As the GAO report shows, C-TPAT is not perfect. As with so many areas of homeland security, there are still a number of challenges that must be addressed and improved. Most critical among them is the lack of systematic follow-up by Customs and Border Protection officials to ensure that full implementation of their security requirements are met before granting benefits. Anyone who reads this report, however, will be struck by the degree of improvement C-TPAT has undergone since it was formally adopted, as well as the sophistication of DHS’s overarching risk-based approach to security. It is the very opposite of the model called for by some critics, who want to replace this model with the so-called 100 Percent model.
We see the “100 Percent” debate playing itself out between DHS and Democrats on the Hill — in the areas of employee screening at our nation’s airports, the screening of air cargo, and the screening of shipping containers coming from overseas. In all these instances, Democrats have passed legislative mandates requiring DHS to implement the costly solution of 100% scanning. DHS has been correct to push back, and they should do so more forcefully.