CBP's Efforts to Address the Impacts of COVID-19 (GAO-22-105803)
Summary
A GAO report to congressional committees, GAO-22-105803, dated September 2022, on maritime cargo security. It reports that the COVID-19 pandemic affected two of U.S. Customs and Border Protection's (CBP) key maritime cargo security programs, the Container Security Initiative (CSI) and the Customs Trade Partnership Against Terrorism (CTPAT) program. It explains that CSI officers largely work from foreign ports and were subject to COVID-19 lockdown and social distancing requirements that varied by location. The report examines CBP's efforts to address these impacts.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
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United States Government Accountability Office
Report to Congressional Committees
September 2022
MARITIME CARGO
SECURITY
CBP’s Efforts to
Address the Impacts
of COVID19
Accessible Version
GAO-22-105803
September 2022
GAO Highlights MARITIME CARGO SECURITY
Highlights of GAO-22-105803, a report to CBP's Efforts to Address the Impacts of COVID-19
congressional committees
Why GAO Did This Study What GAO Found
The U.S. economy is dependent on the The COVID-19 pandemic impacted two of U.S. Customs and Border Protection’s
flow of millions of tons of cargo each (CBP) key maritime cargo security programs—the Container Security Initiative
day throughout the global supply (CSI) and the Customs Trade Partnership Against Terrorism (CTPAT) program.
chain—goods moving from CSI officers largely work from foreign ports and were subject to COVID-19
manufacturers to end users. Cargo lockdown and social distancing requirements that varied by location. Overall, the
shipments can present security COVID-19 restrictions led to some changes in work practices and operational
concerns, as individuals have used procedures. In particular, CSI officers at many CSI ports began to telework in
cargo containers to smuggle narcotics, early 2020. The length of time they teleworked varied by CSI location based on
stowaways, and other contraband. local COVID conditions and restrictions. In addition, a number of CSI ports
Within the federal government, CBP, a amended operational procedures. This included coordinating examinations of
component within the Department of high-risk, U.S.-bound cargo shipments with host country officials via email and
Homeland Security, has responsibility telephone rather than in-person. In some instances, CSI relied on CBP staff in
for cargo security. the U.S. to conduct the cargo examinations.
CBP has developed programs that CTPAT supply chain security specialists are largely based in domestic field
focus resources on identifying U.S.- offices, but they were also subject to COVID restrictions that required them to
bound cargo shipments that may be at telework during 2020 and 2021. In addition, COVID travel restrictions meant that
high risk of transporting terrorist CTPAT supply chain security specialists—could not conduct such visits in-person
weapons or other contraband and from March 2020 to early April 2022. Traditionally, these specialists traveled to
examining those shipments. In conduct in-person validations and periodic revalidations of CTPAT members’
addition, CBP provides benefits to supply chain security practices. As a result, the CTPAT program was not able to
CTPAT members that employ cargo keep pace with required security validations and revalidations of members’
security practices that meet CBP’s supply chain security practices, which led to backlogs. To address the
criteria. Such benefits include backlogged security validations, the CTPAT program trained additional staff and
expedited processing of their U.S.- prioritized completing security validations dating from 2020 and 2021. To address
bound shipments. the backlogged security revalidations, the CTPAT program developed
procedures for conducting virtual security revalidations using videoconferencing
The CARES Act includes a provision technology. While these efforts were still ongoing at the time of our review, the
for GAO to report on monitoring and CTPAT program had made progress in decreasing the backlogged security
oversight efforts related to the COVID- validations and revalidations.
19 pandemic. This report addresses
how COVID-19 impacted CBP’s Photo of a Vessel Laden with Cargo Containers
maritime cargo security programs.
GAO analyzed data on CBP’s maritime
cargo security mission activities,
reviewed relevant policies and
procedures, and interviewed CSI and
CTPAT officials. GAO also interviewed
selected members of the international
trade community.
The Department of Homeland Security
and CBP reviewed a draft of this report
and CBP provided technical comments
that have been incorporated into the
report, as appropriate.
View GAO-22-105803. For more information,
contact Heather MacLeod at (202) 512-8777,
or MacleodH@gao.gov
United States Government Accountability Office
Contents
GAO Highlights ii
Why GAO Did This Study ii
What GAO Found ii
Letter 1
Background 3
COVID-19 Impacted CBP’s Maritime Cargo Security Programs’
Work Practices and Operational Procedures 13
Agency Comments and Our Evaluation 20
Appendix I: Information on Container Security Initiative (CSI) Ports and Reported Impacts of COVID-19 on
Work Practices or Operational Procedures 23
Appendix II: GAO Contact and Staff Acknowledgments 32
GAO Contact 32
Staff Acknowledgements 32
Tables
Table 1: Description of U.S. Customs and Border Protection’s
(CBP) Cargo Targeting Tools and Maritime Cargo
Security Programs 4
Text of Figure 1: Process Used for Reviewing Customs Trade
Partnership Against Terrorism (CTPAT) Applicants’ and
Members’ Supply Chain Security Practices 8
Text of Figure 2: Key Steps in U.S. Customs and Border
Protection’s (CBP) Efforts to Target High-Risk
Containerized Cargo Shipments throughout the Global
Maritime Supply Chain 12
Table 2: Number of Backlogged Security Validations and
Revalidations for Customs Trade Partnership Against
Terrorism (CTPAT) Members as of the end of Calendar
Year 2020 18
Table 3: Information on Container Security Initiative (CSI) Ports
and any Impacts of COVID-19 on Work Practices or
Operational Procedures, as of June 2022 23
Page i GAO-22-105803 Maritime Cargo Security
Figures
Figure 1: Process Used for Reviewing Customs Trade Partnership
Against Terrorism (CTPAT) Applicants’ and Members’
Supply Chain Security Practices 8
Figure 2: Key Steps in U.S. Customs and Border Protection’s
(CBP) Efforts to Target High-Risk Containerized Cargo
Shipments throughout the Global Maritime Supply Chain 11
Figure 3: Cargo Container Vessels at a CSI Port in Panama 17
Abbreviations
ATS Automated Targeting System
CBP U.S. Customs and Border Protection
DHS Department of Homeland Security
CSI Container Security Initiative
CTPAT Customs Trade Partnership Against Terrorism
MRA mutual recognition arrangement
NII non-intrusive inspection
NTC-C National Targeting Center-Cargo
RPM radiation portal monitors
SFI Secure Freight Initiative
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Page ii GAO-22-105803 Maritime Cargo Security
441 G St. N.W.
Washington, DC 20548
Letter
September 14, 2022
Congressional Committees
The U.S. economy is dependent on the expeditious flow of millions of
tons of cargo each day throughout the global supply chain—the flow of
goods from manufacturers to retailers or other end users. Cargo
shipments can present significant security concerns, as individuals have
exploited vulnerabilities in the supply chain by using cargo containers to
smuggle narcotics, stowaways, and other contraband. Given these
vulnerabilities, there is a risk that terrorists could use a cargo container to
transport a weapon of mass destruction or other terrorist contraband into
the United States. Within the federal government, U.S. Customs and
Border Protection (CBP), a component within the Department of
Homeland Security (DHS), has responsibility for administering cargo
security and reducing the vulnerabilities associated with the global supply
chain.
In performing its maritime cargo security responsibilities, CBP has
developed a layered security strategy to focus its resources on targeting
and examining high-risk cargo shipments that could pose a risk while
allowing other cargo shipments to proceed without unduly disrupting
commerce arriving in the United States. CBP’s layered security strategy is
based on initiatives and programs that include (1) analyzing information to
identify cargo shipments that may be at high risk of transporting weapons
of mass destruction or other contraband, (2) working with foreign
governments to examine U.S.-bound containerized cargo shipments at
foreign ports, and (3) providing benefits to companies that have
implemented supply chain security practices that meet CBP’s minimum
security criteria.
The COVID-19 pandemic has impacted nearly all aspects of society.
COVID-19 also generated unprecedented challenges for federal agencies
tasked with addressing the pandemic’s effects while continuing to carry
out their missions and programs. The CARES Act includes a provision for
us to report on its ongoing monitoring and oversight efforts related to the
COVID-19 pandemic.1 This report is part of our body of work in response
to the CARES Act. In particular, this report addresses how CBP’s
1Pub. L. No. 116-136, § 19010(b), 134 Stat. 281, 580 (2020). All of GAO's reports related
to the COVID-19 pandemic are available on GAO's website at
https://www.gao.gov/coronavirus.
