Moving Targets

Alix Garnier crawls out from under a steel shipping container of aluminum coils at the Baltimore seaport, gingerly holding a glass vial between his thumb and forefinger. The agriculture specialist for U.S. Customs and Border Protection squints at the tiny object inside.

Nearby, Garnier’s colleague, CBP Agriculture Specialist (CBPAS) Timothy Morris, has found mollusks on the exterior of the same cargo container. One of the snails was identified as an Amber Snail (Succineidae, sp.)—and that’s enough to warrant sending the container back to South Africa.

A few miles inland, at the CBP Centralized Examination Station, CBPAS John Taylor is lying on the ground with a flashlight, peering underneath and through the slats of rough wooden pallets that hold stacks of terra cotta flower pots. At this moment, he’s more worried about seeds than splinters.

One of CBP’s many important responsibilities is to prevent potentially harmful or dangerous plant and animal material from entering the U.S. This includes insect pests, invasive plants, plant pathogens, and prohibited animal products that could be carrying diseases that could hurt U.S. livestock or humans.

In fiscal year 2016, CBP agriculture specialists conducted more than 9,800 cargo inspections at the Baltimore seaport.

The primary commodities that come through the port are salt, automobiles, sugar, gypsum, plywood, paper, iron ore, oil, and aluminum. Most of these commodities seem like they would be fairly low-risk for agriculture violations—compared to the tons of cut flowers that arrive in Miami, for example.

But Garnier and Taylor know all too well that some dangers are lurking in—and on—the containers themselves, or in the ubiquitous wooden shipping pallets. In fact, of CBP’s 328 international ports of entry, the Port of Baltimore ranks number one in general cargo “reportable” pests – those that are reported to the U.S. Department of Agriculture.

Meanwhile, 55 miles southwest of where Garnier, Morris, and Taylor are working, in a highly secure state-of-the-art office building in Northern Virginia, five specially trained agriculture specialists are scanning screens to see what sorts of agriculture cargo are on its way to our nation’s 328 land, air, and sea ports of entry. They occupy just a tiny corner of a vast open sea of hundreds of desks staffed by experts on counterterrorism, immigration admissibility, and other specialized disciplines aimed at securing the U.S. border. 

Welcome to the National Agriculture Cargo Targeting Unit, or NACTU. These analysts provide key intelligence to frontline agriculture specialists like Garnier and Taylor, letting them know if a shipment warrants further scrutiny.

The NACTU researches cargo shipments being imported to the U.S. and analyzes national agriculture quarantine activity to identify shipments that pose a significant risk to U.S. agriculture and natural resources. These potential threats include animal pathogens that could harm livestock and people; invasive plants that could damage our ecosystems; and insect pests and plant diseases that could hurt crops and forests.

Identifying the need

The idea for creating a targeting unit specifically on agriculture cargo originated nearly a decade ago, but efforts got under way in earnest in 2014 when the CBP Office of Field Operations’ Agriculture Programs and Trade Liaison office contacted CBP’s National Targeting Center, or NTC, to explore options for piloting the unit and collocating it at the cargo portion of the NTC’s facility outside Washington, D.C.

“We assembled a working group of subject matter experts from various field offices and worked closely with NTC advisers to develop plans to pilot a unit,” recalled Supervisory CBP Agriculture Specialist Nikki Thomas, one of the founders of the NACTU. CBP conducted six pilot cycles before establishing the NACTU as a permanent, full-time unit in September 2015 as part of the Agriculture Safeguarding Unit. 

The five permanent NACTU targeters are led by Branch Chief Nidhi Singla, and they receive assistance from interns who rotate in from the field, bringing valuable knowledge and expertise with them about trends they see developing at the ports of entry.

“The goal is to cross-pollinate knowledge we have residing in the field with that of our permanent targeters here in NACTU, and then to send them back to the ports with the knowledge they receive here,” said Singla.

The targeters have varied backgrounds and experience. For example, after earning a bachelor’s degree in biology, Agriculture Operations Manager Samuel Broom interned with U.S. Fish and Wildlife Service in New Hampshire, researching the spawning habits of Atlantic salmon, and then tracking desert tortoises in the Mojave Desert for the U.S. Geological Survey. 

“We focus not just on agriculture materials themselves—fruits and vegetables and animal products that could harbor pests and diseases—we also look at the miscellaneous commodities that are also capable of harboring pests and pathogens, such as wood packaging materials like pallets, as well as tiles and even steel,” said Singla.

Shipments are sent from the Baltimore seaport to the examination station if CBP believes they merit further inspection. At the station warehouse, agriculture specialists are inspecting a shipment of nails from China—packed on wooden pallets. The reason for the referral: targeters had information indicating the shipment may be contaminated with a weed seed of Imperata cylindrica, or cogongrass, which is classified as a federal noxious weed, or FNW.

