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INS and Airline Industry Relations
Report Number I-2000-020
September 2000


September 25, 2000
SUBJECT: INS and Airline Industry Relations,
Report Number I-2000-020

To assist the Immigration and Naturalization Service (INS) in assessing the success of its interactions with the airline industry, the Office of the Inspector General (OIG), Inspections Division, has completed an inspection of the relationship between INS and the airline industry. At U.S. international airports, INS inspectors have, on average, less than one minute to decide whether to admit applicants for admission to the United States. During this brief encounter, inspectors must observe the applicants, ask questions, examine all travel documents, and run identification checks against computerized databases.

Airlines can also play a vital role in ensuring that individuals have complete and proper documents. Airline industry personnel screen passengers and their documents at foreign airports prior to passengers boarding an aircraft bound for the United States. Those passengers that present blatantly fraudulent documents or do not possess complete and proper documents should not be allowed to board the aircraft. When the airlines fail to screen such passengers, the airlines are subject to fines and the cost of transporting the passengers back to their originating ports. The burden on INS to identify and deny entry to individuals attempting to enter the United States illegally is greatly reduced if airlines are properly trained and have sufficient information from INS to prevent such individuals from boarding the aircraft at foreign points of embarkation.

Our report identifies needed improvements in the areas of airline training, information sharing, and general communication. A discussion of our most significant findings follows.

INS Training of Airline Industry Employees

The INS provides training that helps airlines identify improperly documented passengers.1 The airlines have been very receptive to INS training, thereby potentially reducing costs and fines associated with transporting these passengers. To make this training most effective, INS needs to address several issues. For example, INS does not evaluate the effectiveness of the training it provides to the airline industry and cannot, therefore, determine whether training is sufficient. INS does not have credible information on how many airline personnel need training. Lacking such information, INS cannot properly plan its training efforts. While the airline industry estimates that less than 20 percent of those needing training have been trained, INS does not know how many airline industry personnel have actually been trained.

Additionally, several INS organizations independently conduct airline training but INS does not maintain an advanced centralized training schedule of this training. This is an important issue for many airlines because airlines often have practical restrictions on when they can spare employees to undergo training. For example, many airlines cannot spare employees for training during the summer months when airline travel is heaviest.

INS Sharing of Tactical Information with the Airlines2

During the course of INS's inspection of airline passengers, INS inspectors often notice the same methods used by improperly documented passengers embarking from a particular geographic region, foreign country, and/or foreign airport to enter the United States. This tactical information is typically very helpful to airlines seeking to prevent such improperly documented passengers from boarding aircraft bound for the United States. Within security limitations, it is beneficial for INS and the airlines to share as much tactical information as possible. Generally, this information is most effectively shared when it is provided to airline employees at foreign airports that screen passengers prior to boarding.

INS sharing of tactical information with the airlines, however, is limited. At the national level, there is no formal program for exchanging tactical information with the airlines. At the local level, John F. Kennedy (JFK) and Miami International Airports have developed carrier consultant programs that promote not only training but also sharing of such information. However, most INS offices at U.S. international airports do not regularly share tactical information with airlines.3

Communications between INS and the Airline Industry at the User Fee Advisory Committee Meeting

The User Fee Advisory Committee, consisting of representatives from INS and the transportation industry, was created by a 1986 amendment to the Immigration and Nationality Act. In keeping with the law and its charter, it represents the primary means for INS and the national airline industry to communicate and provide advice to the INS Commissioner on national policy relating to the user fee account.

In recent years, the Committee has not been effectively serving as an advisor to the Commissioner. The Committee meetings do not foster cooperation and understanding on issues of mutual concern. No formal reporting mechanism exists for apprising the Commissioner regarding the proceedings of the Committee meetings. INS is not tracking the resolution of issues raised at meetings and does not ensure that information promised the airline industry is actually provided. The airline industry has expressed frustration with INS's failure to provide requested information. Senior INS Inspections and budget officials, who regularly attend Committee meetings, cannot speak for, or respond on behalf of, INS program areas not represented at the meetings. Without sufficient INS information, the airline industry cannot make informed decisions necessary to advise the Commissioner on user fee issues, including the appropriate user fee amount.

During our visits to the three major INS air ports-of-entry, INS and local airline officials reported that their previously poor relationships had been greatly improved. They reported that when monthly meetings were instituted, in which both groups aired their concerns, the meetings contributed to creating effective working relationships.

Our report contains recommendations to improve airline training, strengthen tactical information sharing, and enhance INS and airline communication. The airline training recommendations specify that INS develop a method to evaluate the effectiveness of the training, identify the universe of airline employees needing training, and improve dissemination of planned training schedules. The recommendations on sharing tactical information are designed to promote the timely exchange of such information at the local ports and clarify INS policy on dissemination of such information to the airlines. Finally, the communication recommendations are designed to ensure that the User Fee Advisory Committee serves in its advisory capacity and to enhance communication at local air ports-of-entry.

We sent copies of the draft report to your office on June 12, 2000, with a request for written comments. Your August 3, 2000, response addressed each of the 12 recommendations. We have attached your response as Appendix III.

Our analysis of your response describes the additional actions needed for each of the recommendations and can be found in Appendix IV. Please provide the additional information by November 1, 2000.

We appreciate the cooperation that your staff extended to us as we conducted our review. If you have any suggestions as to how we might improve our review process, or if we can provide you with any additional information, please let us know.


cc:    Kathleen Stanley
Immigration and Naturalization Service

Vickie L. Sloan
Departmental Audit Liaison Office

  1. An improperly documented passenger is an individual who does not posses the documents required for entry into the United States. For example, someone is typically improperly documented if the person is posing as someone else (i.e., an impostor) or if the person has an invalid visa, a fraudulent passport, or no documents at all.

  2. Tactical information is information developed by INS that can be very useful to airlines in identifying improperly documented passengers. Tactical information includes new types of fraudulent documents, similar circuitous travel routes by improperly documented passengers, the modus operandi of alien smugglers, etc.

  3. A carrier consultant is an INS employee who trains airline personnel who work at foreign airports to identify improperly documented passengers and thereby deny them boarding on flights bound for the United States. In addition to training, INS employees working as carrier consultants at JFK and Miami International Airports also routinely provide tactical information to airline personnel at foreign airports that helps the airlines identify improperly documented passengers attempting to board flights bound for the United States.

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