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GAO: CBP Could Improve Non-Containerized Maritime Cargo Security

Non-containerized cargo can present inspection challenges for CBP officials because crates can hide contraband and may include additional barriers to examination.

U.S. Customs and Border Protection (CBP) should improve its guidance and identify additional actions its personnel could take to reduce crated cargo risks, a new report from the Government Accountability Office (GAO) says.

Non-containerized cargo—like oil or goods in individual crates or pallets—can present inspection challenges for CBP officials because crates can hide contraband and may include additional barriers to examination. In 2020, non-containerized cargo accounted for about 32 percent of the $1.5 trillion total maritime cargo value. 

CBP policies and guidance allow for variation in maritime port of entry (seaport) inspections of non-containerized cargo provided CBP personnel at seaports follow minimum inspection requirements. A GAO review found that CBP’s inspection procedures and practices for non-containerized cargo varied across the 11 seaports it reviewed. Local factors such as the availability of inspection equipment and the type and size of cargo contributed to this variation.

GAO noted in its July 22 report that inspection approaches at some seaports may not fully address the increasing risks related to one type of non-containerized cargo—crated cargo. Specifically, CBP’s guidance states that some crated non-containerized cargo has grown in size and these shipments pose increasing levels of risk in the maritime environment. This is because crated cargo offers the same level of concealment for contraband or other restricted items as a shipping container and may present additional barriers to examination.

CBP inspection requirements for all non-containerized cargo provide that CBP personnel at seaports are to review information for shipments identified as high-risk. Further, personnel are to, at minimum, physically examine shipments placed on hold for examination through its risk assessment process. However, GAO found that CBP did not identify additional inspection actions above the minimum requirements for CBP personnel at seaports to address crated cargo risks.

CBP’s inspection process begins with screening and targeting—i.e. conducting an individualized assessment of risk for each shipment—to identify potential high-risk non-containerized cargo shipments. In particular, each non-containerized cargo shipment undergoes an automated risk assessment using the CBP’s Automated Targeting System (ATS). Through this process, ATS flags potential high-risk shipments and places a hold on them in the system for further review by CBP’s targeting personnel at seaports. Targeting personnel at seaports then conduct additional research and analysis to further assess risk and determine which of the ATS-identified high-risk non-containerized shipments to examine. Based on screening and targeting risk assessments, CBP officers examine certain non-containerized cargo shipments to mitigate their potential threats. CBP also encourages targeting personnel at seaports to conduct discretionary targeting to assess risk and identify other potentially high-risk non-containerized shipments that ATS did not automatically flag.

At the nine seaports GAO reviewed that processed crated cargo, CBP applied a range of approaches to its inspections. For example, at five seaports, CBP had additional procedures that may address crated cargo’s risk, such as subjecting all crated cargo shipments to examination. However, the watchdog found that CBP’s procedures at the other four seaports follow CBP’s minimum requirements for examining shipments flagged as high-risk and do not subject other crated cargo to examination. Examination methods include the use of non-intrusive inspection technology, such as X-ray equipment and radiation detection monitors to scan and image the cargo; physical searches; visual observations while the cargo is unloaded; and use of canine detection.

The type of inbound non-containerized cargo and the size or dimensions of the cargo also affect the extent of CBP’s examination activities. Officials from nine of the 11 seaports GAO reviewed stated that examining bulk cargo, such as salt, sand, or oil, can be hazardous and present risk of physical injury or safety concerns for inspection officers. As a result, officials from seven of these nine seaports stated that, for this type of non-containerized cargo, they are generally limited to conducting visual observations as the vessel unloads.

Other challenges facing CBP include staffing levels, the allocation of non-intrusive inspection equipment, and the adequacy of inspection facilities at seaports. CBP officials representing two of seaports GAO reviewed stated that they would benefit from having additional non-intrusive imaging equipment or new technology to operate radiation portal monitors to help expedite maritime cargo examination processes.

The government watchdog has made two recommendations to improve non-containerized cargo security at seaports. First, GAO wants CBP to identify additional actions that its personnel at seaports should take to address the risks of crated break bulk cargo. Subsequently, CBP should update national maritime cargo processing guidance to reflect the identified actions. 

The Department of Homeland Security agreed with the recommendations and said CBP plans to enhance existing risk mitigation strategies for crated break bulk cargo to include identifying additional recommended measures, such as the use of canine resources and non-intrusive inspection technology to detect radiation, among others; and that the component will then update its national maritime guidance to reflect the procedural enhancements, which it expects to do by the end of November 2022.

Read the full report at GAO

Kylie Bielby
Kylie Bielby has more than 20 years' experience in reporting and editing a wide range of security topics, covering geopolitical and policy analysis to international and country-specific trends and events. Before joining GTSC's Homeland Security Today staff, she was an editor and contributor for Jane's, and a columnist and managing editor for security and counter-terror publications.

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