Page 1 GAO-22-105803 Maritime Cargo Security
Letter
maritime cargo security programs have been impacted by the COVID-19
pandemic.
To address our objective, we focused on two of CBP’s key maritime cargo
security programs—the Container Security Initiative (CSI) and the
Customs Trade Partnership Against Terrorism (CTPAT) program. To
obtain background information on the genesis and primary objectives of
the CSI and the CTPAT program, we gathered and reviewed the statutory
framework for each program. We also reviewed our prior work products,
as well as Congressional Budget Office reports involving the programs.2
In addition, we reviewed maritime cargo security policies and procedures
that were implemented prior to and during the pandemic, to determine the
extent to which CSI and the CTPAT program amended any policies or
procedures as a result of the COVID-19 pandemic. For the CTPAT
program, we also gathered data on how COVID-19 impacted the
program’s ability to keep pace with required security validations (and
periodic revalidations) of members’ supply chain security practices. To
assess the reliability of the data, we interviewed knowledgeable officials
and examined the data for obvious errors or anomalies. We found the
data sufficiently reliable to report on security validations, revalidations,
and backlogs.
To supplement our document reviews and data analyses, we met with
CBP officials from the Cargo and Conveyance Security Directorate and
the National Targeting Center-Cargo (NTC-C), as well as program
management officials for CSI and the CTPAT program. We also collected
information from the 61 CSI ports about how COVID impacted work
practices and operational procedures. Finally, we met with officials from
the World Shipping Council and obtained written responses from a
member of the Customs Operations Advisory Committee to obtain their
perspectives on the impacts of COVID-19 on maritime cargo security
issues, as well as efforts by CBP—through its CSI and CTPAT program—
2GAO, Supply Chain Security: DHS Could Improve Cargo Security by Periodically
Assessing Risks from Foreign Ports, GAO-13-764 (Washington, D.C.: Sept. 16, 2013);
Supply Chain Security: Providing Guidance and Resolving Data Problems Could Improve
Management of the Customs-Trade Partnership Against Terrorism Program, GAO-17-84
(Washington, D.C.: Feb. 8, 2017); Supply Chain Security: CBP Needs to Enforce
Compliance and Assess the Effectiveness of the Importer Security Filing and Additional
Carrier Requirements, GAO-17-650 (Washington, D.C.: July 20, 2017); and CBO,
Scanning and Imaging Shipping Containers Overseas: Costs and Alternatives,
(Washington, D.C: June 2, 2016).
Page 2 GAO-22-105803 Maritime Cargo Security
Letter
to mitigate the impacts of COVID-19 and continue its maritime cargo
security operations.
We conducted this performance audit from February 2022 to September
2022 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 objective. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions.
Background
CBP’s Strategy for Securing the Maritime Cargo Supply
Chain
Since September 11, 2001, Congress has passed and the President has
signed various laws to address concerns about the security of
containerized cargo in the global supply chain. CBP’s strategy for
securing the maritime cargo supply chain uses a risk-based approach to
focus resources on targeting and examining cargo shipments that pose a
potential risk while allowing other cargo shipments to proceed without
unduly disrupting commerce into the United States.3 The strategy is
based, in part, on obtaining advance information on U.S.-bound cargo
shipments. Other aspects of CBP’s maritime cargo security strategy
include using technology to detect potential threats being transported
within cargo containers, and partnering with foreign governments and the
trade industry to examine containers prior to their arrival in the United
States and implement security measures throughout the supply chain
3CBP refers to the process of analyzing data and classifying shipments by risk level as
screening. According to CBP, it screens (but does not scan) all U.S.-bound cargo
shipments before they are loaded onto vessels at foreign ports. In this report, we discuss
the screening process in terms of assessing the risk of a shipment. An examination refers
to either (1) the scanning of a cargo container using non-intrusive inspection (NII)
technology, which may use X-rays or gamma rays to create an image of the contents of
the container; or (2) a physical inspection of a cargo container. If the results of an NII scan
indicate that a threat may be present, CBP may choose to conduct a physical inspection.
In addition to an NII exam, scanning can also refer to the use of radiation detection
equipment, such as radiation portal monitors. According to CBP, 99 percent of containers
are scanned through radiation portal monitors prior to leaving a domestic port.
Page 3 GAO-22-105803 Maritime Cargo Security
Letter
process, respectively. Table 1 provides a description of CBP’s cargo
targeting tools and core maritime cargo security programs.
Table 1: Description of U.S. Customs and Border Protection’s (CBP) Cargo Targeting Tools and Maritime Cargo Security
Programs
Cargo Targeting Tools Description
and Maritime Cargo
Security Programs
Cargo Targeting Automated Targeting ATS is an intranet-based decision support system that compares traveler, cargo,
Tools System (ATS) and conveyance information against intelligence and other enforcement data by
incorporating risk-based targeting scenarios and assessments. ATS assigns a risk
score to U.S.-bound cargo shipments based on shipping information to help CBP
identify and prevent potential terrorists and terrorist weapons from entering the
United States.
National Targeting Center- NTC-C analyzes advance cargo information before shipments reach the United
Cargo (NTC-C) States. NTC-C also promotes information sharing with other federal agencies and
foreign governments to detect and seize threats at U.S. and foreign ports.
Non-intrusive inspection CBP uses NII equipment to scan both randomly selected containers and those
(NII) equipment identified by ATS as high risk. NII uses X-rays or gamma rays to scan a container
and create images of the container’s contents without opening it.
Radiation portal monitors CBP uses RPMs to detect the presence of radioactive material that may be in a
(RPM) container. Certain types of RPMs can identify the type of material emitting the
radiation and whether the material poses a threat or is a naturally occurring
radioactive material, such as that found in certain ceramic tiles.
Maritime Cargo Container Security CBP launched CSI in January 2002 in an effort to protect global shipping by
Security Programs Initiative (CSI) targeting and examining high-risk cargo containers as early as possible in their
movement through the global maritime supply chain. As part of the CSI, CBP
places officers at participating foreign ports to work with host country Customs
officials to target and examine high-risk container cargo for weapons of mass
destruction or other terrorist contraband before they are loaded onto U.S.-bound
vessels. At CSI ports, CBP officers identify the container shipments that may pose
a risk for terrorism contraband and request that their foreign counterparts examine
the contents of the containers with NII and RPM equipment.
Customs Trade The CTPAT program began in November 2001. It is a voluntary program in which
Partnership Against CBP officials work with private companies to review and validate their supply chain
Terrorism (CTPAT) security practices, as well as the security practices of the companies or entities in
their global supply chains, to ensure they meet a set of minimum security criteria
defined by CBP. In return for ensuring their supply chain security practices meet
CBP’s minimum security criteria, CTPAT members are eligible to receive various
benefits, such as reduced scrutiny or expedited processing of their U.S.-bound
shipments. CTPAT members include importers, exporters, manufacturers,
consolidators, customs brokers, and carriers covering all modes of transportation—
to include air, sea (maritime), rail, and highway carriers.
Mutual Recognition Through mutual recognition arrangements with other countries, the cargo security-
Arrangements (MRA) related practices and programs taken by the Customs administration of one country
are recognized and accepted by the Customs administration of another. According
to CBP, the essential concept is that the CTPAT program and the foreign programs
are compatible in both theory and practice so that one program may recognize the
findings and validation results provided by another.
Source: GAO summary of information provided by the Department of Homeland Security. I GAO-22-105803
Page 4 GAO-22-105803 Maritime Cargo Security
Letter
Note: In addition to CSI, CTPAT, and MRA, CBP and the Department of Energy began the Secure
Freight Initiative (SFI) in 2006 at certain overseas ports to scan 100 percent of U.S.-bound container
cargo for nuclear and radiological materials using NII and RPM equipment. Based on various
challenges, all but one SFI port has reverted to CSI operations and the one remaining SFI port is
operated remotely via the NTC-C.
Container Security Initiative (CSI)
CSI is a bilateral government partnership program to station CBP officers
at foreign seaports where they identify U.S.-bound containerized cargo
shipments at risk of containing weapons of mass destruction or other
terrorist contraband. CBP launched CSI in January 2002 in an effort to
protect global trade by targeting and examining high-risk containers as
early as possible in their movement through the global supply chain. The
program was designed to address concerns (after the terrorist attacks of
September 11, 2001), that terrorists could smuggle weapons of mass
destruction or other contraband inside containers bound for the United
States.
