International Trade committee  It certainly could be. One example of that, and we don't describe it in here, but it's known as part of the process, is the database that manages export permits with Foreign Affairs, which is a database in which they collect and issue the permits, and the agency has some access to that information.

International Trade committee  The reason is that the primary means by which the agency is able to do its control work is through export declarations. Export declarations are not required for goods to the United States other than in certain cases where certain permits are required. That is because the system was set up based again on export statistics rather than on risk assessment.

International Trade committee  They certainly do. They have an internal audit and evaluation function and their reports are published publicly on their website.

International Trade committee  I think they've done an evaluation relatively recently on exports, but not on export controls, but not an internal audit. I don't think there's a really a relevant comparison at this point.

International Trade committee  Exactly. However, in principle, they are part of our work because they are not exports for the U.S.

International Trade committee  Mr. Chair, in paragraph 78 we talk about the work we did to try and get at that question, which was to survey the exporters whose goods were detained. We got responses back from about half of the exporters whose goods had been detained and subsequently released in our period. Of them, 11% said they had had a major impact.

International Trade committee  Mr. Chair, we sent a survey to every exporter who had had a shipment detained and then released. There were only 300 such shipments during the period of our audit, which gets back to your initial question about how many. There are millions of containers that leave the country every year, and there were 300 that were detained and subsequently released, which gives you a sense of the overall magnitude.

International Trade committee  Yes.

International Trade committee  It is true that some exports go through the U.S.

International Trade committee  That was exactly our comment about the potential delays. We have noticed two things. First, in a relatively small number of cases, which still add up to 11%, when the products were inspected and delayed as a result, we noticed that they were not being handled in the most effective way.

International Trade committee  Part of the problem with the system is it was not designed for risk assessment. It was designed, essentially, for statistical data collection.

International Trade committee  One that was designed to do that would make a substantial difference, because it would allow you to encode into the system rules to look for things, which at the moment has to be done entirely by staff.

International Trade committee  That is their long-term goal, yes.

International Trade committee  That was what led us to make the comment about uncertainty, because at the time that we were doing this work there wasn't a clear way forward agreed between the two organizations.

International Trade committee  What we would need is that the new system could still receive the declarations electronically.