Many types of weed seeds—like those of cogongrass—have feather-like protuberances that serve as “wings” when the wind blows, carrying them to other areas—often sticking to the rough wood of shipping pallets. The production of seeds is seasonal, so certain times of year are worse than others in terms of interceptions, depending on the country of origin.

Finding the target

The targeters who work for the NACTU need the tenacity of private investigators and the patience of stakeout cops. They must be detail oriented and willing to trace the path of a shipment—not just the physical trajectory of the actual cargo, but the paper trail itself.

For example, a shipment from a certain country might list a major city as the cargo’s origin because that is the manufacturer’s headquarters location. But the materials may have actually been grown, processed, or packed in a remote part of the country where noxious weeds such as wild sugarcane (Saccharum spontaneum) grows. Wild sugarcane is an important habitat for certain animal species, and it is often harvested to thatch roofs.

But here in the U.S., wild sugarcane can quickly colonize disturbed soil to take over fields and pastures, choking out native grasses and crops. In fact, wild sugarcane is on the FNW list, along with cogongrass and more well-known nuisances like mile-a-minute vine (Mikania micrantha Kunth) and kudzu (Puerara montana). Deliberate importation of it is prohibited without a permit from the USDA’s Animal and Plant Health Inspection Service.

The NACTU targeters know this. So based on the trends they see—and patterns of deception—they will flag such shipments for the kind of inspection that requires flashlights and magnifying glasses—so not even one weed seed crosses the border.

Today, the NACTU provides targeting support to all CBP environments—air, sea, and land ports of entry—including rail and truck crossings and international mail and express consignment facilities. Its weapon of choice: CBP’s Automated Targeting System, or ATS.

ATS is a Department of Homeland Security computer system that applies “risk assessment” principles for comparing traveler, cargo, and conveyance information against law enforcement intelligence and other enforcement data. Based on ATS data, CBP identifies people and cargo that may require additional scrutiny, while facilitating the entry of low-risk commodities.

Focused squarely on agriculture, the NACTU does not perform targeting activities for other trade issues, such as potential violations of intellectual property rights or antidumping and countervailing duty evasion. But the NACTU does collaborate regularly with other targeting organizations by referring intelligence to relevant targeting units, such as CBP’s 10 industry-specific Centers of Excellence and Expertise or the Commercial Targeting and Analysis Center.

Taking aim

Besides conducting national agriculture quarantine targeting, the NACTU provides field support and targeting oversight for cargo pathways nationwide. The NACTU has assumed a field support role and is available via direct field support line seven days a week to provide guidance, and assist with research requests to analyze field intelligence.

NACTU also functions as a clearinghouse of sorts, facilitating the communication of observed risk across all port locations. The quarantine activities at the Port of Baltimore, for example, have influenced exams in other port locations.

Here is how it works: the high numbers of FNW interceptions on metal commodities and containers in Baltimore—like those found by Garnier, Morris, and Taylor—are reviewed by the NACTU’s analysts at the NTC. Certain data about these shipments are applied to a national “user defined rule.” The rule is used to identify shipments that might require extra scrutiny by agriculture specialists in other locations.

Collocation at the NTC makes it easier to share information, and the NACTU collaborates regularly with CBP’s other targeting personnel by referring intelligence to the relevant targeting units and centers. “Increasing collaboration with partner government agencies and industry stakeholders really enhances CBP’s ability to execute its agriculture mission,” said Singla.

Each pathway—air, land, sea, and international express consignment—poses its own challenges, Singla explained. Land border commercial cargo is especially difficult. While manifests for cargo ships or planes are available a day or two—or even weeks—before the cargo arrives, manifests for shipments arriving by truck or rail are often available for analysis only a few hours before the goods get here.

Then there are the challenges posed by “intermodal” pathways. Say a shipment destined for San Diego arrives in Mexico’s Manzanillo seaport on the Pacific Ocean from Hong Kong. It might then be offloaded and placed on a train and sent northbound to Tijuana, where it might be offloaded again and divided onto trucks before crossing the border to San Diego. The NACTU targeters need to make sure that the manifests for this shipment remain consistent.

Significantly, the NACTU does not replace the local port’s targeting operations. Instead, the unit helps to focus CBP on critical and higher-risk agriculture quarantine inspections, providing extra capacity for agriculture quarantine targeting. “The NACTU is a force multiplier. It augments the targeting efforts that are already in place at the ports,” according to Singla.

Hitting the mark

The NACTU tries to identify potential first-time violators as well as repeat offenders. By looking at all the different parameters involved in a violative shipment, NACTU targeters can flag future shipments for closer inspection. That’s how they found the rooster eggs also known as “hatching” eggs.

Eggs that do not have the proper import permits are prohibited because they can carry diseases that could harm U.S. poultry, wild birds, and even people. Photo by CBP

Compared to other illicit materials—such as synthetic opioids, for example—rooster eggs might seem harmless. But eggs can carry diseases such as exotic Newcastle disease, or END, and highly pathogenic avian influenza, H5N1, a form of avian influenza, or “bird flu.”