As part of the CSI program, CBP officers are stationed at certain foreign
seaports to conduct the following activities:
Target U.S.-bound container shipments. CSI officers electronically
review advance information collected on U.S.-bound containerized cargo
shipments departing from the foreign port—a process CBP refers to as
“screening.” CSI officers also review the risk scores assigned to the
shipments by CBP’s automated targeting system to identify high-risk
shipments with a potential nexus to terrorism—a process referred to as
“targeting.” CSI officers then refer these high-risk, U.S.-bound cargo
shipments to host government officials for examination.
Request examinations of high-risk, U.S.-bound container shipments.
CBP officers work with host country government officials to mitigate high-
risk, U.S.-bound cargo container shipments. Actions may include
resolving discrepancies in shipment information, scanning cargo
containers’ with radiation detection and imaging equipment, or conducting
physical inspections of the containers’ contents.
In total, the CSI program targets U.S.-bound containerized cargo from 61
foreign ports. According to CSI officials, as of April 2022, these 61 CSI
ports collectively accounted for 72 percent of the cargo shipped to the
United States by volume. For the time period covered by our review—
roughly March 2020 to June 2022—CSI had staff based in 27 foreign
countries that, collectively, covered 50 foreign ports that ship maritime
Page 5 GAO-22-105803 Maritime Cargo Security
Letter
cargo directly to the United States. In addition, during the period of our
review, the National Targeting Center-Cargo remotely targeted U.S.-
bound cargo shipments for an additional 11 CSI ports within seven
countries—Montreal, Vancouver, and Halifax, Canada; Qasim, Pakistan;
Haifa and Ashod, Israel; Aqaba, Jordan; Melbourne, Australia; Auckland,
New Zealand; and Shanghai and Shenzhen, China.
CSI officers at most CSI ports target U.S.-bound cargo shipments only
from their assigned ports. However, based on information provided by
CSI officials, there were seven CSI port locations that, collectively,
targeted U.S-bound cargo shipments for 14 other CSI ports as well—one
in Belgium that covered one additional CSI port; one in France that
covered one additional CSI port; one in Germany that covered one
additional port; two in Italy that, collectively, covered five additional ports;
one in Panama that covered three additional CSI ports; and one in the
United Kingdom that covered three additional ports.
Targeting of cargo shipments across the 61 CSI ports utilized three
separate formats. Specifically, U.S.-bound cargo shipments were
targeted:
· by assigned CSI officers at 36 ports;
· remotely by CSI officers from a different CSI port at 14 CSI ports
(targeting hubs); and
· remotely by officials from the National Targeting Center-Cargo for 11
CSI ports.
Customs Trade Partnership Against Terrorism (CTPAT)
Program
The CTPAT program is a voluntary program that enables CBP officials to
work in partnership with private companies to review and approve the
security of their international supply chains. In November 2001, CBP
announced the CTPAT program as part of its efforts to facilitate the free
flow of goods while ensuring that the cargo containers do not pose a
threat to homeland security. In October 2006, the SAFE Port Act
established a statutory framework for the CTPAT program, codified its
Page 6 GAO-22-105803 Maritime Cargo Security
Letter
existing membership processes, and added new components—such as
time frames for validating and revalidating members’ security practices.4
Figure 1 provides information on CBP’s process for screening CTPAT
applicants and reviewing members’ supply chain security practices.
Entities that join the CTPAT program commit to improving the security of
their supply chains and agree to provide CBP with information on their
specific supply chain security measures. In addition, the entities agree to
allow CBP to validate, among other things, that their security practices
meet or exceed CBP’s minimum security requirements. In return for their
participation in the program, CTPAT members are entitled to certain
benefits, such as a reduced likelihood of scrutiny of their cargo.
46 U.S.C. §§ 961-973.
Page 7 GAO-22-105803 Maritime Cargo Security
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Figure 1: Process Used for Reviewing Customs Trade Partnership Against
Terrorism (CTPAT) Applicants’ and Members’ Supply Chain Security Practices
Text of Figure 1: Process Used for Reviewing Customs Trade Partnership Against
Terrorism (CTPAT) Applicants’ and Members’ Supply Chain Security Practices
· Application and eligibility
· An entity submits an application for CTPAT membership, including
a supply chain security profile describing its security practices. A
security specialist is assigned and determines if the applicant
meets CTPAT eligibility requirements.
· Vetting
Page 8 GAO-22-105803 Maritime Cargo Security
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· The assigned security specialist is to review the entity’s
compliance with customs laws and identify any history of
violations, among other things.
· Certification
· Within 90 days of receipt of the entity’s supply chain security
profile, the security specialist is to determine whether the profile
adequately addresses CBP’s minimum security criteria. If
approved, the entity is certified as a CTPAT member and eligible
for benefits.
· Validation
· Within 1 year of certification, the security specialist is to validate
the security measures outlined in the member’s supply chain
security profile. This occurs through a site visit to the member and,
if the member is an importer, at least one foreign supply chain
partner’s site.
· Annual Review and Revalidations
· Once validated, the member is to undergo a review of its eligibility
status, vetting, and certification processes on an annual basis. In
addition, every 4 years after an initial security validation, the
CTPAT member is to undergo a revalidation of its supply chain
security practices, as required by the SAFE Port Act.
Source: GAO analysis of CBP information. | GAO-22-105803
Note: As a result of COVID-19 travel restrictions, the CTPAT program revised procedures to allow for
some security revalidations to be conducted virtually using videoconferencing capabilities. Details on
this change are provided later in this report.
Mutual Recognition Arrangements (MRA)
Through MRAs with foreign government entities, the security-related
practices and programs taken by the Customs or maritime security
administration of one entity is recognized and accepted by the
administration of another.5 According to the World Customs Organization,
5MRAs can be entered into with other countries as well as other governing bodies, such
as the European Union. The essential concept of MRAs is that CTPAT and certain foreign
Customs administrations have established a standard set of security requirements that
allows one partnership program to recognize the validation findings of the other program.
Because the CTPAT program is CBP’s partnership program, this report does not include a
separate assessment of the impacts of COVID-19 on MRAs. Rather, the report
incorporates information on MRAs within the information presented on the impacts of
COVID-19 on the CTPAT program.
Page 9 GAO-22-105803 Maritime Cargo Security
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MRAs allow Customs administrations to target high-risk shipments more
effectively by, for example, reducing redundant examinations.6 As of early
September 2022, the U.S. has signed MRAs with 15 government
entities.7 The World Customs Organization distinguishes between mutual
recognition of Customs controls and mutual recognition of authorized
economic operator (AEO) programs.8
· Mutual recognition of Customs controls (Customs-to-Customs
MRAs): This is achieved when, for example, the Customs
administrations of two countries have confidence in and accept each
other’s procedures for targeting and examining cargo shipped in
containers.
· Mutual recognition of AEO programs (AEO MRAs): This occurs
when Customs administrations agree to recognize one another’s AEO
programs and security features and to provide comparable benefits to
members of the respective programs. In the United States, CTPAT is
the designated AEO program and businesses participating in the
program are AEOs. According to CTPAT documentation, CBP has
developed an AEO MRA process involving four phases: (1) a
comparison of the program requirements to determine if the programs
align on basic principles, (2) a pilot program of joint validation visits to
determine if the programs align in basic practice, (3) the signing of an
MRA, and (4) the development of mutual recognition operational
procedures.
Figure 2 shows the key steps used by CBP for identifying and targeting
potentially high-risk containerized cargo shipments using the resources
and maritime cargo security programs described earlier.
6The World Customs Organization is an intergovernmental organization that aims to
enhance the effectiveness and efficiency of Customs administrations. As of July 1, 2022,
the organization had 184 member countries that, collectively, were responsible for
managing more than 98 percent of world trade.
7The 15 government entities with which the U.S. has signed MRAs as of early September
2022 are: New Zealand (2007), Canada (2008), Jordan (2008), Japan (2009), South
Korea (2010), European Union (2012), Taiwan (2012), Israel (2014), Mexico (2014),
Singapore (2014), Dominican Republic (2015), Peru (2018), United Kingdom (2021), India
(2021), and Uruguay (2022).
