strengthened relationships with 
host government officials and the trade community have led host 
governments to bolster their customs and port security practices. CBP 
officials we spoke to emphasized that, like the United States, most 
foreign customs administrations have traditionally focused on revenue 
collection and the seizure of contraband, rather than security 
concerns. During our visits to CSI seaports, the CBP and host 
government officials we spoke with reported several examples of how the 
presence of CSI teams at seaports has helped to expand the focus of the 
efforts of these foreign customs administrations and the trade 
community to include enhanced security practices. For example, one 
country developed databases with trade information to achieve its 
customs goals and to assist CSI after seeing how gathering historical 
data benefited CBP. Furthermore, at a couple of the CSI seaports we 
visited, the CSI team or host government officials arranged outreach 
meetings with the trade community to raise companies' awareness of 
security practices and the benefits of providing correct and complete 
data about their cargo.

During our visits to CSI seaports and our review of data CBP collected 
during its evaluations of CSI teams, we also identified instances where 
cooperation between CSI teams and their counterparts in the host 
government could be improved--though, as CBP officials noted, some of 
the factors involved are beyond CBP's ability to control directly. For 
example, in some locations, CBP officials reported that a country may 
have laws that hinder the collaboration of host government officials 
with CSI teams. We identified the following issues during our 
observations at 6 CSI seaports as well as from our review of CBP data 
collected in fiscal year 2007 at an additional 12 CSI seaports (for a 
total of 18 CSI seaports):

* At 9 CSI seaports, the CSI teams there reported that they only 
interacted infrequently with their host government counterparts or the 
host government officials did not readily share information that would 
benefit CSI, such as knowledge about potentially suspicious container 
cargo. In one instance the lack of interaction was attributed to the 
host government's competing priorities.

* At 6 CSI seaports, host governments restricted CSI teams from viewing 
nonintrusive inspection equipment examinations conducted by host 
customs authorities or the resulting images of the container's 
contents, which is one of the key purposes for staffing CBP officers at 
CSI seaports.

* At 4 CSI seaports, host governments prohibited the use of hand-held 
radiation detection devices by CBP officials, which is considered by 
CBP to be an important way to identify a potential anomaly in a high- 
risk container. According to CBP officials, a few of the countries 
prohibit the equipment due to safety and health concerns about the use 
of the equipment.

* At 3 of the CSI seaports, host customs officials lacked access to 
technical equipment, such as computers or nonintrusive inspection 
equipment that worked properly, which CBP believes could limit their 
ability to share customs-related information with CSI team members or 
efficiently conduct examinations. According to CBP officials, sometimes 
host governments lack resources to meet these technological needs.

* At 6 CSI seaports in 2 countries, CBP officers at the seaport 
reported that host customs administrations did not provide a sufficient 
number of staff to assist CSI teams or the host government officials 
were often unavailable, which, according to CSI teams, can sometimes 
lead to delays in examining high-risk containers.

* At 3 CSI seaports, there was evidence of challenges to effective 
communication, such as some CSI teams having limited proficiency in the 
local language.[Footnote 19]

These examples are not intended to represent the CSI program as a 
whole, but are included to illustrate the types of challenges that CSI 
teams at the seaports and CBP program managers face. CBP officials 
responsible for managing the CSI program have reported that overall 
there has been a high level of cooperation at CSI seaports, though they 
acknowledged that the degree of involvement and participation that CBP 
officers have with foreign customs officials during the examination of 
high-risk cargo varies by country. It is also important to note that 
while CBP negotiates a written, nonbinding arrangement stating 
expectations for inclusion in the CSI program with the participating 
foreign governments, the agency cannot compel foreign governments to 
offer information for the purposes of CSI or to examine high-risk 
containers. Later in this report, we describe the processes CBP has in 
place to address difficulties that may be identified at the CSI 
seaports as part of its program oversight and monitoring efforts.

Seaport Environment and Logistics Present Challenges to CSI Operations:

Another factor that can affect CBP's ability to conduct CSI program 
operations involves logistical challenges that are inherent to many 
seaport environments. For example, as illustrated in figure 6, foreign 
government officials we spoke with at CSI seaports reported that many 
seaports are densely packed with equipment and personnel, which can 
make it difficult for host government customs officials to examine 
container cargo.

Figure 6: View of the Physical Layout of a Congested CSI Seaport:

[See PDF for image] 

This figure is a photograph of the physical layout of a congested CSI 
Seaport. 

Source: GAO. 

[End of figure]

According to CBP, open space to place scanning equipment or to conduct 
physical searches of containers can be scarce at some CSI seaports. For 
example, in two of the CSI locations we visited, scanning equipment and 
examination sites were placed several miles from where container cargo 
is unloaded, loaded, or stored. According to the CBP officials we spoke 
with, this adds to the costs and time required for examination and may 
result in logistical difficulties in having high-risk U.S.-bound 
containers examined before being loaded onto the shipping vessel. In 
addition, at one port we visited, the host government limited the 
number of containers it would examine, in part to limit the cost of 
examination and the amount of delay caused by moving these containers, 
according to the CSI team we spoke with. CBP officials reported that 
despite this limit to examine no more than 250 containers (out of the 
over 115,000 container cargo shipments to the United States from this 
seaport in fiscal year 2007), the country has not denied many 
examination requests--only two in fiscal year 2007. However, this 
ceiling was not based on risk factors, and an increase in denied 
requests could lead to additional containers with high-risk cargo 
departing for the United States without being examined.

Finally, CBP officials stated that containers at seaports are generally 
stored in a container yard before they are loaded onto the shipping 
vessel. These container yards may be very large, and containers in 
these yards are often stacked to minimize the time required to load 
container vessels. As shown in figure 7, containers on a vessel may be 
stacked several layers deep. Accordingly, CBP and host government 
officials we spoke to at a few CSI seaports reported it can sometimes 
be challenging to access a container for examination. CBP officials 
noted that any examinations requested but not conducted in the CSI 
seaport would occur at a U.S. seaport upon arrival.

Figure 7: Stacked Containers on a Shipping Vessel at a CSI Seaport:

[See PDF for image] 

This figure is a photograph of stacked containers on a shipping vessel 
at a CSI Seaport. 

Source: GAO. 

