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entitled 'Drug Control: DEA Could Improve Its Heroin Signature and 
Domestic Monitor Programs' Geographic Source Data' which was released 
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United States General Accounting Office: 
GAO: 

Report to the Co-Chairman, Caucus on International Narcotics Control, 
U.S. Senate: 

March 2002: 

Drug Control: 

DEA Could Improve Its Heroin Signature and Domestic Monitor Programs' 
Geographic Source Data: 

GA0-02-416: 

Contents: 

Letter: 

Results in Brief: 

Background: 

Scope and Methodology: 

Purpose of the HSP and DMP Is To Produce Data That Detect Trends in 
Heroin Sources: 

Federal Law Enforcement Used the HSP and DMP Data for Intelligence 
Purposes and Management: 

Quantity of Heroin Seized at Ports-of-Entry by Customs but not Sent to 
DEA for Testing May Be Sufficient To Make a Difference in Results 
Reported by DEA: 

The HSP and DMP Data Could Be Improved: 

Conclusions: 

Recommendations: 

Agency Comments: 

Appendix I: Heroin Signature Program: 

HSP Methodology: 

HSP Limitations: 

HSP Opportunities for Improvements: 

Appendix II: Domestic Monitor Program: 

DMP Limitations: 

DMP Opportunities for Improvements: 

Appendix III: Comments from the Drug Enforcement Administration: 

Tables: 

Table 1: Source and Selection for HSP Heroin: 

Table 2: U.S. Customs Service Heroin Seizures (by line items): 

Table 3: U.S. Customs Service Heroin Seizures Weighing at Least
100 grams, Fiscal Years 1998-2000 (by line items): 

Table 4: Geographic Source and Percentage of Seized Heroin,
Calendar Year 1999: 

Table 5: Stratified HSP Sample Design: 

Table 6: By Metropolitan Area, the Number of Exhibits from Each
Geographic Source, Calendar Year 1999: 

Figure: 

Figure 1: DEA Case/Seizure/Exhibit: 

Abbreviations: 

DAWN: Drug Abuse Warning Network: 

DEA: Drug Enforcement Administration: 

DMP: Domestic Monitor Program: 

FBI: Federal Bureau of Investigation: 

HSP: Heroin Signature Program: 

MOU: Memorandum of Understanding: 

ONDCP: Office of National Drug Control Policy: 

SEACATS: Seized Assets and Case Tracking: 

STRL: Special Testing and Research Laboratory: 

TECS: Treasury's Enforcement Communications System: 

[End of section] 

United States General Accounting Office: 
Washington, DC 20548: 

March 29, 2002: 

The Honorable Charles E. Grassley: 
Co-Chairman, Caucus on International Narcotics Control: 
United States Senate: 

Dear Senator Grassley: 

The Drug Enforcement Administration (DEA) administers two programs, 
the Heroin Signature Program (HSP) and the Domestic Monitor Program 
(DMP), that serve as indicators for assessing trends in the geographic 
source of heroin supplied to the United States. These programs produce 
data on the geographic source of heroin through a series of chemical 
analyses and are the only programs of their kind in the United States. 
The HSP reports the geographic source of heroin seized at ports-of-
entry (primarily by the U.S. Customs Service) and other locations, as 
well as wholesale level purity. The DMP reports the geographic source 
of heroin purchased undercover in 23 U.S. metropolitan areas, as well 
as retail level heroin purity and price. This report does not focus on 
purity and price. 

This report responds to your request that we review how DEA captures 
and reports the data for the HSP and DMP and that we provide, if 
appropriate, possible alternative approaches for DEA to consider to 
improve the HSP and DMP data.[Footnote 1] Specifically, this report 
discusses: 

* the purpose of the HSP and DMP; 

* how federal law enforcement uses the data generated by the HSP and 
DMP; 

* whether the quantity of heroin seized at ports-of-entry by Customs, 
but not sent to DEA for testing, is sufficient to make a difference in 
the results reported by DEA; and; 

* whether the HSP and DMP data could be improved. 

To address these areas, we met with officials from DEA, Customs, and 
the Office of National Drug Control Policy (ONDCP) concerning the 
purpose and operations of the HSP and DMP and how federal law 
enforcement uses the data generated by the programs. We obtained and 
analyzed data from Customs to determine the quantity of heroin that is 
seized at ports-of-entry by Customs, but not sent to DEA for testing. 
To determine if improvements could be made in the HSP and DMP data, we 
met with DEA officials and reviewed the methodology used by DEA in its 
design and implementation of the programs. 

Results in Brief: 

The HSP and DMP produce data for detecting trends in the geographic 
source of the heroin that is found in the United States.[Footnote 2] 
DEA officials stressed that the purpose of these data is not to 
provide overall estimates about the geographic source of heroin. The 
HSP data are intended to provide law enforcement with a "snapshot" of 
where heroin at the wholesale level originates, but only for the 
heroin that is tested; the DMP data are intended to provide law 
enforcement with a "snapshot" of where heroin at the retail level, in 
certain metropolitan areas, originates, but only for the heroin that 
is tested.[Footnote 3] 

According to DEA officials, federal law enforcement used the data 
generated by the HSP and DMP for intelligence purposes and as a 
management tool. The data are used to develop intelligence and 
investigative reports to inform the DEA and other federal law 
enforcement agencies about trends in heroin trafficking. According to 
DEA, federal law enforcement also used the HSP and DMP data as a 
management tool to make adjustments in enforcement activities. For 
example, changes in HSP and DMP data, in conjunction with data from 
other sources, could influence the allocation of federal law 
enforcement resources from one location to another. DEA cited the 
emergence of heroin from South America as an example of how the data 
are used. In 1991, intelligence reports indicated that heroin was 
entering the United States from South America and that Southwest Asian 
heroin producers had taught Colombians their methods of processing 
opium into heroin. DEA subsequently identified, through chemical 
analyses and this other information, that South America was a new 
supplier of heroin into the United States. 

The quantity of heroin seized at ports-of-entry by Customs but not 
sent to DEA for testing may be sufficient to make a difference in the 
results reported by DEA. According to DEA officials, all ports-of-
entry seizures forwarded to DEA by Customs are tested by DEA for 
geographic source. However, DEA and Customs officials noted that, in 
accordance with the Memorandum of Understanding (MOU) between the two 
agencies, Customs is not required to send all heroin seizures to DEA. 
Our analysis of Customs' heroin seizure data revealed that, over 
fiscal years 1998-2000,[Footnote 4] 57 percent of the total weight of 
heroin seized by Customs was not sent to DEA. 

The HSP and DMP data could be improved. As currently designed and 
implemented, there are limitations in the usefulness of the HSP and 
DMP data, because they were based on nonrepresentative samples of 
their respective populations. While DEA said that it did not intend to 
produce any estimates from the HSP and DMP data, our analysis showed 
that with some modifications to its methodology, DEA could produce 
estimates. These estimates would provide a stronger basis for law 
enforcement decision-making. With modifications to the HSP 
methodology, estimates could be made about the geographic source of 
all seized wholesale heroin that is sent to DEA for testing. With 
modifications to the DMP methodology, estimates could be made about 
the geographic source of retail level purchases within the 
metropolitan areas where they are made, and the estimates could 
possibly be combined across the 23 metropolitan areas. Therefore, we 
are recommending that the Attorney General direct the Administrator of 
DEA to (1) ensure that the HSP data are based on a probability sample 
so that all HSP exhibits have a known chance of selection, (2) revise 
the HSP methodology for reporting testing results to include 
procedures to adjust for the probability of exhibits being selected 
for the test sample, (3) take action to ensure that DMP purchases are 
made according to DEA guidelines, and (4) study the use of alternative 
data sources for the total number of retail heroin purchases in an 
area that could allow the DMP data to be combined across metropolitan 
areas. 

We are also recommending that the attorney general and the secretary 
of the treasury direct the administrator of DEA and commissioner of 
Customs, respectively, to enter into discussions to determine whether 
additional seized heroin should be forwarded to DEA by Customs. 

We provided DEA, Customs and ONDCP with a draft of this report. 
Written comments from DEA are discussed in our Agency Comments section 
on pages 17-18. 

Each heroin-producing region has a unique production process,[Footnote 
5] or signature, which generally can be determined through chemical 
analyses. In the HSP, seized or purchased substances are forwarded to 
one of DEA's regional laboratories,[Footnote 6] which confirms whether 
the substance is heroin. If the substance is confirmed to be heroin, 
the laboratory is responsible for preparing a written report for 
judicial purposes and, in certain circumstances, providing a sample to 
DEA's Special Testing and Research Laboratory (STRL) for signature 
analysis. STRL analyzes the heroin samples; in most instances, these 
analyses result in the identification of the heroin's geographic 
source. In the DMP, purchased substances are sent directly to STRL for 
analysis. 

The heroin that is selected for HSP testing is selected from either 
"cases" or "exhibits." Figure 1 illustrates a possible case that 
includes multiple seizures and exhibits. 

Figure 1: DEA Case/Seizure/Exhibit: 

[Refer to PDF for image: illustration] 

DEA Case #1906, opened July 2, 2001: 
Seizure #1: 9/17/01; 
Seizure #2: 9/18/01; 
Seizure #3: 9/19/01: 
- Exhibit 1: Desk; 
- Exhibit 2: Closet; 
- Exhibit 1: Coat Pocket. 