8AEOs include, for example, manufacturers, importers, exporters, brokers, ports, airports,
terminal operators, warehouses, and distributors.
Page 10 GAO-22-105803 Maritime Cargo Security
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Figure 2: Key Steps in U.S. Customs and Border Protection’s (CBP) Efforts to Target High-Risk Containerized Cargo
Shipments throughout the Global Maritime Supply Chain
Page 11 GAO-22-105803 Maritime Cargo Security
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Text of Figure 2: Key Steps in U.S. Customs and Border Protection’s (CBP) Efforts
to Target High-Risk Containerized Cargo Shipments throughout the Global Maritime
Supply Chain
· Manufacturing at a foreign factory
· Packing and sealing the container
· Private companies, including manufactures, shippers, and
carriers, can participate in the Customs Trade Partnership Against
Terrorism program. As part of this program, members ensure their
supply chain security practices meet CBP’s minimum security
criteria and, in exchange, the members are eligible to receive
various benefits, such as reduced scrutiny or expedited
processing of their U.S.-bound cargo shipments.
· Targeting process begins
· Importers and carriers provide advance data to CBP, which uses the
Automated Targeting System (ATS) to analyze data and identify high-
risk containers.
· Loading the container shipment onto a U.S.-bound vessel at a foreign
port.
· Container on a vessel, in transit to the United States
· While cargo is in transit, importers and carriers are to provide
status updates on containers for CBP to analyze again using ATS.
· Unloading the container at the port of arrival in the United States
· Scanning high-risk containers with nonintrusive inspection equipment
· High-risk containers that were not scanned at a Container Security
Initiative port and containers that are selected by CBP targeters
are scanned at a port in the United States using nonintrusive
inspection equipment.
· Scanning all containers with radiation portal monitors
· All containers leaving a U.S. port, regardless of risk level, are to
be scanned for radiation by passing through radiation portal
monitors prior to exit.
· Exiting the U.S. port
Source: GAO (analysis and photos) and CBP and DHS Science and
Technology Directorate (photos). | GAO-22-105803
Page 12 GAO-22-105803 Maritime Cargo Security
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COVID19 Impacted CBP’s Maritime Cargo
Security Programs’ Work Practices and
Operational Procedures
The COVID-19 pandemic impacted CBP’s key maritime cargo security
programs—CSI and CTPAT—by leading the programs to implement new
work practices and operational procedures. For example, because of
COVID-19 lockdowns and social distancing requirements, CSI and
CTPAT staff teleworked from their homes rather than from their offices for
varying lengths of time during March 2020 through March 2022. In
addition, at some CSI ports, CSI officers were not always able to directly
observe cargo examinations and, instead, had to rely on reviewing
electronic information on the results of those cargo examinations provided
via email. Further, because of COVID travel restrictions, the CTPAT
program developed new procedures for conducting security revalidations
virtually. Collectively, the amended work practices and operational
procedures allowed CBP to mitigate the impacts of COVID-19 on its
maritime cargo security programs.
Container Security Initiative
One of the key impacts of COVID-19 on CSI operations was that some
CSI locations were subject to lockdowns and social distancing
requirements, which required that CSI officers in those locations change
work practices and begin teleworking from their in-country residences
rather than working onsite at the ports. The need for some CSI officers to
telework also had broader ramifications in terms of CSI operational
procedures. For example, CSI officers who teleworked may also have
needed to coordinate and communicate with their host country
counterparts via email or telephone rather than in-person, and review
electronic information on the results of cargo examinations rather than
being able to directly observe the cargo examinations.
To determine the extent to which COVID-19 impacted CSI operations
across the 61 CSI ports, we gathered and analyzed information from each
of the CSI ports on any changes made to either work practices (e.g., use
of telework) or operational procedures (e.g., requesting cargo
examinations via email rather than in-person with host country officials)
as a result of COVID-19. The bullets below provide specific examples
from CSI ports of the reported impacts of COVID-19 on work practices or
operational procedures. The list of any reported impacts of COVID-19 on
Page 13 GAO-22-105803 Maritime Cargo Security
Letter
the work practices and operational procedures for all 61 CSI ports can be
found in Table 3 in Appendix I.
· 29 of the 36 CSI ports where targeting of U.S.-bound cargo shipments
was done by CSI officers assigned to the port required the CSI
officers to telework for at least some period of time during March 2020
to June 2022. For example:
· Port of Sines, Portugal: From March to May 2020, and from
January to April 2021 the port was locked down. CSI officers were
not allowed at the port and were required to telework during these
periods. Then, from June 2020 to January 2021, and from April to
December 2021, the port experienced partial lockdowns during
which time CSI officers worked in-person at the port 50 percent of
the time and teleworked 50 percent of the time. Beginning in
January 2022, the CSI officers returned to work in-person at the
port full-time.
· Port of Balboa, Panama: Travel restrictions were implemented in
early 2020 and CSI officers were not allowed to travel to the port
of Balboa until July 2021. As a result, CSI officers had to telework
during this time period.
· 13 CSI ports shifted from in-person interactions with host country
officials to using email or a messaging application to request cargo
examinations for at least some period of time during March 2020 to
June 2022. For example:
· Port of Caucedo, Dominican Republic: The host country
discontinued use of hand-delivered hard copy forms to request
cargo examinations and, instead, CSI officers were required to
request cargo examinations via email.
· Port of Dubai, United Arab Emirates: Cargo examinations
ceased at the port during October 2019 to June 18, 2021 and
were coordinated with the National Targeting Center-Cargo during
this time period. When cargo examinations resumed at the port
beginning on June 19, 2021, CSI officers used a messaging
application to request cargo examinations by Dubai Customs
officials.
· At 19 CSI ports, CSI officers were not able to directly observe
requested cargo examinations in person for at least some period of
time during March 2020 to June 2022 and, instead, reviewed
electronic information on the results of those cargo examinations. For
example:
Page 14 GAO-22-105803 Maritime Cargo Security
Letter
· Port of Tokyo, Japan: In-person observations of cargo
examinations by CSI officers were sometimes suspended at the
discretion of the host country. In such instances, results of the
cargo examinations were provided to CSI officers via email.
· Port of Singapore: CSI officers were not permitted to directly
observe cargo examinations from June 2020 to December 2020.
During this time period, results of cargo examinations were
emailed to CSI officers.
While the impacts of COVID on CSI operations generally pertained to the
need to implement varied telework schedules or operational procedures
to limit personal interactions, there were more significant impacts at
certain CSI ports, such as the following examples.
· Ports of Shanghai and Shenzhen, China: CSI officers left the Port
of Shanghai in April 2021, and the Port of Shenzhen in October 2021.
Because of visa restrictions, CSI has not been able to replace the
officers at these two ports. There have been no CSI officers at either
of these ports since April 2021 and October 2021, respectively. CSI
has shifted targeting responsibility for these two ports to the National
Targeting Center-Cargo. As of June 2022, all U.S.-bound cargo from
Shanghai and Shenzhen continued to be remotely targeted and
examined. CSI officials stated that while CSI officers have not been
present at these ports since 2021 to conduct examinations of high-risk
cargo shipments before they are loaded onto U.S.-bound vessels, CSI
has been able to mitigate the impact of these limitations. For example,
CSI has relied on staff at the National Targeting Center-Cargo to
target high-risk, U.S.-bound cargo shipments from Shanghai and
Shenzhen. CSI has also coordinated with the respective ports of
destination in the U.S. to examine any high-risk cargo shipments upon
arrival, according to CSI officials.
· Ports of Tanjung Pelepas and Klang, Malaysia: From April 2020 to
April 2022, CSI officers could not work at these two ports because of
COVID restrictions. CSI officers assigned to these two ports continued
to target U.S.-bound shipments from their telework locations, but all
cargo examinations at the port ceased beginning in April 2020. While
cargo examinations at Port Klang resumed beginning on May 17,
2022, cargo examinations had not yet resumed at the Port of Tanjung
Pelepas as of June 2022. CSI officers stated that they did not have
any estimates for when cargo examinations would resume at the port.
The officers stated that they were able to resolve any potentially high-
risk cargo shipments using a collection of electronic research tools, as
well as officer knowledge and experience.
