High Risk Containers Should be Inspected Before Lower Risk Contai

To compare the effectiveness of the Coast Guard’s targeting process with the various container selection processes used by inspectors, we applied Coast Guard’s targeting system to 10 days of inspection activity in 1998. Using the criteria prescribed by the targeting system we were able to relatively rank the
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containers and determine which ones posed the highest risk. We then compared our results with what the Coast Guard actually inspected during the same 10 days. We found that 68-percent of the containers the Coast Guard inspected were not ranked sufficiently high to have been selected for inspection had the targeting system been applied.
The Exhibit to this report shows the high and lower risk containers actually inspected at 10 terminal facilities selected for review. By inspecting lower risk containers at the expense of higher risk containers, inspection resources are not being used effectively. For example:


• On May 5, 1998, Coast Guard inspectors conducted container inspections at the Global terminal in Bayonne, New Jersey. On the day of inspection, there were 42 identified hazardous material containers at the terminal. The Coast Guard inspector stated he did not use the targeting process to select the nine hazardous material containers he inspected. Our application of the Coast Guard’s targeting system to the universe of hazardous material containers showed that the Coast Guard only inspected three of the nine highest risk containers.
• On April 14, 1998, Coast Guard inspectors in Los Angeles conducted container inspections at the Hanjin terminal. There were 110 hazardous material containers at the terminal that day. The Coast Guard inspected 12 of them. Our application of Coast Guard’s targeting system to the universe of containers carrying hazardous materials showed that Coast Guard only inspected one of the 12 highest risk containers.

In making this comparison, we excluded data pertaining to shipper violation history because it was not available at the terminal. To determine whether excluding this information affects the validity of the comparison, we included shipper violation history when applying the Coast Guard’s targeting system for two of the ten days reviewed. The results of our comparison did not change because of the small number of points assigned to the shipper violation history. However, research into shipper violation history, which can be accomplished by the inspector contacting the local Coast Guard field office, could provide information to the inspector regarding shippers who have a history of violations.

On May 12, 1998, Coast Guard inspectors in San Francisco conducted container inspections at the Matson terminal. There were 81 hazardous material containers at the terminal that day. The Coast Guard inspected three. We applied Coast Guard’s targeting system and found that the Coast Guard did not inspect any of the highest risk containers. The highest risk container inspected by the Coast Guard ranked 26th according to their targeting system.

After our fieldwork was completed, the National Coordinator for the Container Inspection Program advised us the Coast Guard was considering alternative sources to obtain timely data easier and facilitate the use of its targeting process. In the interim, the Coast Guard will continue to obtain information from shipping terminal operators, and utilize Dangerous Cargo Manifests to identify containers with hazardous materials and to identify those posing the most risk. Information from these sources, and violation information from the Marine Safety Information System, will permit the Coast Guard to utilize its targeting system until easier and more timely sources of data are accessible. For example, access to the Research and Special Programs Administration’s UNISHIP database is being explored as a method of easily obtaining data for the Coast Guard targeting system, as is access to U.S. Customs ACS interactive cargo database. Once more efficient data sources have been developed, the Coast Guard will still need to establish controls for ensuring that the targeting system is implemented at it field locations and is accomplishing program goals.

In addition, the Department Of Transportation will conduct an agency-wide program evaluation of the hazardous materials transportation program. We will participate in the evaluation, which will allow the Department to determine the effectiveness of the current program structure, including the division of responsibilities and the allocation of resources across and within the operating administrations. This evaluation could identify additional opportunities to increase the level of safety and environmental protection when hazardous materials are in commerce.