Source: GAO's analysis of DEA information. 

[End of figure] 

As shown in figure 1, a single case can include more than one seizure 
of heroin. For example, a single case would include more than one 
seizure if agents seized heroin from the same person (the same case), 
but on different dates. In turn, a single seizure might include more 
than one exhibit, if agents find heroin associated with the same 
person on the same date, but at multiple locations. For example, a 
seizure would include three exhibits if agents, on the same date, 
seize heroin from multiple locations such as the person's desk, 
closet, and coat pocket. 

DEA initiated the HSP in 1977. Heroin for the HSP is obtained from 
eight sources and selected for signature analysis as shown in table 1. 

Table 1: Source and Selection for HSP Heroin: 

Source: 1. Seizures from passengers, luggage, or cargo on flights that 
have originated outside the United States; 
Selected: A sample from each case. 

Source: 2. Seizures made at nonairport ports-of-entry; 
Selected: A sample from each case. 

Source: 3. Seizures from letters, packages, or freight shipped by the 
U.S. Postal Service or a commercial mail or freight-forwarding company 
and that originated outside the continental United States and were 
sent to a DEA laboratory for analysis; 
Selected: A sample from each case. 

Source: 4. Nonairport seizures in Hawaii, Alaska, and Puerto Rico; 
Selected: A sample from each case. 

Source: 5. Special requests from DEA; 
Selected: All are to be selected. 

Source: 6. FBI seizures that have been submitted directly to a DEA 
laboratory for analysis; 
Selected: One exhibit from each case. 

Source: 7. Seizures made by the Washington, D.C., Metropolitan Police 
Department; 
Selected: A random sample of exhibits, determined through the use of 
random numbers provided by DEA to its regional laboratories every 6 
months. 

Source: 8. DEA seizures (includes seizures from flights and mail that 
originate inside the United States and Federal Bureau of Investigation 
seizures submitted through a DEA field office); 
Selected: A random sample of exhibits, determined through the use of 
random numbers provided by DEA to its regional laboratories every 6 
months. 

Source: DEA. 

[End of table] 

DEA initiated the DMP in its New York Field Division in 1979. The 
program has expanded to include 23 metropolitan areas. The DMP was 
originally designed to enable DEA to monitor the price and purity of 
retail-level heroin sold in the United States; it now also provides 
for the purchase of heroin for signature analysis. In the DMP, DEA 
provides funding for quarterly purchases by DEA field divisions, that 
may utilize cooperating sources to make retail-level purchases of 
heroin.[Footnote 7] Ten purchases are to be made in 22 of the 23 
metropolitan areas, each quarter; in New York City, 20 purchases are 
to be made in each quarter.[Footnote 8] 

DEA guidelines provide that a certain number of DMP purchases be made 
each quarter, throughout the 3 months of each quarter, and in various 
locations in the metropolitan areas. According to the DEA guidelines, 
it would seldom be necessary to make more than one purchase in any one 
location, per day. The most important requirement is that exhibits 
should be purchased from locations within the metropolitan areas that 
are dissimilar enough to ensure that they come from different 
suppliers. Each purchase should weigh at least 1 gram net, including 
diluents and adulterants, to ensure that there is a sufficient amount 
of pure heroin available to perform a signature analysis. 

According to DEA, the average time necessary to complete the signature 
analysis of a heroin sample is about 4 hours, with an associated cost 
of about $375 per sample. DEA indicated that the STRL performs 
signature analyses of 3,000 heroin samples annually, for a total 
annual STRL cost of about $1.13 million. DEA provides its field 
divisions with a total of $200,000 annually for the DMP purchases. 

DEA prepares annual reports on the HSP and DMP data The HSP reports 
display data on geographic source by net weight on a national basis. 
The DMP reports display data on geographic source by the number of 
exhibits by metropolitan area. 

Scope and Methodology: 

To determine the purpose of the HSP and DMP and how they operate, we 
interviewed officials at DEA's Office of Intelligence, Forensic 
Sciences, and the STRL. We reviewed relevant policies, reports, and 
other documentation. 

To determine how federal law enforcement uses the data generated by 
the programs, we interviewed officials at DEA's Office of Intelligence 
and Office of Forensic Sciences and ONDCP. We also reviewed relevant 
documentation of the use made of the data, including documentation of 
instances in which changes have been made in federal law enforcement 
efforts as a result of the data. 

To determine if the heroin seized at ports-of-entry, but not tested by 
DEA, is of sufficient quantity to make a difference in the results 
reported by DEA, we interviewed officials at DEA's Office of 
Intelligence, Office of Forensic Sciences, and the STRL, as well as 
Custom's Smuggling Investigations Division and Office of Intelligence. 
We also obtained and analyzed data from Customs regarding seized 
heroin in fiscal years 1998-2000. [Footnote 9] These data were derived 
from the Department of the Treasury's Enforcement Communications 
System (TECS), Seized Assets and Case Tracking (SEACATS) subsystem. We 
did not verify the accuracy of these data. The data included the date 
and location of the seizure,[Footnote 10] the total weight of the 
seizure (less the weight of any packaging or container), and the 
disposition of the heroin. According to Customs, a seizure is recorded 
in the system when contraband is discovered and physical custody is 
taken. Under Customs' policy, seizures that involve taking heroin from 
more than one place, for example, from an individual's pocket and from 
his suitcase, are counted as one seizure but entered into the system 
as two "line items." We were provided data by line items. Each line 
item from the same seizure equates to a DEA exhibit. 

To determine if the sample-based HSP and DMP data could be improved, 
we interviewed officials at DEA's Office of Intelligence and Office of 
Forensic Sciences. We reviewed sample design and sample selection 
methodology and the formulas and methodology used to develop data on 
the geographic source of heroin. We obtained and reviewed HSP and DMP 
data files for calendar years 1999 and 2000. We reviewed earlier 
reports, analyzed current methodology, and how DEA reports and caveats 
the figures. 

In performing our work, we did not talk with officials from all 
federal law enforcement agencies that may make use of the programs' 
data. We performed our work from May 2001 to February 2002, in 
accordance with generally accepted government auditing standards. We 
requested comments from DEA, Customs, and ONDCP. Comments from DEA are 
summarized at the end of this report and contained in appendix III. 

Purpose of the HSP and DMP Is To Produce Data That Detect Trends in 
Heroin Sources: 

According to DEA officials, the HSP and DMP produce data for detecting 
trends in the geographic source of heroin supplied to the United 
States. Officials stressed that the purpose of these data is not to 
provide overall estimates of where all heroin supplied to the United 
States originates. The HSP data are intended to provide law 
enforcement with a "snapshot" of where heroin at the wholesale level 
originates. The DMP data are intended to provide law enforcement with 
a snapshot of where heroin at the retail level, in certain 
metropolitan areas, originates. Officials explained that they believe 
that, over time, the snapshots begin to tell a story about what is 
happening with drug trafficking patterns. When this happens, officials 
can make their decisions, in conjunction with other investigative and 
intelligence data. 

Officials also stressed that direct comparisons should not be made 
between the geographic source data from the HSP and DMP. For example, 
the wholesale heroin seized in one market (HSP seizures) may not be 
intended for retail-level sale (DMP purchases) in the same market. In 
addition, comparisons should not be made between the HSP data and DMP 
data because the HSP data reflect law enforcement investigative 
priorities and techniques, in terms of where and how seizures are 
made, as well as the difficulties associated with the various 
concealment techniques used by smugglers. In addition, large quantity 
seizures of heroin from one geographic source area may boost that 
geographic source area's representation in the HSP data. This may be 
especially applicable to heroin from Southeast and Southwest Asia that 
has been traditionally smuggled in large, multikilogram quantities.
The officials also noted that these same factors could influence year-
to-year fluctuations in the proportion of heroin from each geographic 
source area. For example, law enforcement priorities and smuggler 
concealment techniques are reflected in the numerous small-quantity 
heroin seizures from Colombian air couriers. 

Federal Law Enforcement Used the HSP and DMP Data for Intelligence 
Purposes and Management: 

According to DEA officials, the HSP and DMP data are used for 
intelligence purposes and as a management tool by federal law 
enforcement. Data drawn from a variety of sources, including the HSP 
and DMP, are used to develop a comprehensive picture of heroin 
trafficking in the United States.[Footnote 11] 

For example, HSP and DMP data are frequently included in DEA 
intelligence and investigative reports to corroborate heroin 
trafficking trends in the United States and to inform DEA and other 
federal law enforcement agencies about heroin trafficking. In 
addition, ONDCP officials noted that the data are used as a 
confirmation of data from other sources, such as opium production and 
cultivation estimates provided by the Central Intelligence Agency. 

ONDCP officials noted that it uses data from the HSP and DMP for drug-
flow modeling and that the data,[Footnote 12] which are viewed as one 
of the better heroin market indicators, are key components of ONDCP's 
data analysis efforts. ONDCP officials also said that data from the 
HSP and DMP are used for such purposes as testimony before the 
Congress and in ONDCP's annual National Drug Control Strategy. 