[End of figure]

CBP Has Enhanced Its CSI Evaluations at CSI Seaports and Performance 
Measures but Still Does Not Capture Critical Information about Host 
Government Examination Systems:

CBP has enhanced how it collects CSI data by strengthening its approach 
to conducting periodic evaluations of CSI officers at CSI seaports 
through on-site evaluations of performance. However, weaknesses remain 
in how CBP conducts evaluations, the information collected regarding 
host government examination systems, and performance measurement of the 
program as a whole.[Footnote 20] For example, CBP does not 
systematically collect information on the equipment, people, and 
processes that are part of the host government's overall examination 
system. Also, while CBP has refined and updated its performance 
measures, we identified remaining limitations, such as the omission of 
measures for all core program elements and several performance targets.

CBP Significantly Improved Its CSI Evaluations to Assess Program 
Operations at CSI Seaports, but Weaknesses Remain:

CBP conducts evaluations at CSI seaports to determine the effectiveness 
of the program. Specifically, CBP uses these on-site evaluations to 
assess CSI team operations and capabilities, such as how well CSI team 
members use ATS to determine the risk levels associated with U.S.-bound 
containers passing through CSI seaports. CBP's CSI strategic plan 
states that these periodic reviews are intended both to ensure that 
deployed CSI teams are adhering to standard operating procedures as 
well as to evaluate the relationships between the teams and the host 
customs administrations. In fiscal years 2006 and 2007, CBP reported 
conducting 42 and 45 evaluations, respectively. Since the program's 
inception in 2002, the agency reported conducting a total of 202 
evaluations.

In November 2006, CBP significantly changed the way it conducts CSI 
team evaluations. Prior to that time, CBP officials reported that its 
evaluators relied on self-reported information from CSI team members on 
how proficiently they performed CSI program activities. CBP's current 
approach to conducting CSI team evaluations seeks to provide a more 
thorough review of CSI team performance. According to CBP officials, 
the agency now requires the CSI team members under review to 
demonstrate their targeting competence to an evaluator, such as by 
physically showing the evaluator how they review information about 
container cargo to determine its risk level. To better assess the 
deployed CSI team's performance, CBP augmented its evaluation teams 
with officers who have expertise in areas such as targeting and 
intelligence gathering.

Also, CBP has developed a new software tool that enables evaluators to 
record evaluation data electronically, using laptop computers to 
conduct the on-site evaluations. This tool, CSI Team Evaluation 
(CSITE), consists of a series of yes or no questions that cover the 
various areas of CSI team performance, including whether all of the 
container cargo that the CSI team designated high-risk were examined 
and whether these actions were properly documented. The CSITE tool also 
provides guidance on each question and prompts evaluators as they 
conduct their review by, for example, directing them to ensure that the 
CSI team is using the correct settings in ATS. In addition, employing 
CSITE, CBP reported it can now aggregate the results of some or all of 
its evaluations, a capability it previously lacked, and can conduct 
statistical analyses of the results of the evaluations. The agency can 
determine, for example, what percentage of CSI team members 
successfully demonstrated proficiency in targeting high-risk 
containers. According to CBP officials, CSITE will eventually allow the 
agency to make comparisons of CSI performance across seaports. 
Moreover, CBP now retains the information it collects at CSI seaports 
and the resultant evaluation reports in a more systematic fashion. CBP 
officials acknowledged that the agency did not always store this data 
effectively prior to the implementation of the new evaluation system 
and could not provide us with documentation of all of the evaluations 
it had conducted since the program's inception.

While these efforts should help to strengthen the CSI team evaluation 
process, CBP is still not consistently collecting all available data to 
aid in its analysis of CSI team performance, and we identified 
instances in which the agency did not reconcile contradictory 
information it had collected. Based on our review of CBP's 
documentation associated with 34 evaluations to assess the information 
the agency collected and its methods for doing so, we found that 
evaluators do not always answer all of the questions contained in 
CSITE.[Footnote 21] For example, the software tool instructs the CBP 
evaluation team to collect information on whether recommendations made 
in prior evaluations have been implemented. This information could 
allow CBP to determine whether past problems have been addressed, but 
it is not always provided by the evaluation team. We also identified 
discrepancies between (a) the CSITE checklist of questions that the 
evaluation team completes during the onsite evaluation, and (b) the 
resulting evaluation report produced by CBP headquarters officials for 
2 of the 14 locations for which we had both documents to compare. At 
one seaport, for example, the CBP evaluation team indicated in the 
CSITE checklist that the CSI team did not have all of the data systems 
it needed to effectively target outbound shipments, whereas the 
evaluation report stated the team had access to all of the appropriate 
targeting tools and databases. With more complete information, 
collected in a consistent manner, CBP may be better able to determine 
how well CSI teams are performing, what corrective actions may be 
needed to improve the program, or whether the CSI program is achieving 
its security goals.

CBP Lacks a Process for Systematically Gathering Information on Host 
Government Examination Systems, Which Include Equipment, People, and 
Processes:

Host Government Examination Systems--Equipment:

In April 2005, we recommended that CBP establish minimum technical 
criteria required for the capabilities of nonintrusive inspection 
equipment at CSI seaports, while considering sovereignty issues with 
participating countries. CBP agreed to evaluate the feasibility of 
establishing such criteria. In 2006, section 205(e) of the SAFE Port 
Act required DHS to establish minimum technical capability criteria for 
the use of nonintrusive inspection equipment and nuclear and 
radiological detection systems in conjunction with CSI, but noted that 
these criteria should not be designed to conflict with the sovereignty 
of host countries. In 2007, the 9/11 Act also required the Secretary of 
DHS to develop technological standards for scanning systems that will 
be used to conduct 100 percent scanning at foreign seaports in the 
future and to ensure that these and other actions implementing the 
act's 100 percent scanning provisions do not violate international 
trade obligations and are consistent with the World Customs 
Organization framework or other international obligations of the United 
States. [Footnote 22] CSI host governments, which are responsible for 
conducting examinations of container cargo, purchase and operate 
nonintrusive inspection equipment, though as of November 2007, 13 CSI 
seaports use equipment on loan from the United States. The capabilities 
of this inspection equipment vary by manufacturer and model. The 
equipment may differ, for example, in its ability to penetrate steel 
shielding in order to generate an image of container contents, or may 
scan containers at different rates. Appendix IV describes the 
capabilities of this equipment in greater detail. As of November 2007, 
CBP had not yet implemented our prior recommendation or taken actions 
to meet the SAFE Port and 9/11 Acts requirements for setting minimum 
technical criteria. CBP officials stated that the reason for this is 
that they do not consider the agency to be a standard-setting 
organization. While CBP refers host governments to the World Customs 
Organization' SAFE Framework regarding the procurement of inspection 
equipment, this document does not include specific technical criteria 
or standards. Moreover, they added that it is important to acknowledge 
the inherent challenges involved in efforts to ascertain the 
capabilities of nonintrusive inspection equipment that is owned and 
operated by CSI host governments.