Page 15 GAO-22-105803 Maritime Cargo Security
Letter
The CSI program was able to adapt to varied COVID restrictions and
implement amended work practices and operational procedures to
mitigate their impact. This allowed CSI officers to continue their cargo
security mission responsibilities. Specifically, a number of CSI locations
already had contingency plans in place for CSI officers to telework from
their residences as a result of prior weather-related emergencies or civil
unrest. As a result, CSI was able to implement telework schedules for CSI
officers that were tailored to the varied COVID-19 restrictions in place
across the CSI locations. CSI officials stated that although some officers
teleworked for extended periods of time during the pandemic, the use of
telework did not impact CSI’s ability to carry out its maritime cargo
security program responsibilities. In particular, the officials noted that the
CSI program routinely uses technology to perform remote targeting of
U.S.-bound maritime cargo shipments. Consequently, according to the
officials, allowing CSI officers to telework from their in-country residences
did not decrease the program’s effectiveness or productivity.
CSI officials stated that while the amended work practices and
operational procedures that CSI officers implemented allowed them to
mitigate the impacts of COVID-19, they are not contemplating any
changes to CSI officers’ in-person work requirements moving forward.
The officials noted that they value face-to-face interactions and
collaboration with their host country counterparts and prefer to be able to
directly observe and participate in cargo examinations, as authorized by
the host countries. The CSI officials noted, though, that they will remain
flexible and adapt to any circumstances that may require the use of these
flexible work practices and amended operational procedures in the future.
Figure 3 shows a CSI port in Panama.
Page 16 GAO-22-105803 Maritime Cargo Security
Letter
Figure 3: Cargo Container Vessels at a CSI Port in Panama
Customs Trade Partnership Against Terrorism
There were two primary impacts of COVID-19 on CTPAT operations.
First, because of COVID restrictions and social distancing requirements,
CTPAT staff were directed to telework for a period of time. Specifically,
CTPAT program managers directed CTPAT staff to telework beginning in
March 2020. CBP authorized CTPAT staff to return to their offices
beginning in January 2022. Second, because of COVID travel restrictions,
CTPAT supply chain security specialists—who traditionally traveled to
conduct in-person validations and revalidations of CTPAT members’
Page 17 GAO-22-105803 Maritime Cargo Security
Letter
supply chain security practices—could not conduct in-person visits for 2
years—from March 2020 to early April 2022.
The CTPAT program has relied on the use of travel to conduct in-person
visits to validate and periodically revalidate (every 4 years) CTPAT
members’ supply chain security practices. Specifically, CTPAT supply
chain security specialists travel domestically to validate members’ supply
chain entities within the United States and travel internationally to validate
members’ supply chain entities based outside the United States. While
the CTPAT program has historically been able to keep pace with the
required security validations and revalidations, COVID-19 travel
restrictions that went into effect in early 2020 halted these visits, which
led to backlogs. As shown in table 2, the number of backlogged security
validations and revalidations had grown to 4,779 as of the end of 2020.
Table 2: Number of Backlogged Security Validations and Revalidations for Customs
Trade Partnership Against Terrorism (CTPAT) Members as of the end of Calendar
Year 2020
Category Domestic Number International Total
Number
Certified but awaiting initial security 271 764 1,035
validation
Validated but due for a security 1,628 2,116 3,744
revalidation
Total 1,899 2,880 4,779
Source: GAO analysis of information provided by CTPAT program officials. I GAO-22-105803
In an effort to mitigate the impacts of COVID-19 restrictions, the CTPAT
program took several steps to address the backlogged security
validations and revalidations. To address the backlogged security
validations, the CTPAT program: (1) made it a priority to reduce the
backlog of security validations dating from 2020 and 2021 before it
conducted the security validations of members’ supply chain security
practices that have come due in 2022, (2) began training more CBP staff
to become supply chain security specialists; and (3) began easing travel
restrictions. Specifically, in early April 2022, the CTPAT program eased
travel restrictions to allow supply chain security specialists to travel within
a 50-mile radius of the program’s six field offices—Buffalo, NY; Houston,
TX; Los Angeles, CA; Miami, FL; New York, NY; and Newark, NJ. As of
July 1, 2022, the CTPAT program had made no further adjustments to its
travel policies.
Page 18 GAO-22-105803 Maritime Cargo Security
Letter
While these three actions were in progress during the period of our
review, the CTPAT program had made some progress in reducing the
backlog of initial security validations. According to information provided by
CTPAT officials, as of the end of June 2022, the CTPAT program had
completed seven security validations. CTPAT officials noted that, while
they have not been able to complete security validations in as timely a
manner as they had done prior to COVID, members who are awaiting
security validations remain eligible to receive the benefits that accrued to
them as certified CTPAT members.
To address the backlogged security revalidations, the CTPAT program
developed and implemented new procedures for conducting security
revalidations virtually. Specifically, in the summer of 2020, the CTPAT
program tested the concept of conducting security revalidations virtually
using video conferencing software. CTPAT officials stated that the test
proved successful, so the CTPAT program developed new standard
operating procedures for conducting virtual security revalidations, which it
implemented in October 2020. The new procedures govern the use and
application of the virtual validation process—to include low, medium, and
high risk categories—in an effort to: (1) establish a risk-based approach
for conducting virtual security revalidations, and (2) ensure that CTPAT
staff follow a uniform process when determining whether it is appropriate
to use the virtual security revalidation process based on the member’s
risk level.
According to information provided by CTPAT officials, from October 2020,
when the revised, virtual revalidation procedures were implemented, to
March 1, 2022, the CTPAT program conducted 2,424 virtual security
revalidations—1,225 that were domestic and 1,199 that were
international.9 The Director of the CTPAT program stated that the intent
moving forward is that the virtual security revalidation process will remain
a tool that can be used by CTPAT staff to revalidate low and medium risk
members’ supply chain security practices. Members of international trade
community that we met with viewed the new virtual security revalidation
9CTPAT officials told us that that the program began reducing the number of backlogged
security revalidations in October 2020 when it implemented new procedures for
conducting security revalidations virtually. However, we are not able provide information
on the specific progress the CTPAT program has made in reducing the number of
backlogged security revalidations over time because the number of CTPAT members with
security revalidations due is constantly evolving. For example, new security revalidations
come due and some CTPAT members drop out of the program, negating the need for
their security revalidations.
Page 19 GAO-22-105803 Maritime Cargo Security
Letter
process as an innovative and efficient way to revalidate CTPAT members’
security procedures.
In addition to developing and implementing new procedures for
conducting security revalidations virtually, the CTPAT program also used
mutual recognition arrangements with other countries as a means for
reducing the backlog of international security revalidations.10 According to
information provided by CTPAT officials, as of the end of June 2022,
MRA partners had completed 266 international security revalidations.
Agency Comments and Our Evaluation
We provided a draft of this report to DHS and CBP for review and
comment. CBP provided technical comments, which we have
incorporated into the report as appropriate.
We are sending copies of this report to the appropriate congressional
committees, the Secretary of Homeland Security, the Commissioner of
U.S. Customs and Border Protection, and other interested parties. In
addition, the report is available at no charge on the GAO website at
http://www.gao.gov.
If you or your staffs have any questions about this report, please contact
Heather MacLeod at 202-512-8777 or macleodh@gao.gov. Contact
points for our Offices of Congressional Relations and Public Affairs may
be found on the last page of this report. GAO staff that made key
contributions to this report are listed in appendix II.
Heather MacLeod
Acting Director,
Homeland Security and Justice Issues
10 Mutual recognition arrangements indicate that the security requirements and verification
procedures of the foreign entity are comparable to those of the CTPAT program. As a
result, the CTPAT program recognizes and accepts the security validation findings of the
foreign entity to be equivalent to a CPAT-initiated security revalidation.
Page 20 GAO-22-105803 Maritime Cargo Security
Letter
List of Addressees
The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Patty Murray
Chair
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate
The Honorable Gary C. Peters
Chairman
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Rosa L. DeLauro
Chair
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Frank Pallone, Jr.