According to DEA, federal law enforcement also uses the HSP and DMP 
data as management tools to make adjustments in enforcement 
activities. Changes in HSP and DMP data could alert management to 
changing trafficking patterns. DEA cited the emergence of heroin from 
South America as an example of how the HSP and DMP geographic source 
data have been used in law enforcement intelligence and management. 
Southeast Asian heroin dominated the market on the East Coast until 
1991; Southwest Asian heroin was also readily available. In 1991, a 
high-purity heroin entered the eastern U.S. market and was initially 
identified by DEA as high-purity but atypical Southwest Asian heroin. 
Intelligence reports indicated that heroin was entering the United 
States from South America. Also, reportedly Southwest Asian heroin 
producers had taught Colombians their methods of processing opium into 
heroin. DEA's subsequent determination of a signature unique to South 
America confirmed this intelligence and, as a result, South America 
was identified as a new supplier of heroin into the United States. 

Officials said that the data are also used to monitor the success of 
various initiatives. For example, a decrease in the amount of tested 
heroin that is found to have originated in a particular geographic 
source area can be an indicator that law enforcement initiatives 
against that particular area have been successful. 

Quantity of Heroin Seized at Ports-of-Entry by Customs but not Sent to 
DEA for Testing May Be Sufficient To Make a Difference in Results 
Reported by DEA: 

According to DEA officials, all ports-of-entry seizures sent to DEA by 
Customs are tested by DEA for geographic source. However, for several 
reasons, Customs is not required to send all seized heroin to DEA. DEA 
and Customs officials noted that Customs is not required to send to 
DEA abandoned heroin or heroin that is turned over to state or local 
officials for prosecution. "Abandoned heroin" is heroin that cannot be 
connected to any individual or defendant. For example, an unmanifested 
kilogram of heroin found in an aircraft cargo hold is considered 
abandoned. Under its MOU with DEA, Customs is not required to send 
abandoned heroin to DEA. Instead, it is to be reported on a Customs 
Search, Arrest, Seizure report (CF-151) and turned over to the Customs 
seized property custodian for destruction. Also, under the MOU, 
Customs does not submit for testing heroin that does not meet local 
U.S. attorney prosecution guidelines.[Footnote 13] Instead, Customs 
officials explained that in most instances, this heroin is to be 
turned over to state or local officials for prosecution. According to 
Customs officials, there are also instances in which the weight of the 
seized heroin is so low that it is not turned over to state or local 
officials for prosecution. In these instances, it is to be destroyed. 

Our analysis of Customs' heroin seizure data revealed that, for fiscal 
years 1998-2000, 57 percent of the total weight of the heroin seized 
by Customs was not sent to DEA. Data on the number and weight of 
Customs heroin seizures,[Footnote 14] including the number and weight 
of heroin seizures not sent to DEA for testing, are displayed in table 
2. 

Table 2: U.S. Customs Service Heroin Seizures (by line items): 

Disposition[A]: Forwarded to DEA[D]; 
Number of line items: 1998: 244; 
Number of line items: 1999: 353; 
Number of line items: 2000: 503; 
Number of line items: Total: 1,100; 
Weight of seizures[B]: 1998: 320.1; 
Weight of seizures[B]: 1999: 425.9; 
Weight of seizures[B]: 2000: 677.1; 
Weight of seizures[B]: Total: 1,423.1. 

Disposition[A]: Not forwarded to DEA; 
Number of line items: 1998: 1,078; 
Number of line items: 1999: 708; 
Number of line items: 2000: 533; 
Number of line items: Total: 2,319; 
Weight of seizures[B]: 1998: 932.5; 
Weight of seizures[B]: 1999: 459.2; 
Weight of seizures[B]: 2000: 496.7; 
Weight of seizures[B]: Total: 1,888.4. 

Disposition[A]: Destroyed; 
Number of line items: 1998: 794; 
Number of line items: 1999: 380; 
Number of line items: 2000: 263; 
Number of line items: Total: 1,437; 
Weight of seizures[B]: 1998: 769.6; 
Weight of seizures[B]: 1999: 326.0; 
Weight of seizures[B]: 2000: 251.2; 
Weight of seizures[B]: Total: 1,346.8. 

Disposition[A]: Turned over to state or local officials or another 
federal agency; 
Number of line items: 1998: 223; 
Number of line items: 1999: 242; 
Number of line items: 2000: 164; 
Number of line items: Total: 629; 
Weight of seizures[B]: 1998: 81.9; 
Weight of seizures[B]: 1999: 89.0; 
Weight of seizures[B]: 2000: 136.1; 
Weight of seizures[B]: Total: 307.1. 

Disposition[A]: Abandoned and turned over to state or local officials 
or another federal agency; 
Number of line items: 1998: 8; 
Number of line items: 1999: 37; 
Number of line items: 2000: 5; 
Number of line items: Total: 50; 
Weight of seizures[B]: 1998: 3.0; 
Weight of seizures[B]: 1999: 9.8; 
Weight of seizures[B]: 2000: 13.5; 
Weight of seizures[B]: Total: 26.3. 

Disposition[A]: Abandoned and destroyed; 
Number of line items: 1998: 15; 
Number of line items: 1999: 17; 
Number of line items: 2000: 18; 
Number of line items: Total: 50; 
Weight of seizures[B]: 1998: 3.0; 
Weight of seizures[B]: 1999: 0.6; 
Weight of seizures[B]: 2000: 2.2; 
Weight of seizures[B]: Total: 5.8. 

Disposition[A]: Abandoned and pending final disposition; 
Number of line items: 1998: 0; 
Number of line items: 1999: 2; 
Number of line items: 2000: 0; 
Number of line items: Total: 2; 
Weight of seizures[B]: 1998: 0; 
Weight of seizures[B]: 1999: 3.8; 
Weight of seizures[B]: 2000: 0; 
Weight of seizures[B]: Total: 3.8. 

Disposition[A]: Not abandoned and pending final disposition; 
Number of line items: 1998: 38; 
Number of line items: 1999: 30; 
Number of line items: 2000: 83; 
Number of line items: Total: 151; 
Weight of seizures[B]: 1998: 75.0; 
Weight of seizures[B]: 1999: 30.0; 
Weight of seizures[B]: 2000: 93.7; 
Weight of seizures[B]: Total: 198.6. 

Disposition[A]: Total; 
Number of line items: 1998: 1,322; 
Number of line items: 1999: 1,061; 
Number of line items: 2000: 1,036; 
Number of line items: Total: 3,419; 
Weight of seizures[B]: 1998: 1,252.6; 
Weight of seizures[B]: 1999: 885.1; 
Weight of seizures[B]: 2000: 1,173.8; 
Weight of seizures[B]: Total: 3,311.5. 

[A] Customs seizure disposition categories. 

[B] Rounded to the nearest tenth of a kilogram. 

[C] Totals may not equal the individual entries due to rounding. 

[D] Includes 36 line items, totaling 49.9 kilograms, in which heroin 
was abandoned but still forwarded to DEA. 

Source: GAO's analysis of Customs' data. 

[End of table] 

According to DEA officials, it is not crucial to test the relatively 
smaller seizures. Table 3 displays amounts seized by Customs over a 3-
year period. Of the total number of line items that were not forwarded 
to DEA, about 72 percent exceeded 100 grams in weight; these line 
items accounted for over 99 percent of the total weight of all line 
items not forwarded to DEA for testing. 

Table 3: U.S. Customs Service Heroin Seizures Weighing at Least 100 
grams, Fiscal Years 1998-2000 (by line items): 

Disposition[A]: Forwarded to DEA[C]; 
Total number of line items: 1,100; 
Total weight of line items: 1,423.1; 
Number of line items weighing 100 grams or more: 965; 
Weight of line items weighing 100 grams or more[B]: 1,418.6. 

Disposition[A]: Not forwarded to DEA; 
Total number of line items: 2,319; 
Total weight of line items: 1,888.4; 
Number of line items weighing 100 grams or more: 1,675; 
Weight of line items weighing 100 grams or more[B]: 1,876.0. 

Disposition[A]: Destroyed; 
Total number of line items: 1,437; 
Total weight of line items: 1,346.8; 
Number of line items weighing 100 grams or more: 1,193; 
Weight of line items weighing 100 grams or more[B]: 1,341.3. 

Disposition[A]: Turned over to state or local officials or another 
federal agency; 
Total number of line items: 629; 
Total weight of line items: 307.1; 
Number of line items weighing 100 grams or more: 320; 
Weight of line items weighing 100 grams or more[B]: 302.0. 

Disposition[A]: Abandoned and turned over to state or local officials 
or another federal agency; 
Total number of line items: 50; 
Total weight of line items: 26.3; 
Number of line items weighing 100 grams or more: 15; 
Weight of line items weighing 100 grams or more[B]: 25.8. 

Disposition[A]: Abandoned and destroyed; 
Total number of line items: 50; 
Total weight of line items: 5.8; 
Number of line items weighing 100 grams or more: 12; 
Weight of line items weighing 100 grams or more[B]: 5.3. 

Disposition[A]: Abandoned and pending final disposition; 
Total number of line items: 2; 
Total weight of line items: 3.8; 
Number of line items weighing 100 grams or more: 2; 
Weight of line items weighing 100 grams or more[B]: 3.8. 