In May 2005, however, CBP put forth minimum technical criteria to 
evaluate the quality and performance of nonintrusive imaging inspection 
equipment being considered for use at U.S. seaports.[Footnote 23] These 
domestic standards set baseline performance requirements for 
penetration, contrast sensitivity, throughput, image quality, and scan 
size. To determine whether certain types of nonintrusive inspection 
equipment were acceptable for use at domestic seaports--and could meet 
the criteria that had been set--CBP conducted tests comparing the 
capabilities of nonintrusive imaging inspection equipment provided by 
seven manufacturers with its technical operating standards. On the 
basis of the test results, CBP recommended the inspection equipment 
from five of the seven manufacturers for use at domestic seaports, 
while equipment from two manufacturers was not recommended. CBP 
officials stated that there are no plans to systematically compare the 
capabilities of inspection equipment at CSI seaports against these 
criteria for domestic equipment due to sovereignty concerns.

CBP collects limited information on certain characteristics of the 
inspection equipment installed at CSI seaports, such as manufacturer; 
however, information related to capabilities and performance is not 
generally obtained. Officials in CBP's Office of Technology stated that 
they have information on the capabilities of equipment that the United 
States loans to other countries for 16 CSI seaports, and that only this 
equipment can be assured of meeting the CBP domestic requirements. 
However, these CBP officials said that they had neither determined 
which other CSI seaports use the inspection equipment that was assessed 
as part of CBP's test and recommended for use at domestic seaports, nor 
systematically determined the specific capabilities of the equipment 
used at those CSI seaports. Host government officials in the countries 
we visited stated that they followed their country's acquisition 
procedures, which included reviewing equipment capabilities and 
performance, among other things, for the purchase of nonintrusive 
imaging inspection equipment. However, CBP does not have documentation 
on the testing used by the host countries or the manufacturers to 
determine the basis for the equipment's stated performance or whether 
this stated performance is less than, meets, or exceeds the criteria 
CBP established for equipment used at domestic seaports.

According to CBP officials, the capabilities of nonintrusive inspection 
equipment are vetted during an assessment phase of the CSI program, 
when CBP is determining whether a seaport is prepared to operate within 
CSI. While, as part of the assessment phase, CSI officials stated that 
they collect descriptive technical information about the type of 
nonintrusive inspection equipment to be used at seaports, we did not 
find--in our review of CBP's checklist used to guide its assessment 
teams as they examine prospective CSI seaports--questions covering 
inspection equipment other than general direction to ascertain whether 
some type of this equipment was in place. Also, through our review of 
CBP's assessments of 10 CSI seaports--through which approximately 55 
percent of all U.S.-bound containers passed in fiscal year 2007--we did 
not find any assessments that described the performance capabilities of 
the equipment or judgments about the proficiency of host government 
officials in operating these systems. CBP officials stated that the 
agency has never prohibited a seaport from participating in CSI on the 
basis of its inspection equipment, and CBP documents show that 
participation in the program requires only that some type of 
nonintrusive inspection equipment be available at or near the potential 
CSI port.

Host Government Examination Systems--People and Processes:

The SAFE Port Act also directed DHS to (1) establish standard operating 
procedures for the use of nonintrusive inspection equipment at CSI 
seaports and (2) require CSI seaports to operate the equipment in 
accordance with the criteria and operating procedures established by 
DHS.[Footnote 24] Also, the 9/11 Act required DHS to develop 
operational standards for scanning systems that will be used to conduct 
100 percent scanning at foreign seaports in the future. CBP officials 
stated that they recognize that the capabilities of nonintrusive 
inspection equipment are only one element for determining the 
effectiveness of examinations that take place at CSI seaports. It is 
better, in their view, to make assessments of the whole examination 
system, which includes nonintrusive inspection equipment, personnel, 
and processes.However, CBP acknowledged it does not systematically 
collect information on host governments' use of examination systems and 
has not developed general guidelines or criteria that could provide CBP 
with the means to determine the quality of examinations of high-risk 
container cargo bound for the United States. CBP officials stated that 
they rely on CSI teams to notify headquarters if they have concerns 
about the host government customs or examination practices. 
Specifically, each CSI team leader is to meet weekly--usually via 
teleconference--with a CSI manager located at CBP headquarters to 
discuss ongoing CSI operations. However, CBP officials acknowledged 
that equipment, capabilities, and examinations practices of host 
government customs personnel are not routinely discussed.

CBP officials also reported that CSI team members witness most 
examinations of high-risk U.S.-bound containers, and their presence at 
the examinations would allow them to make judgments about aspects of 
the host government's examination system. However some host governments 
specifically prohibit CSI team members from witnessing examinations. 
Also we found that CBP officials did not routinely observe inspections 
at one CSI seaport we visited, and were not always able to be present 
for inspections at two other CSI seaports because those inspections 
were scheduled and conducted when CBP officials were not available.

CBP officials told us that their CSI team evaluations are also a means 
of capturing some information on various aspects of the host 
government's examination system. In order to participate in CSI, CBP 
requires that, among other things, host governments have customs staff 
capable of examining cargo originating in or transiting through its 
country and maintain a program to prevent breaches in employee 
integrity. However, the 15 CSI team evaluations we reviewed, which CBP 
had conducted since the agency revised its evaluation process in 
November 2006, showed limited coverage of whether host government 
customs personnel have been trained to use nonintrusive inspection 
equipment or are using it properly, the sufficiency of host staffing 
levels, and host government efforts to ensure the integrity of their 
customs administration. Specifically, 6 of the 15 CSI team evaluations 
discussed whether equipment was used properly, 1 discussed host 
staffing levels, and none discussed host integrity programs.

