The Office of Inspector General (OIG) has again been critical of canine teams within the Department of Homeland Security. In May 2020, OIG found a number of faults with the Transportation Security Administration’s Passenger Screening Canine unit, including a failure to determine the number of teams needed to provide security and mitigate risks.
Now, its latest report says U.S. Customs and Border Protection’s (CBP) training approach and execution do not fully support the canine teams’ mission of detecting smuggling of illegal narcotics, agriculture products, and humans at and between ports of entry.
Canine teams play a vital role in detecting people, illicit goods, and prohibited agricultural items from entering the country illegally. CBP’s Canine Program is the largest canine program in the Department of Homeland Security, with more than 1,500 canine teams deployed. The primary goal of CBP canine teams, each consisting of a certified detection canine and a certified handler, is to detect and apprehend persons attempting entry into the United States whose intent is to organize, incite, and carry out acts of terrorism. The Canine Program’s secondary goal is detection and seizure of controlled substances and other contraband, often used to finance terrorist and criminal drug trafficking organizations.
In fiscal year 2019, CBP decided to realign its Canine Academy, which contributed to a decrease of canine teams trained in the first two quarters of FY 2020. This occurred, OIG says, because CBP did not adequately plan for the realignment or measure performance to demonstrate how the realignment would affect canine performance. The watchdog found that the Office of Field Operations (OFO) canine teams used pseudo narcotic training aids past the recommended replacement cycle (outdated). Both Border Patrol and OFO canine teams used outdated actual narcotic training aids during proficiency training in the field. Additionally, OFO canine team files did not have required proficiency training documentation. OIG said in its February 8 report that use of outdated training aids and the missing documentation occurred because CBP Canine Program management did not provide adequate oversight to ensure training aids were available to canine teams and certified instructors were properly documenting proficiency training.
At the time of OIG’s fieldwork, Border Patrol and OFO Canine Program policies and procedures had not been updated in more than nine years, despite changes in the operational environment.
Ultimately, OIG found CBP’s inadequate governance of canine team operations led to outdated Canine Program policies and procedures, inconsistent retention periods for training documents, and an absence of Canine Tracking System policies and procedures. This inadequate governance ensued because CBP Canine Program management did not prioritize program management as other challenges took precedence.
To address the shortcomings discovered in its review, OIG has made four recommendations, with which CBP has concurred:
First – develop a comprehensive assessment of the realignment of the Canine Program to ensure implementation according to the Office of Training and Development’s training standards. The assessment should: ensure the training curriculum aligns with component policies, strategic plans, and if applicable, specific Canine Program strategic plans; and evaluate post-graduation performance measures to validate efficiency and effectiveness of the component specific objectives and curriculum to demonstrate continual improvement in the canine training program.
To meet this recommendation, Border Patrol and OFO will provide applicable policies and strategic planning documents to the Office of Training and Development (OTD). Additionally, they will assist OTD with post-graduation performance measures to validate efficiency and effectiveness of component-specific objectives and continued improvement of the canine training program. Work is expected to be complete by October 31, 2021.
Next, CBP should ensure the Canine Program has enough certified canine instructors and adequate training aids to provide proficiency training for canines after they are deployed. This should include: implementing a process to ensure sufficient staff are available to provide all training needs to U.S. Border Patrol and the Office of Field Operations canine teams; and creating a systemic schedule and plan for pseudo and actual narcotic replacement for every U.S. Border Patrol sector and Office of Field Operations field office within the time recommended by the Laboratories and Scientific Services Directorate.
Border Patrol officials asserted their 471 canine instructors are capable of providing the required training and accompanying documentation. Border Patrol will improve applicable training documentation and processes to include adding the instructor-to-student ratio of 1:5; standardizing the training aid acquisition, establishing an automatic training aid replenishment system; and coordinating with the Laboratories and Scientific Services Directorate (LSSD) on courses of action.
The third recommendation calls for a study to determine the appropriate time for replacement of pseudo and actual narcotics to limit the constant expiration of these training aids. Pseudo and actual narcotic replacement cycles should be updated according to the results of the LSSD study.
LSSD will work with Border Patrol, OFO, and OTD canine components to collect and replace training aids that are nearing, or past, their recommended replacement dates. LSSD will create a standard operating procedure that outlines the actions needed for this study and has begun collection of training aids. LSSD will perform chemical testing on those collected aids to determine whether noticeable changes are present that may be detrimental to the aids’ effectiveness. By June 30, 2021, LSSD anticipates completing analysis and assessment. LSSD will update policies and procedures with training aid lifecycles based on scientific results, risk-minimization, and practicality with the CBP canine components. CBP expects all work to meet the recommendation to be complete by September 30, 2021.
Finally OIG recommends CBP update the Canine Program policies to provide adequate oversight to ensure program needs are being met. The policies should include: record retention timelines for all training documents to be consistent with the CBP Records General Schedule or provide adequate documentation on retention policies after consultation with record retention personnel to determine the appropriate approach; a systematic schedule and plan for pseudo and actual narcotic training aids; and development of standard operating policies, procedures, and quality assurance measures for use of the Canine Tracking System.
Border Patrol and OFO will collaborate on specific policies that define the appropriate retention timeframe for Border Patrol and OFO canine documents, and will collaborate with LSSD to establish a narcotic replacement standard operating procedure. Border Patrol will establish policies for the use of the Canine Tracking System. OFO will update policies to ensure adequate oversight and program needs are met, to include appropriate records retention in accordance with the agency records management plan. The estimated date of completion for this final recommendation is October 31, 2021.
For its part and in response to OIG’s May 2020 report, TSA has already been at work developing its Capability Strategic Road Map for Passenger Screening Canine teams and is scheduled to complete an annual assessment by the end of March this year.