Disposition[A]: Not abandoned and pending final disposition; 
Total number of line items: 151; 
Total weight of line items: 198.6; 
Number of line items weighing 100 grams or more: 133; 
Weight of line items weighing 100 grams or more[B]: 198.0. 

Disposition[A]: Total; 
Total number of line items: 3,419; 
Total weight of line items: 3,311.5; 
Number of line items weighing 100 grams or more: 2,640; 
Weight of line items weighing 100 grams or more[B]: 3,294.7. 

Note: Rounded to the nearest tenth of a kilogram. 

[A] Customs seizure disposition categories. 

[B] Totals may not equal the individual entries due to rounding. 

[C] Includes 36 line items, totaling 49.9 kilograms, in which heroin 
was abandoned but still forwarded to DEA. The number of line items 
weighing 100 grams or more was 30, with a total weight of 49.7 
kilograms. 

Source: GAO's analysis of Customs' data. 

[End of table] 

The HSP and DMP Data Could Be Improved	The HSP and DMP data on the 
geographic source of heroin could be improved. The HSP data have 
limitations; appendix I of this report describes the current HSP 
selection methodology, its limitations, and opportunities for 
improvements. The DMP data also have limitations; appendix II 
describes the current DMP selection methodology, its limitations, and 
opportunities for improvements. 

HSP Limitations and Opportunities for Improvement: 

According to DEA, it does not intend that the HSP data be used either 
to produce estimates as to where all wholesale heroin supplied to the 
United States originates or as to where all wholesale heroin seized in 
the United States and forwarded to DEA for testing originates. 
[Footnote 15 Our analysis showed that the data, with some 
modifications to DEA's methodology, could be used to produce estimates 
about the geographic source of all wholesale heroin seized in the 
United States and forwarded to DEA for testing. To make these 
estimates, the DEA data must be based on a probability sample. 
[Footnote 16] The HSP data, however, are not based on a probability 
sample because not all exhibits have a known chance of being selected 
for testing. Consequently, there is no way to tell how the HSP sample 
relates to the universe of all heroin seized in the United States and 
forwarded to DEA for testing. Our analysis revealed an additional 
problem. Even if the HSP data were based on a probability sample, 
DEA's current methodology for reporting testing results does not 
include procedures to adjust for the probability of exhibits being 
selected for the test sample. Thus, DEA's current methodology for 
reporting HSP testing results would not produce valid estimates even 
if a probability sample were used. 

With these limitations in mind, opportunities exist for making 
improvements that would allow DEA to make valid estimates about the 
geographic source of all seized wholesale heroin that is sent to DEA 
for testing. These improvements could include modification of sampling 
procedures and record keeping to ensure that the HSP data are based on 
a probability sample and revision of its methodology for reporting 
testing results to include procedures to adjust for the probability of 
exhibits being selected for the test sample. (See appendix I of this 
report for detailed information.) 

DMP Limitations and Opportunities for Improvement: 

According to DEA, it does not intend that the DMP data be used to 
either produce estimates about retail heroin markets outside the 23 
metropolitan areas covered by the DMP or about the geographic source 
of all retail level purchases within the 23 metropolitan areas. Our 
analysis found that the DMP data, with some modifications, could 
produce estimates about the geographic source of retail level 
purchases within the 23 metropolitan areas covered by the DMP, and the 
DMP estimates could possibly be combined across the 23 metropolitan 
areas. These estimates cannot be made now because of limitations in 
the DMP sampling and estimation procedures. 

The DMP data are limited for two reasons. First, our analysis showed 
that the purchases made by DEA agents were not made in accordance with 
the DEA guidelines that indicate that a certain number of purchases 
should be made each quarter and that the purchases should be made 
throughout the 3 months of each quarter. DEA officials told us that 
they perform periodic reviews to determine compliance with the 
guidelines. However, our analysis found that the required number of 
purchases was not always made and that they tended to occur in certain 
periods of each quarter and on certain days of the week. Second, the 
DMP contains no information on the size of the market in each of the 
metropolitan areas. For example, City A could have 10 out of 10,000 
purchases tested by the DMP, but in City B there may be relatively few 
heroin users and the quarterly DMP sample could be 10 out of 1,000 
purchases. The size of the markets is not known. As a result, DMP data 
reflect only DMP purchases. 

With these limitations in mind, there are opportunities for making 
improvements that would allow DEA to produce estimates about the 
geographic source of heroin purchased in the 23 metropolitan areas and 
to combine them across the metropolitan areas. These improvements 
could include taking action to ensure that DEA agents follow DEA 
guidelines when making the DMP purchases and utilizing alternative 
data sources for the total number of retail heroin purchases in an 
area, such as the number of hospital emergency room admissions related 
to heroin.[Footnote 17] (See appendix II of this report for detailed 
information.) 

Conclusions: 

The HSP and DMP data are used for important purposes by federal law 
enforcement. For instance, DEA uses the data as an indicator of the 
geographic source of heroin found in the United States, to measure the 
success of law enforcement initiatives, and to corroborate trends in 
heroin trafficking over time. ONDCP uses the data for drug-flow 
modeling, in testimony before the Congress, and in its annual National 
Drug Control Strategy. We recognize the challenges and difficulties of 
the HSP and DMP programs. However, current HSP and DMP data could be 
providing misleading information about the geographic source of heroin 
found in the United States because of sampling and statistical 
analysis problems. 

Our analysis showed that problems with sampling and statistical 
analysis in the HSP might lead to misleading information about the 
geographic source of heroin in the wholesale market. HSP data are 
derived from a sample of seized heroin. However, our analysis showed 
that DEA did not obtain a large proportion of the heroin seized by 
Customs, the seized heroin that was analyzed was not obtained from a 
random probability sample, and that the reporting methodology did not 
include procedures to adjust for the probability of exhibits being 
selected for the sample. If a snapshot of wholesale heroin geographic 
source is based on HSP data, then this snapshot may be misleading 
because accurate information about seized heroin cannot be developed 
from the flawed sample. 

Our analysis also showed that problems with sampling and statistical 
analysis in the DMP might lead to misleading information about the 
geographic source of heroin in the retail market also. DMP data are to 
be collected from random undercover purchases made in select 
metropolitan areas. However, our analysis of DMP data showed that 
these undercover purchases were not spread randomly over the year, as 
provided by DEA guidelines, but instead were concentrated in certain 
time periods of the quarter. Therefore, if the retail market 
characteristics vary over time or vary between midweek and weekend, 
the data could produce results that would be different from those that 
might have been obtained had these guidelines been followed. 
Furthermore, without knowledge of the size of the retail markets in 
the sampled metropolitan areas there are difficulties in combining DMP 
results across those metropolitan areas. 

The quality/validity of data derived from these two programs could be 
improved by more careful sampling, adhering to existing DEA 
guidelines, and enhancing data analysis. 

Recommendations: 

To help improve the HSP and DMP data on the geographic source of 
heroin, we recommend that the attorney general direct the 
administrator of DEA to: 

* ensure that the HSP data are based on a probability sample so that 
all HSP exhibits have a known chance of selection, 

* revise the HSP methodology for reporting testing results to include 
procedures to adjust for the probability of exhibits being selected 
for the test sample, 

* take action to ensure that DMP purchases are made according to DEA 
guidelines, and, 

* study the utilization of alternative data sources for an estimate of 
the total number of retail heroin purchases in an area that could 
allow the DMP data to be combined across metropolitan areas. 

To enhance the usefulness of HSP data, we recommend that the attorney 
general and the secretary of the treasury direct the administrator of 
DEA and commissioner of Customs, respectively, to enter into 
discussions to determine whether additional seized heroin should be 
forwarded to DEA by Customs. 

Agency Comments: 

We requested comments on a draft of this report from DEA, Customs, and 
ONDCP. In its comments, DEA indicated that it strongly disagreed with 
two of our recommendations and concurred with the remaining three. 
(See appendix III.) 

DEA disagreed with our recommendations that it (1) ensure the HSP data 
are based on a probability sample and (2) revise the HSP methodology 
for reporting testing results. DEA said that the HSP should remain a 
program whose data are based solely on the results of signature 
analysis. This seems to imply that the application of statistical 
analysis to signature testing results would yield unscientific data. 
We disagree. Without the use of data based on a probability sample, it 
is impossible to know how to interpret the HSP data. In addition, DEA 
seems to imply that we want the signature of untested exhibits to be 
imputed based on the results of actual analyses of tested exhibits. 
This is incorrect. We recommended the use of a probability sample and 
standard weighting procedures that would allow the estimation of the 
geographic source of all seized heroin. DEA also said that it should 
implement a stratified sample similar to the one we proposed to ensure 
that a significant portion of the total weight of heroin seized by DEA 
is sampled. However, DEA did not want to use the stratified sample to 
produce estimates with the resulting data. We believe that by 
implementing a stratified probability sample, DEA could produce 
estimates of the seized heroin, which would improve the overall data. 