CBP's Lack of Information on Host Government Examination Systems 
Potentially Limits Assurance That Examinations of High-Risk Container 
Cargo are Effective:

CBP's lack of a systematic way to collect information on host 
governments' examination systems--including their equipment, people, 
and processes--potentially limits CBP's ability to ensure that 
examinations of high-risk container cargo at CSI seaports can detect 
and identify WMD. Without information on host governments' examination 
systems, CBP management may not be able to determine the reliability of 
the host government's inspections of high-risk U.S.-bound container 
cargo. This is of particular concern since, according to CBP officials, 
most high-risk cargo that has already been examined at a CSI seaport, 
is generally not reexamined once it arrives at a U.S. seaport.[Footnote 
25] CBP officials stated that if problems are found in the examination 
process at a CSI seaport, then high-risk container cargo would be 
reexamined upon arrival in the United States.

As already noted, CBP must respect participating countries' 
sovereignty. CBP cannot require that a country use specific equipment. 
However, if a high-risk container was examined using an examination 
system found by CBP to be less capable than established criteria, the 
agency could require that the container be reexamined upon arrival at a 
U.S. seaport. CBP officials stated that they believe that in general 
the equipment used by participating governments meets or exceeds the 
capabilities of the nonintrusive inspection equipment used at U.S. 
seaports. However, because CBP has not set minimum technical criteria 
for nonintrusive inspection equipment at CSI seaports, and the agency 
does not systematically review the operations of the host government 
examination systems at CSI seaports, CBP potentially has limited 
assurance that their inspection equipment is capable of detecting and 
identifying potential WMDs. In light of the new 9/11 Act requirement 
that 100 percent of U.S.-bound container cargo be scanned in the future 
with nonintrusive inspection equipment at foreign seaports before 
leaving for the United States, it is important that CBP have processes 
in place to gather the information necessary to ensure that cargo 
container examinations--and the equipment used as part of the 
examination process--are reliable, regardless of the point of origin.

CBP Made Efforts to Refine CSI Performance Measures, but Did Not Fully 
Address our Previous Recommendation:

While CBP has taken steps to strengthen performance measures for the 
CSI program, we identified areas that did not fully address our April 
2005 recommendation to develop outcome-based performance measures or 
proxy measures of program functions--if program outcomes could not be 
captured--and performance targets to track the program's progress in 
meeting its objectives. Whereas CBP's CSI team evaluations and program 
monitoring activities help to evaluate CSI operations at the seaport 
level, CBP uses performance measures to gauge the effectiveness of the 
overall program in meeting its broader strategic objectives for CSI 
across seaports. By definition, performance measures are a particular 
value or characteristic used to quantify a program's outputs--which 
describe the products and services delivered over a period of time--or 
outcomes--which describe the intended result of carrying out the 
program. A performance target is a quantifiable characteristic that 
establishes a goal for each measure; agencies can determine the 
program's progress, in part, by comparing the program's measures 
against the targets. For example, the target of one of CBP's 
performance measures--the "number of operational CSI seaports"--was to 
have 58 CSI seaports operating in fiscal year 2007, which the agency 
achieved as described previously in this report. The Government 
Performance and Results Act of 1993 incorporated performance 
measurement as one of its most important features, and the 
establishment and review of performance measures are a key element of 
the standards for internal control within the federal 
government.[Footnote 26] As discussed in the Government Performance and 
Results Act of 1993 and as we reported in 1996, measuring performance 
allows organizations to track progress being made toward specific goals 
and provides managers crucial information upon which to base their 
organizational and management decisions.[Footnote 27] In addition, 
leading organizations recognize that performance measures can create 
powerful incentives to influence organizational and individual behavior.

In the past 2 years, CBP has made efforts to refine and modify its 
performance measures as the CSI program has matured. Since 2005, for 
example, CBP has eliminated five performance measures that it had used 
to track the implementation of seaports participating in CSI, measures 
that CBP determined were no longer needed because CSI operations were 
under way at the majority of planned CSI seaports. Also, in our April 
2005 review of CSI, we identified a CSI performance measure that was 
calculated inappropriately, and in response, CBP modified how the 
measure was calculated to address our concerns. Specifically, for the 
CSI measure that tracks the number of container examinations waived 
because they are determined to be unnecessary, CBP began excluding 
inappropriate data that made the results of the performance measure 
misleading.[Footnote 28] This was an important modification because, as 
we reported in November 2002, measures that are defined inconsistently 
with how they are calculated can be confusing and create the impression 
that performance is better or worse than it actually is.[Footnote 29]

CBP has made efforts to enhance CSI performance measures, but we 
identified limitations in the information available for CSI program 
managers to assess the program. In the past, we and the Office of 
Management and Budget have encouraged federal departments and agencies 
to measure whether programs are achieving their intended outcomes, such 
as CSI's purpose of protecting global trade from being exploited by 
international terrorists. However, we and the Office of Management and 
Budget have acknowledged the difficulty in developing outcome measures 
for programs that aim to deter or prevent specific behaviors. In such 
an instance, we have reported that proxy measures should be designed to 
assess the effectiveness of program functions. CBP officials reported 
the agency has not been able to develop a way to measure the deterrence 
effect of the program, as CSI is designed to support the CBP mission to 
prevent and deter terrorists and terrorist weapons from entering the 
United States. Examples of CSI program functions include targeting and 
examining high-risk container shipments before they are loaded on 
vessels bound for the United States, and in our 2005 review of CSI we 
provided guidance on an alternative method of developing proxy measures 
to evaluate program performance. Further, according to the Office of 
Management and Budget, proxy measures should be closely tied to the 
intended program outcome, and it may be necessary to have a number of 
proxy measures to help ensure sufficient safeguards are in place to 
account for performance results. According to CBP officials the 
following three of its existing performance measures were proxies for 
program outcomes.[Footnote 30]

(1) The percentage of worldwide U.S.-bound containers passing through 
CSI seaports--since these containers are to be targeted and, if 
determined high-risk, may be examined by host government officials, 
this is a measure of the program goal to detect and prevent WMDs headed 
to U.S. seaports from leaving foreign seaports.

(2) The number of foreign mitigated examinations (that is, examinations 
determined to be unnecessary due to information provided by host 
government officials and thus waived) by category--developed to 
quantify whether collocating CBP officials at CSI seaports increases 
information sharing and collaboration.

(3) The number of intelligence reports based on CSI foreign sources--
intended to measure whether having CBP officials located at foreign 
seaports leads to increased collaboration with foreign customs 
officials.

The Office of Management and Budget has stated that performance 
measures should capture the most important aspects of a program's 
mission and priorities. However, CBP does not have a measure that 
tracks the extent to which U.S.-bound containers carrying high-risk 
cargo are examined at CSI seaports, despite the fact that this activity 
is a core element of the CSI program.