Chairman
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives
The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable Carolyn B. Maloney
Page 21 GAO-22-105803 Maritime Cargo Security
Letter
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives
The Honorable Richard Neal
Chairman
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives
Page 22 GAO-22-105803 Maritime Cargo Security
Appendix I: Information on Container Security
Initiative (CSI) Ports and Reported Impacts of
COVID-19 on Work Practices or Operational
Procedures
Appendix I: Information on
Container Security Initiative (CSI)
Ports and Reported Impacts of
COVID19 on Work Practices or
Operational Procedures
As of June 2022, the Container Security Initiative (CSI) had officers based
in 27 foreign countries covering 50 foreign ports within those countries
that ship maritime cargo directly to the United States. In addition, there
were seven countries covering an additional 11 ports where U.S.-bound
cargo shipments from those countries are targeted remotely from the
National Targeting Center-Cargo. In total, the CSI program targets U.S.-
bound cargo shipments from 61 foreign ports. Table 3 includes
information obtained from the CSI ports on any change in work practices
or operational procedures the ports implemented as a result of COVID-
19.
Table 3: Information on Container Security Initiative (CSI) Ports and any Impacts of COVID-19 on Work Practices or
Operational Procedures, as of June 2022
CSI Ports Changes in Work Practices and Operational Procedures as a Result of COVID-19
Western 1 Buenos Aires, · There were no changes in work practices as a result of COVID-19.
Hemisphere: Argentina · There were no changes in operational procedures as a result of COVID-19.
8 Countries
CSI officers began to telework in March 2020. Once the COVID restrictions were
with 11 CSI 2 Santos, Brazil ·
lifted, CSI officers returned to work in-person at the port in April 2022.
Ports
· Cargo examinations were requested via email rather than in-person.
· CSI officers were not present to directly observe cargo examinations.
· Results of cargo examinations were sent to CSI officers via email.
3 Cartagena, Colombia · CSI officers began to telework full-time beginning around March 2020. CSI officers
returned to their office at the port using rotational shifts beginning in late 2021.
· Host country officials were not able to conduct all cargo examinations. When host
country officials were unable to conduct cargo examinations, the CSI officers would
request that cargo examinations be conducted at the destination port(s) in the U.S.
4 Caucedo, Dominican · CSI officers began to telework around March 2020 and continued until the COVID
Republic restrictions were lifted in September 2021.
· The host country discontinued the use of hand-delivered hard copy forms to request
cargo examinations and, instead, CSI officers requested cargo examinations via
email.
Page 23 GAO-22-105803 Maritime Cargo Security
Appendix I: Information on Container Security
Initiative (CSI) Ports and Reported Impacts of
COVID-19 on Work Practices or Operational
Procedures
CSI Ports Changes in Work Practices and Operational Procedures as a Result of COVID-19
5 Guayaquil, Ecuador · CSI officers began to telework as a result of COVID restrictions in March 2020, and
continued to telework due to sustained COVID restrictions, as well as for security
reasons as a result of regional violence.
· As of early June 2022, CSI officers were still teleworking.
· All requests for cargo examinations, as well as the results of the cargo
examinations, were transmitted via email.
6 Puerto Cortes, · There were no changes in work practices as a result of COVID-19.
Honduras · CSI officers were not always able to observe the cargo examinations. In such
cases, host country officials would provide the examination results to CSI officers
via email.
7 Kingston, Jamaica · From September 2020 to January 2022, CSI officers teleworked while COVID
restrictions were in place.
· There was a reduction of in-person staffing and the implementation of curfews. In
February 2022, restrictions were gradually lifted by the host country and by March
2022 the port returned to normal operations.
8 Balboa, Panama · Travel restrictions were implemented in early 2020 and CSI officers were not
allowed to travel to the port of Balboa until July 2021. As a result, CSI officers had
to telework during this time period. CSI officers from the port were not authorized to
travel to the Ports of Colon, Cristobal, or Manzanillo until September 2021.
· Through a memorandum of understanding, CSI officers would email Panamanian
Customs to request cargo examinations.
· The cargo examinations requested by CSI officers were fulfilled at a slower pace
due to reduced staff availability as a result of COVID restrictions, but the cargo
examinations continued.
· When CSI officers were not available to observe cargo examinations, Panamanian
Customs provided CSI officers with the results of the examinations via email.
9 Colon, Panama · Because targeting was done remotely from Balboa due to travel restrictions, there
were no changes in work practices as a result of COVID-19.
· CSI officers reduced: (1) the amount of cargo examination requests to ease the
burden on Panamanian Customs personnel; and (2) the number of times they
visited the port due to travel restrictions, so they were not able to observe cargo
examinations as frequently as before COVID.
· When CSI officers from Balboa were not able to travel to the port to observe the
cargo examinations, Panamanian Customs provided CSI officers with the results of
the cargo examinations via email.
10 Cristobal, Panama · Because targeting was done remotely from Balboa due to travel restrictions, there
were no changes in work practices as a result of COVID-19.
· CSI officers reduced: (1) the amount of cargo examination requests to ease the
burden on Panamanian Customs personnel; and (2) the number of times they
visited the port due to travel restrictions, so they were not able to observe cargo
examinations as frequently as before COVID.
· When CSI officers from Balboa were not able to travel to the port to observe the
cargo examinations, Panamanian Customs provided CSI officers with the results of
the cargo examinations via email.
Page 24 GAO-22-105803 Maritime Cargo Security
Appendix I: Information on Container Security
Initiative (CSI) Ports and Reported Impacts of
COVID-19 on Work Practices or Operational
Procedures
CSI Ports Changes in Work Practices and Operational Procedures as a Result of COVID-19
11 Manzanillo, Panama · Because targeting was done remotely from Balboa due to travel restrictions, there
were no changes in work practices as a result of COVID-19.
· CSI officers reduced: (1) the amount of cargo examination requests to ease the
burden on Panamanian Customs personnel; and (2) the number of times they
visited the port due to travel restrictions, so they were not able to observe cargo
examinations as frequently as before COVID.
· When CSI officers from Balboa were not able to travel to the port to observe the
cargo examinations, Panamanian Customs provided CSI officers with the results of
the cargo examinations via email.
Middle East 12 Salalah, Oman · From March 22 to May 24, 2020, CSI officers teleworked as a result of COVID-19.
and Africa: 3 · CSI operational procedures did not change as a result of COVID-19 because CSI
countries owns and operates the cargo examination equipment at the port, so CSI officers
with 3 CSI conduct the examinations (in-person) themselves and do not rely on host country
ports officials to conduct the cargo examinations.
13 Dubai, United Arab · From October 2019 to June 18, 2021, CSI officers teleworked.
Emirates · CSI officers continued to target U.S.-bound cargo shipments, but no cargo
examinations were conducted during October 2019 through June 18, 2021.
· During October 2019 through June 18, 2021, any cargo shipment to be examined
was referred to the National Targeting Center-Cargo to arrange the examination at
the U.S. destination port(s).
· Once cargo examinations resumed on June 19, 2021, CSI officers used a
messaging application to request cargo examinations by Dubai Customs
· CSI officers were generally able to observe the cargo examinations in-person. If a
CSI officer was not able to be physically present for a cargo examination, Dubai
Customs would send the results to CSI officers via email.
14 Durban, South Africa · From March 2020 to July 2021, CSI officers implemented a rotational telework
policy in which one targeting officer would work in-person from the office while the
other worked from home.
· During the period March 2020 to July 2021, any cargo examinations conducted
involved imaging of container contents only and did not involve the use of radiation
detection equipment.
· CSI officers were not able to observe the cargo examinations in person; rather
results of cargo examinations were provided to CSI officers via email.
Asia and 15 Shenzhen, China · In October 2021, CSI officers left the port and, because of visa restrictions, no
Oceana: 9 replacement CSI officers had returned to the port as of June 2022.
countries · While there are no CSI officers at the port, the National Targeting Center-Cargo has
with 15 CSI oversight of the cargo shipments from this port and can work with relevant domestic
ports cargo targeting units to arrange for cargo examinations at U.S. destination ports.
16 Shanghai, China · In April 2021, CSI officers left the port and, because of visa restrictions, no
replacement CSI officers had returned to the port as of June 2022.
· While there are no CSI officers at the port, the National Targeting Center-Cargo has
oversight of the cargo shipments from this port and can work with relevant domestic
cargo targeting units to arrange for any cargo examinations at U.S. destination
ports.
17 Hong Kong · From February 2020 to April 2022, CSI officers implemented a rotating telework
policy in which some CSI officers worked from their residences, but at least one CSI
officer was in the office during duty hours.
· There were no changes in operational procedures as a result of COVID-19.