Furthermore, DEA suggested expanding the number of DEA and Customs 
exhibits submitted for analysis. However, this method would increase 
reliability only if a probability sample were used. Expanding the 
number of exhibits submitted without using a probability sample limits 
the interpretation of the data to the tested exhibits alone. Finally, 
DEA said that the estimation model proposed in our report was 
simplistic. We provided this straightforward model only as an example 
and strongly endorse any attempt DEA might make to enhance the 
suggested model. DEA concurred with the remainder of our 
recommendations, that it take action to ensure that DMP purchases are 
made according to DMP guidelines; study the utilization of alternative 
data sources for an estimate of the total number of retail heroin 
purchases in an area; and that the attorney general and the secretary 
of the treasury direct DEA and Customs to enter into discussions to 
determine whether additional seized heroin should be forwarded to DEA 
by Customs. 

DEA concurred with our recommendation that it study the utilization of 
alternative data sources for the DMP. DEA also commented that data 
sources do not exist that measure either the number of retail heroin 
purchases or the prevalence of heroin abuse in a metropolitan area 
While we recognize that these data sources may not exist, we suggested 
that the DAWN data could provide a useful surrogate measure; without 
such a measure, the DMP data could be misleading. 

DEA concurred with our recommendation that DEA and Customs discuss 
whether additional seized heroin should be forwarded to DEA. However, 
DEA incorrectly characterized our recommendation by saying we 
recommended they work to ensure that more seizures are sampled. We did 
not make this recommendation. We recommended only that DEA and Customs 
discuss whether additional heroin should be forwarded. DEA officials 
also provided additional technical comments, which we have 
incorporated where appropriate. 

Customs and ONDCP said that they had no comments on the draft report. 

As agreed with your office, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 30 days 
from its issue date. At that time, we will send copies of this report 
to the cochairman, Senate Caucus on International Narcotics Control; 
the attorney general; the secretary of the treasury; the administrator 
of DEA; the commissioner of Customs; and the director, Office of 
National Drug Control Policy. We will also make copies available to 
others upon request. This report will also be available on GAO's home 
page at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please call 
me or Weldon McPhail at (202) 512-8777. Other key contributors to this 
report were Doris Page, Mark Ramage, Anthony Patterson, David 
Alexander, and Geoffrey Hamilton. 

Sincerely yours, 

Signed by: 

Laurie E. Ekstrand: 
Director, Justice Issues: 

[End of section] 

Appendix I: Heroin Signature Program: 

The Heroin Signature Program (HSP) sample was selected using sampling 
procedures for two categories of eligible[Footnote 18] exhibits. The 
first category included exhibits from seizures made by the Drug 
Enforcement Administration (DEA) and the Washington D.C., Metropolitan 
Police Department. This sample is referred to as the "DEA exhibit 
sample." The second category was comprised of all other exhibits, 
including those seizures submitted to DEA by the Federal Bureau of 
Investigation (FBI), and those submitted to DEA by the U.S. Customs 
Service from passengers, luggage, or cargo on flights that originated 
outside of the United States. This sample is referred to as the "POE 
exhibit sample." (See table 1 of this report for additional details on 
the source and selection of HSP heroin.) 

HSP Methodology: 

DEA calculated the results of the HSP signature analyses in the 
following manner: 

* First, the total weight of heroin from sampled exhibits from each 
geographic source was computed.[Footnote 19] 
	
* Second, the total weight of heroin from sampled exhibits from all 
geographic sources was combined. 

* Last, the total weight of heroin from each geographic source was 
divided by the total weight of heroin for all areas. The result was 
expressed as a percentage. 

We analyzed calendar year 1999 and 2000 data in our review of the HSP. 
Because 1999 was the most recent year for which finalized reports were 
available, some analyses are based solely on the 1999 HSP data. 
According to DEA, there were no methodological changes from 1999 to 
2000. 

HSP analyses results for calendar year 1999 are displayed in table 4. 

Table 4: Geographic Source and Percentage of Seized Heroin, Calendar 
Year 1999: 

Geographic source: South America; 
Percentage of seized heroin: 60%. 

Geographic source: Mexico; 
Percentage of seized heroin: 24%. 

Geographic source: Southeast Asia; 
Percentage of seized heroin: 10%. 

Geographic source: Southwest Asia; 
Percentage of seized heroin: 6%. 

Source: DEA. 

[End of table] 

HSP Limitations	Our analysis of the HSP methodology found that the HSP 
data, with modifications, could produce valid estimates about the 
geographic source of all wholesale heroin seized in the United States 
and forwarded to DEA for testing. These estimates could not currently 
be made because not all exhibits had a known chance of being selected 
for testing; therefore, the HSP data were not based on a probability 
sample. In addition, our analysis revealed that, even if the data were 
based on a probability sample, DEA's current methodology that is used 
to report testing results would not produce valid estimates, because 
it does not include procedures to adjust for the probability of 
exhibits being selected for the test sample. 

HSP Data Not Based on a	Probability Sample: 

Our analysis showed that, for the following three reasons, not all 
exhibits had a known positive chance of being selected for testing. 

1. The procedure for selecting the POE exhibit sample resulted in the 
selection of heavier exhibits. DEA laboratory personnel were 
responsible for identifying POE sample exhibits for testing and, 
according to DEA, selected exhibits generally tended to be the 
heaviest exhibit from a case. For example, if a POE seizure resulted 
in 3 exhibits weighing 10 gram, 15 grams, and 50 grams, it was likely 
that the 50-gram exhibit was tested. While not conclusive, the DEA 
exhibit sample also contained heavier than expected exhibits, 
suggesting that the heavier exhibits may generally have been selected 
for testing. Although only about 13 percent of the DEA exhibits were 
sampled in 1999, these sampled exhibits accounted for about 45 percent 
of the total weight of seized wholesale heroin sent to DEA for 
testing.[Footnote 20] 

2. Exhibits did not have a known chance of selection because it 
appears that DEA did not consistently follow its policy for selecting 
exhibits, for either the POE or the DEA exhibit samples.[Footnote 21] 
The policy requires that, except for special request exhibits, no more 
than one exhibit per case be chosen. However, based on our review of 
1999 and 2000 HSP data, this policy was apparently not implemented 
consistently. There were multiple exhibits for individual cases in the 
HSP sample for both 1999 and 2000. In 1999, about 9.5 percent and 8.4 
percent of the DEA and the POE sample exhibits, respectively, were 
from cases that had multiple exhibits in the sample. For 2000, 10.5 
percent and 3.4 percent of the DEA and the POE sample exhibits, 
respectively, were from cases that had multiple exhibits in the sample. 

3. Exhibits for the DEA exhibit sample also did not have a known 
chance of selection because DEA's sampling procedures are apparently 
not working as intended. Before the start of each 6-month sampling 
period, DEA produced a list of random numbers for the DEA exhibit 
sample. A separate list of random numbers was sent to each DEA 
regional laboratory. The random numbers were to contain approximately 
20 percent of the exhibits expected in the sampling period. However, 
our analysis showed that the actual percentage of exhibits sampled was 
13 percent for 1999 and 8 percent for 2000.[Footnote 22] 

DEA's Methodology Used to Report HSP Testing Results Did Not Include 
Procedures to Adjust for the Probability of Exhibits Being Selected 
for the Test Sample: 

If DEA developed a probability sample, it would still be unable to 
produce valid estimates because its current methodology for reporting 
HSP testing results does not include procedures to adjust for the 
probability of exhibits being selected for the test sample. In 
computing estimates using HSP data, DEA did not take into account that 
some exhibits had a low probability of selection and some had a high 
probability of selection. As a result, DEA produced only simple 
tabulations of sample data that could not be used to produce estimates 
about the geographic source of all seized wholesale heroin sent to DEA 
for testing. 

HSP Opportunities for Improvements: 

Opportunities exist for making improvements that would allow DEA to 
estimate the geographic source of all seized wholesale heroin that is 
sent to DEA for testing. These improvements could include (1) 
modification of sampling procedures and record keeping to ensure that 
the HSP data are based on a probability sample and (2) revision of its 
methodology for reporting testing results to include procedures to 
adjust for the probability of exhibits being selected for the test 
sample. If these improvements were made, it would also be possible to 
produce confidence intervals for estimates.[Footnote 23] 

Modification of Sampling Procedures to Ensure That HSP Data Are Based 
on a Probability Sample: 

HSP sampling procedures could be improved to ensure that all exhibits 
have a known chance of selection. For example, DEA could use a 
stratified sample in which exhibits are divided into different strata, 
or categories, and sample selections are made from each stratum. The 
heaviest exhibits and the exhibits DEA considers to have special 
intelligence importance could all be selected,[Footnote 24] and a 
portion of the remaining exhibits could also be chosen. Table 5 shows 
this alternative sample design. 

Table 5: Stratified HSP Sample Design: 

Stratum number: 1. 
Description of exhibits: POE exhibits weighing at least y grams and 
those for which DEA makes a special request; 
Chance of selection: 100. 

Stratum number: 2. 
Description of exhibits: DEA exhibits weighing at least x grams and 
those for which DEA makes a special request; 
Chance of selection: 100. 

Stratum number: 3. 
Description of exhibits: POE exhibits weighing less than y grams and 
for which DEA does not make a special request; 
Chance of selection: K. 

Stratum number: 4. 
Description of exhibits: DEA exhibits weighing less than x grams and 
for which DEA does not make a special request; 
Chance of selection: H. 