CBP has taken other actions to address our April 2005 recommendation 
that includes ways to improve CSI performance measures, but we found 
additional weaknesses as well. The strategic plan demonstrated how each 
performance measure corresponds to the three strategic goals of CSI, 
which include (1) securing U.S. borders, (2) building a robust CSI 
cargo security system, and (3) protecting and facilitating trade. This 
marked an improvement, as this linkage had not been made previously. In 
addition, CBP addressed an additional aspect of our prior 
recommendation by establishing performance targets for four of the six 
CSI performance measures currently used. However, only one measure had 
a target for multiple years. In addition, since issuing the CSI 
strategic plan the agency has not updated its performance targets for 
fiscal year 2008 or beyond for any of its measures. Without this 
information about the performance targets, it may be difficult for CBP 
to determine whether the results were more positive or negative than 
expected.

Also, we identified a weakness in how some CSI performance measures are 
calculated. As we noted earlier in this report, as the number of CSI 
seaports has increased in recent years, program activities have 
increased as well. However, CBP does not appropriately control for this 
program growth in how it calculates three of its six performance 
measures. For example, since the "number of foreign mitigated 
examinations by category"--the number of container examinations 
determined to be unnecessary due to information provided by host 
government officials--is not calculated on a per-container basis (i.e., 
per 10,000 containers), it may be difficult to determine whether 
fluctuation in the numbers across years is due to (1) increased 
collaboration with foreign government officials or (2) simply an 
increase in the number of containers reviewed and considered for 
examination at the increasing number of CSI seaports. Similarly, the 
number of intelligence reports and the number of investigative cases 
initiated may be due to an increase in the number of operational CSI 
seaports, not increased collaboration with host government officials. 
Without controlling for program growth, CBP's calculation of results 
for its performance measures may be misleading or confusing to CBP and 
DHS program managers or the Congress, who provide program oversight.

Conclusions:

Since we began reporting on the CSI program in 2003, CBP has made 
significant progress in expanding and developing the program. However, 
CBP continues to face several management and operational challenges, 
which may limit CBP's ability to ensure that the CSI program provides 
the intended level of security for U.S.-bound container cargo moving 
through the international supply chain. Also, balancing security 
concerns with the need to facilitate the free flow of commerce remains 
an ongoing challenge for CBP.

Recognizing that program evaluation data are important for program 
managers to understand why results occur and what value a program adds, 
CBP has taken actions to enhance its evaluation of CSI team activities. 
The revised evaluation program has increased the information available 
to make policy and programmatic decisions regarding the operations at 
the CSI seaports. However, limitations that remain in CBP's evaluation 
process affect the accuracy and completeness of the program information 
available for making sound management decisions about the CSI program 
as a whole. Specifically, when CBP's evaluation teams do not complete 
the evaluation tools or resolve contradictory information, program 
managers may receive limited or inaccurate information. Further, when 
the data collected using the CSI evaluation tool during the evaluations 
are not reliable and readily available for assessment, CBP's planned 
programwide trend analyses of the CSI program may be misleading.

In assessing CSI performance, CBP lacks information about a very 
important aspect of the program--the overall examination systems used 
by the host governments to examine high-risk cargo shipped in 
containers as requested by CBP. CBP's efforts have led to the 
successful participation of a wide array of foreign governments in the 
CSI program, and CBP has established many cooperative relationships 
with its foreign partners. While we acknowledge the agency cannot force 
security requirements upon foreign governments, the lack of information 
systematically gathered about the examination systems used by 
participating governments is problematic. Data about the equipment, 
people and processes involved in the examination system are vital for 
determining whether high-risk U.S.-bound containers have been properly 
examined or should be examined or reexamined upon arrival at a U.S. 
seaport. CBP lacks guidelines and criteria for most of the equipment 
and the people and processes used by host government examination 
systems--as required, in some instances, by the SAFE Port and 9/11 
Acts--for evaluating CSI seaport operations and determining overall 
program effectiveness. In light of the new 9/11 Act requirement that 
100 percent of U.S.-bound container cargo be scanned in the future at 
foreign seaports before leaving for the United States, it is important 
that that CBP have programs in place to gather the information 
necessary to ensure that cargo container examinations--and the 
equipment used as part of the examination process--are reliable, 
regardless of the point of origin.

Program evaluations are just one source of information that managers 
need to make decisions, and evaluation data must often be coupled with 
performance measurement to assess overall program results. Measuring 
the overall impact of the CSI program remains difficult due to the 
challenges involved in creating effective performance measures, and 
because of great difficulty in measuring the deterrent effect of the 
program. As we and the Office of Management and Budget have reported, 
performance measurement can be very valuable to program managers, as 
the process can indicate what a program is accomplishing and whether 
intended results are being achieved. Measuring program performance 
encourages managers to focus on the key goals of a program and helps 
them by providing information on how resources and efforts are best 
allocated to ensure effectiveness. Though CBP identified performance 
measures it considers proxies for program outcomes (given the 
difficulty in assessing the deterrent effect of CSI), these measures do 
not cover a key core program function, for example a performance 
measure for the number of high-risk U.S.-bound containers examined at 
CSI seaports. Finally, without clearly developed performance targets 
for each of its measures, program managers, Congress, and the public 
lack information needed to determine the extent to which the CSI 
program is performing as intended. Taken as a whole, the lack of 
clearly articulated performance measures and accurate and reliable 
evaluative data may hinder CBP's ability to ensure that the resources 
it expends for CSI effectively achieve its goal of helping to secure 
U.S. borders against terrorists and terrorist weapons.

Recommendations for Executive Action:

To help ensure that CBP has the information needed to assess its 
achievement of CSI program goals to help enhance supply chain security-
-while at the same time balancing security concerns with the need to 
facilitate the free flow of commerce--we recommend that the Secretary 
of Homeland Security direct the Commissioner of U. S. Customs and 
Border Protection to take the following actions in three areas:

* Strengthen CBP's process for evaluating CSI teams at overseas ports 
by (a) systematically capturing and maintaining all relevant evaluation 
data and documentation so that it can be used by CBP management to 
guide operating decisions, monitor program performance, and inform 
resource allocation decisions; (b) ensuring that CSI evaluation teams 
follow established evaluation procedures; and (c) monitoring the 
completion, within established time frames, of recommendations made in 
previous evaluations.