Page 25 GAO-22-105803 Maritime Cargo Security
Appendix I: Information on Container Security
Initiative (CSI) Ports and Reported Impacts of
COVID-19 on Work Practices or Operational
Procedures
CSI Ports Changes in Work Practices and Operational Procedures as a Result of COVID-19
18 Kobe, Japan · From March 2020 to May 2022, the port implemented a rotational telework policy in
which one CSI officer would work in-person from the office while the other officer
would work from home.
· There were no changes in operational procedures as a result of COVID-19.
19 Nagoya, Japan · From March 2020 to May 2022, the port implemented a rotational telework policy in
which one CSI officer would work in-person from the office while the other officer
would work from home.
· There were no changes in operational procedures as a result of COVID-19.
20 Tokyo, Japan · From March 2020 to May 2022, the port implemented a rotational telework policy in
which one CSI officer would work in-person from the office while the other officer
would work from home.
· In-person observations of cargo examinations by CSI officers were sometimes
suspended at the discretion of the host country. In such instances, results of the
cargo examinations were provided to CSI officers via email.
21 Yokohama, Japan · From March 2020 to May 2022, the port implemented a rotational telework policy in
which one CSI officer would work in-person from the office while the other officer
would work from home.
· There were no changes in operational procedures as a result of COVID-19.
22 Busan, South Korea · From March 2020 to September 2021, the port implemented a rotational telework
policy in which one or two CSI officers would work in-person at the office while
other CSI officers would work from home.
· Beginning in October 2021, one CSI officer teleworks two to three times a week.
· CSI officers were not always present for cargo examinations. When a CSI officer
was not able to observe cargo examinations, the results of the examinations would
be provided to CSI officers via email.
23 Port Klang, Malaysia · From April 2020 to April 2022, CSI officers teleworked because of restrictions
implemented as a result of COVID-19.
· Targeting of U.S.-bound cargo shipments continued, but all cargo examinations
were suspended and did not resume until May 17, 2022.
· CSI officers stated that they were able to resolve any potentially high-risk cargo
shipments using a collection of electronic research tools; as well as officer
knowledge and experience.
24 Tanjung Pelepas, · From April 2020 to April 2022, CSI officers teleworked because of restrictions
Malaysia implemented as a result of COVID-19.
· Targeting of U.S.-bound cargo shipments continued, but cargo examinations were
suspended and had not yet resumed as of June 2020.
· As of June 2022, the CSI program did not have an estimated date for when cargo
examinations will resume at the port.
· CSI officers stated that they have been able to resolve any potentially high-risk
cargo shipments using a collection of electronic research tools, as well as officer
knowledge and experience.
Page 26 GAO-22-105803 Maritime Cargo Security
Appendix I: Information on Container Security
Initiative (CSI) Ports and Reported Impacts of
COVID-19 on Work Practices or Operational
Procedures
CSI Ports Changes in Work Practices and Operational Procedures as a Result of COVID-19
25 Singapore · From June 2020 to April 2022, CSI officers implemented a rotational telework policy
in which a CSI officer would work in-person at the office while other CSI officers
would work from home.
· Beginning in April 2022, CSI officers returned to the office.
· CSI officers were not permitted to directly observe cargo examinations from June
2020 to December 2020. During this time period, results of cargo examinations
were emailed to CSI officers.
· Beginning in December 2020, CSI officers resumed direct observations of cargo
examinations.
26 Colombo, Sri Lanka · There were no changes in work practices as a result of COVID-19.
· The percentage of cargo examinations requested that were actually conducted was
reduced. While all requested cargo examinations were conducted prior to COVID-
19, only 80 percent of the cargo examinations requested were conducted at the
height of the pandemic due to the infection rate among host country officials. As of
June 2022, the cargo examination rate returned to 100 percent.
· Prior to COVID, CSI officers directly observed about half of the cargo examinations
in-person and during COVID there was a reduction in the percentage of cargo
examinations that CSI officers were able to directly observe.
· CSI officers began to request cargo examinations via email. In addition, results of
cargo examinations were also provided to CSI officers for those cargo examinations
that they were not able to observe.
27 Kaohsiung, Taiwan · There were no changes in work practices as a result of COVID-19.
· There were no changes in operational procedures as a result of COVID-19.
28 Keelong, Taiwan · There were no changes in work practices as a result of COVID-19.
· There were no changes in operational procedures as a result of COVID-19.
29 Laem Chabang, · There were no changes in work practices as a result of COVID-19.
Thailand · CSI officers were not always able to directly observe all cargo examinations in-
person. If the officers were not able to observe a cargo examination, the host
country would send the results of the examination to CSI officers via email.
Europe: 9 30 Antwerp, Belgium · CSI officers began to telework starting in April 2020 and returned to work in-person
countries beginning in March 2022.
with 23 CSI · There were no changes in operational procedures as result of COVID-19.
ports
31 Zeebrugge, Belgium · Because this port is covered remotely by CSI officers in Antwerp, there were no
changes in work practices as a result of COVID-19.
· There were no changes in operational procedures as result of COVID-19.
32 Le Havre, France · CSI implemented evolving telework schedules for the CSI officers based on the
changing COVID conditions and restrictions in place.
· From March 2020 to June 2020, the port went into full lock-down and CSI officers
teleworked full-time. Beginning in June 2020, CSI officers started to return to the
office on rotating schedules. As of June 2022, CSI officers each telework one day a
week.
· For the period of March 2020 through October 2021, CSI officers were not able to
directly observe cargo examinations and would, instead, receive the results of the
cargo examinations via email to review.
· CSI officers have generally been present for cargo examinations beginning in
November 2021.
Page 27 GAO-22-105803 Maritime Cargo Security
Appendix I: Information on Container Security
Initiative (CSI) Ports and Reported Impacts of
COVID-19 on Work Practices or Operational
Procedures
CSI Ports Changes in Work Practices and Operational Procedures as a Result of COVID-19
33 Marseille, France · Because this port is covered remotely by CSI officers in Le Havre, there were no
changes in work practices as a result of COVID-19.
· There was a reduction in the number of in-person meetings with host country
officials during periodic visits to the port. Due to COVID-19 restrictions, no in-person
meetings took place between CSI officers and French officials during March 2020 to
May 2022.
34 Bremerhaven, · CSI implemented evolving telework schedules for the CSI officers based on the
Germany changing COVID conditions and restrictions in place, as well as to mimic the work
practices of the host country counterparts.
· From March 2020 to August 2021, CSI officers teleworked full-time. As of August
2021, CSI officers began using rotational telework schedules.
· Work practices returned to pre-COVID routines beginning in March 2022.
· There were no changes in operational procedures as result of COVID-19.
35 Hamburg, Germany · CSI implemented evolving telework schedules for the CSI officers based on the
changing COVID conditions and restrictions in place.
· From March 2020 to August 2021, CSI officers teleworked full-time and, as of
August 2021, CSI officers began using rotational telework schedules.
· Beginning in October 2021, CSI officers (1 per day) began reporting to the office 5
days per week.
· CSI officer work practices returned to pre-COVID routines in March 2022.
· There was a reduction of in-person contact with host country officials. Requests for
cargo examinations, as well as the results of cargo examinations, were conveyed
using email. Prior to the COVID restrictions, CSI officers could request cargo
examinations in person and were able to observe the cargo examinations.
· Port Operations in Hamburg, Germany returned to pre-COVID conditions effective
June 1, 2022. CSI officers returned to their office and have resumed in-person
contact with German Customs officials.
36 La Spezia, Italy · Beginning in March 2020, the port went into full lockdown and CSI officers
teleworked full-time. Starting in June 2020, the CSI officers began returning to the
office on a rotational basis while still maintaining some telework. Some degree of
telework will continue until the U.S. Embassy approves a return to work full-time.
· In-person interactions between the CSI officers and their host country counterparts
were discontinued during March 2020 to June 2020.
· All direct observations of cargo examinations by CSI officers ceased during March
2020 – June 2020.
· Starting in June 2020, one CSI officer was present during cargo examinations.
· As of June 2022, requests for cargo examinations continued to be communicated
using the CSI’s remote targeting platform, email, or via telephone calls.
37 Livorno, Italy · Because this port is covered remotely by CSI officers in La Spezia, there were no
changes in work practices as a result of COVID-19.
· There was a reduction in the number of visits to the port to conduct in-person
meetings with host country officials.
38 Genoa, Italy · Because this port is covered remotely by CSI officers in La Spezia, there were no
changes in work practices as a result of COVID-19.