Note: Values for x, y, h, and k could be chosen to achieve the desired 
sample sizes, and sampling errors and confidence intervals, and to 
take into account special requests made by DEA to meet intelligence 
needs. 

Source: GAO's analysis. 

[End of table] 

This suggested design would result in a known chance of selection for 
all heroin exhibits. All exhibits in strata 1 and 2 would be selected 
Exhibits in strata 3 and 4 would have a less than 100 percent chance 
of selection. For example, if k equals 5, then 5 percent of exhibits 
in stratum 3 would be selected. If h equals 20, then 20 percent of 
exhibits in stratum 4 would be selected. 

DEA should also draw the sample and centrally maintain sufficient 
records in such a way that the resulting sample selection could be 
verified. For example, 

* if exhibits are selected manually, with the use of a list of random 
numbers, the exhibits should first be numbered sequentially, before 
the random number list is used to identify sample exhibits; 

* after identifying the sample exhibits, DEA should ensure that 
sufficient information is maintained to identify each exhibit, 
indicate whether the exhibit was selected for the sample, and whether 
it was sent for signature analysis testing; and; 

* if an exhibit, that is ineligible for testing due to its low weight, 
were selected by the sampling procedure, it should be recorded as 
"insufficient for signature analysis." 

Revision of Current Methodology to Include Procedures to Adjust for 
the Probability of Exhibits Being Selected for the Test Sample: 

Several changes to DEA's methodology are possible that would include 
procedures to adjust for the probability of exhibits being selected 
for the test sample. For example, DEA could use statistical weights 
for the sample design to produce estimates about the geographic source 
of all seized wholesale heroin sent to DEA for testing. These 
statistical weights would be determined by calculating a value that is 
the inverse of an exhibit's chance of selection. For example, 
referring to the example following table 5, all exhibits in stratum 1 
would be selected and 5 percent of exhibits in stratum 3 would be 
selected. Stratum 1 sample exhibits would get a weighting factor of 
1/1=1 and stratum 3 sample exhibits would get a weighting factor of 
1/.05 = 20. 

DEA could also use supplemental data to improve the estimates. DEA 
could use data on the total weight of seized heroin sent to DEA for 
testing, by regional laboratory. This same quantity could be estimated 
from the HSP sample. The ratio of these two quantities could then be 
computed and used as a refinement to the statistical weights described 
above. For example, if one DEA regional laboratory received a total of 
210 kg of heroin, and the sample estimate of heroin for that regional 
laboratory was 200 kg, then the final statistical weight for sample 
data from that regional laboratory would be the initial statistical 
weight multiplied by 210/200=1.05. Using the weighting factor for 
stratum 3 (from above), the final statistical weight for stratum 3 
sample exhibits selected from that laboratory would be 20 x 1.05=21. 

Estimates of the percentage of seized heroin by geographic source area
would then be computed as follows: 

* Compute the total weighted sum of heroin in grams[Footnote 25] for 
each of six categories.[Footnote 26] The weighted sum would use the 
final statistical weighting factors described earlier.[Footnote 27] 
This would produce six sums, H1, ..., H6; 

* Compute the total over all six categories, H = H1 + ... + H6; 

* The ratio of each category to the total (converted to percentages) 
would then yield estimates of the percentages of seized wholesale 
heroin, sent to DEA for testing, by geographic region. For example, 
the percentage from geographic region i would be pi = 100(Hi/H). 

[End of section] 

Appendix II: Domestic Monitor Program: 

DEA produced tables using the Domestic Monitor Program (DMP) data. For 
example, one table displayed, by metropolitan area, the number of 
exhibits from each geographic source. Table 6 displays this 
information for calendar year 1999. 

Table 6: By Metropolitan Area, the Number of Exhibits from Each 
Geographic Source, Calendar Year 1999: 

Metropolitan area: Atlanta, Georgia; 
Southeast Asia: 9; 
Southwest Asia: 1; 
Mexico: 1; 
South America: 7; 
Unknown or insufficient: 7. 

Metropolitan area: Baltimore, Maryland; 
Southeast Asia: 2; 
Southwest Asia: 0; 
Mexico: 0; 
South America: 33; 
Unknown or insufficient: 4. 

Metropolitan area: Boston, Massachusetts; 
Southeast Asia: 0; 
Southwest Asia: 0; 
Mexico: 0; 
South America: 25; 	
Unknown or insufficient: 12. 

Metropolitan area: Chicago, Illinois; 
Southeast Asia: 6; 
Southwest Asia: 1; 
Mexico: 0; 
South America: 14; 
Unknown or insufficient: 18. 

Metropolitan area: Dallas, Texas; 
Southeast Asia: 1; 
Southwest Asia: 0; 
Mexico: 29; 
South America: 0; 
Unknown or insufficient: 6. 

Metropolitan area: Denver, Colorado; 
Southeast Asia: 0; 
Southwest Asia: 0; 
Mexico: 23; 
South America: 0; 
Unknown or insufficient: 5. 

Metropolitan area: Detroit, Michigan; 
Southeast Asia: 3; 
Southwest Asia: 4; 
Mexico: 0; 
South America: 22; 
Unknown or insufficient: 8. 

Metropolitan area: El Paso[A], Texas; 
Southeast Asia: 0; 
Southwest Asia: 0; 
Mexico: 6; 
South America: 0; 
Unknown or insufficient: 0. 

Metropolitan area: Houston, Texas; 
Southeast Asia: 0; 
Southwest Asia: 0; 
Mexico: 38; 
South America: 3; 
Unknown or insufficient: 8. 

Metropolitan area: Los Angeles, California; 
Southeast Asia: 0; 
Southwest Asia: 0; 
Mexico: 18; 
South America: 0; 
Unknown or insufficient: 7. 

Metropolitan area: Miami, Florida; 
Southeast Asia: 0; 
Southwest Asia: 0; 
Mexico: 4; 
South America: 18; 
Unknown or insufficient: 10. 

Metropolitan area: Newark, New Jersey; 
Southeast Asia: 1; 
Southwest Asia: 0; 
Mexico: 0; 
South America: 36; 
Unknown or insufficient: 7. 

Metropolitan area: New Orleans, Louisiana; 
Southeast Asia: 0; 
Southwest Asia: 0; 
Mexico: 0; 
South America: 14; 
Unknown or insufficient: 7. 

Metropolitan area: New York, New York; 
Southeast Asia: 0; 
Southwest Asia: 0; 
Mexico: 0; 
South America: 54; 
Unknown or insufficient: 4. 

Metropolitan area: Orlando, Florida; 
Southeast Asia: 0; 
Southwest Asia: 0; 
Mexico: 0; 
South America: 15; 
Unknown or insufficient: 4. 

Metropolitan area: Philadelphia, Pennsylvania; 
Southeast Asia: 0; 
Southwest Asia: 1; 
Mexico: 0; 
South America: 33; 
Unknown or insufficient: 5. 

Metropolitan area: Phoenix, Arizona; 
Southeast Asia: 0; 
Southwest Asia: 0; 
Mexico: 38; 
South America: 0; 
Unknown or insufficient: 2. 

Metropolitan area: San Diego, California; 
Southeast Asia: 0; 
Southwest Asia: 0; 
Mexico: 30v
South America: 0; 
Unknown or insufficient: 3. 

Metropolitan area: San Francisco, California; 
Southeast Asia: 0; 	
Southwest Asia: 0; 
Mexico: 31; 
South America: 0; 
Unknown or insufficient: 3. 

Metropolitan area: San Juan, Puerto Rico; 
Southeast Asia: 0; 
Southwest Asia: 0; 
Mexico: 0; 
South America: 24; 
Unknown or insufficient: 6. 

Metropolitan area: Seattle, Washington; 
Southeast Asia: 0; 
Southwest Asia: 0; 
Mexico: 37; 
South America: 0; 
Unknown or insufficient: 3. 

Metropolitan area: St. Louis, Missouri; 
Southeast Asia: 0; 
Southwest Asia: 0; 
Mexico: 33; 
South America: 0; 
Unknown or insufficient: 6. 

Metropolitan area: Washington, D.C. 
Southeast Asia: 4; 
Southwest Asia: 1; 
Mexico: 0; 
South America: 20; 
Unknown or insufficient: 4. 

Metropolitan area: Total; 
Southeast Asia: 26; 
Southwest Asia: 8; 
Mexico: 288; 
South America: 318; 
Unknown or insufficient: 142. 

[A] El Paso was added to the DMP in mid-1999. 

Source: DEA. 

[End of table] 

DMP Limitations	Our analysis of the DMP methodology found that the DMP 
data, with modifications, could (1) produce estimates about the 
geographic source of retail heroin purchases in the 23 metropolitan 
areas covered by the DMP and (2) possibly be combined across the 23 
areas. These estimates could not currently be made because the DMP 
data have the following limitations. First, the purchases were not 
made by DEA agents in accordance with the DEA guidelines that provide 
that a certain number of purchases be made each quarter and that the 
purchases be made throughout each quarter. Second, DMP data analysis 
did not take into account the size of the heroin market in each of the 
metropolitan areas. 

DMP Purchases Are Not Made in Accordance with DEA Guidelines: 

DEA agents did not make the DMP purchases in accordance with the DEA 
guidelines that provide that a certain number of purchases be made 
each quarter and that the purchases be made throughout each quarter. 