* In collaboration with host government officials, improve the 
information gathered about the host governments' examination systems-- 
which includes people, processes, and equipment--at each CSI port by 
(a) establishing general guidelines and technical criteria regarding 
the minimal capability and operating procedures for an examination 
system that can provide CBP with a basis for determining the 
reliability of examinations and related CSI activities; (b) 
systematically collecting data for that purpose; and (c) analyzing the 
data against the guidelines and technical criteria to determine what, 
if any, mitigating actions or incentives CBP should take to help ensure 
the desired level of security.

* Enhance CSI performance measures to better assess CSI performance 
overall by (a) developing measures for all core CSI program functions 
designed to have a deterrent effect, (b) establishing annual 
performance targets--based on explicit assumptions--for all performance 
measures, and (c) revising how performance measures are calculated to 
take into account CSI program growth.

Agency Comments and Our Evaluation:

We provided a draft of this report to the Department of State and the 
Department of Homeland Security for their review and comment. The 
Department of State did not provide written comments but provided 
technical comments, which have been incorporated into the report as 
appropriate. DHS provided written comments--incorporating comments from 
CBP--on December 20, 2007, which are presented in Appendix II. In 
commenting on a draft of this report, DHS noted that it concurred with 
one recommendation and partially concurred with the remaining two 
recommendations.

In its written comments, DHS and CBP concurred with our recommendation 
on strengthening its process for evaluating CSI teams at overseas 
locations. Specifically, CBP noted that by June 2008, it planned to 
establish a database that would contain all recommendations and action 
plans as a result of CSI port evaluations as well as due dates for 
implementing recommendations and actions taken. To ensure that CSI 
evaluation teams follow procedures, CBP indicated that it would make it 
mandatory that the teams complete all database fields. Furthermore, CBP 
reported that it would assign values to questions in its evaluation 
tool on the basis of the criticality of the activity evaluated in each 
question to CSI's mission as a whole.

DHS commented that CBP partially concurred with our second 
recommendation to improve information gathered about host governments' 
examination systems by (a) establishing general guidelines and 
technical criteria regarding the minimal capability and operating 
procedures; (b) systematically collecting data for that purpose; and 
(c) analyzing the data against the guidelines and technical criteria. 
CBP agreed on the importance of an accepted examination process and 
noted it continues to take steps in addressing improvements in the 
information gathered about host government's examination systems at CSI 
seaports by working directly with host government counterparts, through 
the World Customs Organization, and providing capacity building 
training and technical assistance. While CBP does engage in capacity 
building, it does so with only 5 of the 33 countries with CSI ports. 
CBP also stated that it will continue to use the WCO through its SAFE 
Framework of Standards to address a uniform customs process and 
technical standards for equipment. However, the SAFE Framework mentions 
no specific technical capability criteria for inspection equipment. 
Additionally, CBP does not systematically collect or assess information 
on the people, processes, or technology used by these host governments 
to examine high-risk U.S.-bound containers. CBP also noted in its 
comments to this report, that equipment used for inspection of 
containers in foreign countries is equal to or better than the 
equipment used by CBP at its domestic ports. While CBP has performance 
information for the 16 seaports that have inspection equipment on loan 
from CBP, it is not in a position to assess the performance of 
equipment used at the remaining 42 CSI seaports. Although we repeatedly 
requested systematic information regarding the equipment technical 
capabilities in these other ports, CBP officials were unable to provide 
it to us. In response to our 2005 report, CBP stated that it would 
evaluate the feasibility of technical requirements for nonintrusive 
inspection equipment, but a legal issue may exist regarding CBP's 
ability to impose such requirements. While we understand CBP's 
position, it could still gather information on such equipment's 
technical capabilities. Because the CSI inspection might be the only 
inspection of a container before it enters the United States, it is 
important that information on the people, processes, and equipment used 
as part of CSI be obtained and assessed to provide some level of 
assurance of the likelihood that the examination system could detect 
the presence of WMD. If a port's examination system were determined to 
be insufficient, CBP could take mitigating actions, such as re- 
examining container cargo upon its arrival at a domestic seaport.

Finally, DHS commented that CBP partially concurred with our third 
recommendation to enhance CSI performance measures to better assess CSI 
performance overall. CBP stated that it believes its current measures 
address core program functions of targeting and collaboration with host 
governments to mitigate or substantiate the risk of a maritime 
container destined for the United States. We disagree. As discussed 
earlier in this report, a core element of the CSI program, specifically 
the extent to which U.S.-bound containers carrying high-risk cargo are 
examined at CSI seaports, is not addressed through CBP's performance 
measures. In its comments, CBP stated that its outcome performance 
indicator captures the number of foreign mitigated examinations by 
category, however CBP did not respond to our requests for more 
information regarding these categories, including whether risk was a 
category. Although it considers action on this recommendation 
completed, CBP noted its intention to continue to refine, evaluate, and 
implement measures to track progress toward meeting CSI objectives. As 
previously stated, since issuing the CSI strategic plan, CBP has not 
updated its performance targets for fiscal year 2008 or beyond for any 
of its measures. Thus, we believe additional action is warranted. 
Establishing annual targets for performance measures is important, as 
agencies can determine the program's progress, in part, by comparing 
the performance measures against the targets. In addition, CBP did not 
address whether it plans to reconsider how it calculates some of its 
performance measures to control for CSI program growth. Without doing 
so, CBP's calculation of results for its performance measures may be 
misleading or confusing to CBP and DHS program managers, or the 
Congress, who provide program oversight.

DHS and CBP also provided technical comments, which have been 
incorporated into the report as appropriate.

If you or your staff have any questions about this report, please 
contact me at (202) 512-9610 or at caldwells@gao.gov. Key contributors 
to this report are listed in appendix VI. This report will also be 
available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

Signed by: 

Stephen L. Caldwell: 
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):

* How has CBP contributed to strategic planning for supply chain 
security efforts and the CSI program in particular, and what progress 
has been made in achieving CSI performance goals?

* How has CBP strengthened CSI operations in response to our 2005 
review, and what challenges, if any, remain?

* How does CBP evaluate CSI port operations and assess program 
performance overall, and how has this process changed over time?

