Container Inspection Targeting Process and Instructions for CIP Field Guide

Encl. (1) to COMDTINST 16616.11B

CONTAINER INSPECTION TARGETING PROCESS &

INSTRUCTIONS FOR CIP FIELD GUIDE

Statistics gathered since the inception of the Container Inspection Program (CIP) have been

analyzed, and continue to show an unacceptable rate of non-compliance with the Hazardous

Materials regulations. This fact has been noted by both the Department of Transportation's

Office of the Inspector General (DOTOIG), and most recently by the House and Senate

Committees on Appropriations, who have expressed concern about the inspection procedures

employed at the port level. The recent audit of the CIP by the DOTOIG identified the need to

improve the Coast Guard's method of targeting those cargoes posing the greatest risk to the

public. The DOTOIG also was concerned the Coast Guard was not inspecting general cargo to

determine if hazardous materials were being shipped without being declared. In response, the

Coast Guard developed three major program improvements, the first being the new inspection

form CG-5577, which was issued October 1, 1998.

Enclosure (2) combines the other two major improvements into a new targeting process for

hazardous materials container inspections; (a) a process flow chart and risk ranking matrix, and

(b), a random selection process for undeclared cargoes. Units shall discontinue use of the

targeting matrix given in Reference (a) and all locally developed targeting systems.

Commandant (G-MOC) developed these new processes to ensure uniformity of selection

throughout the program, to avoid any appearance of arbitrary enforcement, and in response to

the DOTOIG recommendations from the September 8, 1998 audit of the Container Inspection

Program.

The scoring system in Enclosure (2) is based on an analysis of actual hazardous materials

incident consequence data. The detailed basis for the ranking is briefly described below, is

designed to reduce the calculations needed by field personnel, and identify those containers

posing the greatest risk to the public.

Enclosure (2) is intended to be a self-contained job aid for container inspectors. The following

are brief explanations and expansions on each step:

SIDE A - Declared shipments:

Step 1: Select Inbound Ship: To make the most of limited resources, the Coast Guard intends

to focus principally on containers entering the United States. Export containers have passed

through several safety nets (industry standards and other modal administration jurisdictions)

before arriving at the marine terminal. By contrast, enforcement of hazardous materials

regulations varies widely overseas, and in many cases, the Coast Guard provides the first

safety net for hazardous materials entering the U.S. transportation system. Inbound ships can

be pre-selected from Notices of Arrival, published regular schedules, from information

acquired from U.S. Custom's data sources (a separate test program being conducted in 4

coastal ports), or other means. Although the Coast Guard is