The bird flu has killed millions of poultry throughout Asia, Europe, and Africa, and there have been hundreds of cases involving bird-to-human transmission. In the U.S., an outbreak of END in 2002-2003 resulted in the destruction of more than 3.5 million birds at a cost of more than $160 million before the disease was contained.

Hatching eggs can show up anytime, anywhere. But certain types of interceptions are seasonal. Ykeisha Horton, a NACTU operations manager who joined CBP at the Houston, Texas, seaport in 2007, explained
that the NACTU targeters are mindful of the weather patterns, cultural religious observances, and historical trends of a shipment’s country of origin.

Every spring, for example, Chinese Americans celebrate the Autumn Moon Festival. CBP sees a spike in the number of “moon cakes” being imported into the U.S.—pastries that sometimes contain partially cooked egg or meat stuffing. Depending on the origin of the cakes, and whether the importer can prove that the filling is permissible, CBP can seize the delicacies.

Deceptions and distractions

The NACTU’s targeters also know that violators learn from their mistakes. “Changing parameters is common and staying on top of these changes is imperative for NACTU’s success,” noted Horton. This practice, called “mis-manifesting,” makes it especially difficult to target future potential violations.

Jacob Rodler, another NACTU agriculture operations manager, noted that mis-manifesting is quite common in the express mail pathway. Take those eggs, for example. Their distinctive shapes might prompt a smuggler to list them on the manifest as something else entirely—golf balls, perhaps— anything that might look normal during an X-ray inspection, Rodler explained. 

Meat might be mis-manifested as “tee-shirts.” Or a shipment of “vases” could turn out to be eels. The NACTU referred the shipment of “vases” only because it had observed certain patterns that suggested the parcel might contain prohibited meat. Generally, CBP agriculture specialists might encounter eels during the standard inspection process, and eels are promptly turned over to the Fish and Wildlife Service. These eels suffered the same fate, despite the manifest’s label as T-shirts. 

Another danger: “port-shopping.” This occurs when shippers choose U.S. ports based on whether they believe they can bypass examinations. Let’s say shippers who have been sending goods through the Newark, N.J., seaport have run into problems because agriculture specialists there have found pests or contraband in their cargo. The shippers might switch destinations to a different seaport—maybe a smaller one—hoping that inspection resources there might be stretched thin enough to miss prohibited material, whether contraband or pest or weed seed, that might get the shipment rejected.

What these shippers don’t know is that the NACTU is way ahead of them. The NACTU is able to detect and analyze changes in shipping patterns, and it can warn other ports to give these shippers’ cargo an extra look.

The eco-stakes:  economy and ecology

Besides protecting native flora and fauna from invasive pests, plants, and diseases, the NACTU’s work also protects endangered species on the other side of the world.

Many plant and animal species are protected under the Convention on International Trade in Endangered Species, or CITES. This international pact aims to ensure that trade in specimens of wild animals and plants does not jeopardize their survival in the wild.

NACTU Agriculture Operations Manager Nancy Pinder recalled receiving port information regarding a seizure of orchids from Thailand. A passenger arrived at an airport and the agriculture inspection revealed 72 plant species and 14 seed species in the traveler’s luggage.

Knowledge obtained from the passenger pathway often helps in seizing shipments of prohibited agriculture commodities in the cargo pathway. NACTU targeters use what is called “link analysis,” which evaluates relationships between objects, organizations, people, places, or transactions. They also collaborate with the agriculture specialists at the local ports.

“When CBP agriculture specialists seize certain plants protected under CITES, the plants are sent to USDA for final identification and then destroyed to prevent any possibility that invasive pests or diseases will be released into our environment,” Pinder explained. Why not send the endangered plants back to Thailand? Destroying them ensures that they do not go back to their native environment bearing any pests that could hurt the species or other indigenous plants.

But the NACTU protects not just ecosystems; it also protects our economy. Pinder offers a short history lesson: “In the early 80s, there was an outbreak of Mediterranean fruit fly in California. It cost hundreds of millions of dollars to eradicate that infestation,” she said. The so-called “Medfly” eats more than 300 kinds of fruits, nuts, and vegetables, wreaking havoc on orchards and crops. For California—which ranks as the world’s fifth largest producer of food—this pest is a serious problem, as it is in Florida and other states where agriculture is important to the economy.

Finally, the NACTU helps CBP fulfill another part of its trade mission: facilitating lawful trade, which helps the U.S. economy. Conducting risk analysis lets agriculture specialists focus their inspections on shipments that pose more potential dangers.

Rodler explains: “Too often, targeting is looked at from the perspective of enforcement, but there is also an element of trade facilitation. For our outside partners in trade, they often look at our efforts as just stopping their freight or holding their freight, but by focusing on risk, we can actually help expedite the movement of compliant goods.”