Scope and Methodology:

To address our first objective, we reviewed the strategic plans of the 
Department of Homeland Security (DHS), CBP, and CSI as well as national 
strategies like the National Maritime Security Strategy and the 
Strategy to Enhance International Supply Chain Security. We also 
analyzed the CSI strategic plan to determine whether it includes all of 
the key elements included in the Government Performance and Results 
Act. In addition, to measure CSI's progress in meeting its performance 
goals, we reviewed and analyzed CBP data related to the number of CSI 
seaports, the cargo CBP targeted and referred to the host government to 
examine, and the number of cargo containers that were (and were not) 
examined by host government officials at the CSI seaports. We also met 
with CBP officials responsible for managing the CSI program, from the 
CSI Strategic Planning and Evaluation Branch, and from CBP's Office of 
Field Operations and Office of International Affairs and Trade 
Relations, not only to gather information about CSI strategic planning 
and performance goals, but to discuss all of the issues within the 
scope of this review.

To examine CBP's efforts to enhance CSI operations and the operational 
challenges that remain at CSI seaports, we reviewed GAO's previous 
assessments of the CSI program and examined CBP's efforts to implement 
our three prior recommendations. We also reviewed the CSI human capital 
plan and spoke to CBP officials about actions the agency has taken to 
ensure that CSI human resources are appropriately allocated. As part of 
that process, we met with officials at CBP headquarters and at the 
National Targeting Center - Cargo (NTCC) in Virginia to discuss the 
agency's decision to conduct some targeting of high-risk containers 
from the NTCC rather than at CSI seaports.[Footnote 31] In addition, we 
spoke to CBP officials at three domestic seaports, selected according 
to geographical location and container volume. We also visited six CSI 
seaports located overseas, and selected the locations based on 
geographic and strategic significance, container volume to the United 
States from the seaports, when the seaports began conducting CSI 
operations, and whether the seaport was involved in CBP's Secure 
Freight Initiative. At the CSI seaports, we also interviewed host 
government officials and CSI teams to discuss the frequency and level 
of collaboration involved in their interactions with each other, 
circumstances at seaport facilities that affect CSI operations, and 
financial cost issues associated with examinations. The results from 
our visits to seaports provided examples of CBP and host government 
operations but cannot be generalized beyond the seaports visited 
because we did not use statistical sampling techniques in selecting the 
seaports.

To determine what progress CBP has made in strengthening its tools for 
monitoring and measuring the progress of the CSI program, we reviewed 
the performance measures presented in the CSI strategic plan against 
criteria developed by the Office of Management and Budget and GAO. In 
addition, to appraise CBP's efforts to strengthen its methods to 
evaluate CSI teams and to learn about operations at CSI seaports, we 
analyzed a sample of evaluation documents. Our nonrepresentative sample 
consisted of evaluations for all 40 seaports for which we had 
documentation at the time of our review, including (1) the 15 
evaluations conducted between November 2006 (when CBP revised its 
evaluation process and began using the Container Security Initiative 
Team Evaluation software tool) and May 2007 (when we conducted our 
analysis), (2) the 7 available evaluations that directly preceded them 
chronologically and were conducted using CBP's previous evaluation 
methodology (for the purpose of comparison), and (3) the most recent 
evaluations conducted at each of the additional locations for which 
documentation had been provided by CBP. Thus, we reviewed a total of 34 
evaluations (covering 40 CSI seaports) out of the 114 evaluations that 
GAO had obtained from CBP as of May 2007. For each of the evaluations 
reviewed, we assessed any available materials, which could include a 
narrative report and/or a checklist of yes or no responses. While our 
sample covered various aspects of CBP's evaluations, our sample was not 
selected using statistical sampling techniques. Thus, the results from 
our review of CBP evaluation data provide illustrative examples about 
CSI team evaluation methods and program operations at CSI seaports--and 
generally corroborated our seaport site visit observations--but cannot 
be generalized to the all 58 seaports conducting CSI operations.

We also met with CBP officials managing the CSI program to assess the 
agency's efforts to collect information about the equipment, people, 
and processes involved in the host governments' examinations of U.S.- 
bound container cargo, including the capabilities of examination 
equipment operating at CSI seaports and the proficiency of host customs 
administrations using the equipment. In addition, we selected and 
analyzed a nonrepresentative sample of 10 port assessments among those 
that CBP conducted at each port prior to its admission into the CSI 
program--the sample was composed of the 6 seaports we visited plus the 
4 highest-volume locations as of January 2007. As of that date, 
approximately 55 percent of containers bound for the United States 
passed through these 10 seaports. Thus, our findings from our review of 
the assessments provide examples about the type of information 
collected as part of the process, but cannot be generalized to all 58 
seaports in the program.

We conducted this performance audit from May 2006 through January 2008 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives.

Data Reliability:

We met with CBP officials to discuss the agency's efforts to ensure CSI 
data on the number of cargo shipments and containers subject to 
targeting and examination are reliable. In our 2005 review of the 
program, we found the data to be sufficiently reliable to support our 
findings. Since that time, CBP has further enhanced the way in which it 
collects and aggregates information about CSI program activities at 
foreign seaports, including the targeting and examination of high-risk 
container cargo. Specifically, CSI teams now utilize improved 
technology, eliminating the need for transmitting data to CBP 
headquarters via e-mail and thereby reducing the opportunity for human 
error in manually entering and aggregating data for the program. CBP 
officials at headquarters can now directly access the data entered at 
each CSI port as soon as they are entered into the shared system and 
can monitor the data on a daily basis to identify errors in or 
mischaracterization of the data. While we did not directly test the 
reliability of 2006 data, the recent CBP initiatives to improve 
reliability, combined with GAO's previous assessment of the 2005 data, 
gave us confidence in using CSI targeting and examination data to 
provide descriptive, background information regarding the extent to 
which high-risk container cargo is targeted by CBP and examined by 
foreign governments participating in CSI.

[End of section]

Appendix II: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
Washington, DC 205211: 
[hyperlink, http://www.dhs.gov]: 

December 20, 2007: 

Mr. Stephen L. Caldwell: 
Director, Homeland Security and Justice Issues: 
U.S. Government Accountability Office: 
Washington, D.C. 20548: 

Dear Mr. Caldwell:

Thank you for providing us with a copy of the draft report entitled 
"Supply Chain Security: Examinations of High-Risk Cargo at Foreign 
Seaports have Increased, but Improved Data Collection and Performance 
Measures are Needed" (GAO-08-187SU), which examines U.S. Customs and 
Border Protection's (CBP) Container Security Initiative (CSI) program 
and how CBP has contributed to strategic planning for supply chain 
security, strengthened CSI operations, and evaluated CSI operations and 
overall performance.

