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Supply Chain Security: U.S. Customs and Border Protection Has Enhanced Its Partnership with Import Trade Sectors, but Challenges Remain in Verifying Security Practices

GAO-08-240 Published: Apr 25, 2008. Publicly Released: May 27, 2008.
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Highlights

U.S. Customs and Border Protection (CBP) is responsible for ensuring the security of cargo containers shipped into the United States. To strike a balance between security and commerce, CBP oversees the Customs-Trade Partnership Against Terrorism, or C-TPAT program. As part of this program, CBP aims to secure the supply chain--the flow of goods from manufacturers to retailers--through partnerships with international trade companies. Member companies agree to allow CBP to validate their security practices and, in exchange, they are awarded benefits, such as reduced scrutiny of their cargo. In 2005, GAO reviewed the C-TPAT program and noted operational challenges. For this report, GAO was asked to assess the progress CBP has made since 2005 in (1) improving its benefit award policies for C-TPAT members, (2) addressing challenges in validating members' security practices, and (3) addressing management and staffing challenges. To perform this work, GAO analyzed a nonprobability sample of completed validations; reviewed annual, human capital, and strategic plans; and held discussions with CBP officials.

Recommendations

Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Homeland Security To improve CBP's implementation of SAFE Port Act provisions and to strengthen C-TPAT program management, ensure adequate internal controls to manage the program, provide management with complete program data for decision making, and establish indicators of the program's impact on supply chain security, the Secretary of Homeland Security should direct the Commissioner of U.S. Customs and Border Protection to continue to improve the consistency with which validations are conducted and documented by revising the electronic instrument used in validations to include appropriate response options and eliminate the use of default "no" responses.
Closed – Implemented
U.S. Customs and Border Protection reported in October 2009 that it has responded to our recommendation by eliminating the default "no" response and reprogramming the instrument to allow for response options of "yes," "no," "other," and "best practices."
Department of Homeland Security To improve CBP's implementation of SAFE Port Act provisions and to strengthen C-TPAT program management, ensure adequate internal controls to manage the program, provide management with complete program data for decision making, and establish indicators of the program's impact on supply chain security, the Secretary of Homeland Security should direct the Commissioner of U.S. Customs and Border Protection to strengthen the evaluation of security during validations by requiring validations to include the review and assessment of any available results from audits, inspections, or other reviews of a member's supply chain security.
Closed – Implemented
U.S. Customs and Border Protection (CBP) reported in October 2009 that it responded to our recommendation by issuing policy guidance on May 30, 2008 that instructs field directors to require supervisory supply chain specialists to request this type of information from Customs-Trade Partnership Against Terrorism members as part of preparing for the validation visit. CBP has also included a question in its automated validation reports system that requires specialists to document whether an external audit was conducted on the importer's supply chain security program.
Department of Homeland Security To improve CBP's implementation of SAFE Port Act provisions and to strengthen C-TPAT program management, ensure adequate internal controls to manage the program, provide management with complete program data for decision making, and establish indicators of the program's impact on supply chain security, the Secretary of Homeland Security should direct the Commissioner of U.S. Customs and Border Protection to ensure that C-TPAT validation report recommendations are implemented by establishing a policy for security specialists to follow up with member companies when CBP requires them to make security enhancements to ensure that the necessary steps are taken.
Closed – Implemented
U.S. Customs and Border Protection (CBP) reported that it responded to our recommendation by issuing policy guidance on June 13, 2008 which instructs field directors and supervisors to immediately require supply chain specialists to ensure required actions and recommendations are completed. CBP has also created an automated platform in its electronic data-gathering instrument to track and capture the content and communication between the specialists and Customs-Trade Partnership Against Terrorism members.
Department of Homeland Security To improve CBP's implementation of SAFE Port Act provisions and to strengthen C-TPAT program management, ensure adequate internal controls to manage the program, provide management with complete program data for decision making, and establish indicators of the program's impact on supply chain security, the Secretary of Homeland Security should direct the Commissioner of U.S. Customs and Border Protection to ensure that the C-TPAT Portal records management system completely documents key data elements needed to track compliance with SAFE Port Act and other CBP internal requirements.
Closed – Implemented
U.S. Customs and Border Protection (CBP) reported that it responded to our recommendation by making programming changes to the system to automatically document time sensitive decisions mandated by the Security and Accountability For Every Port Act, specifically 90-day certification, validation within 1 year of a company being certified, and re-validation within 3 years of the initial validation. CBP provided screen shots of their system to demonstrate this change.
Department of Homeland Security To improve CBP's implementation of SAFE Port Act provisions and to strengthen C-TPAT program management, ensure adequate internal controls to manage the program, provide management with complete program data for decision making, and establish indicators of the program's impact on supply chain security, the Secretary of Homeland Security should direct the Commissioner of U.S. Customs and Border Protection to identify and pursue opportunities in information collected during C-TPAT member processing activities that may provide direction for developing performance measures of enhanced supply chain security.
Closed – Implemented
U.S. Customs and Border Protection (CBP) reported that it responded to our recommendation by working to identify output measures to quantify actions required and to gauge Customs-Trade Partnership Against Terrorism's impact on supply chain security. CBP provided us with examples of analytical tools that are currently in development and may provide direction for developing performance measures. CBP officials explained how information from the automated validation reports system may provide the basis for trend analysis and developing performance measures.

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Border controlBorder securityCargo securityEntry securityHomeland securityHuman capital managementImport regulationImport restrictionInternational relationsInternational tradeInternational trade regulationInternational trade restrictionPerformance measuresPolicy evaluationPort securityPort security assessment programProgram evaluationProgram managementRecords managementRisk assessmentRisk factorsRisk managementSecurity assessmentsSecurity policiesSecurity regulationsSecurity threatsStaff utilizationSupply chain management