THE THREAT
New York harbor has become scarier since 9/11 with the emergent threat of Al Qaeda terrorists using the port to smuggle in a nuclear weapon in a container or sinking a ship in the harbour cutting off fuel supplies to the eastern seaboard.
The Harbor Commission’s response is a case study in the use of risk assessment tools for identifying and analyzing risks in logical systematic ways, tools that complement rather than replace the experience of seasoned inspectors and investigators, helping regulatory staff differentiate between shipments that seem to be deserving of equal attention but are not.
RISK ASSESSMENT TOOLS SUPPORT INVESTIGATORS
William Finnegan, in a recent article in the New Yorker Magazine, outlines the response of the Harbor Commission to the terrorist threat and illustrates some of the benefits of using risk assessment tools, which include:
- Faster decision making
- More clarity and logic to support decisions
- Better communication about decisions
- Improved consistency and fairness
- Improved use of investigator resources (costly investigations can be targeted to address the most serious threats)
- Improved use of information management resources (determining what information needs to be collected and reported for effective decision making)
NEW SITUATIONS REQUIRE DIFFERENT APPROACHES
“New York harbor is vast, antiquated, Mob-ridden and notoriously hard to police. With 5,300 foreign boats docking there each year, how easily could Al Qaeda buy its way in?” Finnegan asks.
Prior to 9/11, threats originated with the Mob. In risk terms, these threats were of relatively low consequence and frequent. The Mob wanted to perpetuate its business. To do so, most of its activities had to fly below the line of risk tolerance. If the negative consequences associated with its activities became too great, law enforcement would step in and “business as usual” would become more difficult.
After 9/11, with the threat of terrorism, the Commission has recognized that it must have a risk strategy to deal with the low probability of a high consequence event, a threat that must be mitigated because the consequence is intolerable.
COMBINATION OF RISK FACTORS TRIGGER INVESTIGATIONS
The Commission chose a risk assessment tool developed by the National Targeting Centre in Virginia. It’s a tool with 3,000 rules for evaluating data. Finnegan quotes a former port official, “If somebody wants to try something, they have to be very careful to avoid any historical anomaly. We have 20 years of entry data. We know how much a hundred bales of cotton should weigh. Our targeting system will tell us if this is the eight thousandth time we’ve seen this commodity from this importer from this port - but this time there is something different about it. Each rule in the targeting system has a derogatory weight to it. So if this is an unusual commodity to be coming from - paint from Syria, say - then that’s points. Points pile up to trigger an exam [before the ship gets to the harbor.]“
Prior to the implementation of this risk assessment tool, when the Commission was dealing with the frequent but low consequence type threats, local officers inspected ships and containers in the port and made a call based on their experience and observation. Now everything goes through this targeting system. The Harbor Commission is able to direct its inspection and enforcement efforts in a way that corresponds with the priorities of a changed world.
Finnegan’s article can be found in the June 2006 issue of the New Yorker. If you are a regulator who manages risk, you may find it interesting reading.