The Department of Homeland Security (DHS) and CBP agrees with the GAO's 
overall observations and recommendation that CBP needs to enhance the 
data collected about CSI team performance. CBP is concurring in part 
with the recommendations made by GAO concerning host government 
examinations and the further development of
performance measures and annual targets for core CSI functions as CBP 
believes it has addressed and will continue to work on these areas as 
deemed necessary. The following represents the Department and CBP 
response to the recommendations included in the report.

Recommendation 1: Strengthen CBP's process for evaluating CSI teams at 
overseas ports by (a) systematically capturing and maintaining all 
relevant evaluation data and documentation so that it can be used by 
CBP management to guide operating decisions, monitor program 
performance, and inform resource allocation decisions; (b) ensuring 
that CSI evaluation teams follow established evaluation procedures; and 
(c) monitoring the completion, within established time frames, of 
recommendations made in previous evaluations.

Response: CBP concurs with the recommendation and will enhance the 
Container Security Initiative Team Evaluation (CSITE) by establishing a 
data base that will contain all recommendations and action plans as a 
result of a CSI port evaluation. The data base will include due dates 
for each recommendation and annotate the appropriate action taken and 
the results. In addition, the data base will be linked to CSITE in 
order for the evaluator to have a record of previous recommendations 
and actions taken for reference when conducting additional evaluations 
or follow-up.

To ensure that CSI evaluation teams follow established procedures, it 
will become mandatory that all data base fields are properly completed 
in CSITE. This enhancement will address GAO's concern that not all 
questions in CSITE had a response.

Moreover, CBP will establish a numerical "weight/value" for the 
questions in CSITE. Numerical "weight/value" will be set for each 
question and that numerical value will correspond to how critical a 
negative response would affect the CSI mission as a whole. With these 
numerical "weight/value", CBP will be able to provide an instant 
"Report Card" on the CSI port being evaluated.

Due Date: June 30, 2008

Recommendation 2: In collaboration with host government officials, 
improve the information gathered about host governments' examination 
systems – which includes people, process, and equipment – at each CSI 
port by (a) establishing general guidelines and technical criteria 
regarding the minimal capability and operating procedures for an 
examination system that can provide CBP with a basis for determining 
the reliability of examinations and related CSI activities; (b) 
systematically collecting data for that purpose; and (c) analyzing the 
data against the guidelines and technical criteria to determine what, 
if any, mitigating actions or incentives CBP should take to help ensure 
the desired level of security.

Response: CBP agrees in part with this recommendation on the importance 
of an accepted examination process and continues to take steps in 
addressing improvements in the information gathered about host 
governments' examination systems at CSI ports by working directly with 
host government counterparts, through the World Customs Organization 
(WCO), capacity building training and technical assistance.

CBP understands GAO's position in trying to determine the effectiveness 
of the foreign customs service conducting examinations of high-risk 
maritime containers destined for the United States. CSI has been in 
operation for over five years and its success is attributed to the 
cooperation and collaboration of our host government counterparts 
examining high-risk containers that are referred for inspection.

Through the CSI program, CBP Officers work with host customs 
administrations to establish security criteria for identifying high-
risk containers. With the establishment of security criteria, CBP has 
benefited in identifying high-risk containers that pose a risk for 
terrorism. Prior to CSI, many of these customs administrations were not 
using non-intrusive (NII) technology to inspect the high-risk 
containers before they are shipped to U.S. ports. Since the inception 
of the CSI program, 58 CSI operational ports host government 
administrations have invested millions of dollars on NII equipment that 
includes their purchase of radiation detection devices such as 
Radiation Portal Monitors for use in their examination process. The 
level of examinations conducted at CSI locations increased by 93% from 
70,902 in FY2006 to 136,815 in the FY2007. For the same time periods, 
the percentage of cargo examined to overall CSI related shipments 
increased by over 50% from 0.80% to 1.25%. These increased levels of 
workload resulted in an array of enforcement actions and investigative 
cases. This level of success could not have been accomplished without 
the host government continued cooperation and having an effective 
examination process.

Furthermore, host government officials have not hesitated in providing 
CBP with all the information on equipment used for the inspection of 
containers. This equipment is equal to or better than the equipment 
used by CBP at its domestic ports. CBP Officers are fully trained in 
the equipment being used by the host government, and in the cases where 
CBP has provided NII equipment, those host government customs officials 
also have been trained in the use of such equipment.

In addition to working directly with host governments, CBP provides 
training and technical assistance to customs administrations of a 
number of countries that currently participate in CSI. Such training 
and technical assistance forms a long-term capacity building program to 
support implementation of the WCO Framework of Standards to Secure and 
Facilitate Global Trade. The standards incorporated in the Framework 
contain key elements which support CSI including:

* Advance electronic presentation of cargo information; 

* Screening of cargo containers using non-intrusive inspection 
equipment; 

* Use of automated risk management systems; 

* Standardization of targeting criteria to identify high-risk cargo and 
containers; 

* Employee integrity programs; and; 

* Inspection of cargo in the country of origin, transit and 
destination. 

CBP also provides a number of assistance and training programs to 
foreign customs and border security agencies to facilitate 
implementation of port security antiterrorism measures.

As a nation's sovereignty is critical, CBP will continue to use the WCO 
through its Safe Framework of Standards, to address a uniform customs 
process and technical standards for equipment to ensure that the 
examination process of cargo is one that is uniform throughout the 
world.

Recommendation 3: Enhance CSI performance measures to better assess CSI 
performance overall by (a) developing measures for all core CSI program 
functions designed to have a deterrent effect, (b) establishing annual 
performance targets — based on explicit assumptions — for all 
performance measures, and (c) revising how performance measures are 
calculated to take into account CSI program growth.

Response: CBP concurs in part with the recommendation. CBP believes 
that its current measures do address and assess CSI core program 
functions of targeting and collaboration with the host government in 
order to mitigate or substantiate the risk of a maritime container 
destined to the United States.

CBP will continue to refine, evaluate and implement any and all 
performance measures needed to track the progress in meeting any 
additional CSI objectives.

CBP's current performance measures include two outcome, four 
information and one efficiency measures. These performance measures 
have been accepted by the Office of Management and Budget and are part 
of the DHS Performance and Accountability Report (PAR).

The performance indicators include:

* Outcome: (I) number of foreign mitigated examinations by category; 
and (2) number of investiga