A review of the 1999 DMP data showed that the DEA guidelines, that 
provide that 10 purchases be made in each quarter (20 in New York 
City) and that the DMP purchases be spread over the quarter, were not 
consistently met. For example, in the first quarter there were less 
than 5 purchases made in 3 of the metropolitan areas. Our analysis 
also showed that a disproportionate number of DMP purchases occurred 
in a certain month of a quarter, and on certain days of the week. If 
the purchases were spread randomly throughout each quarter, 
approximately a third of the purchases would be expected each month, 
and approximately one seventh of the purchases would be expected each 
day of the week. However, based on our analysis of the DMP data, the 
purchase dates were not random by day of the week or by month of 
quarter. 

As a result, it is unlikely that the DMP data for 1999 were derived 
from a sample in which the days in each quarter selected for purchases 
were chosen with a known, equal probability of selection.[Footnote 28] 
In addition, assuming that the characteristics of retail heroin might 
change over time, biases may have been introduced due to oversampling 
in certain time periods within the quarter. For example, if the 
geographic source of heroin supplied to one location changed between 
the beginning and the end of a quarter, making most of the purchases 
during one part of the quarter would not reflect the geographic source 
of the heroin over the entire quarter. 

DEA Does Not Take into Consideration the Size of the Heroin Markets: 

The total number of retail sales in each metropolitan area in each 
quarter is not known. As a result, it is difficult to appropriately 
combine DMP data across metropolitan areas. For example, in one 
metropolitan area (City A) there may be 1,000 retail sales in a 
quarter, but in another area (City B) there may be 5,000 retail sales 
in a quarter. So, for City A, DMP would sample and analyze 10 
purchases representing 1,000 sales, but for City B, the 10 purchases 
would represent 5,000 sales. Without knowing how many purchases are 
represented by the DMP purchases, the data should not be
combined across metropolitan areas. 

DMP Opportunities for Improvements: 

Opportunities exist for making improvements that would allow DEA to 
estimate the geographic source of heroin purchases in the 23 
metropolitan areas and possibly to combine them across the areas. 
These improvements could include ensuring that DEA agents follow 
guidelines when making the purchases and using alternative data 
sources for the total number of retail heroin purchases in an area. 

Ensure that DEA Agents Follow Guidelines When Making DMP Purchases: 

DEA could take actions to ensure compliance with its own guidelines. 
For example, a list of randomly chosen dates on which purchases are to 
be made each quarter could be sent to each metropolitan area. 
Additionally, actual purchase dates in each metropolitan area could be 
more closely monitored, to ensure that purchases are made according to 
scheduled dates. 

DEA Should Study the Use of Alternative Data Sources for the Size of 
the Heroin Markets: 

To calculate the chance of selecting any one purchase, the total 
number of retail heroin sales per quarter for each metropolitan area 
is needed. It is unlikely that this number would ever be known. 
However, DEA could study using alternative data sources as a 
substitute for the total number of retail heroin sales. For example, 
the Drug Abuse Warning Network (DAWN) collects information on hospital 
emergency room admissions that are drug abuse related. If the number 
of heroin purchases in a metropolitan area is proportional to 
emergency room mentions for heroin-related admissions, then DAWN could 
provide information on the relative number of heroin purchases by 
metropolitan area. 

[End of section] 

Appendix III: Comments from the Drug Enforcement Administration: 

U.S. Department of Justice: 
Drug Enforcement Administration: 
Washington, D.C. 20537: 

March 18, 2002: 

Laurie E. Ekstrand, Director: 
Justice Issues Division: 
General Accounting Office: 
441 G Street, N.W., Room 2A38: 
Washington, D.C. 20548: 

Dear Ms. Ekstrand: 

This is to provide you with the Drug Enforcement Administration's 
(DEA) formal response to the General Accounting Office's (GAO) 
recently completed draft report, "Drug Control: DEA Could Improve Its 
Heroin Signature and Domestic Monitor Programs' Geographic Source 
Data" (GAO-02-416). Technical comments have previously been provided 
to the GAO addressing corrections for accuracy and sensitivity 
concerns. DEA submits the following comments on the facts and findings 
of this report. 

DEA has reviewed the draft report and takes strong exception with some 
of GAO's conclusions as noted within this response. The GAO was 
directed to review the Heroin Signature Program (HSP) and the Domestic 
Monitor Program (DMP) to determine the following: 

* the purpose of the HSP and the DMP; 

* how federal law enforcement uses the HSP and DMP data; 

* whether the quantity of heroin seized at ports-of-entry by the U.S. 
Customs Service (USCS) that is not sent to DEA laboratories for 
analysis is of sufficient quantity to make a difference in the HSP 
results; and; 

* whether the HSP and the DMP could be improved. 

Based on interviews with officials from the DEA, USCS, and the Office 
of National Drug Control Policy, as well as an analysis of HSP and DMP 
data, the GAO made the following recommendations (DEA has provided 
numbering for easier reference): 

To help improve the HSP and the DMP data on the geographic source of 
heroin, we recommend that the Attorney General direct the 
Administrator of DEA to: 

1. Ensure that the HSP data are based on a probability sample so that 
all HSP exhibits have a known chance of selection. 

2. Revise the HSP methodology for reporting testing results to include 
procedures to adjust for the probability of exhibits being selected 
for the test sample. 

DEA Response: 

DEA strongly disagrees with these first two GAO recommendations 
regarding the HSP. The intent of those recommendations is to allow the 
estimation of source areas for heroin seizures that have not been 
submitted for signature analysis. DEA believes that the HSP should 
remain a program whose source area figures are based solely on the 
results of scientifically based signature analysis. The HSP should not 
be converted to a program that relies on a fairly simplistic 
probability model to estimate the geographic source of heroin seizures.
DEA believes that other measures can and should be taken that would 
improve the HSP information while retaining the scientific basis of 
that information. 

The HSP looks at the wholesale side of the domestic heroin trafficking 
situation. Included in the program are samples drawn from USCS 
seizures at ports-of-entry that are submitted to DEA regional 
laboratories for analysis. These provide insight into the routes and 
methods used to smuggle heroin into the country. Also sampled are 
randomly selected DEA seizures and purchases that are submitted to DEA 
laboratories. These samples provide a glimpse into wholesale 
distribution patterns within the country. 

HSP samples are submitted to DEA's Special Testing and Research 
Laboratory (STRL) for heroin signature analysis. Initiated in 1977, 
heroin signature analysis is based on an exhaustive chemical profile 
of authentic samples acquired from each of the four major heroin 
source areas: Mexico, South America, Southeast Asia, and Southwest 
Asia. Heroin signature analysis is the only scientifically based 
source of information currently available on the origins of heroin 
encountered in the U.S. drug market. 

Each year, through the HSP, an in-depth chemical analysis is performed 
on an average of 600 to 900 samples taken from heroin seizures and 
purchases made in the United States. As a result of heroin signature 
analysis, DEA chemists at the STRL are able to associate the heroin 
samples with a heroin production process, or signature, which is 
indicative of a particular geographic source area. The resultant 
proportion of heroin associated with each geographic source area is 
measured in terms of the net weight of heroin seized and analyzed in 
the program from each area that year. 

The HSP is not intended to provide U.S. market shares for each of the 
heroin source areas in any given year. Moreover, fluctuations from 
year to year in the proportion from each source area may reflect 
shifting law enforcement priorities, significant seizures, as well as 
changing trafficking patterns. Rather, data from the HSP is used in 
conjunction with investigative intelligence and with drug production 
and seizure data to develop an overall, long-term assessment of the 
trafficking of heroin to and within the United States. 

The GAO recommends that the HSP estimate signatures for heroin 
exhibits submitted to DEA field laboratories that did not undergo 
signature analysis at the STRL. If implemented, the recommendations 
would accomplish little while compromising the scientific basis of the 
HSP results. The HSP would remain a seizure-based program; it still 
would not provide U.S. market shares for each of the heroin source 
areas. Moreover, the geographic source statistics would not be based 
entirely on signature analysis, but would also be generated by a 
probability model. The probability model proposed by the GAO to 
estimate signatures are a standard estimation model, but fairly 
simplistic for this application. To estimate a signature for a 
seizure, the model only takes into account the DEA regional laboratory 
where the seizure was submitted. The model considers no other seizure 
characteristics, such as the location of the seizure, concealment 
method, transportation mode, or point of origin of the drug shipment. 
Recent trends indicate the complexity of heroin trafficking. For 
example, in 2000 HSP signature analysis determined that several 
seizures were comprised of both Southeast Asian and Southwest Asian 
heroin. In some instances, the two types were commingled. 

Instead of estimating heroin signatures, DEA recommends that measures 
be taken to increase the number of USCS and DEA seizures submitted for 
HSP signature analysis as noted in GAO's recommendation 5. The goal 
would be to include in the HSP as much of the total weight of heroin 
seizures as possible. 