· There was a reduction in the number of visits to the port to conduct in-person
meetings with host country officials.
Page 28 GAO-22-105803 Maritime Cargo Security
Appendix I: Information on Container Security
Initiative (CSI) Ports and Reported Impacts of
COVID-19 on Work Practices or Operational
Procedures
CSI Ports Changes in Work Practices and Operational Procedures as a Result of COVID-19
39 Naples, Italy · In March 2020, CSI officers began teleworking full-time and have maintained a
rotational telework posture since. Fifty (50) percent of employees work in-person at
the office and 50 percent telework from their residences.
· As of June 2022, the State Department and host country continued to urge the use
of telework. Once all COVID restrictions are lifted, CSI officers plan to return to the
office full-time.
· Notifications about when requested cargo examinations were to occur were
provided via email or telephone whereas before COVID such notifications were
done in-person.
40 Gioia Tauro, Italy · Because this port is covered remotely by CSI officers in Naples, there were no
changes in work practices as a result of COVID-19.
· There were no changes in operational procedures as a result of COVID-19.
41 Salerno, Italy · Because this port is covered remotely by CSI officers in Naples, there were no
changes in work practices as a result of COVID-19.
· There were no changes in operational procedures as a result of COVID-19.
42 Cagliari, Italy · Because this port is covered remotely by CSI officers in Naples, there were no
changes in work practices as a result of COVID-19.
· There were no changes in operational procedures as a result of COVID-19.
43 Rotterdam, The · There were no changes in work practices as a result of COVID-19.
Netherlands · There were no changes in operational procedures as a result of COVID-19.
44 Sines, Portugal · The port experienced two lockdowns. From March to May 2020, and from January
to April 2021, CSI officers were not allowed at the port and were required to
telework.
· From June 2020 to January 2021, and from April to December 2021, the port
experienced partial lockdowns during which time CSI officers worked in-person at
the office 50 percent of the time and teleworked from their homes 50 percent of the
time.
· In January 2022, CSI officers returned to work in-person at the office full-time and
had to wear masks. Beginning in April 2022, the mask requirement ended. CSI
officers have continued to work from the office full-time.
· CSI officers were not permitted to travel to the port during the two lockdown
phases, so all communication with their host country counterparts had to occur via
email or telephone.
· CSI officers were not able to be present for cargo examinations during the
lockdown phases.
45 Algeciras, Spain · During March 2020 to May 2022, CSI officers teleworked, with one officer in the
office and one teleworking. Since March 2022, CSI officers have been in the office
full-time.
· When the CSI officers teleworked, cargo examination requests were made using
email or telephone calls.
46 Barcelona, Spain · During March 2020 to February 2022, CSI officers teleworked, with one officer in
the office and one teleworking. Since February 2022, all CSI officers have been in
the office full-time.
· When the CSI officers teleworked, cargo examination requests were made using
email or telephone calls.
Page 29 GAO-22-105803 Maritime Cargo Security
Appendix I: Information on Container Security
Initiative (CSI) Ports and Reported Impacts of
COVID-19 on Work Practices or Operational
Procedures
CSI Ports Changes in Work Practices and Operational Procedures as a Result of COVID-19
47 Valencia, Spain · During March 2020 to June 2020, CSI officers teleworked full-time due to COVID
restrictions. Beginning in June 2020, COVID restrictions were eased some and the
CSI officers began to use rotational telework, with one officer in the office and one
teleworking. Since May 2022, CSI officers have been in the office full-time.
· When the CSI officers teleworked, cargo examination requests were made using
email or telephone calls.
48 Gothenburg, Sweden · Because this port is covered remotely by CSI officers in other locations—previously
Naples, Italy and now Bremerhaven, Germany (effective May 2022)—there were no
changes in work practices as a result of COVID-19.
· There were no changes in operational procedures as a result of COVID-19. Rather,
the operational changes were brought about by changes in the routing of cargo
from Gothenburg to the U.S.in April 2022
· Prior to April 2022, the port did not have any direct cargo container routes to the
United States and contact was maintained via email to maintain relationships.
Because of this new direct cargo routing between Gothenburg and the U.S., CSI
officials have held discussions with Swedish Customs officials to re-establish CSI
operations in Gothenburg.
49 Felixstowe, United · From March 2020 to March 2021, CSI officers teleworked full-time. Beginning in
Kingdom March 2021, CSI officers switched to using a rotational telework policy in which they
would split time between coming into the office and teleworking.
· CSI officers returned to work in-person full-time beginning in May 2022.
· From March 2020 to May 2021, CSI officers were not authorized to observe cargo
examinations and were, instead, provided the results of cargo examinations via
email.
· CSI officers were authorized to resume observing cargo examinations beginning in
May 2021.
50 Southampton, United · Because this port is covered remotely by CSI officers in Felixstowe, there were no
Kingdom changes in work practices as a result of COVID-19.
· There were no changes in operational procedures as a result of COVID-19.
51 Tilbury, United · Because this port is covered remotely by CSI officers in Felixstowe, there were no
Kingdom changes in work practices as a result of COVID-19.
· There were no changes in operational procedures as a result of COVID-19.
52 London Gateway, · Because this port is covered remotely by CSI officers in Felixstowe, there were no
United Kingdom changes in work practices as a result of COVID-19.
· There were no changes in operational procedures as a result of COVID-19.
National 53 Montreal, Canada · Because targeting was done remotely from NTC-C, there were no changes in work
Targeting practices or operational procedures as a result of COVID-19.
Center- 54 Vancouver, Canada · Because targeting was done remotely from NTC-C, there were no changes in work
Cargo (NTC- practices or operational procedures as a result of COVID-19.
C): 6
countries 55 Halifax, Canada · Because targeting was done remotely from NTC-C, there were no changes in work
with 9 CSI practices or operational procedures as a result of COVID-19.
ports, all 9 56 Qasim, Pakistan · Because targeting was done remotely from NTC-C, there were no changes in work
of which are practices or operational procedures as a result of COVID-19.
targeted 57 Haifa, Israel · Because targeting was done remotely from NTC-C, there were no changes in work
remotely practices or operational procedures as a result of COVID-19.
58 Ashod, Israel · Because targeting was done remotely from NTC-C, there were no changes in work
practices or operational procedures as a result of COVID-19.
Page 30 GAO-22-105803 Maritime Cargo Security
Appendix I: Information on Container Security
Initiative (CSI) Ports and Reported Impacts of
COVID-19 on Work Practices or Operational
Procedures
CSI Ports Changes in Work Practices and Operational Procedures as a Result of COVID-19
59 Melbourne, Australia · Because targeting was done remotely from NTC-C, there were no changes in work
practices or operational procedures as a result of COVID-19.
60 Auckland, New · Because targeting was done remotely from NTC-C, there were no changes in work
Zealand practices or operational procedures as a result of COVID-19.
61 Aqaba, Jordan · Because targeting was done remotely from NTC-C, there were no changes in work
practices or operational procedures as a result of COVID-19.
Source: GAO analysis of information provided by Container Security Initiative (CSI) officials. I GAO-22-105803
Notes: Cargo “examinations” generally refer to collecting a non-intrusive inspection (NII) image of the
contents of the requested containerized cargo container shipments and, in some locations, also
scanning the selected cargo containers for any radiological emissions using a radiation portal monitor
(RPM) or other, similar equipment.
For the purposes of this table: (1) changes in work practices refers to the use of telework versus
reporting to the CSI office in-person, and (2) changes in operational procedures refers to factors such
as whether CSI officers were able to directly observe and participate in requested cargo examinations
versus not being allowed to observe cargo examinations and having to review documentation of the
examination results after they are completed.
Page 31 GAO-22-105803 Maritime Cargo Security
Appendix II: GAO Contact and Staff
Acknowledgments
Appendix II: GAO Contact and
Staff Acknowledgments
GAO Contact
Heather MacLeod at 202-512-8777 or macleodh@gao.gov.
Staff Acknowledgements
In addition to the contact named above, Christopher Conrad (Assistant
Director), Jason Jackson (Analyst-in-Charge), and Yasmine Evans made
key contributions to this report. Nasreen Badat, Ben Crossley, Michele
Fejfar, and Tracey King also contributed to this report.
(105803)
Page 32 GAO-22-105803 Maritime Cargo Security
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