Some of the analysis is solid, such as her comment on “requirements for a strategic plan” that the bill only mandates that DHS look at cargo containers, and not also at other means of carriage in the system, i.e. bulk cargo, breakbulk cargo, air freight, etc. But two of the things that she cites as “wasteful items” seem to reflect a misreading of the bill. She writes:
Office of Cargo Security Policy. The Act would establish an office to coordinate all DHS policies and programs relating to cargo security and to conÂsult with stakeholders and federal agencies on best practices and regulation. This office is redundant; the Assistant Secretary of Policy already coordiÂnates policy across the department. This proposed office would stovepipe information and policy decisionmaking rather than addressing internaÂtional supply chain security policy in the central DHS policy office, which can coordinate policy among all of the departmentâ€™s many components.
But the bill explicitly states that this new office would be located inside the office of and report to the Assistant Secretary of Policy (Sec. 431(c)). That isn’t redundancy; it’s simply filling out part of the org chart for the new policy office.
She then writes:
Radiation Detection and Radiation Safety. This provision would require that all containers entering the United States be inspected for radiaÂtion within one year of the Actâ€™s signing. Such a mandate would waste scarce resources on scanÂning mostly innocuous containers. Time, money, and effort should go toward investigating and examining suspect containers rather than every piece of hay in the haystack.
There might be some confusion here on the definition of “inspect.” Inspect in the context of the bill doesn’t mean opening every container, or moving containers through relatively slow gamma ray imaging devices; it means putting radiation portal monitors in place at fixed locations that trucks and containers can rapidly move through. This creates very little disruption to normal port operations. In fact, trucks can drive through radiation portal monitors today without stopping. I think it’s absolutely a good idea to scan 100% of containers for radiation, if it can be done non-intrusively, as part of a layered security strategy that includes other elements of the cargo security system such as C-TPAT and the National Targeting Center.