To that end, DEA recommends other measures that can be taken to 
increase the portion of DEA heroin exhibits that are sampled for the 
HSP. At this time, the random sample of DEA exhibits is based on the 
total number of exhibits, not the weight of those exhibits. DEA 
recommends that this sample is redesigned from a simple random sample 
to a stratified sample in which DEA heroin exhibits above a certain 
threshold weight are selected with certainty and exhibits falling into 
other weight strata are selected with differing probabilities. This 
sample design is similar to the one proposed by the GAO, but its goal 
is different. The purpose of the proposed DEA sample is not to 
estimate signatures for unsampled seizures, but to ensure that a 
significant portion of the total weight seized by the DEA is sampled 
for HSP signature analysis at the STRL. 

3. Take action to ensure that DMP purchases are made according to DMP 
guidelines; and; 

DEA Response: 

DEA concurs with this recommendation. The guidelines indicate that a 
certain number of DMP buys should be made each quarter and those 
purchases should be made throughout the quarter. Despite periodic 
reviews by the DEA Intelligence Division (NC) and the Office of 
Inspections of field compliance with the DMP guidelines, the required 
number of purchases is not always made. Also, the purchases are 
sometimes not spread over the entire quarter. DEA concurs that DEA 
management should continue to emphasize the importance of the DMP and 
take all possible steps to improve compliance with the guidelines. 

4. Study the utilization of alternative data sources for an estimate 
of the total number of retail heroin purchases in an area that could 
allow the DMP data to be combined across metropolitan areas. 

DEA Response: 

DEA concurs with this recommendation to evaluate using other data 
sources such as the Drug Abuse Warning Network, which provides drug-
related emergency room admissions data, that could be used to weight 
the metropolitan-area data to overall DMP figures. Although such data 
sources cannot provide an accurate measure of the size and scope of 
retail heroin market in an individual location, they can provide a 
means of weighting the DMP metropolitan data to more meaningful DMP 
total figures. Nonetheless, both the limitations of the data sources 
used as weights and the fact that the DMP is not a national sample 
preclude considering such weighed overall DMP figures as national 
estimates. 

In its discussion of DMP limitations and opportunities for 
improvement, the GAO notes that "DEA does not intend that the DMP data 
be used to either produce estimates about retail heroin outside the 23 
metropolitan areas covered by the DMP or about the geographic source 
of all retail level purchases within the 23 metropolitan areas." That 
is correct. It is not possible to determine accurately the scope and 
size of each metropolitan-area retail market. Consequently, a DMP 
probability sample for each metropolitan area cannot be designed and 
estimates cannot be produced from the DMP data. 

The GAO suggests "utilizing alternative data sources for the total 
number of retail purchase in an area, such as the number of hospital 
emergency room admissions related to heroin." Emergency room data only 
measure the health consequences of drug abuse. Data sources do not 
exist that measure either the number of retail heroin purchases or the 
prevalence of heroin abuse in a metropolitan area. Moreover, even if 
such data sources existed, the DMP metropolitan-area data would have 
to be weighted to such an extent that the resulting estimates would be 
very unreliable. 

Again, it should be noted that like the HSP, the DMP is not intended 
to provide U.S. market shares for each of the heroin source areas in 
any given year. Rather than try to artificially convert the DMP to a 
probability sample, the DMP should continue to be used as it is now, 
as an indicator of trends in the retail market that is used in 
conjunction with other information to develop an overall, long-term 
assessment of the trafficking of heroin within the United States. DEA 
objects to forcing these programs to serve purposes other than those 
that DEA has established for these programs. 

DEA does not agree with GAO's conclusion that "the DM? data, with some 
modifications, could produce estimates about the geographic source of 
retail level purchases within the 23 metropolitan areas covered by the 
DMP." As noted above, there are no accurate measurements of local 
heroin markets upon which to base such an estimate. 

5. The GAO also recommends that the Attorney General direct the 
Administrator of the DEA, and that the Secretary of the Treasury 
direct the Commissioner of the USCS, to enter into discussions to 
determine whether the additional seized heroin should be forwarded to 
the DEA by USCS [for inclusion in the HSP] 

DEA Response: 

In its review, the GAO determined that the USCS is not submitting 
samples of a substantial portion of its heroin seizures to DEA 
laboratories. DEA concurs with GAO's recommendation that the DEA and 
USCS work together to ensure that more USCS seizures are sampled for 
the HSP signature analysis. This would provide critical additional 
information from port-of-entry seizures. 

In sum, DEA concurs with recommendations 3, 4 and 5, but strongly 
disagrees with recommendations 1 and 2 and the conclusions supporting 
these recommendations. DEA will follow up with GAO on a course of 
action to address the recommendations included in this report. 

If you have any questions regarding this matter, please contact Acting 
Deputy Chief Inspector, Wayne Nicks or Marjorie Snider, DEA's Audit 
Liaison, at 202-307-8200. 

Sincerely, 

Signed by: 

Asa Hutchinson: 
Administrator: 

cc: Vickie L. Sloan: 
Director: 
Audit Liaison Office: 
Justice Management Division: 

[End of section] 

Footnotes: 

[1] GAO's Office of Special Investigations provided you with 
information on the two programs. U.S. General Accounting Office, 
Review of the Drug Enforcement Administration's Heroin Signature and 
Domestic Monitor Programs, [hyperlink, 
http://www.gao.gov/products/GAO-01-237R], (Washington, D.C.: 2001). 

[2] As noted, this report does not focus on the purity and price 
aspects of the programs. 

[3] As used in the context of the two programs, "wholesale" represents 
heroin seizures at ports-of-entry and seizures and purchases from 
heroin dealers made elsewhere in the United States; "retail" 
represents individual-use heroin purchases. 

[4] We chose these years as they represented the most recent data 
available at the time of our analysis. 

[5] The regions are: Southeast Asia, Southwest Asia, South America, 
and Mexico. The South American heroin signature was developed in 1993. 
This heroin is produced mainly in Colombia. 

[6] DEA operates the STRL in addition to its regional laboratories. 

[7] According to DEA, a cooperating source is an individual who 
performs an investigative activity or provides information regarding 
drug trafficking, with a reasonable expectation of confidentiality, 
under the direction and control of DEA personnel. 

[8] The DMP is a collection of undercover retail purchases in the 23 
metropolitan areas. The DEA uses undercover purchases as a substitute 
for actual retail purchases in these 23 metropolitan areas. 

[9] DEA maintains signature analysis and HSP and DMP data on a 
calendar-year basis. Customs maintains seizure data on a fiscal-year 
basis. 

[10] Location was defined as airport or other. 

[11] Other data sources include opium cultivation/production 
estimates; investigative intelligence; other heroin seizure data such 
as where, when, and from whom heroin was seized; data from DEA's 
System To Retrieve Information from Drug Evidence; and drug abuse 
indicator data. 

[12] The data are used to develop information on the flow of drugs 
into the United States. 

[13] Each of the 93 U.S. attorneys has discretion as to the minimum 
threshold weight that will trigger prosecution in that federal 
judicial district. 

[14] Line items from Customs' database. 

[15] For our analysis, seized wholesale heroin is that seized heroin 
that has been sent to DEA for signature analysis. 

[16] A probability sample means that each exhibit has a known positive 
chance of being selected, and this chance could be computed. 

[17] The Drug Abuse Warning Network (DAWN), administered by the U.S. 
Department of Health and Human Services' Substance Abuse and Mental 
Health Services Administration, provides these data. 

[18] In order for an exhibit to be eligible for HSP testing, the 
exhibit must have contained enough heroin to ensure that a sufficient 
amount remained after removal of a portion of the heroin for testing. 

[19] Excluded from these sums were heroin amounts associated with 
sample exhibits for which a source region could not be determined. 

[20] In 1999, DEA laboratories received a total of 2,510 exhibits 
eligible for the random sample. For the same time period, 327 exhibits 
were selected for the random sample, with a total weight of 151,706 
grams. 

[21] DEA did not provide FBI exhibit data for this analysis. 

[22] In 1999, the regional laboratory sample consisted of 327 exhibits 
out of a total of 2,510; in 2000, the sample consisted of 218 exhibits 
out of a total of 2,598. 

[23] A particular probability sample is only one of a large number of 
samples that might have been drawn using the same sampling procedure. 
Estimates derived from the different samples would differ from each 
other. Confidence in the precision of a particular sample's results is 
expressed as a "confidence interval." For example, we may be 95 
percent confident that the true population value is within plus or 
minus 7 percentage points of a sample estimate. 

[24] If, to meet intelligence needs, DEA continues to make special 
requests for signature analysis of certain exhibits (not already 
included in strata 1 or 2 of table 5), the data for these special 
request exhibits should not be included in the final estimates of the 
geographic source of seized heroin, because they would already have 
had a chance of selection. 

[25] DEA's computations did not account for differences in heroin 
purity levels. DEA could take this into account by using the amount of 
pure heroin, if the total amount of pure heroin is of interest. If the 
substance of interest were grams of various mixtures of heroin and 
adulterants, then an adjustment for purity would not be necessary. 
However, if a purity adjustment were not made, it would be difficult 
to describe what the estimates represented. 

[26] The four geographic source areas plus "unknown" and 
"insufficient." DEA's current HSP data tables do not report unknown 
and insufficient. 

[27] Statistical weighting is an adjustment to data that takes into 
account the probabilities of selection. 

[28] Similar patterns were found in the calendar year 2000 data. 

[End of section] 

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